| Action Date |
Action |
Description |
DEC Staff |
| 4/29/1939 |
Update or Other Action |
Land was withdrawn from the public domain for military purposes under Executive Order 8102, dated April 29, 1939. Non-military use of the land is within the jurisdiction of the BLM and grants for use of the land are subject to the concurrence of the Department of the Air Force. |
Louis Howard |
| 1/6/1978 |
Update or Other Action |
ADF&G Memo Diagnostic/Inspection Report at the Ship Creek Hatchery by Kent Hauck Regional Fish Health Specialist- person contacted Lee Ohlinger. On January 4, 1978, a residue mixture of Jet-A 50 fuel and aircraft lube oil surfaced in gallery I during a routine water flow check using fluorescein dye. The fuel mixture with the dye passed separately through the cooling ponds containing 6,400 brood stock rainbow trout (Salmo gairdneri) and the raceways containing 818,000 fingerling chinook salmon (Oncorhynchus tshawytsca). A sample of the chinook examined on January 6, 1978 showed no pathological effects.
Daily mortalities of chinook from January 6 to the present have been approximately 0.057%, which is normal for this facility (fish hatchery). The extent of exposure of the fuel to the fish is unknown since the concentration of the contaminant as it enters the gallery is not known, On the day of the exposure, the gallery was emptied by pumping stream water and groundwater from the gallery at 1,200 gpm for approximately 45 minutes.
The possible impact of the presence of these pollutants in the hatchery system should be evaluated. It has been postulated that if exposure to hydrocarbon fuels is not extensive, long term biological effects will not occur. If exposure lasts a few days, uptake of the contaminants in fish will occur.
After the fish have been in clean water several weeks after exposure, however, hydrocarbon contaminants are very difficult to detect analytically. The concentration of fuel contaminant in Ship Creek was possibly much lower than 100 ppm. In addition, a fish kill soon after exposure should have occurred had the concentration of the contaminants been sufficient, since jet fuels are highly volatile and toxic |
Louis Howard |
| 3/8/1978 |
Update or Other Action |
ADF&G March 8, 1978 Memorandum from Bob Baker Regional Biologist to John McMullen Regional Program Manager both in the F.R.E.D. Division, Anchorage. This is in response to your memo of March 6, 1978 regarding the results of our investigation of the Ship Creek water supply contamination by petroleum products. Extent of Contamination: To date, petroleum products have been located at 14 sites within the Ship Creek watershed extending from the hatchery to the bluffs on the north and approximately 2,200 meters (approx. 1.36 miles) upstream.
These sites include: the facility's mixing building and the present cooling pond, four Tryck, Nyman, and Hayes (TNH) wells, four USGS wells, the west sump of the new ADF&G well field, the old cooling pond, and two ground seeps. Additionally all three (3) coring sites approximately 30 meters north of the sumps apparently yielded evidence of petroleum. This coring effort was requested by Tommy Heinrich at a meeting with the Air Force officials on February 7, 1978. A combination of factors within the Air Force delayed the coring until March 6.
These data suggest that the watershed of this system is inundated with oil over much of the area north of the creek and upstream for at least 2,000 meters. The contamination apparently stems from three (3) basic sources.
First, there is the area north of the facility which originated some 20 years ago (approximately 1958) from a major spill (200,000 to 300,000 gallons) caused by a break in one of the two military pipelines running along the bluff area. Two other sources may have also contributed to pollution in this area: i.e. an 8,000 gallon arctic diesel spill two years ago (1976) of which some 6,800 gallons were recovered, and the Alaska Railroad operations in that area over the years.
The second pollution source area includes that zone of the watershed which is on the north side of the creek approximately 900 to 1,600 meters upstream of the facility. This zone was apparently used for dumping oil products years ago.
The third pollution source is also north of the creek in an area about 1,800 meters to 2,000 meters from the facility. This zone may also have received used products draining down from the aircraft maintenance area. These products are contaminating the eight (8) wells of TNH and the USGS.
The fourth contamination source is also a possibility. I can only speculate about this possibility now, but my speculations are shared by Ray Morris (EPA) and Tommy Heinrich. The source concerns "fresh" arctic diesel type fuel contaminating our sumps; i.e. the point source which initiated this investigation.
If, as I and others suspect, the three coring sites in the vicinity of the sumps do contain a petroleum product, there is a reasonable likelihood that this product is coming from the U.S. Army's line which originates in Whittier, crosses Ship Creek about 600 meters upstream of our facility, and then proceeds west along the north side of Post Road to the Air Force Terminal.
A determination of this fourth pollution source will take time. The most positive approach is a full scale pressure test of the line by the Army. Such a test is made annually and the next one is anticipated in April or May of this year (1978). Secondly, a trench could be cut downstream of this pipeline and at least test corings made above the line in an attempt to intercept products flowing downstream in the ground water.
Thirdly, an attempt to chemically match fuel samples taken from the sump and the arctic grade diesel storage tanks on the bluff north of the facility. This matching effort will be attempted by the EPA and the Air Force. The EPA test results could be available next week, but the Air Force results could take 3-5 weeks since the sample will be sent to their laboratory in Texas. |
Louis Howard |
| 3/14/1978 |
Update or Other Action |
Roger S. Grischkowsky Div. Pathologist March 14, 1978 Ship Creek (SCH) support memorandum to A.K. Hauck Regional Fish Health Specialist. Effective March 13, 1978, I have removed the emergency status of SCH. During the last two months: 6 bacteriology, 4 parasitology and one virology diagnostic samplings have been accomplished.
Findings for bacteriology and parasitology indicated mixed aeromonad/pseudomonad infection (which we have associated with that hatchery for 3 years) and essentially no metazoan parasites. Also, apparent (meaning it has been reported and I have confirmed it) are abnormal flashing behavior, lordosis, and scoliosis and hemorrhagic gills. These latter signs are associated with effects of petroleum, but are general enough to be cause by other factors.
The poor disease resistance apparent in fish at SCH over the past years of its operation do relate well to immunosuppression due to petroleum exposure. Known findings of petroleum there (at SCH) are well within chronic exposure limits.
A freeze on fish removal and addition at SCH was initiated yesterday by myself. Mortalities are approaching 1%/day, but although sample collection is therapeutic for fish culturists, it will not reduce mortalities. As they reach 1-1 1/2%/day, place fish on drug therapy, but don't expect significant improvement if immunogenisis is truely suppressed. Daily/weekly examination doesn't seem an efficient resource utilization. |
Louis Howard |
| 3/14/1978 |
Update or Other Action |
March 14, 1978 Memorandum from Roger S. Grischkowsky Division Pathologist to John McMullen Regional Program Manager Subject: Position statement on Ship Creek Hatchery (SCH) - Effects of oil. In an attempt to facilitate the decision making process as pertains to SCH operation continuance and fish dispostion, I have gathered some information and will make some recommendations.
Hydrocarbon findings
January 4, 1978: Hydrocarbons found in Gallery I and passed through raceways and pond with fluorescein dye.
February 17, 1978: 1.2 ppm hydrocarbons in Tryck, Nyman and Hayes new well. 0.56 ppm hydrocarbon in old cooling pond.
Februayr 18, 1978: 0.03 ppm hydrocarbons found in above well (TNH) and four USGS wells in vicinity contained unidentified hydrocarbons.
February 24, 1978: 0.06 ppm, 1.2 ppm and 0.03 ppm hydrocarbons from above wells.
March 3, 1978: 2.8 ppm total hydrocarbons for 7 (1/2) livers equates to 0.06 ppm hydrocarbons/liver.
Discussion: Signs associated with toxic effects of oil are prominent in SCH fish. These signs are not specific and could be caused by other disease problems. Current operations of SCH is in violation of Title 18 chapter 70 Water Quality Standards. Films and sheens have been detected on water surface in raceways. Oil is present along the immediate shoreline. Projections of lowered immune response paint a pretty dismal picture for continued fish holding. A Ship Creek R&D facility would be constantly faced with oil toxicity. The question of credibility of experimental results would be omnipresent.
Elmendorf cooling ponds fish have a history of serious disease problems which have not responded to routine treatment techniques. Is a legitimate human health problem from ingestions of adult returns on Elmendorf Derby caught fish present? Chronic oil release into this creek may be responsible for extremely poor returns.
Recommendations relative to SCH:
1) Terminate Phases I and II,
2) Don't plan or build an R & D Facility,
3) Request a formal position paper from the Dept. of Human Health&Social Services via the Commissioner,
4) If no human hazard exists, release all the fish as soon as possible,
5) If a human hazard exists, destroy all the fish as per hazard statement,
6) Terminate Air Force fishing derby immediately at the SCH,
7) Discontinue use of the facility for fish propagation,
8) Release fish only into Ship Creek if release is appropriate,
9) Conduct a petroleum search at other state hatcheries, and
10) Conduct petroleum searches routinely for hatchery site selections. |
Louis Howard |
| 3/14/1978 |
Update or Other Action |
FRED Div. Tommy Gene Heinrich memorandum to John McMullen Regional Program Manager FRED Div. RE: Ship Creek Water Pollution Engineering Summary. The pollution of the sumps proper appears to be from a recent pollution source. The Air Force has test cored three holes in an effort to determine where the petroleum product is coming from. In my opinion, this is inadequate and a trench is the only way to determine the direction of flow and the source. Ray Morris with EPA agrees, and has indicated he will try to get the Air Force to trench near the sumps.
An estimate has been obtained from a local contractor for grouting the sumps. Grouting the sumps, however, is only a cosmetic solution. By grouting this sump, we can probably eliminate the contaminants from the immediate pollution source, but not from those sources farther upstream. It also appears that we will get by the critical flow period without having to use the galleries this year, which gives another reason for EPA (the Air Force or the Army) to locate and cleanup the source. |
Louis Howard |
| 3/17/1978 |
Update or Other Action |
Bob Baker Regional Biologist FRED Div March 17, 1978 memorandum to John McMullen Regional Program Manger FRED Div RE: Ship Creek. As you know, we have found petroleum products throughout the 2,000 meters of the Ship Creek Watershed upstream of the facility. Laboratory results taken March 4, 1978 from the south side well: Number 6 TNH well (a flow sample 24 hours after pumping was started) contained 0.160 mg/L of petroleum. This was the highest value from any of the TNH wells. The presence of petroleum in the no. 6 well is important since it demonstrates that petroleum contamination of groundwater extends to both sides of the stream.
Analyses of samples taken from three cores in the vicinity of the ADF&G wells also revealed petroleum. Chem & Geo Labs: 1.18 to 2.3 mg/L and CORPS lab: 0.3 to 3.2 mg/L. Ray Morris (EPA) is attempting to arrange for a ditch to be dug on the N/S line some distance to the east of the wells. The ditch may help to further localize the source of the well contamination. These new data have demonstrated: That the contamination is even more extensive than indicated heretofore, and there is a substantial contamination of the ground water in the near vicinity (<30 meters) of our wells.
I now believe that : 1) petroleum products are possibly trapped in a shallow (1-3m) aquifer between two thin clay layers near our wells, and 2) that the possibility of a leak in the Army line (past or present) is even greater than before. GC analyses of fresh Arctic diesel fuel and the contaminate in the west sump were quite similar, thus supporting point 2). Trace metal (AA) analyses of these two samples may provide better evidence of this latter possibility. |
Louis Howard |
| 4/28/1978 |
Update or Other Action |
Roger Grischkowsky Div. Pathology Fish Pathology Laboratory ADF&G April 28, 1978 memorandum to James Allen, Supervising Sanitarian, Dept. of Social Services, Environmental Health Section RE: Position Statement concerning Elmendorf, Ship Creek Fish. A position statement is appropriate concerning the Elmendorf, Ship Creek fish presently exposed to oil , as the enclosed documents indicate, relative to human health hazards. Two essential exposures are present in these fish.
The large rainbow trout have received anywhere from 3 to 5 years of chronic exposure to hydrocarbons. This brood stock has been eliminated from future egg takes and the Air Force's annual fishing derby or plants in local lakes would be a normal disposition. The second exposure concerns the salmon juveniles which have had one year or less exposure to Ship Creek water and resultant hydrocarbons.
The first group in my opinion poses more of a threat to a consumer than the salmon juveniles which will depurate (To cleanse or purify or become cleansed or purified) or at least reside in natural waters years before return. |
Louis Howard |
| 6/13/1978 |
Update or Other Action |
Memorandum Dated June 13, 1978 from Robert Fraser M.D. Director, Div. Public Health, thru James Allen, Supervising Sanitarian, Environmental Health Section, to Dr. Roger Grischkowsky Div. of Pathology, Dept. Fish & Game RE: Position Statment Concerning Elmendorf, Ship Creek Fish. It is impossible to make a definitive position paper with the knowledge available. Our impression however, is that the low level of hydrocarbons plus the very intermittant nature of human exposure in eating fish from the Ship Creek area would pose an extremely minimal risk to humans.
If further clarification is advisable, I would suggest Region X , EPA, be contacted regarding the study of hydrocarbons in fish and the relationship to this fairly low level of hydrocarbons in Ship Creek area. This might be a nice study for them to embark upon, but from the standpoint of public health, we feel the concern at this point is insignificant. |
Louis Howard |
| 3/17/1986 |
Update or Other Action |
Final Report, Installation Restoration Program Phase II— Confirmation/Quantification Stage 1, Elmendorf AFB received.
Site SP-11 JP-4 Fuel Line Leak
An unknown quantity of JP-4 leaked from an underground fuel line leak in 1978. The spilled fuel leaked from the bank of a stream north of two 840,000-gallon JP-4 storage tanks. In 1983 & 1984, fuel was still leaking from the bank of this stream, which discharges through a swampy area into Ship Creek.
This site is the location of a JP-4 underground fuel line leak of unknown volume. Fuel was noted to be seeping from the bank of a small stream that flows west, through a wetland, into Ship Creek (Dames & Moore, 1983). The seeps were noted again during the 1984 drilling & sampling program. One monitor well, W-14, was installed west of the pumphouse, Bldg. 23-714, on the bank of the stream to a depth of 25.5’.
Water was encountered at a depth of 5.0 feet, approximately the same elevation as the water surface in the adjacent creek, on 21 June 84. Soil moisture in the analyzed samples was 15 & 21 percent. Explosimeter & HNU photoionization meter readings were low at the borehole location; the explosimeter reading was 4 percent LEL, & the HNU reading was 100 ppm at 5 feet.
Two bottom sediment grab samples were taken in the wetland, approximately 1,800 feet west-southwest of the pumphouse. These samples contained 29 & 66 percent moisture.
W-14 was installed near this site of a JP-4 underground fuel line leak. No TOC, lead, phenol,: or pesticides were detected in this well, & TOX, TDS, & specific conductance levels were only slightly above expected background. However, pH, at 8.15, was elevated in W-14. Little oil & grease was detected in the W-14 soil samples, but one of the surface samples from the adjacent wetland, G-l, had a relatively high oil & grease concentration of 3.0 mg/g dry weight. G-2, the second wetland sample, had moderately high oil & grease at 0.159 mg/g dry weight.
The results of almost all the water quality analyses from W-14, the one well installed near this fuel line leak, are very near expected background levels. The elevated pH (at 8.15) suggests there has probably been some contamination of ground water at the site. Further, the oil & grease levels in grab samples in the nearby wetland (G-1 & G-2) indicate surface water contamination as well. This site is close to base well No. 1, & although it is probably downgradient from that shallow well, the contaminant plume could be intersected by the well's cone of depression. This may present a human health risk. Further, surface water contamination from Site SP-11 could threaten the fish hatchery on Ship Creek downstream from the base.
Well W-14 at Site SP-11 could be resampled & an analysis performed for indicator parameters to confirm the previous testing. An HNU survey could be performed along the small stream north of the site to determine whether JP-4 fuel has run off in this direction. An electromagnetic (metal detector) survey could be performed to accurately locate the underground pipes responsible for the leak. However, the survey will not be able to distinguish between leaking & nonleaking pipes. Historical information may have located the pipes sufficiently accurately for the present purposes.
Surface water was not sampled during this study, but it is potentially threatened near SP-11, where oil & grease was found in a soil sample (G-l) & by the discharge of contaminated ground water, especially to Cherry Hill Ditch (Site D-17) & Ship Creek.
Surface water contamination could threaten the fish hatchery on Ship Creek.
Sites SP-7, SP-10, SP-5, SP-12, FT-1, SP-2, SP-11, & SP-14
Some ground water contamination was found at each of these sites, but a second round of sampling is necessary to confirm the presence of contaminants. Resampling the nine wells at these sites for the screening parameters (TDS, pH, specific conductance, & oil & grease) & for purgeable aromatics (USEPA Method 602) is recommended to confirm the presence of the contamination & to assess its severity.
In addition, one monitor well each should be installed downgradient of Sites SP-12, SP-11, FT-1, SP-14, & SP-2 because of their potential impact on base wells. Base wells Nos. 2, 52, & 16 should be sampled & analyzed for the same parameters. At SP-5, analyze W-7 & W-8 for major cations & anions. An HNU survey should be conducted at each fuel spill site to determine the areal extent of contamination. |
Ron Klein |
| 4/3/1989 |
Update or Other Action |
Prior to 1989, the Alaska Department of Health and Human Services posted signs along Ship Creek stating, "The municipality of Anchorage recommends against the eating of fish taken from these waters because of chemical contamination of stream sediment." The signs were removed in 1989 for administrative reasons. |
Jennifer Roberts |
| 4/15/1993 |
Update or Other Action |
Keven K. Kleweno (KKK) of ADEC received a fax from the Alaska Department of Fish and Game regarding the high nitrate levels in Ship Creek surface water. Letter was addressed to Colonel Tipp Simpson 11530 Q Street. ADF&G has been working with the Base Environmental office on the problem with the high nitrate levels in Ship Creek. ADF&G began investigating the problem in 1990 after nuisance weed began growing in the Base Power plant cooling pond (ADF&G is responsible for maintaining the water flow through the cooling pond).
ADF&G's labor costs to remove the weeds from the power plant's cooling water intake screen is approximately 5,000 dollars annually. The nuisance weed is an indication of nitrate pollution. After a year of water tests, ADF&G found that most of the nitrates enter the creek through a bog at the end of the EAFB North-South runway. The level of nitrates in the water is as much as 30 times higher below the base runway as above and the total amount of nitrates entering the creek is over 100,000 pounds per year.
ADF&G believes the source of the nitrates is the urea and de-icing agents used on the runways. Snow plowed from the runway is deposited at the south end of the runway. The runoff from this snow pile may be entering a bog south of the runway and the bog eventually drains into Ship Creek. The high nitrate levels pose several problems:
1) The weeds, besides increasing labor costs to ADF&G, also increase the risk of loss of cooling water to the power plant.
2) The power plant has found their cooling tubes eroding faster than usual. This may be due to the higher nitrate levels.
3) Increased risk to fish health. Though the nitrate levels in the Creek water are not directly toxic to the fish, in the last four years we have seen greater organic loads. The increase in organics can eventually lead to greater parasite populations and to more fish health problems at the hatchery.
In the future, ADF&G would like the AF to deposit the runway snow to an area that does not drain into Ship Creek. |
Kevin Kleweno |
| 3/4/1994 |
Update or Other Action |
Final version of Remedial Investigation/Feasibility Study received and approved which contains the Central Operable Unit (OU) 5 contains the source areas storage tank (ST) ST38 and surface spill (SS) SS42. Central Area of OU5 extends from the western outlet of the snowmelt pond east to the Waste Paint Tank. The area includes source areas ST38, SS42 and the snowmelt pond.
The fish hatchery is located in this area between the toe of the bluff and Ship Creek. Eastern Area of OU5=SS53, SD40 and ST46 and the Beaver Pond. Western Area of OU5=ST37
FYI: Waste Paint Tank area is 400 ft. northeast of source SS42. Contaminants of concern (COC) total fuel hydrocarbons (TFH)-Diesel, JP4, BTEX was reported in soil 10 feet and 60 feet bgs in SB23, MV11, SP2/6-10, and SP2/6-04. Detected contaminant concentrations pose less than 1 x 10-6 cancer risk and have a Hazard Index less than 1 for non-cancer risks. COC concentrations do not exceed Applicable, Relevant or Appropriate Requirements (ARARs) or to-be-considered (TBC) levels; and there are no identifiable affects of contaminants on aquatic biota or terrestrial plants and animals.
Depth of groundwater is 36 ft. at this location. Xylenes were also reported at 10 ft. at a total concentration of 9.4 mg/kg, higher than expected for the low levels of fuel. Total BTEX at 10 ft. level was 10.2 mg/kg. Total petroleum hydrocarbons (TPH) detected in two locations ranged from 1763 mg/kg to 9843 mg/kg.
Diesel fuel (720 mg/kg) in soil 1 to 2 feet below surface, the result of groundwater seepage, does not pose a significant health risk. However, the soil should be evaluated in the FS because it exceeds the interim remediation goal of 200 mg/kg. Sediments, represented by sample SE06, containing TFH diesel and gasoline, should be considered a part of the area of soil contamination. Hydrocarbon concentrations of 50 to 9,843 mg/kg that occur from 30 to 60 feet below surface pose no risk to surface receptors unless they migrate to the surface as seeps in the future. Because these concentrations are at or below the water table, they should be addressed with groundwater.
Although the inorganic element concentrations exceed soil background concentrations, they are present because of natural processes and do not exceed interim remediation goals. Therefore, soil remediation on the basis of inorganic element concentrations is not warranted.
A groundwater plume with gasoline and benzene concentrations that pose greater than 1 x 10-6 cancer risk was detected at MW13. Because of the potential health risks, the gasoline and benzene plume should be evaluated for feasibility of remedial action. In initial sampling, the concentration (20 ug/L) of bis (2-ethyl hexyl) phthalate at MWll exceeded the interim remediation goal of 6 ug/L. The well was resampled in December 1993 because this compound is atypical in au 5. No phthalates were discovered in this second sample. Since the phthalate is a potential laboratory contaminant, it was concluded that the first sampling results were inaccurate. |
John Halverson |
| 5/31/2006 |
Update or Other Action |
BLM Anchorage Field Office's Environmental Assessment Case File#s: AA-085927 and AA-09596 AK-040-06-EA-043. FLPMA ROW 43 CFR 2800 and R&PP Lease Adjustment 2912. NE1/4SW1/4, Section 9, T. 13 N., R. 3 W., Seward Meridian.
In August 2005, BLM issued ADF&G a right of way (AA-85927) to authorize the use of a small area adjacent to the hatchery lease area. Due to the closure of the Air Force power plan, the hatchery must rely on more groundwater rather than creek water. The result is that the Elmendorf Hatchery needs to increase groundwater supplies to continue production.
The hatchery has identified a need to secure more groundwater to continue fish production. The Proposed Action has been reviewed and found to be in compliance with the Southcentral Management Framework Plan (MFP) March 1980. Objective Number L-1 of the MFP states the BLM intends to "Satisfy state and local government needs as well as public and/or private demonstrated needs for land as they arise."
Proposed Action and Alternative: Proposed Action-ADF&G is proposing to construct three additional wells within and near the boundary of the Elmendorf Fish Hatchery Lease Area; this will include Wells 6, 7 and 8. Wells 6 and 7 are within the existing boundary of the hatchery lease area. Well 8 is located outside the boundary of the current lease area located in the northeast corner of the decommissioned power plant cooling pond, and will require an amendment of right of way grant AA-85927, for the wellhead and the connecting pipeline and electrical lines. Providing that there is sufficient water in this new location and development of the well system is determined to be practical, ADF&G will apply for permanent water rights and connect the wells to the existing water system supporting the hatchery.
The diameter of the well casings will be 12-16 inches with the expectation of producing up to 3,000 gallons of water per minute. Only the lower confined aquifer shall be developed and screened. The depth of the wells will be at least 130 ft. deep and a maximum of 440 ft. deep depending on the depth of the aquifer. The drill sites will be on lands that have been cleared previously. Soil extracted during the drilling process will be spread around the area to a maximum depth of two inches. During the initial capacity testing, water will be discharged into an existing settling pond.
Connecting the well to the existing water system will require digging a ditch to accomodate a pipeline. The ditch will start at the Aeration Filtration and Lift Station and run to Well 6 or 7. For Well 8, the ditch will run from the intake building to Well 8. The dimensions for each well will be as follows: Trenching for Well 6 is approximately 3 1/2 ft. deep x 650 ft. long. Well 7 is approximately 3 1/2 ft. deep x 450 ft. long and Well 8 is approximately 3 1/2 ft. deep x 250 ft. long with the excavated soil piled next to the trench. Trenching will be accomplished with a small rubber tired backhoe and refilled at the end of the work. The pipeline will consist of 6 to 10" HDPE pipe buried approximately 3 1/2 ft. deep. A conduit for electrical wiring will be laid in the same trench.
By Executive Order 8102, this land is under a withdrawal for military reservation. BLM's role is to manage the vegetative and mineral resources. BLM issues land authorizations for this withdrawal, subject to the concurrence of the military. The U.S. Air Force will issue a letter of non-objection prior to authorization being given to construct any improvements. |
Louis Howard |
| 11/30/2007 |
Update or Other Action |
Part I of II
Shannon & Wilson submitted to HDR Alaska Inc. the Site Characterization Anchorage Fish Hatchery dated November 2007. This report presents the results of S&W's site characterization activities conducted at the Hatchery located at 941 N. Reeve Blvd, Anchorage, AK, The project objective was to evaluate the potential environmental concerns identified in S&W's July 2007 report titled, Phase 1 ESA, Anchorage Fish Hatchery, Anchorage, AK. The site characterization activities were conducted concurrently with the geotechnical drilling program & included collecting & testing soil, sediment, & water samples.
The site activities were performed in general accordance with 18 AAC 75 Oil & Other Hazardous Substances regulations (December 30, 2006) & our June 20 & September 21, 2007 proposals.
As part of the preconstruction investigation, a Phase I ESA was conducted in July 2007. Potential environmental concerns documented in the Phase I ESA included:
• a JP-4 jet fuel release that occurred to the north of the Cooling Pond in 1964,
• former buildings at the property that predated the availability of natural gas or public sanitary sewer system service,
• potential presence of PCBs associated with the former power plant, &
• impacted GW on the EAFB.
On August 14, 2007, one sediment & one surface water sample were collected from the seep area located near the NE comer of the Cooling Pond. The sediment sample, designated Sample Sed 1, was collected from approximately 0.3 foot bgs using a stainless steel spoon. The surface water sample, designated Sample SS 1, was collected by submerging a clean, 1-liter amber jar in the seep water & transferring the water to the laboratory supplied jars.
Two of the 26 geotechnical borings were used to also collect environmental samples. Borings B20 & B25, were drilled on September 24 & 25, 2007, respectively. Boring B20 was advanced in the eastern portion of the Cooling Pond, & Boring B25 was advanced to the northnortheast of the Cooling Pond, south of North Post Road. Boring B20 was drilled & advanced to 46.5 feet bgs. Borings B25 was advanced to a depth of 16.5 feet bgs.
Split-spoon samplers were used to collect soil samples at 5-foot intervals to the bottom of the borings. The samples were screened in the field using a photoionization detector (PID) & an ADEC-approved headspace screening technique. Based on PID readings & visual observations, one soil sample from each boring was submitted for chemical analysis.
Two temporary wells, designated Wells TWI & B25MW, were installed on August 23 & September 25, 2007. Water was encountered at about 10 feet bgs in Boring B25 during drilling activities. Water was present at the base of the pond when Boring TWI advanced. The wells were screened in shallow (Well B25MW) & deep locations (Well TWI) to characterize both the lighter & denser contaminants of concern. The screened section in Well B25MW was positioned from 10 to 15 feet bgs & the well screen in Well TWI extended from 18.4 to 23.4 feet below the base of the pond. After collection of GW samples, the PVC Well casings were removed & the borings were backfilled with drill cuttings.
After PCBs were identified in Sample Sed 1 during the initial site characterization efforts, a sediment sampling program was implemented to evaluate the potential presence & concentrations of PCBs in both the Cooling Pond & the Settling Pond sediments. The samples from the Settling Pond sediments were collected because water & possibly sediments were transferred from the Cooling Pond to the Settling Pond.
The samples were selectively analyzed for gasoline range organics (GRO) by Alaska Method (AK) 101; diesel range organics (DRO) by AK 102; residual range organics (RRO) by AK 103; volatile organic compounds (VOCs) by Environmental Protection Agency (EPA) Method 8260B; Resource Conservation & Recovery Act (RCRA) metals by EPA 600017000 series; & PCBs by EPA 8082. For quality control purposes, one water duplicate sample, three soil duplicate samples, and five trip blanks (two soil and three water) were included in the sampling program. The field duplicate samples were tested for the same analytes as their associated project samples. The five trip blanks were analyzed for VOCs. One trip blank (WTB2) was also tested for GRO.
Five soil samples. including one field duplicate, were submitted for analytical testing. Petroleum hydrocarbon constituents were reported samples from three locations. DRO was reported in Sample B25S5 and its duplicate, Sample B25S6, at concentrations of 42.4 milligrams per kilograms (mg/kg) and 69.9 mg/kg, respectively. The reported ORO concentrations are less than the applicable cleanup criterion. |
Louis Howard |
| 12/5/2007 |
Update or Other Action |
07239933902 Spill DatelTime: 12/05/2007. Anchorage Fish Hatchery/Former EAFB Power Plant C 941 North Reeve Blvd. Cooling pond for former EAFB Power Plant. Unknown historic release to cooling pond for powerplant. Investigation Report to follow for discovery of Soil contamination exceeding ADEC soil cleanup levels during Geotech work. 12/18/2007: Geotech site characterization report by S&W recieved by PERP and CSRP-Louis Howard. |
Frank Wesser |
| 3/21/2008 |
Spill Transferred from Prevention Preparedness and Response Program |
Spill transferred by PERP staff Frank Wesser. Spill No. 07239933902; Spill Date = 12/5/07; Substance = Diesel, Quantity = Unknown. |
Mitzi Read |
| 5/6/2008 |
Update or Other Action |
On 5/6/08, Contaminated Sites Program (CSP) provided comments to Shannon & Wilson (S&W) regarding its "Environmental Management Plan Anchorage Fish Hatchery Anchorage, Alaska" dated April 2008. DEC received the document via e-mail on 5/2/2008. The management plan proposes to handle and remediate/treat/temporarily store potentially contaminated soil and water that may be encountered during construction of a new fish hatchery located on Elmendorf Air Force base (EAFB) on 941 North Reeve Blvd. in Anchorage.
The location of the new hatchery is leased to the Alaska Department of Fish & Game (ADF&G) and is located within the footprint of the former EAFB Power Plant cooling pond. ADF&G has an existing hatchery located nearby the proposed new hatchery. It appears that the former Power Plant cooling pond will be demolished and the new hatchery will be constructed in that location.
The plan provides information from previous environmental investigations by S&W in the area of the proposed hatchery which has detected PCBs in sediment (Sed1) up to 0.93 mg/kg or just below the 18 AAC 75.341 regulatory level;
diesel range organics (DRO) in soil up to 3,630 mg/kg (at boring B25S6) in excess of the 250 mg/kg threshold in 18 AAC 75.341 Method 2;
arsenic up to 6.24 mg/kg and chromium at 38.3 mg/kg in excess of 18 AAC 75.341 cleanup levels of 2.0 mg/kg and 26.0 mg/kg, respectively; and
DRO in groundwater up to 69.7 mg/L (at monitor well B25MW);
and for a sample collected in the sediment (at Sed1) the laboratory practical quantification level of 313 mg/kg was above the 250 mg/kg regulator threshold.
The document considered that the elevated levels of arsenic and chromium were within background concentrations.
The report listed four suspected releases that may contribute to the contamination on site: a former JP-4 release near the cooling pond in 1964; former buildings on the property; PCBs releases from the former Power Plant; and impacted groundwater on EAFB.
The plan proposes to:
1) containerize about 10cy of soil in the PCB area that tested at 0.93 mg/kg and place on site in supersacks for site landscaping.
-field screen soils for volatile organic compounds (VOCs) during excavation with a PID or FID.
a) if >10 ppm of background on the detector and visual or olfactory evidence, the soil would be deemed "hot" contaminated and stockpiled for later consideration for use on site or transported off site to an approved treatment/disposal facility such as ASR or the MOA Highland Landfill.
b) if the detector showed <10 ppm and no visual or olfactory evidence the soil would be either transported off site or reused on site without further screening/sampling.
2) confirmation samples would not be collected from soil reused on site or from undisturbed soil.
3) further sampling would be performed on soil excavated in areas with unknown contaminant conditions and designated as contaminated (hot) that is unsuitable for reuse on onsite fill and transported off site to an approved facility to treat/dispose such as ASR or the MOA Highland Landfill.
4) prior to transport off site, potentially impacted soil will be stockpiled on site in accordance to 18 AAC 75.370.
5) characterization of soils will be in accordance to 18 AAC 78 for stockpiled soils and tested for GRO, DRO, RRO, VOCs, PCBs and total metals of the eight RCRA regulated metals.
6) a cutoff wall will be constructed that should reduce the potential for DRO impacted water from the area of B25MW in the northeast corner of the cooling pond to reach the excavation.
7) dewatering of the excavation will occur and may:
a) require submitting a Notice of Disposal for Excavation Dewatering under General Permit 2004DB0101 to DEC if >250,000 gal. is dewatered and if <250,000 gal. the permit is not required but even if less than <250,000 gal., the contractor shall comply with all the permit requirements.
b) may dispose of the water in the sanitary sewer system if approved of by AWWU.
c) may treat the water on site and test to meet DEC General Permit conditions.
8) a Construction General Permit under the NPDES is required for stormwater discharges from construction sites > 1 acre. At this time, it appears uncertain whether it will be pursued to coordinate to allow the new work to be under the auspices of the existing permit or a new permit be obtained from either the MOA, or EPA and DEC. |
Rich Sundet |
| 5/16/2008 |
Update or Other Action |
On 5/16/08, Dan Billman of HDR provided clarification on the points of contact for the operator and their consultants and the landowner. Dan clarified that ADF&G will be leasing property on EAFB for the fish hatchery and had contracted ADOT as the lead in the design and construction of the hatchery - Dave Kemp is the ADOT POC. HDR Alaska is the lead design consultant - Dan Billman is the HDR POC. S&W is the subcontractor for HDR to address the contamination issues and development of the EMPlan - Bill Burgess of S&W is its POC. |
Rich Sundet |
| 5/22/2008 |
Update or Other Action |
On 5/22/08, CS provided via email to Bill Burgess that it could proceed with the review of the plan but it had not heard back from Larry Opperman of EAFB whether EAFB would address contamination outside of the footprint of the fish hatchery and where contamiantion had been detected in MW25. DEC also had not received the agreement between BLM, EAFB and ADF&G to allow ADF&G to lease the property. In an earlier 5/19 email from Dan Billman, he noted that BLM manages the land for EAFB - Larry Opperman is the POC for EAFB, and that BLM would be preparing an Environmental Assessment and the EMP was requested by BLM and EAFB to be part of the EA.. |
Rich Sundet |
| 6/3/2008 |
Site Added to Database |
Site added to the database. |
Mitzi Read |
| 6/4/2008 |
Exposure Tracking Model Ranking |
Initial ranking with ETM completed. |
Mitzi Read |
| 9/15/2008 |
Update or Other Action |
Shannon & Wilson submitted to HDR Alaska Inc. the Site Characterization Anchorage Fish Hatchery dated November 2007. This report presents the results of the site characterization activities conducted at the Hatchery located at 941 N. Reeve Blvd, Anchorage, AK, The project objective was to evaluate the potential environmental concerns identified in S&W's July 2007 report titled, Phase 1 ESA, Anchorage Fish Hatchery, Anchorage, AK. The site characterization activities were conducted concurrently with the geotechnical drilling program & included collecting & testing soil, sediment, & water samples.
The site activities were performed in general accordance with 18 AAC 75 Oil & Other Hazardous Substances regulations (December 30, 2006) & our June 20 & September 21, 2007 proposals.
As part of the preconstruction investigation, a Phase I ESA was conducted in July 2007. Potential environmental concerns documented in the Phase I ESA included:
• a JP-4 jet fuel release that occurred to the north of the Cooling Pond in 1964,
• former buildings at the property that predated the availability of natural gas or public sanitary sewer system service,
• potential presence of PCBs associated with the former power plant, &
• impacted GW on the EAFB.
On August 14, 2007, one sediment & one surface water sample were collected from the seep area located near the NE comer of the Cooling Pond. The sediment sample, designated Sample Sed 1, was collected from approximately 0.3 foot bgs.
Two of the 26 geotechnical borings were used to also collect environmental samples. Borings B20 & B25, were drilled on September 24 & 25, 2007, respectively. Boring B20 was advanced in the eastern portion of the Cooling Pond, & Boring B25 was advanced to the northnortheast of the Cooling Pond, south of North Post Road. Boring B20 was drilled & advanced to 46.5 feet bgs. Borings B25 was advanced to a depth of 16.5 feet bgs.
Split-spoon samplers were used to collect soil samples at 5-foot intervals to the bottom of the borings. The samples were screened in the field using a photoionization detector (PID) & an ADEC-approved headspace screening technique. Based on PID readings & visual observations, one soil sample from each boring was submitted for chemical analysis.
Two temporary wells, designated Wells TWI & B25MW, were installed on August 23 & September 25, 2007. Water was encountered at about 10 feet bgs in Boring B25 during drilling activities. Water was present at the base of the pond when Boring TWI advanced. The wells were screened in shallow (Well B25MW) & deep locations (Well TWI) to characterize both the lighter & denser contaminants of concern. The screened section in Well B25MW was positioned from 10 to 15 feet bgs & the well screen in Well TWI extended from 18.4 to 23.4 feet below the base of the pond. After collection of GW samples, the PVC Well casings were removed & the borings were backfilled with drill cuttings.
After PCBs were identified in Sample Sed 1 during the initial site characterization efforts, a sediment sampling program was implemented to evaluate the potential presence & concentrations of PCBs in both the Cooling Pond & the Settling Pond sediments. The samples from the Settling Pond sediments were collected because water & possibly sediments were transferred from the Cooling Pond to the Settling Pond.
The samples were selectively analyzed for gasoline range organics (GRO) by Alaska Method (AK) 101; diesel range organics (DRO) by AK 102; residual range organics (RRO) by AK 103; volatile organic compounds (VOCs) by Environmental Protection Agency (EPA) Method 8260B; Resource Conservation & Recovery Act (RCRA) metals by EPA 600017000 series; & PCBs by EPA 8082. For quality control purposes, one water duplicate sample, three soil duplicate samples, & five trip blanks (two soil & three water) were included in the sampling program. The field duplicate samples were tested for the same analytes as their associated project samples. The five trip blanks were analyzed for VOCs. One trip blank (WTB2) was also tested for GRO.
Five soil samples, including one field duplicate, were submitted for analytical testing. Petroleum hydrocarbon constituents were reported samples from three locations. DRO was reported in Sample B25S5 & its duplicate, Sample B25S6, at concentrations of 42.4 milligrams per kilograms (mg/kg) & 69.9 mg/kg, respectively. The reported DRO levels are less than the applicable cleanup criterion.
For additional information see site file.
|
Louis Howard |
| 2/11/2009 |
Update or Other Action |
AK-010-08-EA-029
DECISION RECORD and FINDING OF NO SIGNIFICANT IMPACT
I. Decision:
Alaska Department of Fish and Game (ADF&G) are planning to build a fish hatchery on Elmendorf Air Force Base (EAFB) in spring of 2009. In 2008, ADF&G completed pre-construction site preparation activities, and are ready to begin the construction phase of the project. BLM has determined that the fish hatchery construction activities fall within the scope of the Environmental Assessment, and the construction project requires no further examination. These activities are considered to be Phase II of a multi-phase operation. Phase II would include the construction of the fish hatchery, and any additional improvements needed to the surrounding lease area.
II. Rationale for the Decision: It has been determined that there is a need for a local fish hatchery to replenish brood stock to rivers and streams within the Municipality of Anchorage. Recreational fishing is a large part of Alaskan culture, and replenishing yearly fish take with fry would offset the depleted resource. State monies have been set aside to construct, operate and maintain a new fish hatchery. Operations at the existing hatchery would continue until it is replaced by the new hatchery once it becomes fully functional. The approved pre-construction activities that were completed in 2008 have prepared the site for the new construction work, scheduled to begin in Spring of 2009.
III. Finding of No Significant Impact (FONSI): The proposed action is consistent with existing national environmental policies and objectives as set forth in Section 101 (a) of the National Environmental Policy Act of 1969 (NEPA). Further and based on the analysis of potential environmental impacts contained in the attached environmental assessment, it is my determination that the proposed action does not constitute a major Federal action significantly affecting the quality of the human environment and that an environmental impact statement is not required.
IV. ANILCA Section 810 Compliance: The proposed action will not significantly restrict Federal subsistence uses, decrease the abundance of federal subsistence resources, alter the distribution of federal subsistence resources, or limit qualified Federal subsistence user access.
V. Adverse Energy Impact Compliance: This action has been analyzed as required by Washington Office Instruction Memorandum 2002-053 to determine if it will cause an adverse impact on energy development. The action will not have an adverse direct or indirect impact on energy development, production or distribution. The preparation of a Statement of Adverse Energy Impact is not required.
VI. Compliance and Monitoring Plan: N/A |
Louis Howard |
| 5/29/2009 |
Update or Other Action |
BLM Special Stipulations
The Bureau of Land Management requires the following Special Stipulations be adhered to during construction and operation of the Elmendorf Air Force Base Fish Hatchery. These stipulations are based on mitigation measures established in the Anchorage Sport Fish Hatchery Environmental Assessment (EA# AK-010-08-EA-029), dated 10/14/2008, and are as follows:
- Sanitation and Waste Disposal
An Environmental Management Plan (EMP) has been developed and coordinated with ADEC regarding how to deal with contaminated soil and groundwater if it is encountered during construction. The EMP addresses disposal of impacted soil. PCBs would be contained and remain on site. Petroleum hydrocarbons would be removed and would be transported to a local soil remediation facility for treatment and disposal. Confirmation sampling for PCBs will be collected and
analyzed. The EMP also addresses buried debris. Since some demolition (of spillways and concrete structures) is needed for installation of the sheet pile, an additional opportunity for exposure to impacted soils is presented. Disposal of buried debris will be determined by the contractor and will likely go to the landfill.
- Invasive/Non-native Species
During construction of the new hatchery facilities, Best Management Practices (BMPs) will be employed to prevent or reduce the establishment of invasive plants during site preparation and facility construction. (See “Construction,” Section 4.13, Environmental Assessment – Anchorage Sport Fish Hatchery Project, 10/14/08). At BLM’s request based on standard requirements, all
construction equipment brought on site would be cleaned prior to entry.
- Water Quality
Alaska Department of Fish and Game shall adhere to a primary and secondary filtration standard for rearing system effluent prior to it being discharged into Ship Creek, as discussed within Section 4.5.1 – “Water Quality” of the Anchorage Sport Fish Hatchery Environmental Assessment. There will be no increase in the amount of waste discharged into the creek during proposed hatchery operations that would exceed existing conditions. Effluent being discharged into Ship Creek will not exceed 10 °C, nor will it exceed permit standards for temperature (13 °C)
(18 AAC 70).
- Wildlife
Clearing of vegetation on lands for project-related development shall occur before or after the nesting season (from May 1 to July 15 in South Central Alaska) to minimize the risk of violating the Migratory Bird Treaty Act (MBTA). |
Louis Howard |
| 5/29/2009 |
Update or Other Action |
Air Force Special Stipulations
The following stipulations were requested by the Department of the Air Force by a memo dated
December 18, 1975:
1. “Installation, operation & maintenance of the fishery is to be as outlined in Cooperative Agreement between Commissioner, Alaska Department of Fish & Game & Commander, 21st Air Base Group, Elmendorf Air Force Base (EAFB). Any deviation will be coordinated with the Commander, 21st Air Base Group prior to actual on-site change.”
2. “All new construction will be approved by the Commander, EAFB or his delegated representative prior to commencement of work.”
The following stipulations are required by the Department of the Air Force Letter of Non Objection, signed on January 27, 2009:
1. The lease term is hereby leased to the State for twenty-five (25) years, beginning April 17th, 2009, & ending April 17th, 2034. The Secretary of the Air Force (AF) may terminate the lease if the President or Congress declares a national emergency that necessitates such termination in the national public interest. Upon request of the State of Alaska & approval by the Department of the AF, the term may be extended another 25 years for a maximum term of 50 years.
2. That the use & occupation of the land incident to the exercise of the privileges leased shall be subject to such rules & regulations regarding ingress, egress, safety sanitation & security as the AF, may from time to time prescribe.
3. The State agrees that it has inspected & accepts the condition & state of repair of the Property. It is understood & agreed that the Property is leased in an "as is, where is" condition without any representation or warranty by the Government concerning its condition, & without obligation on the part of the Government to make any alterations, repairs, or additions. The Government shall not be liable to the State for any latent or patent defects in the Property. The State acknowledges that the Government has made no representation or warranty concerning the condition & state of repair of the Property nor any agreement or promise to alter, improve, adapt, or repair them.
4. Subject to a specific appropriation by the legislature for this purpose, the State agrees to indemnify, defend & hold harmless the AF from any damages, costs, expenses, liabilities, fines, or penalties resulting from releases, discharges, emissions, spills, storage, treatment, disposal, or any other acts or omissions by the State, its officers, agents, employees, or contractors, or licensees, or the invitees of any of them, giving rise to government liability, civi1 or criminal, or responsibility under federal, state, or local environmental laws. All parties to this agreement recognize & agree that the State has no appropriation currently available to it to indemnify the AF under this provision & that enactment of an appropriation in the future to fund a payment under this provision remains in the sole discretion of the legislature & the legislature's failure to make such an appropriation creates no further liability or obligation of the State. This condition shall survive the expiration or termination of the lease, & the State's obligations hereunder shall apply whenever the Government incurs costs or liabilities for the State's actions of the types described in this condition.
5. The State may elect to remove any toxic or hazardous wastes, substances or materials found on any portion of the Property, including the old cooling pond, at its sole expense in order to complete the hatchery project. Alternatively, the State may elect to cancel the hatchery project, & terminate the lease after restoring the property to its condition as it existed on the date of the signing of the lease, provided it has first stabilized any disturbed contamination in accordance with applicable state & federal laws if the contamination was not caused by the State. The State will be responsible for remediation of any contamination resulting from its operations on the Property. Except as provided in this paragraph, the State is not responsible for any preexisting condition on the Property that it has not caused or negligently exacerbated.
6. The existing dam will remain in place & in good working order as a barrier to fish passage. ADF&G will take no action to seek removal of the dam or to facilitate fish passage through the dam. ADF&G recognizes AF's belief that removal of the dam & fish passage would adversely impact flying operations at EAFB. Any actions by ADF&G to seek removal of the dam or facilitate fish passage may result in the lease being terminated.
For additional information see site file. |
Louis Howard |
| 6/11/2009 |
Site Characterization Workplan Approved |
The Contaminated Sites Program (CSP) within the Department of Environmental Conservation (DEC) has reviewed Shannon & Wilson's (S&W) "Environmental Management Plan Anchorage Fish Hatchery Anchorage, Alaska" dated April 2008 & its amended Section 1 of the plan, as well as a revised version dated February 2009.
We received the original plan via e-mail on May 2, 2008 & the amended Section 1 on February 26, 2009. We provided comments to S&W & HDR, Inc. on the May 2nd plan via e-mail on May 6 & May 16, 2008, respectively.
In its May 6th correspondence, CSP requested further clarification on how the area will be field screened & sampled & managed, & how GW would be monitored.
On May 13, 2008, we received a response from S&W regarding our comments but there were still some issues we had with the plan. Some of the questions that we also had were regarding the agreement between the Federal Government & the State for the leasing of the land & responsibilities of the two parties for contamination issues, e.g., GW contamination.
In February 2009 we were in correspondence with S&W as they were addressing some of our comments.
On May 15, 2009, we received a revised version of the “Environmental Management Plan Anchorage Fish Hatchery Anchorage, Alaska" dated February 2009 from S&W.
In June 2009, S&W provided us with a copy of the lease agreement between the BLM & the ADF&G for the construction & use by ADF&G of a fish hatchery on Elmendorf AFB.
The management plan proposes to handle & remediate/treat/temporarily store potentially contaminated soil & water that may be encountered during construction of a new fish hatchery located on EAFB on 941 North Reeve Blvd. in Anchorage. The location of the new hatchery will be within the footprint of the former EAFB Power Plant cooling pond.
The April 17, 2009 lease agreement by the BLM states that BLM will manage the land on behalf of EAFB, & the land will be leased to the ADF&G who will operate the hatchery. ADF&G has an existing hatchery located nearby the proposed new hatchery. It appears that the former Power Plant cooling pond will be demolished & the new hatchery will be constructed in that location.
Under Stipulation #5 in Attachment F it include language that states that the State may elect to remove any hazardous substance on any portion of the Property at its expense to complete the hatchery project, the State will be responsible for remediation of any contamination resulting from its operation, & the State is not responsible for any preexisting condition on the property that it has not caused or negligently exacerbated.
The plan provides information from previous environmental investigations by S&W in the area of the proposed hatchery which has detected
-PCBs in sediment (Sed1) up to 0.93 mg/kg or just below the 18 AAC 75.341 regulatory level;
-diesel range organics (DRO) in soil up to 3,630 mg/kg (at boring B25S6) in excess of the 250 mg/kg threshold in 18 AAC 75.341 Method 2;
-arsenic up to 6.24 mg/kg &
-chromium at 38.3 mg/kg in excess of 18 AAC 75.341 cleanup levels of 2.0 mg/kg & 26.0 mg/kg, respectively; &
-DRO in GW up to 69.7 mg/L (at monitor well B25MW); &
-for a sample collected in the sediment (at Sed1) the laboratory practical quantification level of 313 mg/kg was above the 250 mg/kg regulator threshold.
The document considered that the elevated levels of arsenic & chromium were within background concentrations.
The report listed 4 suspected releases that may contribute to the contamination on site: a former JP-4 release near the cooling pond in 1964; former buildings on the property; PCBs releases from the former Power Plant; & impacted GW on EAFB.
The revised February 2009 plan & its amended Section 1 proposes to:
• Containerize about 10cy of soil in the PCB area that tested at 0.93 mg/kg & place on site in supersacks for site landscaping.
• Field screen soils for VOCs during excavation with a PID or FID.
o If >10 ppm of background on the detector & visual or olfactory evidence, the soil would be deemed "hot" contaminated & stockpiled for later consideration for use on site or transported off site to an approved treatment/disposal facility such as ASR or the MOA Highland Landfill.
o If the detector showed <10 ppm & no visual or olfactory evidence the soil would be either transported off site or reused on site without further screening/sampling.
• Confirmation samples would not be collected from soil reused on site or from undisturbed soil.
• Further sampling would be performed on soil excavated in areas with unknown contaminant conditions & designated as contaminated (hot) that is unsuitable for reuse on onsite fill & transported off site to an approved facility to treat/dispose such as Alaska Soil Recycling (ASR) or the Municipality of Anchorage’s (MOA) Highland Landfill.
For additional information see site file. |
Rich Sundet |
| 6/22/2009 |
Update or Other Action |
On 6/22/09, DEC approved of S&W's request received via email on 6/22/09 for them to transport about 10 cy of petroleum contamianted soils to ASR for thermal treatment, but there may be more soils added to this amount. |
Rich Sundet |
| 6/29/2009 |
Update or Other Action |
On 6/29/09 DEC approved via email of two email requests by Shannon & Wilson on that date. S&W proposed a change to the confirmation sampling frequency in the EMP. The approved plan calls for two samples for the first 250 square feet and one sample for each additional 250 square feet. We agree that this remains reasonable for areas that we are trying to document as ‘clean’ excavations.
For areas where contamination exists at project limits S&W requested a modification to the sampling frequency. For excavations less than 1,000 square feet we propose to continue as above. For excavations greater than 1,000 square feet we propose to collect one sample for each 500 additional square feet over 1,000 (a 1,500 square foot excavation would have 6 samples instead of 9 per the EMP). The reason for this change is that S&W found a thin zone of contamination (about 6 inches thick) in the NW corner of the project that appears to have a pretty substantial areal extent.
The other S&W request was for a modification to the post-treatment analysis for soil treated at ASR. Per the EMP S&W is collecting characterization samples prior to transport to ASR. These samples are analyzed for GRO/DRO/RRO/BTEX and PCBs (soil with detectable PCBs are not included in our transport request). S&W requested to change the post-treatment analysis to only those analytes that exceed the Method 2, Migration to Groundwater Standard (to date only DRO).
|
Rich Sundet |
| 7/23/2009 |
Update or Other Action |
USAF (Daniel A. Barnett) sent a memorandum to Louis Howard (ADEC) in response to ADEC Memorandum on Shannon & Wilson's Environmental Management Plan Anchorage Fish Hatchery, Anchorage, Alaska dated 11 June 2009.
1. This memorandum documents the responsible party to address the groundwater contamination at the site of the Alaska Department of Fish & Game (ADF&G) fish hatchery under construction on Elmendorf AFB. Per the April 2009 lease agreement administered by the Bureau of Land Management (BLM), the State is not responsible for preexisting conditions of the property thit it has not caused or negligently exacerbated. However, the State may elect to remediate contamination at its sole expense in order to complete the hatchery project.
2. This site has been validated under the Air Force's One Cleanup Program concept and site
characterization is anticipated to occur in FY10, pending availability of funds. The State's
construction project shall not alter our remediation priorities. Should the State wish to remediate the site sooner than our schedule anticipates, it may do so at its sole expense under the terms of the Lease.
3. Should you have any questions, please.contact Mr. Gary Fink, Chief, Environmental Cleanup
at (907) 552-2875 or email at-gary.fink@elmendorf.af.mil. |
Louis Howard |
| 10/16/2009 |
Offsite Soil or Groundwater Disposal Approved |
On 10/16/09 DEC approved via email of two email requests by ASR on that date to transport contaminated soil to ASR from the Anchorage Fish Hatchery. DEC requested that ASR post treatment analyze for DRO, BTEX, GRO and RRO. |
Rich Sundet |
| 5/11/2010 |
Update or Other Action |
Email from S&W Glashan Stafford to Richard Sundet
Attached is a drawing that shows the location of utility tie-in’s at the hatchery site. Some are on-site utilities, some are connecting to utilities in the ROW. The Hatchery would like permission to return the excavated soil to the trenches. We are on board for field screening during the process; the Hatchery is out of space and money to address impacted soil that might have to go to ASR. As currently approved, we are segregating anything that field screens higher than 50 ppm on the PID as potentially contaminated (>1,000 mg/kg DRO).
Would it be acceptable to replace excavated trench material that screens >50 ppm to the location it was excavated? How about if a characterization sample is collected to document what was actually returned to the trench?
|
Louis Howard |
| 5/12/2010 |
Update or Other Action |
Rich Sundet ADEC email to S&W Glashan Stafford: Utility Excvation
Since this project began, CS has come out with a closure policy in 8/09 that places more emphasis on human health cleanup levels vs migration to groundwater cleanup levels. CSMs still need to be developed to show that there is no pathway risk and we know that DRO has impacted one area in groundwater. A somewhat qualified response but ADEC does not have an objection to what you propose but the above issues need to be properly addressed in addition to ensuring that contamination will not migrate to impact any nearby sensitive areas and within the protective zone of a drinking water supply system. I would assume also that the landowner may need to agree with the proposal. |
Rich Sundet |
| 3/31/2011 |
Update or Other Action |
Air Force submits a work plan addendum for Environmental Sampling at Fish Hatchery, April 2011.
This work plan addendum describes the work to be performed at the Post Road Fish Hatchery Building in April 2011. Work described below will be performed in accordance with the 2010 Investigation and Closure Sampling for Environmental Compliance Sites Work Plan (Work Plan) (USAF 2010) as updated by this document. The goal of this project is to further investigate the extent of fuel contamination found in soil and groundwater during the 2007 Site Characterization (Shannon and Wilson 2007) and during 2010 construction activities.
Soil borings are planned to investigate the potential extent of soil contamination. Three soil borings will be advanced in the area surrounding the backfilled waterline trench on the western side of the hatchery building. Soil borings will not be advanced directly in the waterline trench due to the density of utilities in that area.
Two soil borings will be advanced upgradient and three soil borings will be advanced downgradient of the 2007 soil boring B25 in the northeastern section of the site, as noted on the attached site sketch.
Soil borings will be advanced to a depth of approximately 20 feet, or until groundwater is encountered, and will be screened every 5 feet using PetroFlag field kits. Two analytical soil samples will be collected from each soil boring as described in the Work Plan (USAF 2010).
These samples will be submitted to the laboratory for DRO analysis.
As proposed in the Work Plan (USAF 2010), soil borings will be advanced and groundwater grab samples will be collected via SP16 and analyzed for DRO. No other contaminants of concern have been found in soils at this site. However, the extent of surface water influence on groundwater is unknown. Therefore, grab groundwater samples will be analyzed for BTEX and polycyclic aromatic hydrocarbons (PAHs) to look for potential exceedences of surface water criteria (TAH and TAqH).
Based on Elmendorf Well Atlas maps, the groundwater gradient across the site is thought to be from northeast to southwest. Groundwater on the site may flow directly towards Ship Creek. The newly installed sheet pile retaining wall is also thought to influence groundwater flow locally on the northeast side of the site.
Groundwater grab samples are planned in the vicinity of the proposed soil borings on the attached sketch using SP16 tooling. Three groundwater grab samples will be collected on the western side of the hatchery building to triangulate the possible downgradient groundwater flow from the contaminated soils returned to the waterline trench. Five samples will be collected from the northeastern section of the site. The proposed locations are in an assumed upgradient and downgradient location from the original contaminated boring, assuming that groundwater flows downgradient from that corner by flowing around the retaining wall to the south. One additional groundwater sample will be collected from the existing monitoring well on the north side of the site (OU5MW-12).
Groundwater samples will be analyzed for DRO, BTEX, and PAHs to look for potential exceedences of surface water criteria (TAH and TAqH). The SP16 sample points will not be developed, so the results will represent a grab sample to assist in evaluating whether contamination is reaching groundwater. The monitoring well (OU5MW-12) will be sampled following low-flow procedures as detailed in the work plan.
A report will be prepared to present the analytical results for this investigation. As noted in the Work Plan, if SP16 groundwater samples exceed the ADEC standard for DRO, then the installation of permanent monitoring wells will be considered. TAH and TAqH were not part of the originally proposed analyte list because soil results do not indicate VOCs are of concern.
If TAH and TAqH criteria are not exceeded in SP16 groundwater samples, then additional
investigation will focus only on potential DRO contamination. |
Louis Howard |
| 4/1/2011 |
Update or Other Action |
On 4/1/11, CS's DoD section approved a plan by the Air Force to advance some borings and soil and groundwater grap samples will be collected in the area B25 for DRO. This location is where elevated DRO levels had been detected in groundwater. |
Rich Sundet |
| 10/3/2011 |
Update or Other Action |
Investigative Sampling Report for Post Road Hatchery received from the USAF. This report describes investigative sampling conducted in April 2011 at the Post Road Fish Hatchery located adjacent to Joint Base Elmendorf-Richardson (JBER), Alaska. Investigative sampling activities included GW & soil sample collection in accordance with the 2010 Investigation & Closure Sampling for Environmental Compliance Restoration Sites Work Plan (U.S. Air Force [USAF] 2010a) & the Environmental Sampling at the Fish Hatchery Work Plan Addendum (USAF 2011).
The objective of this project was to further investigate & delineate the lateral extent of petroleum hydrocarbon concentrations identified in soil & GW at the Post Road Fish Hatchery site during November 2007 site characterization activities (Shannon & Wilson 2007) & during 2010 construction activities.
Soil borings were advanced & GW grab samples were collected from temporary well points to investigate the current status of contamination & potential for contaminant migration through GW. One permanent GW well (0U5MW12) was also sampled to investigate the potential for contaminant migration from an upgradient source.
The contaminants of potential concern for the hatchery were originally established based on prior geotechnical & environmental investigations conducted in 2007 & 2010. As described in the prior section, DRO exceeded ADEC cleanup levels for both soil & GW. Soil results also exceeded cleanup levels for metals, but these exceedances reflect background levels native to the area, so metals are not considered contaminants of concern.
The contaminant list for this investigation was established to reflect compounds that are known or suspected to be present at the site, or compounds that needed to be confirmed below cleanup levels. BTEX & polycyclic aromatic hydrocarbons (PAH) were added to the list of GW contaminants of concern to assess the results against surface water criteria (total aromatic hydrocarbons [TAH] & total aqueous hydrocarbons [TAqH]).
Borings were advanced to 10 feet bgs with the exception of BH01, which was advanced to 15 feet bgs. GW was encountered between 6 to 9 feet bgs at all soil boring locations. Soil samples were field screened for total petroleum hydrocarbons using PetroFLAG® at a frequency of one sample per 5 feet of continuous-core boring advanced with the exception of soil borings BH03 & BH05, which were screened twice at the 0- to 5-feet bgs interval. Two analytical samples were collected from each of two different intervals: the upper 5 feet bgs (0 to 5 feet bgs) & at or near the water table (6 to 10 feet bgs), with the exception of soil borings BH03 & BH05 where three analytical soil samples were collected.
One DRO result for Sample FH-BH04A-6-6.5-SO exceeded the ADEC cleanup level of 250 mg/kg at 3,200 mg/kg. This sample was collected from the interval between 6 & 6.5 feet bgs, which is just above the GW interface. All other analytical results for samples collected from this boring & the other six borings were below ADEC cleanup levels & U.S. Environmental Protection Agency (EPA) regional screening levels.
As described previously, analytical samples for GW were analyzed for DRO, BTEX, & PAHs. Sample FH-SPO4A-WG-IP exceeded ADEC Table C cleanup criteria for DRO, PAHs, & TAqH. This sample was collected using the inertial pump. A second primary sample was collected using a peristaltic pump instead of an inertial pump for comparative reasons (due to high turbidity). Analytical results from the sample collected using the peristaltic pump did not exceed ADEC cleanup methods.
Analytical results for the 2011 Post Road Fish Hatchery sample investigation confirm DRO contamination above ADEC cleanup criteria at soil boring BH04, which is located in the northeastern portion of the site. In addition, concentrations of DRO, PAH, & TAqH at this location exceeded the ADEC Table C criteria for GW in a turbid grab sample. The less turbid peristaltic sample did not exceed GW or surface water criteria. DRO levels in soil & GW above ADEC cleanup criteria had been previously documented at the area near BH04.
Based on these results & the history of contamination in the general vicinity, GW impacts may be present; however, GW analytical results are confounded by turbidity in the sample. As such, the recommended remedial action for the contaminated soil at the Fish hatchery is monitored natural attenuation & annual GW sampling. One permanent monitoring well should be installed at the location of BH04, & a second should be installed hydraulically downgradient adjacent to Ship Creek to further determine the degree & extent of potential GW impacts.
|
Louis Howard |
| 10/10/2011 |
Document, Report, or Work plan Review - other |
Staff reviewed and commented on the Post Road Fish Hatchery Investigative Sampling Report Draft September 2011.
5.0 The text states that BH04 is located in the northeastern portion of the site. This location is also referenced in the document as being upgradient. Section 4.2 on page 4-1: “In the northeastern portion of the site, two soil borings were advanced upgradient (BH04 and BH05)…” This would lead the reader to believe either the site has not been characterized enough since there is not a well upgradient of it to see if there is on off-site source which is the source of the 160 mg/L DRO. The level of DRO in BH04 exceeds the theoretical solubility limit of DRO. Indicators of the presence of nonaqueous phase liquid (NAPL) include water samples above the solubility limits – in particular, water samples with DRO concentrations above 4 or 6 mg/L.
ADEC requests, at a minimum, the Air Force install three permanent wells for the Hatchery site. One monitoring well be installed hydraulically downgradient and one monitoring well be installed hydraulically upgradient of the location of BH04. ADEC concurs with the recommendation that a permanent monitoring well be installed at the location of BH04.
Unconsolidated samples for lithologic description shall be obtained at each change in lithology or every 5-foot interval for each of these monitoring wells, whichever is less or as specifically stated in the project work plan.
Analysis will include DRO, BTEX, PAHs for both groundwater and soil samples. Additionally, groundwater well samples will also be analyzed for TAH and TAqH as was done for this investigation.
2.0 Data Quality Summary
ADEC requests the Air Force ensure that the laboratories used are current in their ADEC approval. TestAmerica-Seattle WA (UST-022) certification expires on March 4, 2012 (see ADEC webpage at http://www.dec.state.ak.us/eh/lab/USTLabs.aspx). Instead of repacking the coolers in the TestAmerica Anchorage, Alaska laboratory and shipping off to the TestAmerica Seattle WA laboratory, ADEC requests the Air Force analyze the samples at an Anchorage laboratory. This may minimize the issue with headspace and volatile samples that was experienced with this project.
Analytical Report Job Number: 580-25659-1 Job Description: 05-F525-07-D-010-0013 TO 25, EAFB, AK Contract number: W911KB-04-A-0009 4/27/2011.
Volatile Organic Compounds (GC-MS): “The following samples were received with headspace in the sample vial: FH-SP01A-WG (580-25659-1) and OU5MW12-2011-WG (580-25659-12). Sample 580-25659-1 had an 8 mm air bubble of headspace in one vial used and 10 mm air bubble in the second vial used. Sample 580-25659-12 had a 6 mm air bubble of headspace.”
AFCEE Guidance for Contract Deliverables Appendix C QAPP Final Version 4.0.02 May 2006, (see AFCEE’s webpage for Quality Assurance/Guidance for Contract Deliverables http://www.afcee.af.mil/resources/technologytransfer/guidanceforcontractdeliverables/index.asp) at Section 5.1.2 Sample Volumes, Container Types, and Preservation Requirements Table 5.1.2-1 states for SW8260B, SW8021B sample container - aqueous:
“No Headspace. NOTE: Small bubbles may occur during shipping and handling. Samples with bubbles < 6 mm in diameter (pea sized) are acceptable.”
This implies that aqueous samples with bubbles greater than 6mm in diameter are unacceptable.
All VOC results with headspace greater than 6mm, specifically those associated with samples 580-25659-1 and 580-25659-12, will not be accepted by ADEC for demonstrating compliance with 18 AAC 75 Table C groundwater cleanup levels or TAH/TAqH.
|
Louis Howard |
| 10/12/2011 |
Update or Other Action |
Site name updated from "Anchorage Fish Hatchery" to "JBER-Elmendorf ADF&G Fish Hatchery" to conform to naming convention for JBER-Elmendorf sites. File number reassigned from 2100.38.497 to 2101.38.143. |
Mitzi Read |
| 10/21/2011 |
Document, Report, or Work plan Review - other |
Staff reviewed and approved the final Fish Hatchery Report via email. |
Louis Howard |
| 6/6/2012 |
Update or Other Action |
Draft Project Management Plan for Performance-Based Remediation at JBER May 2012 received.
Performance indicators
Prepare an approved Cleanup Workplan by December 2012
· Coordinate, mobilize, and execute Site Cleanup Activities by September 2013
· Prepare an approved Site Cleanup Report by April 2014
· Conduct 2014 and 2015 RA-O Monitoring Event with an approved Annual RA-O Monitoring Memo
· Prepare an approved Site Closure Report and conduct final site closure requirements and well abandonment to achieve SC.
Potential Risk
Contamination extends vertically or horizontally farther than identified in
investigation, groundwater remains contaminated post excavation.
Risk Mitigation
Excavation will continue until contamination is removed to a depth of <25 feet bgs to
eliminate the migration-to-groundwater pathway, evaluation of groundwater treatment will
occur, and appropriate treatment (ISCO) will be implemented to remediate groundwater.
Brief Description of Planned Approach to Achieve Performance Objective
Prepare an approved Cleanup Workplan with an updated CSM. Coordinate, mobilize, and execute
Cleanup Workplan by installing and sampling ten soil borings and convert three borings to monitoring wells (up, down, and crossgradient).
Use HRC to evaluate SC based on risk to future residential receptors for all pathways. Conduct excavation of contaminated soil exceeding HRC risk levels to groundwater and perform off-site thermal treatment of impacted soils and perform confirmation sampling of excavated area. Monitor downgradient groundwater to ensure groundwater meets cleanup levels post cleanup activities.
Prepare an approved Cleanup Report with an updated CSM including the Site Closure Report requesting Cleanup Complete without ICs. Receive ADEC concurrence with Cleanup Complete without ICs and provide documentation to AFCEE.
NOTE to File:
HRC cannot be used for sites with existing groundwater contamination exceeding Table C (DRO at 1.5 mg/L) |
Louis Howard |
| 6/22/2012 |
Update or Other Action |
ADEC comments on the draft Project Management Plan for Performance-Based Remediation at JBER.
Table 6-3 JBER-Elmendorf
General comments
Risk mitigation: In general, vadose zone soils shall not exceed maximum allowable levels for petroleum contamination for soil from 0 – 15’ bgs (i.e. direct contact for BTEX, PAHs & ingestion for DRO, GRO, RRO) regardless of HRC calculated levels. Treatment or excavations deeper than 15’ bgs may be warranted on a site-specific basis to prevent the soil from acting as a continuing source of GW contamination.
In addition, sites with existing GW contamination above Table C cleanup levels will require that migration to GW cleanup levels be used for soil & ICs will be required. Once GW is below Table C for for a period of time (per the latest approved “Basewide Monitoring Program Well Sampling Frequency Decision Guide”), the maximum allowable levels may become the cleanup levels as determined by ADEC on a case by case basis.
7.1.2 Page 7-3
Document Preparation & Version Control
Draft & Draft Final Versions of documents
Agency review of draft/draft-final version of documents are subject to those review time frames for primary & secondary documents & conditions as specifically identified in the respective Federal Facility Agreements for JBER or a mutually agreed upon schedule agreed to in writing by the three agencies’ remedial project managers.
Independent QA Oversight on Performance Based Contracts
The site cleanup rules require that “collection, interpretation, & reporting of data, & the required sampling & analysis is conducted or supervised by a qualified, impartial third party”. Depending upon the specific terms in a performance based contract, a contractor may no longer be considered an impartial third party with respect to collecting, interpreting & reporting data.
This should be taken into consideration when preparing scopes of work. ADEC strongly recommends the Air Force provide an on-site Quality Assurance Representative or a third party QA oversight contractor to monitor fieldwork for consistency with approved plans & contract requirements.
7.2.1 Pages 7-5 & 7-6
UFP-QAPP Requirements (Planning)
Any existing approved UFP-QAPPs will be updated to reflect current regulations & guidance that have been updated since they were approved.
Page 7-6
The text states: “Our Technical Site Managers & Project Chemists will ensure that, prior to sampling activities, full service analytical laboratories to be used are, at a minimum, DoD ELAP accredited & in good standing based on standard business information sources (e.g., Dunn & Bradstreet). In addition to DoD ELAP, the Project Chemist will also ensure that the supporting laboratories are approved for work in the State of Alaska, when required. Analytical methods used will be Alaska & EPA standard methods, unless technically impractical.”
ADEC disagrees. The full service analytical laboratories have to be both DoD-ELAP accredited & Alaska approved. Any non-EPA &/or Alaska methods must be approved by the department prior to sample collection
Table 11-1
Hatchery CS-C506 (CRP)
GW is already impacted at the site (160 mg/L DRO detected in sample FH-SP04A-WG-IP) & migration to GW cleanup levels (e.g. Table B1) are applicable. Staff previously commented & agreed in an October 10, 2011 letter to JBER regarding the proposed locations of monitoring wells recommended in the November 2011 Post Road Fish Hatchery Investigative Sampling Report: “…one at BH04, a second hydraulically upgradient of BH04, & a third downgradient of BH04, adjacent to Ship Creek.” Sites with GW contamination above Table C cleanup levels will not receive a “cleanup complete” designation without ICs.
|
Louis Howard |
| 9/21/2012 |
Update or Other Action |
Draft Basewide UFP-QAPP received. This UFP-QAPP encompasses activities at 141 sites on JBER during the 8 year contract Period of Performance (POP) (includes the Hatchery known as CS506). The project approach is to advance sites to site closeout utilizing Optimized Exit Strategies (OES). Activities will include investigations/characterizations, remedial actions, active and passive remediation, long term monitoring/management and the use of the Hydrocarbon Risk Calculator (HRC), where applicable.
Decision Rule: If groundwater exceeds ADEC Table C, remedial options will be evaluated and/or ICs implemented.
Note to file:
In general, vadose zone soils shall not exceed maximum allowable levels for petroleum contamination for soil from 0 – 15’ bgs (i.e. direct contact for BTEX, PAHs and ingestion for DRO, GRO, RRO) regardless of HRC calculated “risk” levels. Treatment or excavations deeper than 15’ bgs may be warranted on a site-specific basis to prevent the soil from acting as a continuing source of groundwater contamination.
In accordance with ADEC’s Risk Assessment Procedures Manual, “The maximum detected concentration in groundwater shall be used as the EPC for the assessment of risk posed due to exposure to groundwater (i.e., ingestion, dermal contact, inhalation of volatiles from water). Considering the dynamic nature of groundwater, it is not deemed appropriate to average concentrations over an aquifer. This is recognized in 18AAC75.345 (e) regarding the point of compliance where groundwater cleanup levels must be met throughout the aquifer.
Using the maximum detected concentration provides a conservative approach to assess risks from this pathway, since it assumes the individual well is utilized as a residential drinking water source. This is also consistent with DEC’s compliance determination in 18AAC75.380(c)(2) requiring the use of the maximum concentration in groundwater.” |
Louis Howard |
| 12/17/2012 |
Update or Other Action |
Pre-draft UFP-QAPP received.
Site characterization activities will be performed to delineate the extent of impacts to site soil exceeding 18 Alaska Administrative Code (AAC) 75 soil cleanup criteria for petroleum product contaminant, Diesel Range Organics (DRO). Site characterization soil samples will also be analyzed for extractable petroleum hydrocarbons (EPH), and volatile petroleum hydrocarbons (VPH).
The overall objectives for the site are to meet “unrestricted or residential site use” criteria and achieve a “cleanup complete without institutional controls (ICs)” determination. To meet these objectives soil samples will be collected to characterize risk to human health and the
environment within the framework of the Alaska Department of Environmental Conservation
(ADEC) site cleanup process (18 AAC 75).
If ADEC Method Two criteria is exceeded, the Hydrocarbon Risk Calculator (HRC) approach under Method 3 will be used to assess whether site conditions meet ADEC risk criteria (in which case, a “cleanup complete without ICs” determination will be requested) or whether the site poses unacceptable risk. Soils that are determined to pose an unacceptable risk as indicated by the HRC will be excavated.
Approximately 8 borings will be installed to groundwater approximately 10 ft bgs to delineate
the vertical and horizontal extent of the soil contamination. The borings will start at the potential source, BH04, and step out perpendicular to groundwater flow. The first step out will be approximately 15 ft., to one cross gradient side, and dependent on what the screening results of that boring are will determine the next step out length. This process will continue until a clean sample is encountered, once the one cross gradient side is delineated, that same length will be applied to the opposite cross gradient side. Once the lateral extent of the contamination is delineated this process will be used to delineate the down gradient extent of contamination.
Confirmation sampling will be conducted after excavation is complete in accordance with
Table 2B of the ADEC Draft Field Sampling Guidance (ADEC 2010). Confirmation soil samples
will be analyzed for DRO. At a minimum one floor sample will be collect for every 250 ft², and
sidewall samples will be collected at the rate of one for every 20 linear feet.
The samples from the smear zone and the vadose in the soil boring cores will be collected and
screened utilizing a PID. Based upon results of the PID field screening, approximately three
samples from each boring with the three highest PID readings will be collected and submitted for
DRO analysis. The borings will start at BH04 and step down gradient until the edge of the
contaminated smear zone soils have been reached.
Once the downgradient extent has been established the boring will be converted to a new ground
water monitoring well and sampled once the site has come back to equilibrium. The groundwater
will be analyzed for DRO.
Once the extents of the contaminated soil have been delineated and the HRC has been run to
evaluate risk to other residential receptors the soils that exceed both ADEC, and the HRC
cleanup criteria will be excavated. Once the impacted soils are excavated, conformation samples
will be collected and analyzed. All analytical samples will be collected and sent to an ADEC
approved analytical laboratory. The laboratory analytical sample results will be used to
document that the cleanup levels for the analytes described in this UFP-QAPP have been met.
In the event that a floor or sidewall confirmation sample comes back above cleanup levels the
following procedure will be followed:
Floor
- Excavate in six inch lifts until the soil is below cleanup levels and collect additional
confirmation samples as necessary.
Sidewall
- Step out 10 feet from the sample location and excavate in 6 inch lifts until the soil is
clean and collect additional sidewall and floor confirmation samples as necessary. |
Louis Howard |
| 3/19/2013 |
Update or Other Action |
Draft UFP-QAPP received via email.
The overall objectives for the site are to meet “unrestricted use and unlimited exposure (UU/UE), which is equivalent to residential use” determination or site closure. To meet these objectives soil samples will be collected to characterize risk to human health and the environment within the framework of the Alaska Department of Environmental Conservation (ADEC) site cleanup process (18 AAC 75). If ADEC Method Two criteria are exceeded, the Hydrocarbon Risk
Calculator (HRC) approach under Method 3 will be used to assess whether site conditions meet
ADEC risk. Soils that are determined to pose an unacceptable risk as indicated by the HRC will
be excavated. If site meets ADEC risk criteria, a site closure report will be prepared for CS506.
Approximately 8 borings will be installed to groundwater approximately 10 ft bgs to delineate
the vertical and horizontal extent of the soil contamination. The borings will start at the potential
source, BH04, and step out perpendicular to groundwater flow. The first step out will be
approximately 15 ft., to one cross gradient side, and dependent on what the screening results of
that boring are will determine the next step out length. This process will continue until a clean
sample is encountered, once the one cross gradient side is delineated, that same length will be
applied to the opposite cross gradient side. Once the lateral extent of the contamination is
delineated this process will be used to delineate the down gradient extent of contamination. The
Samples from the smear zone and the vadose in the soil boring cores will be collected and
screened utilizing a PID. Based upon results of the PID field screening, approximately three
samples from each boring with the three highest PID readings will be collected and submitted for
DRO analysis. The borings will start at BH04 and step down gradient until the edge of the
contaminated smear zone soils have been reached.
Once the downgradient extent has been established the boring will be converted to a new ground
water monitoring well and sampled once the site has come back to equilibrium. The groundwater
will be analyzed for DRO, PAH, and VOCs. This same process will be completed for the cross
gradient, closest to Ship Creek. The monitoring well that is removed during the excavation will
be replaced with a monitoring well.
Once the extents of the contaminated soil have been delineated and the HRC has been run to
evaluate risk to other residential receptors the soils that exceed both ADEC, and the HRC
cleanup criteria will be excavated. Once the impacted soils are excavated, conformation samples
will be collected and analyzed. All analytical samples will be collected and sent to an ADEC
approved analytical laboratory. The laboratory analytical sample results will be used to
document that the cleanup levels for the analytes described in this UFP-QAPP have been met.
Confirmation sampling will be conducted after excavation is complete in accordance with
Table 2B of the ADEC Draft Field Sampling Guidance (ADEC, 2010). Confirmation soil samples will be analyzed for DRO. At a minimum one floor sample will be collect for every 250 ft, and sidewall samples will be collected at the rate of one for every 20 linear feet. In the event that a floor or sidewall confirmation sample comes back above cleanup levels the following procedure will be followed:
Floor
· Excavate in six inch lifts until the soil is below cleanup levels and collect additional
confirmation samples as necessary.
Sidewall
· Step out 10 feet from the sample location and excavate in 6 inch lifts until the soil is
clean and collect additional sidewall and floor confirmation samples as necessary. |
Louis Howard |
| 5/30/2013 |
Document, Report, or Work plan Review - other |
ADEC has reviewed the responses to its comments on CS506 UFP-QAPP work plan and finds the responses acceptable. Please finalize the document. |
Louis Howard |
| 10/31/2014 |
Update or Other Action |
Draft SC report received for review and comment.
Conclusions
Soil boring and sampling activities started in the assumed source area of BH04. Field observations and analytical results indicated that contamination extended north of Post Road,
upgradient of the assumed source. This was confirmed by placing seven additional borings north
of Post Road. Four of these seven borings were on ARRC property.
The objectives of the 2013 and 2014 activities were to characterize contamination at CS506 and
to remediate contaminated soil through excavation. The results of the site characterization
concluded that there was an unidentified upgradient source of DRO contamination that may be
migrating to the site; therefore, the proposed remedial approach of excavating contaminated soil
was determined to not be a viable option.
A review of 2013 and 2014 results, historical and surrounding site information, and groundwater flow direction indicated that DRO contamination was not associated with other known JBER-E sites or CS506 activities. This new upgradient source is not associated with the CS506 site and is recommended for further investigation. The contamination associated with CS506 and past operations at this location has been remediated.
Recommendations
Based on compliance with environmental cleanup criteria, it is recommended that ADEC grant
Site CS506 at JBER a “Cleanup Complete” determination. Institutional controls do not appear to
be applicable for this site. Additionally, a complete site characterization should be completed
upgradient to determine the source and extent of the DRO contamination. |
Louis Howard |
| 11/12/2014 |
Document, Report, or Work plan Review - other |
Staff provided comments on the draft SC report.
Executive Summary
Last Paragraph
The text states: “A review of 2013 and 2014 results, historical and surrounding site information, and groundwater flow direction indicate that DRO contamination at the site may not be associated with JBER or CS506 past operations. This new source is not associated with CS506 and is recommended for further investigation.”
ADEC concurs that the DRO contamination at the site known as CS506 (Hatchery) is from an unknown upgradient source not associated with CS506. ADEC concurs that further site characterization should be accomplished upgradient to determine the nature and extent of the source of the DRO contamination.
Based on the information provided, ADEC has determined that CS506 has been adequately characterized and it will be administratively closed out with a “cleanup complete determination” assigned to it in the CS database. The contaminated soil identified migrating to CS506 will be subject to 18 AAC 75.325(i) pending additional site characterization. Please finalize the document. |
Louis Howard |
| 11/13/2014 |
Cleanup Complete Determination Issued |
NOTE: Site is administratively closed and information has been forwarded to the project manager for ADEC overseeing work on ARRC sites.
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The Alaska Department of Environmental Conservation (ADEC) has reviewed the environmental records for the referenced site. This decision document memorializes the site history, cleanup actions, cleanup complete determination, and standard conditions for long-term site management for CS DB Hazard ID 4639 and file number 2101.38.143.
In 2013 and 2014, additional site investigation work was conducted to fill data gaps. Soil boring and sampling activities started in the assumed source area of BH04. Field observations and analytical results indicated that contamination extended north of Post Road, upgradient of the assumed source. This was confirmed by placing seven additional borings north of Post Road. Four of these seven borings were on ARRC property.
The objectives of the site investigation work was to characterize contamination at CS506 and to remediate contaminated soil through excavation. The results of the site characterization concluded that there was an unidentified upgradient source of DRO contamination that may be migrating to the site; therefore, the proposed remedial approach of excavating contaminated soil was determined to not be a viable option.
A review of 2013 and 2014 results, historical and surrounding site information, and groundwater flow direction indicated that DRO contamination was not associated with other known JBER-E sites or CS506 activities. Based on the information presented, ADEC concurs with this conclusion. This new upgradient source is not associated with the CS506 site and is recommended for further investigation. Excavation, groundwater monitoring well installation, and groundwater sampling were not conducted at CS506 since the location of the source is unknown.
Based on a review of the environmental records, ADEC has determined that CS506 has been adequately characterized and has achieved the applicable requirements under the site cleanup rules. ADEC is issuing this written determination that cleanup is complete, subject to a future department determination that the cleanup is not protective of human health, safety, welfare, or of the environment [18 AAC 75.380(d)]. A “cleanup complete” designation will be entered for CS506 in the Contaminated Sites Database, subject to the following standard conditions.
Standard Conditions
1. Any proposal to transport soil or groundwater off-site from CS506 requires ADEC approval in accordance with 18 AAC 75.325. A “site” [as defined by 18 AAC 75.990 (115)] means an area that is contaminated, including areas contaminated by the migration of hazardous substances from a source area, regardless of property ownership
2. Movement or use of contaminated material in a manner that results in a violation of 18 AAC 70 water quality standards is prohibited.
3. Notations of these requirements shall be made on the Environmental Restoration map/ Base General Plan which will show up during a dig permit review/work clearance request process.
|
Louis Howard |
