| Action Date |
Action |
Description |
DEC Staff |
| 5/26/1950 |
Update or Other Action |
HQ US Army AK & HW Alaskan Air Command: Joint Agreement on division of Responsibilities in the Operation of Separate Army and Air Force Installations at Fort Richardson and Elmendorf Air Force Base Alaska. This agreement includes the following: a. The extent of joint utilization of existing services and facilities and the responsibility for their operation. b. The extent and method of budgeting for cross-servicing of jointly-utilized facilities. c. The definition of boundaries dividing the present Fort Richardson Military Reservation into two separate installations -Fort Richardson and Elmendorf Air Force Base. Armed Forces Food Service School: Bldgs T-312 and T-310. Various terminal bulk fuel str1rage facilities pertaining to the Quartermaster Section, Alaska General Depot.
The buildings listed above, will be vacated as soon as suitable facilities become available at Fort Richardson. These are expected to be included in the FY 1950-FY 1952 construction programs. The use of the terminal bulk fuel storage and distribution facilities operated by the Alaska General Depot will be authorized by an Agreement.
Toxic Chemical Storage Area The area known as the AC Inert Storage Area, near junction of Flight? Road & Hill Road and approximately 9,000 feet north of Whitney Station, will continue to be used jointly by the Army and Air Force for storage of Army and Air Force chemicals and chemical munitions. AFM 66-12. aka CW006 which encompasses SD015 on the JBER Environmental Atlas (2016).
In addition, the chemical supply section of the U.S. Army, Alaska, had the use of igloo No. B-8 in ammunition storage area "B" of Elmendorf for storage of toxic chemical ammunition, although because of lack of space some items had to be stored outside. |
Louis Howard |
| 6/30/1954 |
Update or Other Action |
In 1954, there were still evidently 28 1-ton containers used for storing 27,540 pounds of H (Mustard Gas) on Elmendorf. A memorandum was found comparing the options of returning them to CONUS, moving them to Ladd or Big Delta for storage, or disposing of them on site. The recommendation was to dispose of them at point of storage, but there was no actual decision indicated (2000 Research of Materiel at PACAF bases). |
Louis Howard |
| 8/2/1988 |
Update or Other Action |
Elmendorf Operable units' source areas that correspond to RCRA SWMU(s) from the RCRA RFA (New Number & Old Number)SD15 D-16 POL Sludge Disposal site #2 - off Loop Road, North side of Base. Located northwest of Alaska Railraod, west of Hubble Rd. and less than one acre. In use from 1970-1983 for weathering filters and pads. Consists of three separate pads (30X50 ft.). This site presence little potential for environmental contamination. |
Louis Howard |
| 10/20/1989 |
Update or Other Action |
ADEC Ron Klein, Supervisor, Contaminated Site Investigations, sent letter to Captain Brad Gerken, Dept. of Air Force, 5099th Civil Engineering Operations Squadron (AAC) Subject: Response to September 27, 1989 Letter; Requirements for Temporary Storage of Petroleum Contaminated Soil. Enclosed is a copy of the Southcentral Region Office's interim policy for storage and disposal of waste oil contaminated soil.
The guidance also applies to storage of soils contaminated with clean fuels if they are to be stored off the site where they were generated or stored on-site longer than thirty (30) days. The guidance document will be revised shortly to make that explicit. Petroleum contaminated soils generated on-site and stockpiled onsite for less than thirty (30) days must be placed on a bermed liner and covered. The liner and cover must be at least 6 mil reinforced polyethylene.
Alaska Department of Environmental Conservation Southcentral Region Office - Interim Policy For Storage and Disposal of Waste Oil Contaminated Soil
The Southcentral Regional Office solid waste program has been working on an interim policy for storage and disposal of waste oil contaminated soil. Currently the Region has approved the removal of waste oil contaminated soil to a facility permitted to properly handle the contamination. With the exception of the Municipality of Anchorage (MOA) Landfill and Alaska Pollution Control Palmer Facility (pre-treatment for landfill disposal) all of these
facilities are located in the contiguous United States.
Currently, if the waste oil contaminated soil does not meet MOA Landfill criteria the only disposal option is to send the contaminated soil out of Alaska. Soil disposal under this method is costly due to handling, shipping, and facility fees. In discussions with Responsible Parties (RP) there appears to be a strong move to develop other local disposal methods that would meet with agency approval. Therefore the Regional solid waste program has developed interim storage guidelines for waste oil contaminated soils.
These guidelines include the following:
1. An approved design for a low-maintenance or maintenance free storage liner and cover that will be able to withstand winter conditions and is petroleum resistant. This will include a schedule to monitor the storage facility to verify that the integrity of the liner and cover is maintained throughout the storage period.
2. Obtain a solid waste storage plan approval for onsite storage of waste oil contaminated soil from ADEC prior to storage construction.
3. The Responsible Party may propose to remove the waste oil contaminated soil to an off-site storage location if long term on-site storage is not practical. This location must be approved of by the Department prior to any transfer of the soils. The storage site must meet, ADEC design criteria and the RP must obtain an off-site; solid waste storage plan approval prior to transfer of the soil. All transfer of soil off-site must be done under a Bill of Lading and copies provided to ADEC.
4. The maximum allowable storage time is one (1) year. |
Ron Klein |
| 12/29/1989 |
Document, Report, or Work plan Review - other |
ADEC Comment letter sent to Air Force Everett L. Mabry, Colonel, USAF Base Civil Engineer on RI/FS Stage 4 Second Draft work plan October 1989. 1. For several sites the disposal method for soil contaminated with high levels of TPH is quoted as "the sanitary landfill". The only area landfill that is permitted to received petroleum contaminated soil is the Municipality of Anchorage (MOA) Landfill. The MOA Landfill will accept soils only if the TPH level is below
1000 mg/kg. In many cases the work plan was referring to soils with TPH in excess of 1000 mg/kg. The issue of proper contaminated soil disposal has been brought up by ADEC several
times (reference letters: Klein to Gerken, October 20, 1989 and Klein to Mabry, November 2, 1989).
The Department requests clarification on the disposal method of soils contaminated with TPH levels over 1000 mg/kg and verification that the proposed sanitary landfill is the MOA Landfill. In addition, the Department requests written notification regarding disposal of all contaminated soils. The notification should include: date of disposal, quantity of soil, location that soil originated, and final disposal method.
2. The Department requests that an expanded seasonal sampling schedule be established for selected monitoring wells. In several sites (for example, well W-18 on site IS-1) there may be floating product. The Department is concerned that accurate data is not being collected based on a once a year sampling schedule. Seasonal water table fluctuations can easily dilute or mask the true concentration level of the contaminate. Determinations on site status and remedial actions are being based on incomplete information.
3. In all the proposed borings/monitoring wells the work plan calls for two soil samples per boring to be taken to determine the extent of vertical contamination. The exact depth of the sample is to be based on field screening results. Field screening techniques to determine the presences of TPH contamination is not reliable and it is not uncommon to miss contaminated zones using field screening in leu of analytical laboratory analysis. Also much of the contamination is from old fuel spills which may now be low in benzene and again would be very difficult to read on any field meter calibrated to benzene. The Department requests that
additional soil samples be taken in soil borings/monitoring wells and recommends that sampling be done on 5 foot or 10 foot intervals depending on the total depth of the boring.
4. Paragraph 2.2.1.2 and many other sections reference HNu readings of less than 1 ppm. Key data such as span setting, ambient HNu reading, and calibration gas used, need to be stated
to interpret HNu data. Ambient levels of greater than 1 ppm at span 9.8 calibrated to benzene are common. Relaying solely on HNu field screening may allow contaminated zones to be missed. Again the Department requests that additional soil samples be taken in soil borings/monitoring wells.
5. In many sites two deep borings/monitoring wells are proposed. The decision to drill the second boring would be based on the results of the first deep boring. The Department is concerned that using only two soils samples per boring to determine if contamination is present will allow layers of contamination to be missed. The Department requests that additional soil samples be taken to determine the vertical location of contamination and that this additional sampling be used to determine the depth of the second deep boring and the other shallow borings.
6. Paragraph 2.2.1.2 and other sections in the RI/FS state that well contamination is not likely because of the Bootlegger Cove aquitard. Stage 3 RI/FS analysis of base well BW-1 shows the presence of chlorinated solvents and TPH, also base well BW-51 had TPH present. This indicates contamination is currently infiltrating into drinking water aquifers. Has a survey of
possible routes through the aquitard been performed? For example, paragraph 3.3.1.5 states that over 400 wells are in the Elmendorf area. Well casings can offer excellent conduits for contamination migration. ADEC requests the following information for each of the base drinking water wells : total depth, wells logs (if available) and how these wells are completed (screened or perforated zones, etc.).
SITE D-16
Paragraph 2.2.1.1 states that TPH levels as high as 8160 mg/kg were detected at Site D-16. The paragraph further recommends disposal of contaminated soil in the landfill. A TPH level of 8160 mg/kg is too high for a landfill disposal option. The soil must be treated prior to landfill disposal.
Paragraph 5.2.2.1 Boring/Monitoring Well Installation states that there will be one 10 foot boring completed. The Department request clarification on the exact purpose of the proposed 10 foot boring when the other shallow borings are to be drilled up to the depth of 50 feet. We also request the location of the proposed 10 foot boring. |
Ron Klein |
| 12/30/1989 |
Site Added to Database |
Gasoline, diesel, chlorinated solvents. |
Louis Howard |
| 1/1/1990 |
Update or Other Action |
Technical Document to Support a Remedial Alternative, January 1990 Draft received. Site D-16 is located in the northwest portion of Elmendorf AFB, AK. Site D-16 is also referred to as petroleum, oils, and lubricants (POL) Disposal Site No. 2. The site itself is fairly flat, but is located in a hummocky area at an elevation of 300 feet, in the northeast portion of Elmendorf AFB.
Site D-16 was used as a waste disposal area from the early 1970's to 1983. It consists of 3 separate concrete pads where fuel tank residue, fuel filters, and pads were placed to weather and an area where fuel tank sludge was buried. Numerous filters remain at the site. In 1983, Engineering-Science reported that an obvious fuel odor and minor fuel stains were present in the area.
Site D-16 has been used as a sludge disposal area from the early
1970's to 1983. The sludges disposed of here were fuel storage tank residues. In addition, fuel filters and pads were placed on concrete pads at this site to weather. Numerous fuel filters remain at the site.
HNu readings of 160 parts per million (ppm) and petroleum odors were noted in boring D16-02 at depths of 0.5 and 5 feet. HNu readings of 75 ppm were recorded and petroleum odors were noted at depths of 0.5 and 5 feet in boring D16-04.
Results of laboratory analyses of soil samples collected at the
site are shown in Table 1. Only total petroleum hydrocarbons (TPH), lead, and moisture contents were analyzed. The laboratory results showed detectable TPH contamination in 2 of the soil borings. The maximum TPH concentrations were 8,160 mg/kg in soil from D16-02 and 1,110 mg/kg in soil from D16-04.
These TPH concentrations are well above the cleanup standards of 100 mg/kg suggested by the ADEC Interim Soil and Groundwater Guidelines (1989). Alternative 9 (Excavation, Offsite Sanitary Landfill Disposal) is the alternative recommended for remediation of Site D-16. This alternative consists of the excavation and removal of soils at Site D-16 and disposal at the Anchorage Regional Landfill facility which accepts soils containing TPH concentrations of less than 1000 mg/kg. It is assumed the mean TPH concentration of soil to be disposed of at the landfill will be less than 1000 mg/kg.
Standard landfill operating equipment, such as bulldozers, backhoes, and dump trucks will be used to remove contaminated soil and transport it to the local landfill. The 3 concrete slabs on the site will be decontaminated, broken apart, and transported to the landfill. All remaining fuel filters and pads will also be transported and disposed of with the soils.
The Regional Landfill is contained with a high density polyethylene (HDPE) liner and is equipped with a leachate collection system and groundwater monitoring system. Alternative 9 is readily implementable, would meet desired performance, reliability, and safety requirements, and would provide the desired result of contamination removal. The alternative would comply with ARARs. It also received a high environmental impact rating. It also received high public health impact ratings. The estimated present worth cost of the alternative ($1.95 million) is 78 percent less than the cost of Alternative 10, which would provide similar beneficial results. |
Jennifer Roberts |
| 11/12/1991 |
Enforcement Agreement or Order |
Federal Facility Agreement under Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) signed for docket # 1089-07-19-120. The agreement ensures that the environmental impacts associated with past and present activities at the Base are thoroughly investigated and appropriate removal and/or remedial action(s) taken as necessary to protect human health and the environment. Elmendorf Federal Facility Agreement signed.
The general purposes of this Agreement are to: (a) Ensure that the environmental impact associated with past and present activities at the Site are thoroughly investigated and appropriate removal and/or remedial action(s) taken as necessary to protect the public health, welfare, and the environment.(b) Establish a procedural framework and schedule for developing, implementing, and monitoring appropriate response actions at the Site in accordance with CERCLA, the NCP, Superfund guidance and policy, RCRA, RCRA guidance and policy, and applicable state law.
The FFA divided the CERCLA study source areas at Elmendorf AFB into the following seven operable unites (OUs), on the basis of geographic proximity and similar source characteristics or contaminants:
- OU1 Landfills (LF05, LF07, LF13, LF59, OT56)
- OU2 Tank Spill Sites (ST20, ST41, including the ST41 Sludge Disposal Area)
- OU3 Central Containment Area (SD16, SD31, SD52, SS21)
- OU4 Northern Containment Area (SD24, SD25, SD28, SD29, FT23, SSl0)
- OU5 Southern Containment Area (ST37)
- OU6 Surface Disposal Sites (LF02, LF03, LF04, SD15, SD73, WP14)
- OU7 Limited Field Investigation (SS19)
Proposed listing on NPL was 07/14/1989 and Final listing on NPL was on 08/30/1990.
See site file for additional information.
|
Jennifer Roberts |
| 11/12/1991 |
Update or Other Action |
Jennifer Roberts Federal Facility Coordinator sent letter to Joe Williamson and Rich Howard pursuant to Section 9.1 of the Elmendorf Air Force Base Federal Facility Agreement (FFA). ADEC designates Jennifer Roberts as the Project Manager and Ron Klein as the Alternate Project Manager for all activities covered under the FFA. |
Jennifer Roberts |
| 12/30/1991 |
Update or Other Action |
EPA sent letter to AF Rich Howard and Joe Williamson. The notification will serve as an addendum to the previous letter of November 4, 1991 which designates the USEPA project managers pursuant to Section 9.1 of the Elmendorf Air Force Base (EAFB) Federal Facilities Agreement (FFA). Marcia Combes will serve a lead remedial project manager (RPM) for Basewide activities, as well as Operable Units (OUs) 2, 3, 5, 6, 7. Michele Poirier-McNeill will serve as lead RPM for OUs 1 and 4. In addition both RPMs will serve as an alternative RPM on OUs for which they are not the lead. For communication and correspondence purposes, the lead RPM should be the point of contact, and the alternate should be copied. |
Jennifer Roberts |
| 4/9/1992 |
Update or Other Action |
EPA Memorandum April 9, 1992 Reply to the ATTN of ES-098. Subject Toxicity of Fuels. From Carol Sweeney, Toxicologist Health and Environmental Assessment Section. To Wayne Pierre Federal Facilities Superfuend Branch (HW-124). A response has been provided to the frequently-asked question of whether a reference dose or other toxicity information can be provided for fuel mixtures so that these mixtures can be addressed quantitatively in Superfund risk assessments. The memo from ECAO Cincinnati is attached (last attachment). They have developed reference doses for gasoline, JP-5/kerosene, and JP-4, and a cancer potency factor for gasoline. The memo emphasizes that these are provisional numbers and that considerable uncertainty is involved in this quantitative assessment, because of data limitations, and because inhalation studies were used to calculate oral reference doses.
I typed up a summary table showing the numbers (first attachment) and calculated some risk-based concentrations (second attachment). On the risk-based concentration table, I also
included ordnance compounds, because I hadn't made a table of those before that I can remember. The risk-based concentrations were calculated the same way as table II-1 and II-2 of the Region
10 Supplemental guidance; for soil, the same limitations apply, that the numbers presented do not consider pathways other than soil ingestion.
Toxicity Reference Vaules for Fuel Mixtures EPA Region 10 4/9/1992 Non-cancer effects-Gasoline (unleaded) RfD (mg/kg-day) Oral: 2.0E-1, Uncertainty Factor-Oral:1000, Level of Confidence-Oral: Low. Toxicity Data Source-Oral RfD: Memo 3/92. Carcinogenicity-Cancer Potency/(mg/kg/day): Oral 1.7E-3, Unit Risk (/ug/m3) 4.8E-7, Cancer Weight Of Evidence-C, Toxicity Data Source-Oral SF and Inhal. SF: Memo 3/1992.
Kerosene/JP-5 RfD2.0E-2, UF Oral: 10,000, LOC Oral: low, TDS Oral RfD: Memo 3/92
JP-4 RfD 8.0E-2, UF Oral: 10,000, LOC Oral: low, TDS Oral RfD: memo 3/92.
Screening Values for Water RBCs based on Ingestion, Residential
Gasoline-Risk = 10-6 (ug/L) 50, 10-4=5000 HI=1 (ug/L) 7000
JP-5 Kerosene Risk 10-6 10-4=NA HI = 1 (ug/L) 700
JP-4 Risk 10-6 10-4 = NA, HI = 1 (ug/L) = 3,000
Screening Values for Soils- RBCs Based on Soil Ingestion Residential
Gasoline-Risk = 10-6 (mg/kg) 400, 10-4 (mg/kg) 40,000, HQ = 1 (mg/kg) 50,000
JP-5 Kerosene Risk 10-6 10-4 NA, HQ =1 5,000
JP-4 Risk 10-6 10-4 NA, HQ = 20,000
USEPA Office of Research and Development, Environmental Criteria and Assessment Office Cincinnati, OH Subj: Oral Reference Doses and Oral Slope Factors for JP-4, JP-5; similar to Kerosene (CAS no. 8008-20-6), Diesel Fuel (CAS No. 68334-30-5), and Gasoline (CAS No. 8006-61-9) (AVGAS) [McChord AFB (Wash Rack/Treatment)/Tacoma, WA]. From Joan S. Dollarhide Associate Director, Superfund Health Risk Techncial Support Center, Chemical Mixtures Assessment Branch TO Carol Sweeney USEPA Region X.
This memorandum is in response to your request for oral systemic and carcinogenic toxicity values for JP-4, JP-5, diesel fuel, and gasoline (AVGAS) found to contaminate soil and
groundwater at McChord AFB (Wash Rack/Treatment), Tacoma, WA. We have attempted to derive RfDs and slope factors for the above fuel mixtures. We have derived provisional RfDs for
gasoline, JP-4, JP-5 and diesel fuel; provisional cancer weight-of-evidence classifications of C for gasoline and D for JP-4, JP- 5 and diesel fuel; and a provisional slope factor (adapted from an interim Agency value) for gasoline
Based on the available evidence, unleaded gasoline can be assigned to U.S. EPA (1986) weight-of-evidence Group C: possible human carcinogen. An earlier U.S. EPA document assigned unleaded
gasoline to Group B2 as a probable human carcinogen (u.s. EPA, 1987a), but that document predates the U.S. EPA (1991d) conclusion that the male rat kidney tumors produced by gasoline
are not predictive for humans, and therefore should not contribute to the weight-of-evidence or dose-response assessment of carcinogenicity. IARC concluded that marine diesel fuel is possibly carcinogenic to humans (Group 2B), but light diesel fuels and jet fuels are not classifiable as to their carcinogenicity in humans (Group 3). |
Jennifer Roberts |
| 9/16/1992 |
Update or Other Action |
Revisions to the EAFB FFA SOW OUs 4 and 7 from Air Force to ADEC (J. Roberts). 1. As a result of this summer's field investigation, we request attachment 1 of the FFA be revised as follows:
a. Move FT23 from OU7 to OU4. Based on the results of the Limited Field Investigation (LFI) it appears FT23 may be a source of contamination observed in past investigations at SD24, SD25,
SD26, and SD27.
b. Move SD31 from OU4 to OU3. Geographically, SD31 is more closely aligned with the sources in OU3.
c. Move SS63 (Classic Owl) from OU4 to OU7. Currently at Classic Owl a building is under construction by the Corps of Engineers. If SS63 remains in OU4, then there could be major
conflicts which several contractors working in the area. Also by moving SS63 into OU7, we would be able to address all of the sources located north of the Elmendorf Moraine in one remedial
investigation.
d. Delete the requirement of an interim remedial action (IRA) at OU4. Based on the LFI, the remedial project managers identified the dry wells at SD24, SD28, and SD31 as potential
IRAs. However, further review of the results of the LFI, indicate only the sludge at the bottom of the dry well at these sources were sampled and no soil samples were obtained. At this
time there is no evidence of soil contamination in the immediate vicinity of the dry wells. Without additional investigation of these wells, it does not appear an IRA is warranted. Instead of an IRA, we will pursue funding to remove the sludge in each dry well.
e. Delete the requirement of an IRA at OU7. In 1988, light non-aqueous phase liquid (LNAPL) contamination was found and an IRA was put into the FFA to remove the LNAPL from this source
area. Based on two rounds of water level measurements that showed no LNAPL and soil samples collected this summer (see attachment 1), it appears that there is no reason to address the
LNAPL and we do not have enough information to address the soil contamination. Without additional investigation of this source, it does not appear an interim action is warranted.
s/s Joseph Williamson and approved by Jennifer Robers RPM ADEC.
NOTE TO FILE: "Limited Field Investigation or "LFI" shall mean screening investigations of potential source areas with, inadequate data to determine whether these areas pose an
unacceptable risk to human health or the environment. Limited Field Investigations (LFIs) will be conducted at the old spill/disposal sites to identify whether or not these sites pose an unacceptable risk to public health from soil ingestion, dust inhalation, future agricultural use and crop uptale or direct contact. The potential for these areas to represent a
significant source to groundwater contamination will also be evaluated. Prior to performing LFI's a workplan will be developed identifying the Data Quality Objectives established based on the conceptual site model development.
As the objectives of the LFI are to ascertain the potential risk to human health from shallow soil contamination and/or the risk to human health from groundwater contamination resulting from the leaching of contaminants from these areas, the scope of the study is significantly less than that of an RI/FS. A sampling analysis plan "SAP" consisting of a field sampling plan (FSP) and QAPP will also be submitted as part of the workplan. At completion of the LFI investigation, a LFI report which contains the findings of the investigation shall be submitted to the agencies for review and comment.
A determination shall be made between the Project Managers to the disposition of each of the
sources. Based on report results a decision will be reached between the Project Managers on
what specific source areas in the operable unit (OU) require follow up action. The decision will be reflected in the administrative record." |
Jennifer Roberts |
| 1/7/1993 |
Update or Other Action |
USAF sent an action memorandum letter regarding the revision to the EAFB FFA scope of work for OUs 4 and 7 (USAF letter 12/21/1992). Currently OU7 is made up of 4 source areas: SS10, SD15, SS19, and SS63. Move SS10 from OU7 to OU4. A limited field investigation (LFI) to be conducted on source areas SD15, SS19, and SS63. If after the LFI it is determined that any of these source areas need to go to RI/FS, then they will be moved into OU6. Since all source areas will be moved into an OU there will no longer be a requirement for an RI/FS at OU7. |
Jennifer Roberts |
| 10/4/1993 |
Update or Other Action |
Conceptual site model received for OU6. SD15 consists of 3 separate 30 by 50 feet concrete pads used from the early 70s to 83 for weathering fuel filters and pads and disposal of tank sludges. A walk through survey of the area revealed 17 old building foundations or concrete pads in the general vicinity. The road was originally cleared to 4 of the pads for weathering filters. 13 of the old foundations did not appear to have been cleared or prepared in any way for potential waste disposal. Based on the historical information and on the results of the 1993 limited field investigation sampling effort conducted at the fourth pad, only the first 3 pads will be investigated as part of OU6.
The direction of groundwater flow, magnitude of hydraulic gradient, and hydraulic properties of the aquifer underlying the source area have not been established. The water table has never been encountered and therefore the potential horizontal and vertical extent of groundwater contamination associated with SD15 has not been established. The lateral and vertical extent of soil contamination at SD15 has not been fully characterized. |
Jennifer Roberts |
| 12/14/1993 |
Update or Other Action |
Operable Unit 7 Limited Field Investigation Report received for SD15 (formerly D-16).
Of the two soil borings at Pad No. 1 (Figure 3-7), E7-SB-06, was the least contaminated, with only 1,1,2,2-tetrachloroethane found in the borehole's surface soil sample and its field duplicate at concentrations up to 98.3 mg/kg. This halogenated volatile compound was detected at lower depths, but below the comparison criteria and at significantly lower concentrations. At boring E7-SB-06, arsenic exceeded both the carcinogenic RBC (0.4 mg/kg) and the deep zone background UTL (9.24 mg/kg) at the
19 to 21 foot depth interval with a concentration of 11.1 mg/kg.
However, since the background concentrations were only marginally exceeded in this sample and one other sample at the source area, and since the potential soil action level of 24 mg/kg was not exceeded, the arsenic detection should not be a concern.
At the other soil borehole, E7-SB-05, a number of compounds exceeded the comparison criteria. Benzene, at 0.351 mg/kg, exceeded the criteria at 7 to 9 feet, while GRO and DRO exceeded the criteria at both the surface (0 to 2 feet) and at depth
(7 to 9 feet).
Benzene was detected (at 1760 ug/kg) above its potential
ARAR of 100 ug/kg in only one soil sample, E7-SB-03, at the 7-9 foot depth interval. All other benzene results for Pad No. 2 were either not detect, or well below the potential soil action level. GRO was detected above both its' carcinogenic RBC (386 mg/kg) and potential ARAR (100 mg/kg) in the surface soil sample E7-SS-04 (0.5-1 feet) and the soil boring E7-SB-03 (7-9 feet) at 8,600 mg/kg and 2,200 mg/kg, respectively. DRO was also detected in these two soil samples above its' noncarcinogenic RBC (2,160 mg/kg) and potential ARAR (200 mg/kg) at 3,000 mg/kg and 6,000 mg/kg, respectively, and at 550 mg/kg from the surface soil sample at E7-SS-05 (0.5-1 feet).
At Concrete Pad No. 3: Benzene was detected above its ARAR (100 ug/kg) in one surface soil sample (1,120 J ug/kg at E7-SS-03, 0.5-1 feet) and three soil borehole samples from E7-SB-01. The values at E7-SB-01 for benzene were 11,900 ug/kg at 2.5-4.5 feet, 3,490 ug/kg in the 2.5-4.5 feet field duplicate, and 194 ug/kg at 14-16 feet depth interval. The benzene concentration did decrease with increasing depth, and was below the comparison criteria at 34-36 feet.
GRO exceeded its carcinogenic RBC (386 mg/kg) and potential ARAR (100 mg/kg) at the same four sample locations and depths as did benzene. These GRO concentrations were 33,000 mg/kg at E7-SS-03 (0.5-1 feet), 21,000 mg/kg at E7-SB-01 (2.5-4.5 feet), 18,000 mg/kg at E7-SB-01 (2.5-4.5 feet field duplicate), and 5,200 mg/kg at E7-SB-01 (14-16 feet). As with benzene, the concentration decreases with increasing depth, and was below the comparison criteria at the 34-36 feet depth interval in the E7-
SB-01 soil borehole. DRO exceeded its comparison criteria at one surface soil sample, E7-SS-03 (0.5-1 feet). This concentration was 10,000 mg/kg, which exceeded the non-carcinogenic
RBC of 2,160 mg/kg, and the ARAR of 200 mg/kg.
Analytical results for this source area indicate that soil contamination is present in local areas, probably from past POL tank sludge disposal activities. Soil contamination is present at levels above RBCs and/or potential ARARs for benzene, as well as for DRO, GRO, and lead, which indicate a wide spectrum of hydrocarbon contamination. In addition, significant benzene and GRO contamination at Concrete Pad No. 3 is evident to depths of at least 14 to 16 feet bgs.
Although the primary contaminants at the site appear to originate from POL products, there is evidence of solvent contamination (e.g., 1,1,2,2-tetrachloroethane at 98,300 ug/kg and 1,4-dichlorobenzene at 147,000 ug/kg). There is also evidence of toxic metals contamination; seen in the presence of barium and thallium above potential action levels.
Relatively high concentrations of volatile organics present in surface soils are also significant, given that the concrete pads have been out of operation for at least 10 years. According to the discussion provided in Section 2.11, the criteria for inclusion into the CERCLA RI/FS process are met at this site. During discussions concerning this site, the EPA, ADEC, and Elmendorf AFB agreed that further studies of this site should be done to determine the nature and extent of contamination. Therefore, a focused investigation through the CERCLA program is recommended for this site. |
Jennifer Roberts |
| 4/15/1994 |
Update or Other Action |
In a meeting held between USEPA, ADEC, and USAF at Elmendorf AFB on 11, August 1993, the USEPA and ADEC requested that a limited modeling effort be performed at source area SD15 in order to characterize the leaching potential of the contaminants to the groundwater. The Hydrologic Evaluation of Landfill Performance (HELP) model was utilized to estimate the travel time of infiltration water through the vadose zone at source area SD15. Once the travel time through the vadose had been established, this information was used to predict the concentration of target organic constituents in the pore water. An evaluation of the potential for migration of inorganic contamination to the groundwater was also conducted based on information obtained from the literature.
The travel time for a slug of infiltration water migrating from the ground surface to a depth of 100 feet can be estimated from the final moisture distribution profile obtained at the end of the 20-year simulation. According to this moisture profile, the uppermost 10 layers of the model (corresponding to a depth of 75 feet below ground surface) have experienced an increase in the moisture content beyond field capacity over a twenty year period. Therefore, the slug of infiltration water is expected to have migrated into the next layer (corresponding to a maximum depth of 83 feet) over 20 years. This translates into a travel time of approximately 4.2 feet/year. Extrapolating on the basis of these results, it would take approximately 24 years for the infiltration water to reach the water table at an assumed depth of 100 feet.
The organic concentrations calculated for a depth of 100 feet below ground surface show all of these concentrations are lower than the respective MCLs for these compounds. The carcinogenic RBC for benzene is exceeded; however, this simple modeling approach does not consider any dilution which will take place when the pore water in the vadose zone reaches the water table, thus decreasing the dissolved concentrations even further. It is reasonable to expect that this dilution as well as dispersion in the saturated zone would decrease the benzene concentration to below the carcinogenic RBC, (8.0E-4 mg/L as per USEPA, 1992).
|
Jennifer Roberts |
| 1/19/1995 |
Update or Other Action |
OU5 Groundwater (GW) Modeling Report received. The objectives of the modeling task were to: Evaluate the movement of contaminants across Elmendorf AFB (EAFB) and within Operable Unit (OU) 5; Predict migration over the next 30 years; and Determine if selected receptor points along Ship Creek and an unnamed beaver pond will be impacted. A 3 dimensional finite element model (SALT) was selected because of its versatility in handling complex geology and boundary conditions. It was modified to improve the program's efficiency, to include contaminant decay and site specific boundary conditions along Ship Creek. This revision was called SALT 3 consists of GW flow and contaminant transport models. The hydrogeology of the modeled area was evaluated using lithologic data collected from all available boreholes within the modeled area and water level data collected from shallow water table monitoring wells in March and September 1993.
After a review of the data from September 1993 GW sampling and available OU 1, 2, and SERA site data, benzene and trichloroethene (TCE) were selected as representative compounds due to their potential health impacts. Concentrations in the recharge over the water table was set to zero except for at source areas. Since improvement in soil quality is expected over time, the sources were assumed to cease contributing benzene and TCE to GW after 5 years. All levels in the recharge zone were set to zero at the end of the first 5 years.
The conclusions show benzene and TCE will migrate toward the south and decline over time. Because of infiltration, there may be some localized areas that experience a temporary increase in level as a "pulse" migrates toward the south. Benzene will be detectable in GW for over 20 years, however, the levels in GW basewide should be below the MCL after 15 years (1993-2008). TCE levels will be detectable in GW after 30 years (2023) and should be less than the MCL basewide after 20 years (2013). |
Ray Burger |
| 6/15/1995 |
Site Ranked Using the AHRM |
Initial ranking. Action code added because it wasn't when the site was originally ranked. |
Bill Petrik |
| 7/12/1995 |
Meeting or Teleconference Held |
Restoration advisory board meeting held to discuss: Elmendorf Air Force Base’s relative risk site evaluation process
Restoration Advisory Board Charter approved and signed, and public meeting for the Proposed Plan for Final Remedial Action at Operable Unit 3. |
Ray Burger |
| 12/22/1995 |
Meeting or Teleconference Held |
The purpose of this confirmation notice is to convey the significant decisions reached and pertinent issues discussed during the above referenced meeting. The meeting was held to address final questions regarding the selection of the preferred alternatives for OU 6.
The Air Force is in concurrence with the decision to excavate and thermally treat shallow contaminated soils at SD15. The specific location for injection of treated groundwater from SD15 was discussed. It was noted that the plan is to inject groundwater which meets ARARs and is at an acceptable risk level (<10'6). The groundwater will be injected into the vadose zone outside the boundary of the perched aquifer and outside of the influence
of the high-vacuum extraction process. The injected water would then percolate (and continue to naturally filter) downwards to the aquifer at 125 feet below grade. Administrative issues associated with re-injection were discussed. Marcia agreed to verify that there would be no special ARARs which would have to be met
for re-injection at SD15. None were identified in the meeting, and none will be identified in the Preliminary Draft Proposed Plan. |
Ray Burger |
| 1/1/1996 |
Update or Other Action |
Elmendorf AFB OU6 RI/FS Addendum January 1996. Work performed during the 1995 investigation included the installation of four soil borings, soil sampling, installation of a monitor well, and
groundwater sampling. The four new soil borings at SD15 show
that the perched aquifer extends somewhat further to the south than was previously estimated. The primary area of recharge to the perched aquifer appears to be in the vicinity of well MW-90 at the southern edge of the grass lake between Pads 2 and 3. Water was encountered at approximately three feet bgs in MW-90 and saturated conditions continued to 26 feet bgs.
Contaminants detected in MW-90 include 216 ug/L benzene, 867 ug/L unidentified gasoline range organics (UGRO), 559 ug/L unidentified diesel range organics (UDRO), and smaller amounts of several chlorinated solvents, of which trichloroethene (TCE) is most abundant at 22.7 ug/L. Samples from MW-17 and MW-18 contain substantial concentrations of BTEX, fuels, and solvents, including 1,2-dichloroethane (DCA), 1,2-dichloroethene (DCE), and
TCE. No significant concentrations of any contaminants were identified in MW-28.
In MW-18, these changes in concentrations are most likely due to the light nonaqueous phase liquids (LNAPL), noted during a
June 1995 water level survey. A thickness of 2.97 feet of LNAPL was present in the well at that time. No LNAPL was noted in MW-17. All LNAPL was removed from MW-18 following the water
level survey. Between June and September 1995 a new accumulation of 0.26 feet of LNAPL has been detected in the well.
|
Jennifer Roberts |
| 1/2/1996 |
Risk Assessment Report Approved |
Risk assessment incorporated with the final version of the remedial investigation/feasibility study which was received and approved. The residential RME scenario had soil at SD15 exceed the 1.0 x 10-6 carcinogenic and 1.0 noncarcinogenic risk thresholds. Arsenic is the only chemical exceeding the carcinogenic risk threshold (1.6 x 10-5). The soil HI equals 2.3 with the majority (1.9) being contributed by manganese. For the more likely visitor scenario, the carcinogenic risk drops to 1.1 x 10-6 due to arsenic. For the subsurface occupational scenario, risk thresholds were not exceeded. The carcinogenic risk for groundwater in the shallow perched aquifer for the residential RME scenario equals 2.7 x 10-3 with benzene being the primary contributor (2.5 x 10-3) and additional contributions coming from chlorinated VOCs, particularly 1,1,2,2-tetrachloroethane and trichloroethene. The noncarcinogenic HI equals 25.3 with the majority (20) coming from toluene and lower contributions from ethylbenzene and trichloroethene.
In the deep aquifer, the carcinogenic risk equals 1.9 x 10-5 for the residential RME and is associated with carbon tetrachloride. The noncarcinogenic threshold was not exceeded for groundwater. Barium and selenium were calculated to have EQs greater than 1.0 for the black-capped chickadee, masked shrew, and meadow vole. The EQ of 1.0 was also exceeded for the black-capped chickadee and masked shrew for three SVOCs. The highest EQ equals 18,000 and is associated with barium for the black-capped chickadee. However, the high results obtained during the 1993 limited field investigations. Comparable high barium concentrations were not found anywhere during the 1994 RI. |
Jennifer Roberts |
| 1/2/1996 |
Site Characterization Report Approved |
Remedial Investigation/Feasibility Study (RI/FS) received for operable unit (OU) 6 which includes surface disposal area (SD) SD15. SD15 is a source area off of Hubble Road now referred to as Talley Avenue, which consist of 3 separate 30 by 30 concrete pads. The pads were used for weathering fuel filters and pads as well as disposal of tank sludge.
1993 Maximum concentrations of contaminants in soil for the following are as follows:
DRO-10,000 mg/kg at 1 foot.
GRO-33,000 mg/kg at 1 foot.
State of Alaaka Cleanup Level for Non-UST soil. Elmendorf OU 6 site. have been ranked as: LF02, LFO3, LF04, WP14, and SD73- Level B; and SDI5 - Level C.
1,1,2,2-Tetrachloroethane at 97.9 mg/kg at 1ft. (NOTE: 18 AAC 75 migration to GW value is 0.017 mg/kg, inhalation value is 5.4 mg/kg and the ingestion value is 42 mg/kg);
1,1,1-Trichloroethane-9.26 mg/kg detected at 1 foot below ground surface (NOTE: 18 AAC 75 migration to GW value is 1.0 mg/kg the inhalation value is 460 mg/kg. The inhalation value for 1,1,1-Trichloroethane are based on soil saturation level (Csat) using the equations set out in Guidance on Cleanup Standards Equations and Input Parameters, adopted by reference in 18 AAC 75.325).
Trichloroethylene-1.2 mg/kg detected at 2 feet below ground surface (NOTE: 18 AAC 75 migration to GW value is 0.027 mg/kg and inhalation value is at 43 mg/kg).
Subsurface soils maximum contaminant levels detected are as follows:
DRO-6,000 mg/kg at 9ft.
GRO-221,000 mg/kg at 4.5 feet.
1,1,2,2-Tetrachloroethane-0.918 mg/kg detected at 21 feet below ground surface (NOTE: 18 AAC 75 migration to GW value is 0.017 mg/kg).
Tetrachlorethene-0.0666 mg/kg detected at 16 feet below ground surface (NOTE: 18 AAC 75 migration to GW value is 0.030 mg/kg).
1,1,1-Trichloroethane-7.740 mg/kg detected at 4.5 feet below ground surface (NOTE: 18 AAC 75 value is 1.0 mg/kg).
Trichloroethene-1.740 mg/kg detected at 21 feet below ground surface (NOTE: 18 AAC 75 migration to GW value is 0.027 mg/kg).
1994 data surface soils
DRO-7,210 mg/kg detected at 0.75 feet below ground surface.
GRO 11,500,000 mg/kg detected at 2 feet below ground surface.
Tetrachloroethene-0.048 mg/kg detected at 2 feet below ground surface (NOTE: 18 AAC 75 migration to GW value is 0.030 mg/kg).
Trichoroethene-0.279 mg/kg detected at 2 feet below ground surface (NOTE: 18 AAC 75 migration to GW value is 0.027 mg/kg).
Subsurface soil contaminants:
GRO-1,490,000 mg/kg detected at 4 feet below ground surface.
Trichloroethene-0.181 mg/kg detected at 36 feet (NOTE: 18 AAC 75 migration to GW value is 0.027 mg/kg).
Little contamination was identified in screening samples from the deep aquifer locations
MW-70, MW-71A, and MW-72. Benzene was the only BTEX constituent detected; it was
found only in MW-72 at 0.6 gg/L. Carbon tetrachloride was detected in all three deep groundwater
screening samples at concentrations of up to 0.27 gg/L (at MW-70). Based on the screening
results, it appears that BTEX and chlorinated VOC contamination in the lower aquifer is
minimal, and that no significant vertical migration from the shallow perched aquifer has taken place.
Only carbon tetrachloride was detected at levels exceeding screening RBCs in samples
from the deep aquifer. This compound was detected in samples from all three wells during
both rounds of sampling. The highest concentration of carbon tetrachloride is in Well MW-71A, and equals 0.58 gg/L. Trichloroethene was also detected in the sample from well MW-72 during Round 1 at a concentration of 0.67 gg/L, which does not exceed the screening RBC. No obvious chlorinated VOC plume is present in the deep aquifer based on the limited detections and low concentrations encountered. No inorganic COPC exceed toxicity screening RBCs in the deep aquifer at Source SD15. |
Jennifer Roberts |
| 3/7/1996 |
Meeting or Teleconference Held |
Minutes from 7 March 1996 Conference Call. OU3 The project schedule will be completed today and distributed to the agencies Monday, March 11. Steve will be working to coordinate the delivery of the schedule to Tim Brincefield at EPA in Seattle.
OU6-We had a conference call yesterday to review the Proposed Plan. As soon as we receive the comments from the State and EPA we will incorporate those comments. We are currently getting the data from the Feasibility Study appendices on the TCE and TCA in the soil at SD15.
We understand that Washington University performed more soil tests on the surface with the very shallow soil at LF02 for lead, if we can get those results we can have our risk specialist review them and find out his opinion is on the risk. We thought another opinion might help to clarify the decision since this issue may be a potention sticking point between the Base and EPA. Sharon noted she will leave a copy of those results with Kim for us to pick up. We are running on a very tight schedule for completing the Proposed Plan.
Kim mentioned the correction to the drawing and the changes to the photograph. Skip noted the illustrator is working on converting two of the drawings into one, and the photo should be ready late
today or Friday. It was noted for the first "murder board" meeting we only need paper copies and do not need to have the drawings mounted. |
John Halverson |
| 4/2/1996 |
CERCLA Proposed Plan |
Proposed plan lists SD15 as being contaminated with benzene, 1,2-dichloroethane, ethylbenzene, toluene, 1,1,2-trichloroethane, trichloroethene in the GW. Soils are contaminated with diesel/gasoline range organics and BTEX in both the shallow and deep areas.
Groundwater and Oeep Soil
High-vacuum Extraction with Institutional Controls and Long-term Monitoring is the preferred alternative for groundwater at SD15. This alternative was recommended for SD15 because the high-vacuum extraction process is a cost effective means of quickly cleaning up the unwanted fuel contaminants in the groundwater. It will also clean the deep soils at SDl5, which will ultimately prevent the movement of the soil contaminants into the groundwater. Active
treatment of the soils at SD15 will serve to help restore affected groundwater in a reasonable time. Active treatment like this is also considered important due to the presence of a layer of oily contaminants detected on top of the groundwater at this source area. The high-vacuum extraction process will quickly remove and clean this layer.
Shallow Soil
Additional action at SD15 will also be taken to cleanup the contaminants in the shallow soil. As at WP14, Excavation, Low Thermal Treatment, and Backfilling (the shallow soil portion of Soil Alternative 4) is preferred as a fast and cost-effective means of removing and cleaning the contaminated shallow soil at SD15. Again, this will prevent movement of the shallow soil contaminants into the groundwater and the removal will prevent the direct contact between
humans or animals with thc contaminated soil. As active treatments, the actions which will be taken at SD15 are the most protective of human health and the environment. |
Louis Howard |
| 5/6/1996 |
Update or Other Action |
Final SD15 Treatability Study Work Plan received. The objective of the treatability study is to evaluate the effectiveness of HVE in treating contaminated soil and groundwater. An HVE system will be designed, installed, and operated for one year. After one year of operation, a report will be written to summarize the effectiveness of HVE in obtaining goals of the treatability study and its contribution towards completion of remedial design/action at SD15.
Initially, shallow, contaminated soil will be excavated to prevent contamination from leaching to the perched aquifer. The excavation task is incidental to the HVE study; therefore, the results will not be analyzed in a treatability study. Shallow soil (less than 5 ft. bgs) with fuel constituents that exceed the cleanup goals established in the OU 6 ROD will be excavated. The soil will then be treated using low-temperature thermal desorption technology at a local soil recycling facility. The treated soil will then be used as backfill in the excavated area. A fifth area of surface soil contamination will be left in place to monitor the effects of HVE on surface soils.
Groundwater contamination above maximum contaminant levels established in SWDA: benzene, 1,2-Dichloroethane, ethylbenzene, 1,1,2,2-Tetrachloroethane (at the time this did not have a MCL), toluene, 1,1,2-Trichloroethane, and trichloroethene. Soil contamination above a preliminary cleanup level "D" of the SOA cleanup level for Non-UST Soil: BTEX, GRO, DRO (100 mg/kg, 1000 mg/kg and 2000 mg/kg respectively). |
Ray Burger |
| 7/24/1996 |
Document, Report, or Work plan Review - other |
Michael Lu Anchorage Western Public Service Office ADEC environmental engineer sent letter to Scott Blount RE: contract F41624-94-D-8049, DO 0003, HVE Treatability Study AWPSA Project # 9621-WW-138-408 review.
The foundation for concrete pad#2, which will facilitate the "Process Building" is currently unknown. Either, a typical of the concrete pad, or verification that the concrete pad was in fact used as a foundation for a building (must specifiy the type of structure), needs to be submitted to this office for review. If neither of the above information can be submitted, then a settlement study will need to be conducted by a Professional Engineer (P.E.) or "registered engineer" to ensure the foundation will support the proposed structure. NOTE: “registered engineer” means a professional engineer who is registered under AS 08.48.171 - 08.48.265.
The following information will need to be submitted to this office for further review and approval.
The extraction blower (B-1301), appears to be acting as a holding tank for oil, as well as, an extraction blower. The oil clean-out process will need to be incorporated in O&M Manual. The turnaround time for water samples that were taken after filtration through the activated carbon adsorbers may exceed the capacity of the treated water surge tank, V-3201. Also if the treated water still contains chlorinated hydrocarbons and fuel hydrocarbons, then the water needs to be re-injected into the system for further treatment.
The design calculations indicates the HVE system can sufficiently extract both liquid and vapor from all the wells. The calculations should, also, demonstrate that the capacity of the liquid discharge rate into the inlet separator, V-1301, does not exceed the capacity of the pump. As a suggestion, in order to ensure continuous operation and decrease any possibility of spill, the removable section of SVE and treated water injection pipe support which crossess the existing road should be left in place as continous pipe and the road should be closed with a detour route posted. The capacity of the activated carbon treatment system needs to be clarified. The 90% design packet, specifies the capacity as 80 gallons with 250 pounds of carbon, however Sheet I-1, specifies 80 gallons with 300 pounds of carbon. |
Ray Burger |
| 8/8/1996 |
Update or Other Action |
Kimberly K. Stricklan, P.E. Booze-Allen & Hamilton Inc. for Elmendorf AFB (AFCEE) reviewed the OU 6 SD15, High Vacuum Extraction Treatability Study, 90% Design. The document provides the draft/final drawings and specifications for a two-phase extraction system at EAFB. This design is considered the final submittal to be reviewed prior to installation of the system. The current project schedule shows that the 100% design will be submitted as the as-built design package. The document was reviewed for technical content, good engineering practices, and compliance with the regulations.
This design submittal was written haphazardly, did not contain all the required information, and did not follow good engineering practices. Several errors were found in the supporting information, and design parameters were used inconsistently throughout the document. In addition to major design flaws, it is apparent that this document did not receive any senior review prior to submission to the Air Force. This design did not follow standard industry procedures and is considered unsatisfactory. Based on the initial review of this design and the attached review comments, we strongly recommend that AFCEE reject this submittal in full and require resubmission of the 90% design prior to approving field installation of the system. |
Kevin Kleweno |
| 8/27/1996 |
Update or Other Action |
ADEC letter to USAF RE: OU 6 Draft ROD July 1996. GENERAL COMMENTS - In all of the discussions of Contaminants of Concern (COCs) the statement is made that some contaminants were not included as COCs because: "(1) their presence was determined to be anomalous, or in the case of groundwater, solely related to smear zone contamination". The second half of this is confusing. It appears to refer to soil contamination found in the smear zone that is to be treated as part of the groundwater remediation. Please clarify.
The cleanup goals stated in the Record of Decision for soil contaminants are different from the cleanup goals stated in the Proposed Plan. Changes in cleanup goals need to be justified and agreed upon by all three parties. Changes between the proposed plan and the ROD need to be adequately described in the ROD.
In the tables summarizing soil analytical results for each section, the "ACM" for toluene, ethylbenzene and xylene are all individually listed as 50 mg/kg. These should be footnoted to indicate that this is a total BTEX level.
Section 2.4.2. Groundwater Alternative G1: No Action: Stating that "cleanup levels are expected to be achieved within the same time frame as Alternative G2" does not take into account the effects of product recovery (a component of G2). This distinction should be made here between the two alternatives.
Section 2.4.4. Soil Alternative S2: This section calls for one sampling event in five years. However, the Proposed Plan calls for annual sampling. Add annual sampling to this section and to the Selected Remedy. Also, the land use restrictions discussed here should be added to the Selected Remedy.
Table 2.4-2 Costs and Time: Alternatives S3 and S5 are not discussed in the text and should be stricken from the table. Also, explain why the intrinsic remediation time estimate is 4 years, versus 13 years in the Proposed Plan.
Section 2.4.5. Summary of Comparative Analysis: Under "Balancing Criteria" it is stated that the no action alternative is not evaluated since it did not meet the threshold criteria. Future mentions of the no action alternative are redundant and should be stricken, e.g., the last sentence under "Implementability".
Section 3.4.5. Summary of Comparative Analysis of Soil Alternatives: Following the statement that the capping and excavation of the landfill are impracticable, the reasons should be explained as in the Proposed Plan.
Section 5.4.3. Summary of Comparative Analysis of Groundwater Alternatives: Under the heading "Overall Protection of Human Health and the Environment" the statement that "Alternatives G2, G3, and G4 provide equal protection" conflicts with the first sentence of the second paragraph and should be stricken.
Section 5.5.1. Protective of Human Health and the Environment: Stating that we will be "removing the waste and covering the surface soils with lead contamination" may be misread as an action placing lead contamination on top of already contaminated soil. This could be clarified by stating our intent of "placing a clean soil cover over the lead contaminated areas."
Section 5.5.1. Statutory Determinations. Action-Specific ARARs: The word "relative"should bereplaced by the word "relevant". This comment also applies to the response to "public comment #4"
in the Responsiveness Summary. |
Ray Burger |
| 1/3/1997 |
Update or Other Action |
The risks for contaminated GW beneath OU 3 are above maximum contaminant levels (MCLs) however; ICs exist at the base for the shallow aquifer & GW monitoring of selected wells located within OU 3 is included as part of OU 5 GW monitoring. Therefore, action is not required for contaminated GW beneath OU 3 under this ROD. The IC against use of shallow GW at the base is through the Elmendorf Air Force Base Facility Board.
ARARS: The Safe Drinking Water Act is not an ARAR for this remedy since no further action is necessary for contaminated GW under the OU 3 ROD. However, it is the ARAR for the GW actions selected in the OU 5 ROD to protect GW receptors.
If further action to protect GW (beneath OU 3) is ever necessary, it will be done pursuant to the OU 5 or OU 6 RODs. OU6 Record of Decision: ICs on land use & water use, as specified in the Base Comprehensive Plan, will restrict access to the contaminated GW. Installation of wells in the contaminated plume for residential, industrial, & agricultural use will be prohibited by the Base Comprehensive Plan until cleanup levels have been achieved.
GW will be monitored semi-annually & evaluated annually to determine contaminant migration & to track the progress of contaminant degradation & dispersion, as well as to provide an early indication of unforseen environmental or human health risk. Five-year reviews will also assess the protectiveness of the remedial action, including an evaluation of any changed site conditions, as long as contamination remains above cleanup levels.
Recoverable quantities of free product found on top of the water table will be regularly removed during GW monitoring events. GW monitoring will be discontinued if contaminant levels are below cleanup levels during two consecutive monitoring events. In that case, no further action for GW will be required.
During the final round of monitoring, samples will be collected & analyzed for ALL constituents that exceeded MCLs during the [remedial] investigation including [but not limited to] VOCs, SVOCs, & metals. These results will be evaluated before a final determination is made that GW meets all cleanup requirements.
OU3 RI
OU3 EAST GW Area (cleanup level)
SD16
TCE 140 ug/L (5 ug/L)
PCE 9.37 ug/L (5 ug/L)
Toulene 1,019 ug/L (1,000 ug/L)
Tetrachloroethene 9.37 ug/L (5 ug/L) MW-11 Appendix R Lab Data (RI/FS OU3)
Intercourse Area-East
TCE 11.5 ug/L (5 ug/L)
1,4-DCB 161 ug/L (75 ug/L)
Benzene 47.9 ug/L (5 ug/L)
Carbon Tetrachloride 29.5 ug/L (5 ug/L)
TCE 35.3 ug/L (5 ug/L)
PCE 33.8 ug/L (5 ug/L)
Bis(2-Ethylhexyl)phthalate 1,150 ug/L (6 ug/L) MW-11 Appendix R Lab Data (RI/FS OU3)
SS21 Table 4-17
TCE 10 ug/L (5 ug/L)
The maximum concentrations of TCE in OU 3 east were found in the groundwater from monitoring wells MW11 and MW12, located at source SDI6. MW11l, which was screened across the water table at the bottom of the aquifer, contained up to 2.98 ug/L cDCE and 140 ug/L TCE. MW12, which is located adjacent to MW11 but is screened at the top of the aquifer, contained 6.46 ug/L cDCE and 44.4 ug/L TCE. Samples from neighboring well MW13 also contained up to 26.9 ug/L TCE. These three wells defined an area of significantly higher TCE concentrations than in surrounding wells to the east and west (up to about 6.ug/L TCE). Elevated TCE concentrations (up to 19.8 ug/L) were also detected in samples from well MW2, which is located approximately 2500 feet south-southeast of wells MW11 and MW12. The presence of cDCE in the groundwater correlates in general with the
presence of TCE, with an elevation in concentrations being present primarily at wells MW13 (up to 14.2 ug/L) and MW12 (up to 6.46 ug/L). Another significantly higher cDCE concentration than in surrounding areas was noted at well MW2 (up to 11 ug/L). which also coincides with an elevation in TCE levels in the groundwater. Concentrations of TCE and/or cDCE exceeding 1 J1.gfL were found as far east as MW15, and as far southwest as MWl6 in the east intersource area with few to no non-detects in between.
The wells at SS21 (MW5R and MW6) were sampled for PCBs; two rounds of sampling did not detect PCB contamination in the groundwater. Benzene was found in the groundwater samples from 12 wells in OU 3 East. The highest concentrations were detected at wells MW12, MW13 and MW14 at source SD16 (maximum of 6.17 ug{L at MW13). roughly coinciding with the maxima observed for TCE and cDCE. |
Louis Howard |
| 1/27/1997 |
Cleanup Level(s) Approved |
Soil: Level D criteria gasoline range organics (GRO) 1000 mg/kg, diesel range organics (DRO) 2000 mg/kg & total benzene, toluene, ethylbenzene, & total xylenes (BTEX) 100 mg/kg.
Groundwater: benzene 5 ug/L, ethylbenzene 700 ug/L, toluene 1000 ug/L 1,1,2-trichloroethane 5 ug/L, 1,2 Dichloroethane 5 ug/L, trichloroethene 5 ug/L (note 1,1,2,2-Tetrachloroethane is listed as a COC but did not have a MCL thus no remediation goal could be established: ROD states that cleanup for it will be considered completed when all other COCs meet MCLs). Institutional controls will remain in place when cleanup levels are met.
NOTE TO FILE: During the final round of groundwater monitoring, samples will be collected & analyzed for all constituents that exceeded MCLs during the 1994 investigation including VOCs & arsenic. These results will be evaluated before a final decision is made that groundwater meets all cleanup requirements.
Exceedances of MCLs from RI Table 10
benzene 1,430 ug/L (5 ug/L)
GRO 31,700 ug/L (2,200 ug/L)
Toulene 4,000 ug/L (1,000 ug/L)
1,1,2,2-Tetrachloroethane 8.6 ug/L (4.3 ug/L)
1,2-Dichloroethane 5.92 ug/L (5 ug/L
TCE 143 ug/L (5 ug/L)
"Jet Fuel" 8,620 ug/L (exceeds 2,200 ug/L for GRO & 1,500 ug/L for DRO)
1,1,2-Trichloroethane 6.97 ug/L (5 ug/L)
§ 300.430 Remedial investigation/feasibility study & selection of remedy.(a) General—(1) Introduction. The purpose of the remedy selection process is to implement remedies that eliminate, reduce, or control risks to human health & the environment. Remedial actions are to be implemented as soon as site data & information make it possible to do so.
Accordingly, EPA has established the following program goal, expectations, & program management principles to assist in the identification & implementation of appropriate remedial actions.
(iii) Expectations. EPA generally shall consider the following expectations in developing appropriate remedial alternatives:
(D) EPA expects to use institutional controls such as water use & deed restrictions to supplement engineering controls as appropriate for short- & long-term management to prevent or limit exposure to hazardous substances, pollutants, or contaminants. Institutional controls may be used during the conduct of the remedial investigation/feasibility study (RI/FS) & implementation of the remedial action &, where necessary, as a component of the completed remedy.
The use of institutional controls shall not substitute for active response measures (e.g., treatment &/or containment of source material, restoration of ground waters to their beneficial* uses) as the sole remedy unless such active measures are determined not to be practicable, based on the balancing of trade-offs among alternatives that is conducted during the selection of remedy.
*“EPA expects to return usable ground waters to their beneficial uses wherever practicable, within a time frame that is reasonable given the particular circumstances of the site. When restoration of ground water to beneficial uses is not practicable, EPA expects to prevent further migration of the plume, prevent exposure to the contaminated ground water, & evaluate further risk reduction” 40 CFR 300.430(a)(1)(iii)(F). |
Jennifer Roberts |
| 1/27/1997 |
Institutional Control Record Established |
Institutional controls (ICs) established by signing of Record of Decision (ROD) and subsequently been enforced by land planning department at the Base and environmental restoration staff oversight.
No current receptors exist for the groundwater at the Base due to the institutional controls (ICs). As a requirement of previously signed RODs for the Base, ICs have been established to restrict the use of the shallow aquifer in the outwash plain on Base. These restrictions are enforced through the Base Comprehensive Plan (BCP).
Projects and other activities are reviewed during the planning stage to ensure compliance with the BCP. In addition, construction projects and other activities also undergo an environmental review. This review helps ensures compliance with groundwater use restrictions. |
Louis Howard |
| 1/27/1997 |
CERCLA ROD Approved |
OU6 ROD:Source SD15 is the 3rd of the OU 6 source areas located on the Elmendorf (EAFB) Moraine. This source area is located several thousand ft. to the east of Sources LF04 & WP14 at an elevation of approximately 275 feet above msl. This source, which is located off Hubble Road, consists of 4 separate 30- by 50-foot concrete pads. The pads were used from the early 1970s to 1983 for weathering fuel filters & pads, & for the disposal of tank sludge. Strong fuel odors, fuel stains on the soil, & fuel filters & pads have been noted at the source area around 3 of the concrete pads (Pad Nos. I, 2. & 3). Cracks were also observed in the weathering pads.
During a walk-through survey conducted in the summer of 1993, a total of 17 old building foundations or concrete pads were noted. The road was originally cleared to 4 of these pads to prepare them to be used for weathering & sludge disposal activities. However, available historical information indicates that disposal activities took place at only the first 3 pads (Pads Nos. 1, 2, & 3). All 4 pads were investigated during the 1993 LFI. Based on the results of the LFI sampling effort, & the historical evidence, only the first 3 pads required further investigation as part of OU 6 (Concrete Pad Nos. 1,2, & 3).
Groundwater (GW) & soil contamination at SD15 consists primarily of metals, HVOCs, & fuel-related constituents. The source of contamination is directly related to the waste management practices conducted in this vicinity. GW data was characterized as 2 distinct aquifers based on the hydrogeology. The GW data were separated into GW results from the perched aquifer & GW results from the deeper aquifer. The predominant type of GW contamination detected at SD15 includes fuel constituents, solvents & other VOCs, & metals. The difference in levels of contamination between the perched aquifer & deeper aquifer at SD15 is substantial with the deeper aquifer showing only minor levels of contaminants & fewer contaminant species.
The perched aquifer results indicated elevated levels of BTEX & fuel constituents, with a maximum benzene concentration of 1,430 ug/L in a sample from monitoring well MW-18. This well had the highest levels of other fuel constituents as well, including gasoline, jet fuel, UDRO, UGRO, & other BTEX constituents. A recurring accumulation of several inches of free phase floating product was also identified in this well. Solvent contamination is also present at SD15, with a maximum detection of 143 ug/L for trichloroethene (TCE) at MW-18. Other volatile organic compounds were detected at substantially lower concentrations.
The contaminants present in the surface soil consist primarily of fuels, weathered fuel residuals, solvents, & metals. Fuel components & metals were the most pervasive contaminants. BTEX constituents were detected at a maximum of 594,000 ug/kg in surface sample E7-SS-03. Other fuels constituents, such as unidentified gasoline range organics (UGROs), were also detected at substantially elevated concentrations. Benzene concentrations were lower in the surface soils than in the subsurface soils; however, concentrations of solvents appear to be slightly higher. SVOCs were only detected sporadically in the surface soils.
Contamination in the subsurface soils were of generally similar types & concentrations to those of the subsurface. Significant concentrations of BTEX (benzene at 11,900 ug/kg, toluene at 135,000 ug/kg, ethylbenzene at 62,000 ug/kg, & xylene at 138,000 ug/kg) were detected in the subsurface soils. Other fuels constituents, such as UGRO, were also detected at elevated levels in (1,490 mg/kg). SVOCs & solvents were detected at significantly lower levels in the subsurface soils.
Seven COCs were identified for the perched GW. All of the COCs contribute to excess risk. All of the constituents except 1,1,2,2-tetrachloroethane were also identified as COCs due to the exceedance of MCLs. Thus, all COCs except 1,1,2,2-tetrachloroethane were identified in the Proposed Plan as having exceeded regulatory guidelines. It is believed that most of the perched aquifer at SD 15 is contaminated, & that a GW plume of dissolved fuel & solvent contamination is present over much of the site. The volatile organic plume at SD15 is depicted based upon concentrations exceeding 5 ug/L, which is the MCL for benzene & TCE. The estimate volume of contaminated GW is 975,000 gallons.
The COCs identified for soil at SD 15 are consistent with those contaminants listed in the Proposed Plan as having exceeded regulatory guidelines. Three COCs were identified in the soils at SD15, including GRO, DRO, & BTEX. These constituents exceeded preliminary remediation goals at multiple locations. Several areas of both shallow (less than 5 feet bgs) & deep (greater than 5 feet bgs) soil contamination requiring cleanup are identified. The estimated volume of contaminated soil is 650 cubic yards.
See site file for additional information. |
Louis Howard |
| 3/13/1997 |
Update or Other Action |
RI action added by Shannon and Wilson on 3/13/97, based on Relative Risk Evaluation worksheet dated 8/22/95. Pathway: Though remote, this area is accessible and could be used recreationally. Perched lens of groundwater (believed transient) was detected at about 30' below ground level.
This aquifer is not typical for potable use. Deeper aquifer (approximately 120' below ground) occurs below the perched lens. This aquifer is relatively clean, however, downward migration from the perched aquifer can occur. Receptors: Recreational users and workers can contact contaminated soil. No drinking water wells in the immediate vicinity. Back-up water supply well is located approximately 3000' to the northwest (cross gradient). This well is believed to be screened in the 120' aquifer, is sampled regularly, and has had minor chloroform detections in the past. |
Louis Howard |
| 6/16/1997 |
Update or Other Action |
USAF Memorandum to ADEC regarding Clarifications to OU2 ROD. The letter is a follow-up to the discussions regarding institutional controls at OU2. The USAF hopes by this correspondence, to clarify appropriate land use controls at OU2 and setup a land use restriction method consistent with the most recent Elmendorf RODs. The OU2 ROD states that groundwater at ST41 needs remedial action and a part of the selected remedy was to restrict land use by implementing zoning controls. The Summary of the ROD on page 9-2 states that the selected remedy includes "Zoning the affected area for industrial use only, excluding the development of commercial aquaculture."
However, the Declaration of the ROD states "Zoning the affected area for undeveloped outdoor/recreational use only." In light of this contradiction and the use of "restricted use areas" under the RODs for OU3 and OU6 the USAF is providing clarification of the permissible land uses within the area affected by ST41 groundwater. The affected area should include those areas that exceed the groundwater cleanup levels established in the OU2 ROD. A map of the area currently and potentially impacted by the contaminated groundwater from ST41 is at attachment 1.
This map may be revised based upon review of the contamination remaining in place, which will be conducted at least every 5 years. While the affected area remains above cleanup levels, it will be designated as a "restricted use area" in the base Planning Office. This designation provides for recreational use of the parcel (such as cross country skiing, bicycling, etc.) and the construction of unmanned facilities (such as parking lots, storage buildings, etc. ) but prohibits the construction of any manned facilities (such as office buildings or a residence). Construction activities within the affected area of OU2 will be restricted to construction of unmanned facilities. Furthermore no construction will be allowed which comes within five feet of the groundwater. Existing industrial uses within OU2 are allowed as they are unmanned. This description conforms to the current base land use planning terminology and is consistent with the recently signed RODs for OUs 3 and 6.
Land use restrictions will be enforced by the following method. When there is a construction project on Base, the project is to be approved by the Base Planning Office. The planner will route all projects through the Environmental Management Office. The project will be disapproved if it conflicts with the above construction restrictions. The USAF believes this will be a reliable and effective means of enforcing the zoning land use restrictions imposed by the various RODs. Signed by Randy E. Honnet Colonel USAF Vice Commander. |
Louis Howard |
| 7/31/1997 |
Update or Other Action |
The Operation and Maintenance Manual for SD 15 high-vacuum extraction system is finalized. |
Louis Howard |
| 6/30/1998 |
Update or Other Action |
First SD15 HVE System Annual report submitted. Contaminant removal - a total of 7,543 pounds of VOCs were removed from the subsurface at SD15. This represents over 1,000 gallons of fuel-type product. Most of it was extracted in the vapor phase. About 56,000 gallons of groundwater were extracted, and 0.2 pounds of BTEX and halogenated VOCs were removed with the groundwater.
On average, it costs about $16.10 per pound to extract VOC contamination from the subsurface using the HVE system. W1301 and W1302 do not require as much vacuum to keep them online if there is minimal water in the area influenced by these wells. If the aspiration valves can be closed, contaminated soil vapor around 1301 and 1302 can be pulled into the system as opposed to clean ambient air. If the vacuum required to operate W-1301 and 1302 can be minimized, more vacuum can be applied to W-1303 and 1304 which have higher VOC concentrations in the extracted vapors. |
Louis Howard |
| 8/24/1998 |
CERCLA ROD Periodic Review |
8/98 remedial action report received which states deep (>5') GRO and DRO soil contamination and petroleum/chlorinated solvent impacted groundwater will meet RAOs by 2002. Soils contaminated with DRO, GRO and BTEX to meet Level D within 5 years.
The purpose of this report is to document Remedial Action (RA) Completion for Operable
Unit (OU) 6 at the Elmendorf Air Force Base (AFB), a National Priorities List (NPL) site. As of
September 11, 1997, all remedial actions selected in the January 1997 Record of Decision (ROD) are in place, have been inspected, and are operational and functional. Operation and maintenance of the remedies will continue until cleanup goals are met.
OU 6 consists of six different source areas. The following three source areas are located in the
northern portion of the base, on the Elmendorf End Moraine: LF04 (Knik Bluff Landfill), WP14
(Petroleum, Oils, Lubricant (POL) Sludge Disposal Site No. 1), and SD15 (POL Sludge Disposal Site No. 2). The three remaining source areas are located in the southeastern portion of the base on a glacial outwash plain south of Ship Creek: LF03 (Hospital Road Landfill), SD73 (surface disposal area surrounding the former United States Geological Survey (USGS) rock testing laboratory), and LF02 (landfill located west of the intersection of the Davis Highway and Oilwell Road).
Lessons Learned:
The Bioventing Treatability Study at WP14 concluded that bioventing was not feasible, and
since there is no significant risk from current exposure, and groundwater is expected to naturally attenuate once other sources are removed, the ROD did not require action for deeper soils.
At WP14/LF04, investigations subsequent to the ROD determined that PL81 had been abandoned in place with fuel remaining inside, serving as an ongoing source of groundwater contamination. PL81 and associated valves are scheduled for removal in the summer of 1998 pursuant to
State authorities.
Concentrations of COCs in one well downgradient from WP14 and PL81 have been increasing,
while other wells in the vicinity have primarily been decreasing. This is attributed to PL81 and
associated valves scheduled for removal during 1998, after which contaminant concentrations throughout this area are predicted to decline through natural attenuation processes.
Only minor quantities (less than one gallon total per year) of floating product have been found at WP 14, LF04, and SD15 during sampling events. This is attributed to the fact that remediation of the source areas is not complete.
The LF04 beach sweep was very successful, resulting in 98 tons of material removed, most of
which was non-hazardous metal. Certain hazardous and potentially hazardous materials were recovered; the known hazards were disposed of appropriately and suspected hazardous materials in drums are scheduled for testing and disposal in 1998. The results do not lead to a conclusion that significant quantities of hazardous material is expected to be found in the future.
Implementation, maintenance, and enforcement of effective ICs, as required in the OU 6 ROD
and several other CERCLA RODs at ElmendorfAir Force Base, has proven to be more complicated that
originally envisioned. This was true in part because the base is a dynamic environment and no single control is completely effective. The IC plan and processes now in place seem to be implementable and effective, and includes some overlapping "layers" of controls to ensure protectiveness.
Based on site visits and reviews of 1996 and 1997 site data, the HVE system at SD15 is
operating within design parameters and progress is being made toward remediation in a timely manner. A soil cover at LF02 is in place. Annual removal of landfill debris on the beach at LF04 will continue to occur. Natural attenuation of contaminants in groundwater is occurring at SD15, LF02, and LF04 based on monitoring reports in a timely manner. After the Summer 1998 removal of suspected source areas at WP14, natural attenuation of contaminants in groundwater is expected to occur. Institutional controls are in place and the procedures are being followed.
The USAF, EPA, and ADEC project managers concur that the OU 6 Treatability Studies and the
LF04 Remedial Action have been successful and that the USAF should continue long-term operation of the ICs, HVE system at SD15, annual landfill debris removal at LF04, and monitoring programs pursuant to the OU 6 ROD until cleanup goals have been achieved.
The USAF certifies on the basis of the above that the OU 6 remedies are operational and
functional. The USAF (with contractor support, at this time from Radian International) will continue long-term O&M of the systems until cleanup goals are achieved. |
Louis Howard |
| 11/4/1999 |
Update or Other Action |
November 1999 OU6 round 2 groundwater sampling for TCE increased from round 1 in 3 wells. OU6MW-18 <5 to 14 ug/l, OU6MW-18 33 to 38 ug/l and OU6MW-90 from <5 to 11 ug/l. Benzene increased from 9.3 to 78 ug/l in OU6MW-17 as well from rnd. 1 sampling to rnd. 2. |
Louis Howard |
| 1/24/2000 |
Update or Other Action |
Staff received the wastewater discharge report for 12/99 sampling effort. Discharge from the first carbon canister on the HVE system continues to be below the general permit level of 1 mg/L TPL and reporting limit's for volatile organic compounds. |
Louis Howard |
| 2/1/2000 |
Document, Report, or Work plan Review - other |
Staff reviewed and commented on a draft annual report for SD15 High Vacuum Extraction System. Comments centered upon closure sampling requirements for soils. A minimum of 3 samples per boring from the highest PID reading, highest historical contaminant area, and as close to the soil groundwater interface. |
Louis Howard |
| 3/1/2000 |
Update or Other Action |
Sometime before June 1943, the military built a magazine at an unspecified location at Fort Richardson to house toxic chemical munitions. In addition, toxic gas yards were established at the six Alaskan posts that stored bulk toxic gases (JGK-73). Although no maps were found identifying these yards, they were described as follows: "The theater stocks of chemical agents are located in various toxic gas yards which in most instances are far removed from the other station and post activities.
[See the May 26, 1950 Joint Agreement for Fort Richardson and Elmendorf for location and map of "Toxic Chemical Storage Area" noted on map as the "AC Inert Storage Area"]. |
Louis Howard |
| 4/10/2000 |
Update or Other Action |
1 January- 31 March 2000 quarterly report received. SD15 HVE system continues to operate since cleanup levels have not been met for groundwater contaminants of concern. |
Louis Howard |
| 6/14/2000 |
Document, Report, or Work plan Review - other |
Staff reviewed and commented on work plan for high vacuum extraction system and sampling plan for closure of an extraction point. Staff requested clarification on whether samples were to be taken to 10 feet in a boring or from 10-55 feet at 5 foot intervals. |
Louis Howard |
| 8/14/2000 |
Update or Other Action |
2000 Groundwater monitoring well results received. Benzene and trichloroethene were higher in 2000 at wells OU6MW-17 and 18 in this source area. |
Louis Howard |
| 10/2/2000 |
Update or Other Action |
Quarterly progress report received for the 3rd quarter 1, July 2000-30 September 2000. Round 2 groundwater samples collected in August 2000. SD15 HVE system was not operational for July and most of August 2000. The continued clogging of the water strainer filters has been fixed. Removed 11.73 tons of debris during FY00 LF04 annual beach sweep cleanup in July 2000. Contractor selected for conducting additional investigation at WP14 where observations from several monitoring wells onsite indicate free product on the water table. Installed fence at LF04. |
Louis Howard |
| 10/31/2000 |
Update or Other Action |
Staff received monthly discharge report from the SD15 high vacuum extraction system being operated at the site. Contaminants of concern remain below the reporting limit for effluent discharge after treatment through a carbon filter. |
Louis Howard |
| 11/13/2000 |
Update or Other Action |
Staff reviewed and commented on report received regarding confirmation soil sampling at the site. Soils at soil vapor extraction well W-1201 were all below cleanup levels established in the OU 6 ROD and 18 AAC 75 regulations. Recommend closure be pursued for soils at this site's vacuum extraction well. If any information is presented in the future that indicates contamination from this source area is above established cleanup levels and/or poses an unacceptable risk to human health, safety or welfare or to the environment, then ADEC reserves its rights to require additional assessment and/or corrective action. |
Louis Howard |
| 3/1/2001 |
Update or Other Action |
Year 2000 Draft SD 15 high vapor extraction system annual report received. Staff commented on the document with regards to correctly identifying the cleanup levels for 1,1-dichloroethene and trichloroethene in groundwater. Staff requested including a separate table for the 1997 and 1999 soil data. Staff also requested mention of the Level D criteria for benzene and BTEX in addition to GRO and DRO cleanup levels. Finally, staff provided clarification that the 11/13/2000 letter for SD15 was meant for closure of soils associated with the SVE well W-1201 and not the entire source area. |
Louis Howard |
| 4/12/2001 |
Document, Report, or Work plan Review - other |
Staff reviewed and approved the site work plan and field sampling work plan for SD 15. The objective of the project is to: document effluent water concentrations of VOCs to satisfy the AK general discharge permit requirement for monthly effluent sample and to determine if breakthrough of the first carbon vessel has occurred. Document influent (i.e. groundwater) concentrations of GRO, DRO, BTEX to monitor the performance of the HVE system and make adjustments as needed. Document vapor concentrations of VOCs, halogenated volatile organics, and the alkane hydrocarbon series C1 to C10 for air quality compliance. Generate data of sufficient quantity to obtain closure of SD15 from the ADEC if closure is supported by analytical documentation. |
Louis Howard |
| 2/21/2002 |
Document, Report, or Work plan Review - other |
Staff reviewed and commented on the basewide annual groundwater monitoring report.
Regulatory Levels
ADEC requests removing the word “Potential” from the heading “Potential Regulatory Level” in the tables throughout the document. Listing the word “Potential” gives the reader the impression that compliance with the levels listed is optional or not required (e.g. Tables 4-7, 4-11, 4-15, 4-20, 4-25, 4-29, 4-32, and 6-2).
Free Product
Please note 18 AAC 75.325(f) states: A responsible person shall to the maximum extent practicable,
(A) use permanent remedies;
(B) recover free product in a manner that minimizes the spread of contamination into an uncontaminated area by using containment, recovery, and disposal techniques appropriate to site conditions.
ADEC recognizes that in some cases it may not be technically practicable to implement an active or passive recovery system for free product.
The Elmendorf Remedial Action Report for Operable Unit (OU) 2 (September 1998) set a precedent for defining what is meant by “technically practicable” for free product recovery. Section 2.4.1 Product Recovery Endpoints at the 1st bullet on page 10 states: “As designed and constructed, the ST41 ground water treatment system cannot recover floating product when there is less than a measurable thickness of 0.1 feet of product. Therefore, as an endpoint for product recovery, if less than 0.1 feet is sustained for one year, recovery at that source can be discontinued. Floating product will be measured monthly. When product thickness falls below 0.1 feet for one year, the recovery of product at that source will not be considered “technically practicable”.
Therefore, where free product is greater than 0.10 feet, ADEC expects corrective action (active or passive) to be implemented for free product recovery. Currently, free product was found to exceed 0.10 feet or more in SERA Phase I well 43-WL-11. This well had the highest level of free product measured at 0.86 feet. The presence of measurable free product is generally not considered conducive for intrinsic (natural) attenuation. ADEC requests the identity of the free product be described in the text at each source area that it is found (e.g. gasoline, diesel, or chlorinated solvents).
3.3.4 Target Analytes Pages 3-10 and 3-11
Benzene and TCE are identified as target analytes to evaluate contaminant of concern (COC) trends in detail and be consistent with the Basewide Groundwater model. ADEC concurs, however, focusing on these two analytes does not accurately reflect whether diesel range organics (DRO) and gasoline range organics (GRO) plumes are migrating, expanding, steady state, or receding (especially for wells noted to have either free product or fuel odor and/or sheen being observed during sampling). Benzene can be at low levels or even non-detectable while concentrations of DRO and GRO remain above cleanup levels (1.5 mg/L and 1.3 mg/L respectively). Please see the following examples below of where benzene was below the 5 ug/L cleanup level, but DRO and GRO are above cleanup levels.
OU 4
Round 1 sampling at well 49-WL-01 detected benzene at 0.11 ug/L and DRO at 2,400 ug/L and well OU4W-11 detected benzene at 4.3 ug/L while GRO was detected at 3,000 ug/L and DRO was detected at 6,100 ug/L [NOTE TO FILE: LNAPL is considered present where analytical data shows DRO concentrations above the theoretical solubility limit for diesel of 3.9 mg/L].
OU6
Round 1 sampling at well OU6MW67 detected benzene at 2.8 ug/L, GRO at 2,500 ug/L and DRO at 1,700 ug/L during round 1 sampling. During round 2 sampling, well OU6MW-91 detected GRO at 25,000 ug/L and DRO at 9,500 ug/L while benzene was found to be non-detectable.
See site file for additional information. |
Louis Howard |
| 2/28/2002 |
Document, Report, or Work plan Review - other |
Staff reviewed HVE System Annual Technical Report. 1.3 Remediation Goals Page 1-6
The text states that environmental monitoring will be discontinued at SD 15 when the remediation goals have been satisfactorily achieved. The ADEC wishes to clarify this statement. The OU 6 ROD specifically states on page 4-30:
When two consecutive groundwater-monitoring events indicate contaminant concentrations are below cleanup levels, the high vacuum extraction (HVE) system will be shut-off. Semi-annual monitoring (twice yearly) will continue for another year, and subsurface soil samples will be collected. If levels are confirmed to be below cleanup levels one year after the system was shut-off, no further remedial action (NFRA) will be required. If contamination is present in any of the samples, the system will be restarted, or another remedial option will be considered.
During the final round of groundwater monitoring, samples will be collected and analyzed for all VOCs and arsenic. These results will be evaluated, before a final decision is made, ensuring that groundwater meets all cleanup requirements. The ADEC requests the text in bold placed in this particular section or include it in Table 2-1 at item Number 6.
5.5 Recommendations page 5-5
The text states in Table 5-3 to shut the HVE system off and allow groundwater and soil mediums to rebound to provide an accurate picture of residual contamination at the site. The ADEC concurs. The decision to turn the system off before two years of groundwater monitoring events indicate that concentrations are below cleanup levels as indicated in the OU 6 ROD, may require the Air Force document this action as a “Post-ROD” change.
Considerations must be made concerning the following:
Scope. Does the change alter the scope of the remedy (e.g., type of treatment or containment technology, the physical area of the response, remediation goals to be achieved, type and volume of wastes to be addressed)?
Performance. Would the change alter the performance (e.g., treatment levels to be attained, long-term reliability of the remedy)?
Cost. Are there significant changes in costs from estimates in the ROD, taking into account the recognized uncertainties associated with the hazardous waste engineering process selected? (Feasibility Study cost estimates are expected to provide an accuracy of +50 percent to –30 percent.)
Based on this evaluation, and depending on the extent or scope of modification being considered, the lead agency must make a determination as to the type of change involved (i.e., non-significant or minor, significant, or fundamental change). Remedy changes should fall along a continuum from minor to fundamental. Similarly, an aggregate of non-significant or significant changes could result in a fundamental change.
Documenting Post-ROD changes is typically covered in one of several ways :
1. Memo to the File (post-decision document file) for any non-significant or minor changes;
2. Explanation of Significant Differences for significant changes made to the remedy;
3. ROD Amendment for fundamental change to the basic features of the remedy selected in the ROD with respect to scope, performance or cost; or
4. Notification of a Force Majeure per the 1991 Elmendorf Federal Facility Agreement (FFA) Section XXVI paragraph 26.1
See site file for additional information. |
Louis Howard |
| 5/21/2002 |
Document, Report, or Work plan Review - other |
Staff reviewed and commented on the draft SD15 Work plan. The table states for shallow soils the cleanup for diesel range organics (DRO), gasoline range organics (GRO) and benzene, toluene, ethylbenzene, and total xylenes (BTEX) is 2,000 mg/kg, 1,000 mg/kg and 100 mg/kg, respectively. The January 1997 OU 6 ROD states on page 4-18 the specific remedial action objectives for SD15 include preventing the possible migration of contaminants from soils having DRO, GRO, and BTEX concentrations exceeding ACM Level D. Also in the OU 6 ROD at Table 4.3.6 it shows that for shallow soils (depth of 0-5 feet), the contaminants of concern are GRO, DRO and BTEX. For contamination in the deep soils (depths greater than 5 feet) only GRO and DRO are listed contaminants of concern for SD15.
The OU 6 ROD ARARs section on page 4-34 states “For petroleum contaminated soil that will be remediated, specific cleanup levels “Level D” in the Alaska Cleanup Matrix, 18 Alaska Administrative Code (AAC) 78.315, are relevant and appropriate (Table 4.5-1).” For clarification, Level D cleanup criteria, at the time the OU 6 ROD was signed, consisted of the following: GRO-1,000 mg/kg, DRO-2,000 mg/kg, sum of benzene, toluene, ethylbenzene, and total xylenes (BTEX)-100 mg/kg, and benzene-0.5 mg/kg. |
Louis Howard |
| 1/14/2003 |
Meeting or Teleconference Held |
Meeting Minutes EAFB Basewide Monitoring Program. January 14, 2003. Attendees: J Williamson (USAF) G Fink (USAF), J. Klasen (USAF), K. Oates (USEPA), L. Howard (ADEC), C. Hinds (URS), P. Dworian (URS), K. Paul (URS).
Agenda: Discuss ADEC’s request to add the analyses of Diesel Range Organics (DRO) and Gasoline Range Organics (GRO) to several Operable Units at Elmendorf.
Summary of Discussion:
1. URS summarized recent (year 2000) ADEC risk assessment guidance that shows that DRO and GRO themselves can cause noncarcinogenic human health risks. This information was not known during preparation of the risk assessments and RODs for Elmendorf Operable Units. Therefore, addition of DRO/GRO to the sampling scheme for Elmendorf was recommended.
2. The Air Force agreed to add DRO/GRO, but cannot add funding to cover the additional analysis until 2004.
3. The following was decided on implementation:
A. This decision will be documented in the 5-Year Review. The addition of DRO/GRO to the program should be introduced in the 5-Year Review under mention of new issues affecting protectiveness.
B. The Air Force will NOT add DRO/GRO as a CERCLA ARAR, but will compare DRO/GRO results to ADEC cleanup levels in the annual reports and will discuss in subsequent 5-Year Reviews. The benefit of this is that if CERCLA COCs meet ARARs, the Air Force can achieve a partial delisting.
C. The Air Force will add DRO and GRO to the suite of analyses at monitoring wells associated with fuel plumes starting in 2004.
D. The Air Force will not pursue a decision document with ADEC on DRO/GRO until more data is gathered on the extent of the problem.
E. Until a decision document is signed with ADEC, GRO and DRO concentrations will be compared to ADEC regulations in 18 AAC 75 (Table C, Groundwater Cleanup Levels; 1,500 µg/L for DRO, 1,300 µg/L GRO).
F. Sampling frequency for DRO/GRO will follow the latest Decision Guide for Sampling Frequency (see 2002 Basewide Annual Report). “Immediately upgradient” means within a 2-year warning line, similar to that generated for OU5.
G. ADEC GRO/DRO criteria apply to groundwater, not to seeps which daylight as surface water. Criteria in 18 AAC 70 (TAH, TaqH) apply to surface water. |
Louis Howard |
| 2/14/2003 |
Document, Report, or Work plan Review - other |
Staff reviewed and commented on the draft SD15 annual technical report. Deep soil closure sampling was performed at HVE Wells W1302, W1303 and W1304 in the summer of 2002 to document the effectiveness of HVE at treating deep soils. Sampling at these locations demonstrated remedation was complete at HVE Well 1302 (also referred to as OU6MW-90) and at HVE Well 1304. Deep soil samples at HVE Well 1303 were all below cleanup goals with the exception of the 9 to 11 foot below ground surface interval. Although this contamination is technically in "deep" soils, it is relatively shallow and in the same vicinity as documented shallow soil contamination.
Shallow soil contamination still remains at two distinct locations at the site. One of these is in an area just south of the HVE Process Building. Contamination remaining in this area was verified with the June 2002 sample EHVE02-SB03C. At this location, gasoline range organics (GRO) slightly exceeds the remedation goal. All other COCs at this locality are below remediation goals. The other area of shallow contamination exists near HVE Well W1303. Contamination remaining in this area was verified with the June 2002 sample EHVE02-SB19C and EHVE02-1303C. Institutional controls (preventing use of the shallow aquifer and fencing) have been established to implement remedies selected in the OU6 ROD and are functioning as intended.
Staff concurred with the recommendations in Table 5-3 to address the two known areas of shallow soil contamination, minimize vacuum to the deep soils and to increase vacuum pressure at wells W-1301, 1302 and 1303. |
Louis Howard |
| 2/25/2003 |
CERCLA ROD Periodic Review |
Staff reviewed and commented on the Draft SD 15 Five year review document. The five-year review of remedial actions taken at all operable units is to ensure they remain protective of human health and the environment. Under CERCLA such reviews are required at least every five years after a record of decision is signed if contaminants remain in place. The Department requests the Air Force address whether large variances in Operations and Maintenance (O & M) costs have occurred which could indicate a potential remedy problem or remedy issue. The table does not provide enough information, nor does the text in the document, to the reviewer as to whether a problem or issue exists with regard to the O & M costs.
The Department concurs with the recommendation to implement changes presented in the document:
•Modify existing system configuration to include soil vapor extraction (SVE) in shallow soils at the two known areas of shallow soil contamination; or
•Minimize vacuum to deep soils; and
•Increase groundwater extraction at HVE Wells W1301, W1302, and W1303 (wells at which contaminant of concern levels exceed remediation goals). |
Louis Howard |
| 6/11/2003 |
Meeting or Teleconference Held |
MEMORANDUM FOR FILE FROM: 3 CES/CEVR SUBJECT: Minutes, Remedial Project Manager Meeting, 11 June 2003
A quarterly meeting of the remedial project managers (RPMs) convened at 1430L on 11 Jun
03 in the Environmental Flight (CEVR) conference room, Building 5312. Mr Louis Howard
(Alaska Department of Environmental Conservation (ADEC», Mr Kevin Oates (Environmental
Protection Agency (EPA) - Anchorage), Mr Gary Fink (CEVR), Mr Joe Williamson (CEVR),
Ms Donna Baumler (CEVR), and Ms Doris Thomas (Public Affairs (3WG/PA» attended. Mr
Claude Mayer (CEVR) joined the meeting via teleconference. Mr Jim Klasen (Legal
(11AF/JACE) was attending a training course and was unable to attend.
SD 15, Treatment of Shallow Soils (Mr Mayer). Previously, we discussed the possibility of
conducting a treatability study for the shallow soils at this site. Our concerns are if a treatability study would require opening the Record of Decision (ROD) and what types of documentation would be required. Mr Oates stated that a treatability study would be appropriate at this site and may even lead to closure. He suggested drafting a letter describing the treatability plan for concurrence and signature by both ADEC and EPA. The letter would be sufficient for documentation, and no "letter of significant difference" would be required. Mr Oates also said the SD 15 information can be included in the letter that Mr Fink is preparing for changing groundwater monitoring frequencies for OU6. |
Louis Howard |
| 6/30/2003 |
Document, Report, or Work plan Review - other |
Staff reviewed and approved the Draft technical report as submitted. |
Louis Howard |
| 9/25/2003 |
Update or Other Action |
Memorandum to the Site File signed for OU6. The purpose of this document (Memorandum to the Site File) is to present non-significant or minor changes to the Record of Decision (ROD) signed for OU 6 and Source Area SS 19 at EAFB. The minor changes to the OU 6 ROD involve modifying the sampling frequency of groundwater wells and the inclusion of portions of the shallow soils at SD 15 in a high-vacuum extraction (HVE) treatability study. Other components to the OU 6 selected remedy will not be affected by this minor change.
The shallow soils will be included in the high-vacuum extraction treatability study (Ref. OU6 ROD Final Jan 97 page 4-32). This minor revision to the ROD changes the sampling frequency for groundwater monitoring. Data collected semi-annually over the past seven years has provided an understanding of the nature and extent of contaminant migration and the effectiveness of intrinsic (natural) remediation. In many instances continuation of the semi-annual sampling would not provide any useful new data as compared to less frequent monitoring.
The second component of the minor revision to the ROD includes implementing a high-vacuum
extraction treatability study for shallow soils at SD15. Approximately 170 yd3 of fuel contaminated soil was excavated and treated during the implementation oft.he selected remedy in
1996. Confirmation samples indicate that two of the four areas have elevated levels of
contamination and will, therefore, be included in the high-vacuum extraction treatability study.
Further soil excavation will be determined after evaluation of treatability study results.
Proposed Changes: Sampling changed from semi-annually to a frequency determined by the Decision Guide. The changes to the sampling frequency will continue to provide sufficient data to assess
contaminant migration and timely reduction of contaminant concentrations by intrinsic
remediation as required by the ROD. The revised monitoring frequency will also streamline the
groundwater reporting process and reduce monitoring costs.
The changes to the sampling frequencies were discussed in the 28 Aug 02 meeting between the
USAF, Region X of the EPA and the ADEC. The high vacuum extraction treatability study for shallow soils at SDl5 was agreed upon at the 11 lun 03 Remedial Project Manager Meeting between the USAF, Region X of the EPA and the ADEC. Both EPA and ADEC project managers concurred with the proposed changes. |
Louis Howard |
| 1/27/2004 |
CERCLA ROD Periodic Review |
Second Five Year review signed by ADEC. Land use controls restrict access to contaminated groundwater throughout the site. Installation of wells in the contaminated plume for residential, industrial, or agricultural use will be prohibited until cleanup levels have been achieved. The land use controls at SD15 will continue until groundwater cleanup goals are reached. A groundwater model will be completed in FY05 and this model should provide an estimate on how long the land use controls will continue.
Monitor effectiveness of the recently implemented treatability study (modifications to the HVE system at SD15) and verify effectiveness of treating shallow soils at the two areas of contamination.
Benzene and TCE concentrations remain above cleanup levels and no discernable decreasing statistical trends have been established since 1997, with the exception of benzene at OU6MW-90 and TCE at OU6MW-17. This, in addition to a decline in HVE contaminant removal rates suggests that the HVE system is approaching design limitations and natural attenuation will be more heavily relied upon to reach cleanup goals. This indicates that concentrations of these COCs may not reach cleanup levels within the timeframe (five years of HVE operation that was predicted in the OU6 ROD). |
Louis Howard |
| 2/3/2005 |
Meeting or Teleconference Held |
Elmendorf FFA XIII. REPORTING 13.1 USAF shall submit to the other Parties quarterly written progress reports. The reports will include, but not be limited to, the following information:
(a) A detailed summary of all of the remedial, removal, and investigation activities during the previous quarter, including any analytical results, any community relations activities, and any community contacts or inquiries related to the hazardous substance contamination at the Site; (b) An outline of the planned activities for the upcoming quarter;(c) A detailed statement of the manner and the extent to which the timetables and deadlines are being met;(d) The status of efforts to obtain rights-of-entry necessary for monitoring and well installation off base; and(e) The status of any other activities proposed or underway that may affect any phase of the activities described in the Attachments.
13.2 The quarterly written progress reports shall be submitted on the tenth (10th) day of each calendar quarter following the effective date of this Agreement.
Meeting minutes from RPM meeting February 3, 2005, ADEC and EPA agreed to decrease the frequency of quarterly reports to semi-annual or twice a year. Quarterly Progress Reports (QPRs) (USAF). EPA and ADEC confirmed that the information they receive in the report, in its current format, is quite useful to them when they are briefing their higher headquarters. Both agreed that we could reduce submittals to semi-annual reports, which will be submitted in December and May of every year. ADEC requested that we continue to break sites out by Operable Unit since that is the way their database has been designed to track.
SDI5, Explanation of Significant Difference (ESD) (Mr. Mayer). Mr. Mayer stated that the programming document is complete and that he has received a list of possible contractors from AFCEE. He will begin developing the Statement of Work and expects to have the contract awarded by the 3rd Quarter. Three items were discussed: (1) The ESD will focus on the remedy, specifically the ARAR for Tetrachloroethene. The state has issued a cleanup level based on 10-5, which we will adopt; (2) LUC language will be updated to reflect current Air Force policy as described in the DP98 ROD (the Oct 03 Memo); (3) A treatability study will be added to see if MNA will work for SDI5. Mr. Mayer will forward a draft copy of the SOW to EPA and ADEC. |
Louis Howard |
| 3/3/2005 |
Document, Report, or Work plan Review - other |
Staff reviewed the draft annual 2004 technical report SD15 HVE System at Elmendorf. ADEC concurs with the recommendations that the HVE system has reached its technological limit and is no longer effective at removing contaminants. At ST41: The technically practicable limit was based upon the ratio of product to water recovered during operation of the treatment system. When less than 0.5 gallons of product per 1,000 gallons of treated water are recovered for the entire system or any system component, the recovery will be considered to be at the limit of technical practicability. While the contaminant removal summary for SD15 was based on pounds of product and gallons of groundwater, it can be stated that a recovery rate of 0.66 pounds of volatile organic compounds for 58,209 gallons of groundwater is indicative of not being technically practicable to continue operation of the HVE.
Shallow Soils: Possible migration of contaminants from soils having DRO, GRO, BTEX concentrations exceeding ACM Level "D" cleanup criteria exists at two locations in relatively shallow soils above the perched aquifer. A treatability study is being implemented for the shallow soil locations to determine if the HVE system modifications will effectively treat these areas.
Remedy selection at SD15 currently protects human health and the environment in the short-term because operation of the HVE system has significantly reduced residual contamination and Land Use Controls are in place to eliminate known points of exposure. Approximately 433,333 gallons of groundwater in the perched aquifer have been treated by HVE through December 2004. Monitoring data shows that HVE has successfully reduced COC concentrations; current data suggest that contaminant removal rates for TCE are approaching steady state conditions. No free product has been detected in wells at SD15 since 1999. Product level monitoring was discontinued in 2004. |
Louis Howard |
| 3/11/2005 |
Update or Other Action |
Effluent sampling from July 2004 through December 2004 shows that the discharged water continues to meet the cleanup standards. This effluent monitoring is required under the General Discharge Permit # 9240-DB003. The samples are collected between the first and second carbon treatment vessels to determine if breakthrough is occurring above the reporting limit in the effluent. |
Louis Howard |
| 3/21/2005 |
Update or Other Action |
2004 Phase I RPO Annual Report (Draft Final) Groundwater Performance Optimization Monitoring Program received. The long-term monitoring plan for the SD15 Plume should focus on monitoring benzene and TCE concentrations. Monitoring activities should be performed to verify decreasing benzene and TCE trends continue. Also, the predicted cleanup date of 2002 has passed.
It is recommended that a new cleanup date be developed to replace the current ROD-specified date of 2002 and to compare with the predicted linear regression date of 2012. To optimize performance monitoring at this plume, it is recommended that the following evaluations be performed on the SD15 Plume:
COC monitoring: COC monitoring for this plume is currently performed at three in-source wells. Monitoring network optimization and sampling frequencies should continue to be determined by using the decision guides in Appendix H.
Contaminant mass calculations: Contaminant mass calculations are not recommended at the SD15 Plume. SourceDK Tier 2 would be capable of calculating contaminant mass, but is not compatible with the active SVE and HVE treatment systems at this plume.
MNA monitoring: It is recommended that MNA samples no longer be collected from the SD15 Plume. Wells OU6MW-17, OU6MW-18, and OU6MW-90 are all in-source and are screened within a perched aquifer. This perched aquifer essentially exists in a bowl fed by surface water infiltration and is above the groundwater surface. The three wells do not monitor the deep aquifer, only the shallow perched aquifer. Therefore, geochemical changes created when clean groundwater flows through a plume cannot be observed. MNA monitoring at the SD15 Plume should consist of collecting COC samples and evaluating COC trends over time.
Cleanup date predictions: The OU 6 ROD predicted a cleanup date of 2002 for this plume. This date has passed and cleanup levels have not been met. It is recommended that Tier 1 of the SourceDK program be used to generate a new predicted cleanup date for this plume. Air extracted through the HVE and SVE wells makes this plume incompatible with Tier 2. Milestones can be established manually once this date is known.
HVE/SVE treatment system: HVE/SVE processes have been ongoing for several years at the SD15 Plume and have been conducted to reduce vadose zone contaminants. HVE wells are used to treat deep soil, and shallow site soils are remediated with SVE. COCs within the smear zone at depth have been brought below cleanup standards, and it is recommended that the HVE wells be shut down. The technological limits of the HVE system have been reached, and it is recommended that MNA become the remedy for treating remaining groundwater contamination. As has been noted above, monitoring the performance of natural attenuation at this plume should consist of tracking COC concentrations, rather than analyzing geochemical indicators. The shallow SVE wells should continue to treat existing shallow contaminants to prevent surface water from carrying COCs from these shallow soils to the perched aquifer below.
Remedy protectiveness summary: HVE and SVE are the selected remedies at the SD15 Plume. It is recommended that MNA be added as a groundwater remedy. Additionally, combined air emissions discharged by these two systems have undergone a significant decrease and fulfill RPO requirements in that they have remained in compliance with regulated discharge standards. During baseline source testing in 1997, 7,543 pounds of contaminants were discharged. This total decreased to 61 pounds by 2004. The selected remedies (HVE, SVE, and MNA) should be considered protective of human health and the environment because the HVE and SVE systems have significantly reduced contamination at the SD15 Plume. Although the predicted cleanup date of 2002 has not been met, COC concentrations are decreasing, plume expansion is not occurring, and potential downgradient receptors are not being exposed to groundwater contaminants.
It is recommended that the COC monitoring network be reevaluated with existing decision guides during the summer of 2005 and that the HVE system be shut down. A revised cleanup date for this plume should also be developed. These exercises should be performed and the findings should be submitted as a stand-alone report before the 2005 Annual Report is prepared. The results of the reevaluation would not be generated in time to guide field activities during 2005, but would be available to influence recommendations in the 2005 Annual Report. |
Louis Howard |
| 4/1/2005 |
Document, Report, or Work plan Review - other |
The Alaska Department of Environmental Conservation (ADEC) received the 2004 Remedial Process Optimization (RPO) Draft Final Report on March 21, 2005. Below are ADEC’s comments on the document.
General Comments
Typically, delineating a plume of contaminated groundwater takes more than one well in the source area. ADEC requests the Air Force redraw boundaries for “plumes” in the following figures where one well is defining a “plume” of contaminated groundwater with a bold line and replace it with a dashed line to show it as being “inferred” or “interpreted” rather than a distinct boundary.
Zone 1
Figures 3.2-1 and 3.3-1 for wells: OU6MW-46 and OU6MW-63
Figure 3.3-3 for well OU6MW-46
Figures 3.5-1 and 3.6-1 for well ST41-10R
Figure 3.9-1 for wells: OU6MW-46 and OU6MW-63
Figure 3.10-1 for well OU6MW-46
Zone 2
Figure 4.1-1 for well 59WL-31
Figure 4.3-1 for well SP7/10-04
Figures 4.3-1 and 4.5-1 for well OU4MW-04
Figure 4.6-1 for well OU4MW-08R
Figure 4.7-1 for IS6-01
Figures 4.9-1 and 4.10-1 for wells: SP7/10-04 and W-4
Zone 3
Figure 5.3-1 for well OU3MW-25
Figure 5.5-1 for wells: 60WL-04 and 64WL-01
Figure 5.6-1 for wells: 64WL-01 and 62WL-05
Figure 5.10-11 for well LF59MW-03
3.2.4 Phase I RPO Conclusions and Recommendations
Verifying that plume expansion is occurring with one monitoring well is nearly impossible to do without additional monitoring wells. The text states that the OU6 ROD mandated 5-year reviews be performed to evaluate the performance of the selected remedy (MNA). However, the recommendation in this section for MNA monitoring states MNA assessments cannot be accurately performed at one-well plumes. Also the text states plume expansion is not occurring and potential downgradient receptors are not being exposed to groundwater contaminants. ADEC requests clarification on how it can be demonstrated with one monitoring well that downgradient receptors are not being exposed to groundwater contaminants and whether or not it can be shown a plume is expanding or shrinking when sampling data is limited to one well.
The comments above apply to: PL81 South Plume (Section 3.3.5), ST41 North Plume (Section 3.5.4), 59WL-31 (Section 4.1.5), Hangar 10 Plume (Section 4.5.4), Hangar 11 Plume (Section 4.6.4), OU4 East Plume (Section 4.7.5), SS43 Plum (Section 4.9.4), W4 Plume (Section 4.10.4), OU3MW-25 Plume (Section 5.3.4), and SP01-2 Plume (Section 5.8.4).
7.0 Phase I RPO Recommendations Summary Page 7-1
ADEC concurs with updating the conceptual site models for inclusion in the 2005 Program Baseline Calculations Report.
7.1 Plume-Specific Recommendations
ADEC concurs with the plume-specific recommendations listed in this section which are not provided in Table 7.1-1. |
Louis Howard |
| 5/4/2005 |
Document, Report, or Work plan Review - other |
The Alaska Department of Environmental Conservation (the department) received the work plan on April 29, 2005. The department has reviewed the information provided and approves the work plan as presented in the document.
The purpose of this work plan is to perform system operations and maintenance (O&M), environmental monitoring, and restoration activities in support of the 3 CES/CEVR mission. These activities include maintaining the HVE system at peak performance, optimizing the system’s performance, minimizing system downtime due to repairs, and maintaining system operation at least 75 percent of the time. Included is evaluating and optimizing systems through a recurring, systematic Remedial Process Optimization (RPO) evaluation process.
Work under this work plan will be accomplished by executing the following tasks:
1. Operate and maintain the SD15 HVE system in accordance with the HVE system O&M Manual (USAF, 2005b) and the approved WP. O&M includes completing routine and non-routine maintenance tasks, monitoring system operation parameters, and responding to system emergency calls. This includes semi-annual compressor oil changes to increase operational time of the system. O&M also includes devising and testing strategies to optimize the performance of the SVE and HVE systems.
2. Provide sampling and analysis of water and vapor quality in monitoring wells, in the system, and on the discharge stack. These data will be used to track and report cleanup progress.
3. Evaluate the operation of the SVE wells by sampling and analyzing soil samples near locations EHVE02-SB03C, EHVE02-SB19C, and EHVE02-SB1303C.
4. Report monthly on the status of the project level of effort by submitting a Contractor’s Progress, Status, and Management Report (CPSMR).
5. Provide semiannual discharge monitoring reports.
6. Provide an Annual Report for the SD15 HVE system that summarizes the above information and provides data analysis and recommendations for future field activities including potential steps to close this system. |
Louis Howard |
| 8/15/2005 |
Update or Other Action |
Draft Technical Memorandum: Natural attenuation potential of TCE and benzene at SD15, Elmendorf AFB. The purpose of the technical memorandum is to evaluate the potential for monitored
natural attenuation (MNA) to reduce dissolved phase concentrations of trichloroethylene (TCE) and benzene at site SD15, Elmendorf Air Force Base (AFB), Alaska to below
regulatory standards. At SD15, a high-vacuum extraction (HVE) system, which extracts groundwater and soil vapor, has been in operation since December 1996 and can no longer be operated in an efficient or effective manner.
The results of this analysis indicate that shutting down the HVE system is not expected to adversely affect the ongoing natural attenuation of TCE or benzene, and that MNA is an appropriate follow-on strategy with the potential to achieve the regulatory
standards for TCE and benzene in groundwater. Natural attenuation processes are typically occurring at all sites, but to varying degrees of effectiveness depending on the types and concentrations of contaminants present and the physical, chemical, and biological characteristics of the soil and groundwater.
The efficacy of MNA at site SD15 is evaluated below using a weight of evidence approach. The weight of evidence approach uses independent and converging lines of evidence to evaluate the efficacy of natural attenuation and reduce uncertainty in the
conclusions drawn from the data. The three “lines of evidence” are (USEPA, 1999):
1. Historical groundwater and/or soil chemistry data that demonstrate a clear and meaningful trend of decreasing contaminant mass and/or concentration over time at appropriate monitoring or sampling points.
2. Hydrogeologic and geochemical data that indirectly demonstrate the types and rates of natural attenuation processes at the site. and
3. Data from field or microcosm studies (conducted in or with actual contaminated site media) which directly demonstrate the occurrence of a particular natural attenuation process at the site and its ability to degrade the contaminants of concern (typically used to demonstrate biological degradation processes only).
Summary of the First and Second Lines of Evidence
Trend analysis indicates that MCLs should be reached in all monitoring wells by approximately 2012. The actual time to reach MCLs could change depending on future monitoring results and site conditions. Decreasing trends were noted for all compounds
in all monitoring wells with the exception of OU6MW-90 which showed a stable trend for TCE. |
Louis Howard |
| 3/9/2006 |
Document, Report, or Work plan Review - other |
Staff reviewed and commented on the Draft Annual Technical Report SD15 HVE System Elmendorf AFB, AK February 2006. 5.4 Conclusions and Recommendations Page 5-4 ADEC concurs with the conclusions regarding the mass removal curve for the high-vacuum extraction system has reached an asymptotic steady-state condition. Currently it costs $14,566.36 per pound of contamination removed which is the highest cost to date per pound of contamination removed. The incremental increase in the mass removed for the energy and resources required is not justified. Regarding the increase in benzene concentrations, ADEC concurs with the recommendation to review the conceptual site model and look for data gaps.
|
Louis Howard |
| 3/13/2006 |
Update or Other Action |
Staff received a draft copy of the Explanation of Significant Differences for Operable Unit 6 on February 22, 2006. Staff requested changes to the signature and text for ADEC to the following:
“This signature sheet documents the Alaska Department of Environmental Conservation acceptance of the Explanation of Significant Differences for Operable Unit 6 at Elmendorf Air Force Base. This decision may be reviewed and revised in the future if new information indicates the site may pose an unacceptable risk to human health, safety, or welfare, or to the environment.”
Jennifer Roberts
Federal Facilities Restoration Program Manager
Alaska Department of Environmental Conservation
|
Louis Howard |
| 4/10/2006 |
Document, Report, or Work plan Review - other |
Staff reviewed and commented on the Draft Semi-Annual Discharge Monitoring Report for SD15 High Vacuum Extraction System Elmendorf AFB, Alaska March 2006. Staff approved document as submitted. |
Louis Howard |
| 2/26/2007 |
Exposure Tracking Model Ranking |
|
Louis Howard |
| 6/26/2007 |
Update or Other Action |
FINAL Operable Unit 6 Explanation of Significant Differences (ESD) received.
Main Points----
1) Operation of the High-Vacuum Extraction (HVE) system at SD15 was ongoing since 1996. During that time, over 10,000 pounds (lbs) of contaminant mass has been removed. However, over 99 percent of that mass was removed during the first four years of operation. Since this time, mass recovery has steadily declined to a point where the HVE system is no longer effective. This ESD allows operation of the HVE system to be terminated and shifts focus to the next phase of the remedy at SD15 in the ROD – Monitored Natural Attenuation (MNA).
The change in remedy is expected to reduce operation, maintenance, and monitoring costs in the future (approximately $200K per year for 5 to 10 years). However, it should be noted that costs to date (approximately $1.5M non-discounted dollars) have exceeded the initial remedy estimate in the ROD by 50 percent. The change in remedy will not affect the final outcome contemplated in the ROD for SD15. Cleanup goals stated in the
ROD are expected to be achieved. However, the ROD originally stated that groundwater would be cleaned-up in five years (approximately 2002). Groundwater cleanup standards
are now expected to be met at all wells by 2015. The protectiveness of the remedy remains unchanged.
2) During preparation of the ROD, a risk-based ground water cleanup level for 1,1,2,2-tetrachloroethane of 0.43 micrograms per liter (ìg/L) was established because there was no available federal or state ARAR. Since the ROD was signed, a cleanup level of 4 ìg/L was established in Alaska Administrative Code of Regulations (AAC) 18 AAC 75.345. This ESD establishes 18 AAC 75.345 as a chemical-specific Applicable or Relevant and Appropriate Requirements (ARAR) for LF02 and SD15 which results in a new cleanup level for 1,1,2,2- tetrachloroethane.
The change in remedy is not expected to reduce operation, maintenance, and monitoring costs in the future. The change in remedy will not affect the outcome contemplated in the ROD for SD15 or LF02. Time to reach groundwater cleanup goals at LF02 is not expected to change. The protectiveness of the remedy remains unchanged.
3) In 2003, the USAF published guidance for active installations regarding Land Use Control (LUC) (also known as “institutional controls”) documentation in administrative documents such as the ROD. LUCs are part of the selected remedy in the ROD for five of the seven sites at OU 6. This ESD uses the 2003 guidance to clarify how the USAF intends to implement the LUCs at sites LF02, LF03, LF04, SD15, and WP14.
Considering the new information that has been developed, and the changes that have been made to the selected remedies and in accordance with CERCLA Section 121, the lead and support agencies believe that the remedies remain protective of human health and the environment, comply with federal and state requirements that were identified in the ROD and this ESD as applicable or relevant and appropriate to these remedial actions
at the time of the ROD, and are cost-effective. In addition, the revised remedies continue to utilize permanent solutions and alternative treatment technologies to the maximum extent practicable. |
Louis Howard |
| 8/21/2007 |
Document, Report, or Work plan Review - other |
EPA sends letter to Lt. Col James Hodges, Commander 3rd CES Re: Explanation of Significant Differences (ESD) Operable Unit 6, Elmendorf. A.F. B. EPA appreciates the opportunity to review the referenced document explaining significant differences made in implementation of the remedy for Operable Unit 6 (OU-6) which although significant, do not amount to an amendment of the Record of Decision (ROD). The ESD ensures that the remedy maintains protectiveness of human health and the environment. Please find enclosed the executed signature page that documents the EPA's concurrence.
We agree that preliminary results indicate that the current high-vacuum extraction system at SD15 has reached its useful effectiveness and agree, given site conditions, that it is reasonable to shift to a monitored natural attenuation approach at this time. However, we remain concerned that the lines of evidence for the efficacy of monitored natural attenuation are tenuous. Monitored natural attenuation will need to be evaluated on a frequent basis. We expect each upcoming five year review to revisit the lines of evidence to assure continued protectiveness and to assess progress toward achievement of Remedial Action Goals.
The ESD also reflects the establishment of a groundwater cleanup level of 4 ug/L was established in the Alaska Administrative Code of Regulations, 18 AAC 75.345. This cleanup level is considered by the State of Alaska to be protective of public health and the environment.
EPA has not established a Maximum Contaminant Level for 1,1,2,2-tetrachloroethane; however, based upon EPA's current default exposure assumptions and information in EPA risk assessment databases, the risk at 4 ug/L is acceptable and in accordance with the National Contingency Plan. Signed Daniel Opalski, Director Office of Environmental Cleanup. |
Louis Howard |
| 9/18/2007 |
GIS Position Updated |
|
Louis Howard |
| 3/7/2008 |
Update or Other Action |
Zone 2 Remedial Process Optimization Report received. Zone 2 consists of seven sites
containing a total of eight groundwater plumes and one site with no apparent
groundwater contamination. These sites are spread throughout the central and eastern
areas of Elmendorf AFB. The Zone 2 sites are primarily operated under the Comprehensive Environmental Response, Compensation, and Liability Act of 1980 (CERCLA) and through the OU4
and OU6 Records of Decision (RODs). Site ST32 was formerly managed under a cooperative agreement with the Alaska Department of Environmental Conservation (ADEC) and the State Environmental Restoration Agreement (SERA). On 21 October 2002, SERA was dissolved by mutual agreement between the USAF and ADEC. The sites and programs formerly addressed by SERA are now addressed in accordance with applicable requirements of 18 Alaska Administrative Code (AAC) 78 (Underground Storage Tanks) and 18 AAC 75 (Oil and Other Hazardous Substances Pollution Control)
(USAF, 2005c).
The current remedy for the SD15 plume, LUCs and MNA, remains protective. The monitoring well network in place at SD15 is adequate to track migration of contaminants toward potential human or ecological receptors. LUCs are preventing human and environmental receptors from being exposed to contaminated groundwater. Remediation workers are adequately protected. The 2003 five-year review (USAF, 2003a) found that the remedy is functioning as intended in the OU 6 ROD; exposure assumptions, toxicity data, cleanup levels, and RAOs used at the time of the remedy selection are still valid.
Regulatory Compliance: Monitoring data show that TCE and benzene concentrations remain above the ROD specified cleanup level of 5 µg/L (USAF, 1997). Monitoring of this site is ongoing in
accordance with the ESD, and samples are collected and analyzed in accordance with the
2006 Work Plan, Remedial Action-Operations, Zone 2, Elmendorf AFB, Alaska (USAF, 2006b). ROD-specified LUCs are enforced through the Elmendorf AFB 3rd Wing Dig Permit process. Annual LUC inspections are performed and documented in accordance with the Final Land Use Control Management Plan.
The recommendations for the SD15 plume are as follows:
Short-Term (FY08-FY09)
• Continue monitoring per Figure 1.4.
• If well OU6MW-90 remains below cleanup criteria in 2008, consider eliminating well from monitoring schedule.
Long-Term (FY10 or Longer)
• Continue monitoring per Figure 1.4.
• Monitor according to optimized monitoring schedule.
• Perform RPO evaluation. Perform long-term monitoring optimization study and implement with approval from regulatory agencies. |
Louis Howard |
| 10/15/2008 |
Update or Other Action |
5 YR Review
OU6 Remedy Implementation Status
Perched Aquifer GW Institutional controls (also known as LUCs) on land & water use, as specified in the Base General Plan, will restrict access to the contaminated GW throughout SD15. Installation of wells in the contaminated plume for residential, industrial, & agricultural use will be prohibited by the Base General Plan.
Implemented in August 1998. LUC procedures were updated & clarified in the 2007 ESD.
GW in the perched aquifer at SD15 will be treated by HVE & MNA to remove fuel related contaminants & halogenated VOCs. Treated water will be reinjected into the subsurface beyond the boundary of the contaminated aquifer. Reinjected water will be regularly monitored to ensure it meets cleanup & risk requirements. Recoverable quantities of free product found on top of the water table at SD15 will be removed through the HVE process. HVE will be terminated when operations become ineffective. MNA will be used to reduce remaining GW contaminant concentrations to below cleanup levels.
The HVE was installed & began operating in 1996, & operated for over 10 years. Remedy modified by 2007 ESD. The HVE system was permanently shut down in May 2007 when it was no longer effectively removing contaminants. The 2007 ESD selected MNA as the remedy for the remaining GW contamination at SD15, which is ongoing.
GW in the perched aquifer at SD15 will be monitored & evaluated on a frequency determined by the “Basewide Monitoring Program Well Sampling Frequency Decision Guide” to determine contaminant migration, to track the progress of contaminant degradation & dispersion & progress of the SD15 HVE treatment, as well as to provide an early indication of unforeseen environmental or human health risk. Five-year reviews will also assess the protectiveness of the remedial action, including an evaluation of any changed site conditions, as long as contamination remains above cleanup levels.
Monitoring is ongoing to evaluate MNA. Monitoring frequencies decision guide was adopted in 2003. HVE treatment at SD15 was completed & shut down in 2007, & MNA was selected as the remedy for the remaining GW contamination. Five-year reviews were conducted in 1998, 2003, & 2008.
During the final round of monitoring, samples will be collected & analyzed for all constituents that exceeded MCLs during the 1994 investigation including VOCs & arsenic. These results will be evaluated before a final determination is made that GW meets all cleanup requirements.
GW monitoring is ongoing at all sites as required by the OU6 ROD.
Deep Aquifer GW at SD15 - no further action is required for the deep aquifer GW at SD15.
Soils
Shallow soils (less than five feet deep) with contamination above cleanup levels will be excavated, removed, & thermally treated to eliminate fuel-related contaminants. After treatment, no further action will be required for the shallow soils. Shallow soil will also be included in the HVE extraction treatability study.
Excavation/thermal treatment completed in 1997. Additional contaminated shallow soils were treated with HVE & soil vapor extraction (SVE). All shallow soils met cleanup levels as of 2005.
Deep soils at SD15 will be actively treated through air stripping associated with the HVE process described for the perched aquifer GW.
All SD15 soils met cleanup levels as of 2005.
Soils with contamination above cleanup levels will be sampled one year after HVE system start up & every three years thereafter to evaluate contaminant migration & timely reduction of contaminant concentrations by HVE. If cleanup levels are not being achieved, further remedial action will be evaluated. This will include five-year reviews to assess the protectiveness of the remedial action, including an evaluation of any changed site conditions, as long as contamination remains above cleanup levels.
All SD15 soils met cleanup levels as of 2005. Five-year reviews were conducted in 1998, 2003, & 2008.
HVE will be terminated when operations become ineffective. MNA will be used to reduce GW contaminant concentrations below cleanup levels.
The HVE system was permanently shut down in May 2007 when it was no longer effective removing contaminants, in accordance with the 2007 ESD. The 2007 ESD selected MNA as the remedy for the remaining GW contamination at SD15, which is ongoing.
All soils are expected to be cleaned up within five years. All soils were cleaned up in nine years (since 2005).
Several chemicals were detected in SD15 GW for the first time during the period 2003 through 2007. 1,2,4-Trimethylbenzene (up to 0.17 µg/L), n-propylbenzene (up to 0.24 µg/L), p-cymene (up to 0.34 µg/L) & sec-butylbenzene (up to 0.22 µg/L) were all detected at SD15 for the first time in 2006 or 2007.
See site file for additional information. |
Louis Howard |
| 3/12/2009 |
Document, Report, or Work plan Review - other |
Letter to Air Force re: Draft Letter Report Treatment System Removal at SD15 and ST32 Tank 2, Elmendorf Air Force Base, Alaska March 2009.
The Alaska Department of Environmental Conservation (ADEC) Contaminated Sites Program has received the above document for review and comment on March 2,2009. ADEC will approve the document as a final version pending incorporation EPA comments on the document. |
Louis Howard |
| 3/17/2009 |
CERCLA ROD Periodic Review |
Cover letter to the EPA's Five-Year Review signature sheet sent to Richard J. Walberg, Colonel, US Air Force Vice-Commander from EPA Region 10 Office of Environmental Cleanup Daniel D. Opalski, Director. The Environmental Protection Agency (EPA) has completed their review of the third Five-Year Review report for the United States Air Force (USAF) Elmendorf Superfund site, in Anchorage Alaska.
EPA reviewed this report for technical adequacy, accuracy, and consistency with EPA guidance. In general, EPA agrees with the protectiveness determinations in this report. However, I understand that all parties to the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) Section 120 Federal Facility Agreement (FFA) are aware of a potential new source that has not been fully characterized, namely SS-022. It is also my understanding that while the Five-Year Review identifies this potential new source, the USAF has not adequately discussed the interim measures it has already taken to ensure protectiveness as site characterization proceeds, such as Institutional Controls (ICs) at SS-022 and the ongoing Remedial Investigation.
Therefore, we recommend that within ninety (90) days (by June 15, 2009), USAF supplement the Site File and Administrative Record with a Memorandum to document the ICs (e.g., installation of a fence, signage, and notation on the Environmental Restoration Program Atlas) that have been implemented for the protection of human health and the environment at SS-022. The Memorandum should also mention the Installation-wide ICs (including restriction of ground water use) already in place.
In addition, EPA agrees with USAF's recommendation for further action at the OU-l landfill area for the trichloroethylene (TCE) groundwater contamination, and requests that the Program Managers meet to discuss the timeline for completion of the groundwater contamination characterization and establish deadlines and, as appropriate, target dates for subtasks, as required under the FFA.
|
Louis Howard |
| 10/15/2009 |
Meeting or Teleconference Held |
A meeting of the remedial project managers (RPMs) convened at 0900 on 15 October 2009 in the CEAN Conference Room, Building 5312, at Elmendorf Air Force Base (EAFB), Alaska. Attendees included: Mr. Jacques Gusmano (Environmental Protection Agency [EPA]), Mr. Louis Howard (Alaska Department of Environmental Conservation [ADEC]), Mr. Don Aide (CEANR), Ms. Donna Baumler (CEANR), Mr. Gary Fink (CEAN), Ms. Melissa Markell (CEANR), and Ms. Renee Wright (3 WG/PA).
Presentation by Mr. Donald Aide.
(1) Mr. Aide distributed an RPM Meeting Presentation paper addressing the status of three projects.
The field work has been completed for the LF59 Field Investigation and Conceptual Site Model Update.
Almost all field work has been completed for the pipeline and bioventing decommissioning project; no contaminated soil has been found associated with the pipeline decommissioning work, but more contaminated soil than anticipated was found during hotspot removal at SD15. Soil excavation at SD15 is on hold until all other field work on this contract is complete to ensure that contract limits for soil excavation are not exceeded.
The MMRP CSE Phase II report is expected in December 2009. Three MRSs are expected to go to the Removal Action phase.
(2) Mr. Gusmano asked if CEANR was involved in reviewing the Environmental Impact Statement (EIS) for Eagle River Flats. Mr. Fink responded that we got two days to review an 800-page document, and this review task was taken over by the conservation staff. A discussion ensued about the planned future use of phosphorous at this still-active range site.
(3) Mr. Fink pointed out that the OT92 pipeline decommissioning project would meet the Air Force’s RIP goal. |
Louis Howard |
| 4/14/2010 |
Update or Other Action |
This annual report includes a qualitative evaluation of the 2009 groundwater analytical data to
determine if the current conditions at the Zone 2 potentially warrant changing the 2007 RPO
category for each site. The next detailed RPO evaluation is scheduled for 2012.
Field activities performed during 2009 at Zone 2 included water level measurements; groundwater sampling; operation, maintenance, and monitoring (OM&M) of the bioventing system at Sites FT23 and ST32; decommissioning of the FT23 bioventing system; soil, groundwater, and vapor intrusion investigations at FT23; a groundwater investigation at SS43; soil and groundwater investigations at ST32; monitoring well inspections and surveys at ST32; well abandonment; well maintenance; well flagging; land use control (LUC) inspections; and waste management.
The 2007 RPO evaluation identified Site SD15 as a Green priority site because the remedy was on track, as summarized in the ESD (USAF, 2007). Benzene and TCE concentrations measured in 2009 at wells OU6MW-17 and OU6MW-18 were lower than 2008 concentrations (Figures 3.2 and 3.3). In contrast, the TCE concentration at OU6MW-90 in 2009 was higher than the concentration measured in 2007.
Available data suggest that TCE concentrations are on track to decline below applicable standards at all wells within the estimated cleanup timeframe of 2015. It is unlikely, however, that benzene concentrations at OU6MW-17 will decline below applicable cleanup levels by 2015. This assessment of the trend in benzene concentrations suggests that the priority designation for Site SD15 should be changed from Green to Yellow.
During excavation of treatment system piping in 2008, approximately 10 cubic yards of potentially fuel-contaminated soil was encountered along the south side of former concrete pad No. 2 (USAF, 2009c). The soil was left in place and marked with pin flags. The potentially contaminated soil located adjacent to concrete pad No. 2 should be sampled to determine if contaminants are present at concentrations exceeding ACM Level D.
Wells OU6MW-17 and OU6MW-90 need to be re-surveyed following well maintenance performed in 2009.
Removal of OU6MW-90 from the Elmendorf AFB program should be considered because this well provides redundant data to that collected from OU6MW-17 and OU6MW-18. If removed from the program, OU6MW-90 should be kept in the Elmendorf AFB inventory and maintained to support a site closure determination when COC concentrations in OU6MW-17 and OU6MW-18 are below applicable cleanup levels. |
Louis Howard |
| 4/28/2010 |
Update or Other Action |
Memorandum for ADEC. SUBJECT: Response to ADEC Comment on Draft 2009 Zone 1 Field Activities Report (Ref: ADEC Memo, 12.Mar 10)
1. This memorandum is in response to ADEC's concern as to why diesel-range organics (DRO) and gasoline-range organics (GRO) at select groundwater plumes were not sampled in 2009 as
previously agreed in a January 14, 2003 meeting. Specifically, ADEC's comment (Attachment 1) is in reference to Section 3.7.1 Implications of Contaminant and Geochemical Monitoring, Page 3-17 of the draft 2009 Zone 1 Field Activities Report, which stated:
"The text states: When these parameters were monitored from 1999 to 2007, GRO concentrations in this monitoring well exceeded cleanup levels while DRO concentrations hovered near the cleanup level. ADEC requests the Air Force provide an explanation or a memorandum to the site file as an appendix to the document on why DRO and GRO were eliminated from the monitoring program as previously agreed to in a January 14, 2003 meeting with ADEC, USAF and EPA."
2. The analytes in question were not included in the Zone 1 groundwater monitoring program
for FY09 due to an administrative oversight. The agreement to monitor for DRO and GRO was
captured in meeting minutes (Attachlnent 2), not in a more formal mechanism such as a decision
document or memorandum to the·site file. In preparation for programming of project
requirements, we reviewed the governing documents for the Zone 1 sites. None of the governing
documents for Zone 1 sites identified GRO/DRO as a contaminant ofconcem (COC); therefore,
GRO/DRO sampling was not programmed or conducted in 2009.
3. The U.S Air Force agrees with ADEC's request to continue sampling for diesel-range organics (DRO) and gasoline-range organics (GRO) for CERCLA sites with fuel-related plumes. Minutes of a 14 Jan 03 meeting with EPA, ADEC and DRS, provided with the above referenced ADEC memo, documents that the Air Force agreed to add DRO/GRO into the sampling program under the following conditions:
a. The decision will be documented in the 5-Year Review. The addition of DRO/GRO to the program should be introduced in the 5-Year Review under· mention of new issues affecting protectiveness.
b. The Air Force will NOT add DRO/GRO as a CERCLA ARAR, but will compare DRO/GRO results to ADEC cleanup levels in the annual reports and will discuss in subsequent 5-Year Reviews. The benefit of this is that if CERCLA COCs meet ARARs, the Air Force can achieve a partial delisting.
c. The Air Force will add DRO and GRO to the suite of analyses at monitoring wells associated with fuel plumes starting in 2004.
d. The Air Force will not pursue a decision document with ADEC on DRO/GRO until more data is gathered on the extent of the problem.
e. Until a decision document is signed with ADEC, GRO and DRO concentrations will be compared to ADEC regulations in 18 AAC 75 (Table C, Groundwater Cleanup Levels; 1,500 ug/L for DRO, 1,300 ug/L GRO).
f. Sampling frequency for DRO/GRO will follow the latest Decision Guide for Sampling Frequency (see 2002 Basewide Annual Report). "Immediately up gradient" means within a 2-year warning line, similar to that generated for OU5.
g. ADEC GRO/DRO criteria apply to groundwater, not to seeps which daylight as surface water. Criteria in 18 AAC 70 (TAH, TAqH) apply to surface water.
4. The fact that these analytes were not included in the Zone 1 groundwater monitoring program
for FY09 is attributed to an oversight. The USAF will add DRO/GRO into the suite of analyses
at monitoring wells associated with fuel-related plumes for Zone 1 (LF04 South and WP14) and
will prepare a memo to the site file to prevent this type of oversight from occurring in the future.
The USAF strategy will be to compare DRO/GRO and total aromatic hydrocarbon (TAH)/total
aqueous hydrocarbon (TAqH) sample results as contaminants of interest with current ADEC
regulations in 18 AAC 75 - Table C - Groundwater Cleanup Levels and 18 AAC 70 for surface
water. Should you have any questions, please feel free to contact me at (907) 552-2875.
Signed Gary Fink YF-02 Chief, Environmental Restoration. |
Louis Howard |
| 12/2/2010 |
Update or Other Action |
Letter Report for the Excavation and Disposal of Contaminated Soil at Site SD15 received. This Letter Report addresses the 2009 contaminated soil removal activities associated with the SD15 Hot Spot under Contract No. FA8903-04-C-8008. The SD15 site is located in Operable Unit 6, west of Talley Avenue on Elmendorf Air Force Base.
Excavation began with the stockpiling of clean overburden in the area south of the Weathering Pad #2 footprint along a 10-foot by 3-foot trench running east to west. The trench was then excavated vertically into the zone of contamination to approximately 8 feet below ground surface (bgs). Fuel-contaminated soil was found below the clean overburden from approximately 3 to 8 feet bgs on all sides of the prospect trench. In an effort to identify the lateral extent of contamination, the trench extended to the south and west until field screening sample results indicated a clean boundary.
The scheduled volume of contaminated soil to be removed from the hot spot was 20 cubic yards. However, during excavation activities, the zone of contamination appeared to be greater than anticipated. Excavation halted after the removal of 20 cubic yards, and the USAF Point of Contact (POC) was notified of the situation. The Base POC, in coordination with Air Force Center for Engineering and the Environment (AFCEE), requested that the removal of contaminated soil at SD15 should continue.
On 15 October 2009, excavation and sampling activities resumed. The excavation expanded to the north and east along the footprint of the former Weathering Pad #2 to a vertical depth of approximately 15 feet bgs. Eight samples were collected from the floor and sidewalls, and analyzed for BTEX, GRO, DRO, and residual-range organics (RRO). Four samples collected from the floor and east wall of the excavation exceeded the Alaska Department of Environmental Conservation (ADEC) 18 Alaska Administrative Code (AAC) 75 cleanup criterion for DRO (230 mg/kg) (ADEC 2008). Sample results along the south and west walls were either nondetect or below the cleanup criterion.
A third excavation and further sampling continued along the east wall. Two additional samples were collected with one sample (SSD15-10) exceeding the ADEC cleanup criterion for DRO with a result of 436 mg/kg. Contamination along the north wall, east wall, and the floor of the SD15 excavation persisted, and the Base POC and AFCEE were again consulted concerning the status of the investigation. It was determined that excavation would be discontinued, and the existing excavation would be backfilled with native soil without a liner.
Contaminated soil remains at the site and likely extends north and east along the former footprint of Weathering Pad #2. During 2009 field activities, a total of 250 cubic yards of fuel-contaminated soil was excavated from the SD15 site and transported to a thermal treatment facility, Alaska Soil Recycling, for disposal. Attachment 3 contains the scale tickets from the treatment facility. |
Louis Howard |
| 1/24/2011 |
Update or Other Action |
Work Plan/QAPP for SD15 Limited Site Assessment at 673 CES/CEANR JBER received for review & comment. Soil at Site SD15 has fuel related contaminants present at concentrations that exceed Alaska Department of Environmental Conservation (ADEC) clean-up levels. A soil removal action was conducted in October 2009. The scheduled volume of contaminated soil to be removed was 20 cubic yards. During excavation & soil sampling activities the area of contamination was determined to be much greater than anticipated. At the conclusion of the removal action, 245 cubic yards of contaminated soil had been removed without reaching the extent of contamination. Additional site information is needed to determine the extent of existing soil contamination & if GW has been impacted.
The 673rd Civil Engineer Squadron/ Civil Engineering, Asset Management, Natural Resources, Restoration Element has contracted with AECOM Technical Services, Inc. to conduct a limited site assessment at Site SD15 to define the nature & extent of remaining petroleum contaminated soils & to determine if the release has impacted GW. Assessment activities will follow a systematic approach utilizing soil borings, soil samples, installation of two new temporary GW wells, & GW samples to determine the extent of petroleum contamination.
Assessment of the site will attempt to determine the extent of soil that exceeds State cleanup standards, determine if the contamination has reached the GW table, & to suggest possible future cleanup strategies. Sampling & analytical activities to be conducted include the following:
Drill 10 soil borings, Convert two soil borings to temporary GW monitoring wells, Collect, analyze, & validate two soil samples from each soil boring, Develop the temporary GW monitoring wells, & Collect, analyze, & validate GW samples from the two new temporary wells for one sampling event (Spring 2011).
Samples will be analyzed for contaminants that were previously identified above ADEC clean-up levels or that are associated with petroleum contamination. Results will be used to determine the extent of soil contamination, determine if that contamination has impacted the GW table, & provide viable cleanup options.
The analyses proposed include BTEX, GRO, & DRO/RRO in soil & GW. PAHs will also be analyzed in soils from one boring at the source area. These analyses were selected based on previous investigations & field observations (i.e., staining & olfactory). The results will be used to determine the extent of petroleum contamination in the soil & if contamination has reached the GW table.
If results from the soil borings provide a definitive boundary & limits of excavation can be identified, then potential future cleanup strategies will be recommended.
If results from the soil borings do not provide definitive limits of excavation, then additional delineation efforts will be recommended.
If results from the two temporary GW monitoring wells & ongoing sampling from existing GW wells indicate that contamination has reached the GW table, then future GW cleanup strategies will be recommended.
If results from the GW monitoring efforts indicate that no impact to GW has been realized, then no further action will be recommended.
If soil results are below the TCLP limits, soil cuttings will be disposed at an off-site landfill.
If soil results are above TCLP limits, soil cuttings will be manifested, transported, & disposed at an off-site facility approved to accept Resource Conservation & Recovery Act waste.
All water IDW will be managed by the disposal firm, Emerald Alaska, Inc. TCLP & ignitability results will be provided to Emerald to assist with classification of the waste.
Soil & water IDW concentrations to determine disposal options. Samples will be analyzed for TCLP VOCs, TCLP SVOCs & ignitability. Samples will be analyzed at an off-site laboratory that is accredited in accordance with the DoD ELAP & is certified by ADEC with the exception of the ignitability in liquid IDW test. This test is being subcontracted to Columbia Analytical Services, Inc., Kelso, WA. Columbia Analytical Services is certified for the test through the National Environmental Laboratory Accreditation Program.
Data from IDW needs to be of sufficient quality to meet disposal firm’s requirements for acceptance. Field QC samples & data validation are not required for IDW samples.
Analytical results for IDW samples will be provided to the disposal subcontractor for manifesting, transporting, & disposal. Data quality review & validation is not required.
See site file for additional information. |
Louis Howard |
| 1/24/2011 |
Update or Other Action |
Staff received the 2010 Zone 2 Mgt. Area Annual Report. This annual report presents a description of the activities performed in 2010 at the Zone 2 Management Area at Joint Base Elmendorf-Richardson (JBER), Alaska. This document describes field activities and pertinent observations, presents analytical data, and provides recommendations for the Zone 2 Management Area, which now includes Sites ST48 and ST68. Beginning in 2010, Sites ST48 and ST68 have been included in reports related to the Zone 2 Management Area (rather than the Zone 3 Management Area) because the boundary between the Zone 2 and Zone 3 Management Areas was revised during the 2009 field season.
The 2010 Zone 2 and Zone 3 Management Areas Work Plan (USAF, 2010a) included well maintenance recommendations for groundwater monitoring wells OU6MW-17 and OU6MW-90. Well maintenance was performed at these two wells in 2010 (Table 1.5). A possible obstruction at 47 feet bgs was described in the sampling notes for well OU6MW-18 (Appendix B). The field team was able to get the pump intake past this point for sampling purposes, but this potential break in the PVC well casing should be assessed to determine if the well should be abandoned and/or replaced.
The 2007 RPO evaluation identified Site SD15 as a Green priority site because the remedy was on track, as summarized in the ESD (USAF, 2007a). However, trend analysis performed for monitoring well OU6MW-17 in 2009 suggested that benzene concentrations in this location would not decline below applicable cleanup levels by the projected cleanup date of 2015. Based on this analysis, the priority designation for Site SD15 was changed from Green to Yellow in the recommendations of the 2009 Zone 2 Management Area Annual Report (USAF, 2010b). TCE concentrations measured in 2010 at wells OU6MW-17 and OU6MW-18 were lower than 2009 concentrations.
Benzene concentrations in well OU6MW-17 were approximately equal to 2009 values and benzene concentrations in OU6MW-18 remained below the cleanup level Because benzene concentrations are not expected to degrade below cleanup levels in OU6MW-17 by 2015, the Yellow designation for Site SD15 remains appropriate.
During excavation of treatment system piping in 2008, approximately 10 cubic yards of potentially fuel-contaminated soil were encountered along the south side of former concrete pad No. 2 (USAF, 2009). The soil was left in place and marked with pin flags. Approximately 250 cubic yards of soil were subsequently removed from an excavation that occurred within the Site SD15 boundary in October 2009.
The approximate dimensions of this excavation were 35 feet long, 35 feet wide, and 15 feet deep. The extent of contamination was not reached along the north sidewall, east sidewall, or bottom of the excavation. The unlined excavation was filled with clean soil and the excavation extents were pin-flagged. Additional characterization of the nature and extent of the remaining contamination adjacent to the October 2009 excavation is recommended. |
Louis Howard |
| 1/28/2011 |
Update or Other Action |
Staff received the 2010 Annual Land Use Control (LUC) Monitoring Letter for DP98 and Operable Units (OUs) 1,2,4,5, and 6. References: (a) DP98 Record of Decision, Section 12.2.3.4, dated May 2004, (b) OU6 Explanation of Significant Differences, Section 4.3.1.3, dated Mar 2007, and (c) Memorandum to the Site File for OUs 1,2,4, and 5, Section 4, dated Jan 2010. This letter serves as the annual monitoring report on the status of LUCs in place at DP98 and at OUs 1,2,4,5 and 6.
Perched aquifer groundwater - Institutional controls on land and water use, as specified in
the Base General Plan, restrict access to the contaminated groundwater throughout SD15.
Installation of wells in the contaminated plume for residential, industrial, or agricultural
use are prohibited by the Base General Plan.
Evaluation - A land use control inspection was performed and land use controls are in
place and continue to be protective at SD15.
The Air Force ensures compliance with LUCs by conducting periodic monitoring and completing site inspections. Separate controls are in place and enforced by the Air Force to prevent inappropriate soil and groundwater exposure at these sites. The Air Force currently requires all projects resulting in soil disturbance of greater than four inches below ground surface to follow 3r Wing Instruction 32-1007, Safeguarding Utilities from Damage, dated 17 Aug 07 and 3rd Wing Instruction 32-7003, Land Use control Management, dated 16 Feb 07. Both instructions require the proponent to obtain an approved Base Civil Engineer Work Clearance Request (3 WG Form 3) prior to conducting work on the Base. |
Louis Howard |
| 2/1/2011 |
Document, Report, or Work plan Review - other |
Staff reviewed & commented on the Work Plan/QAPP for SD15 Draft Dated January 22, 2011.
Worksheet #5: Project Organization Chart Page 19 of 103
In accordance with 18 AAC 75.335, ADEC will require the Air Force ensure that the personnel working on its behalf as project manager, field manager, field QC Coordinator meet the definition of a "qualified person I" as stated at 18 AAC 75.990(100) or are directly supervised by a "qualified person" per 18 AAC 75.990(125).
The table shows APPL Inc. as the laboratory subcontractor for this project. ADEC will require the Air Force to use an ADEC approved laboratory (with current approval) for the duration of this project. APPL-Fresno CA (UST-081) laboratory approval expires June 17, 2011. ADEC requests the Air Force have the lab being used for this project supply a copy of their current ADEC .
approvalletter(s).
Worksheet#7: Personnel Responsibilities Table Page 23 of 103
The table shows field staff will be determined at a later date. Please see comment above at Worksheet #5 regarding the requirement for a "qualified person" as defined by 18 AAC 75.990(100) once field staff are selected. The table states that APPL Inc. will subcontract the test for ignitability in liquid. ADEC requests the Air Force ensure that the subcontracted lab has
current approval for conducting the test for ignitability in liquid.
Worksheet # 15: Reference Limits & Evaluation Tables
15.1 Reference Limits & Evaluation Tables for Soil Samples Page 47 of 103
The table lists incorrect cleanup levels/project action limits for the following analytes [the most stringent2 value (regardless of pathway) shall be used from 18 AAC 75.341(c) Under 40 Inch Zone].
Worksheet #19: Analytical SOP Requirements Table Page 57 of 103
The table lists soil samples for BTEX with DI water for containers & in the maximum holding time sections. ADEC will require all samples be preserved with methanol preservation.
The table lists. GW samples for BTEX maximum holding time as 7 days without preservation & 14 days with preservation added. ADEC will require all GW samples to be preserved (see ADEC Draft Field Sampling Guide Appendix E).
Worksheet #29: Project Documents & Records Table Page 87 of 103 Long-Term Storage/Location of Project Documents
In accordance. with 18 AAC 75.380 Final reporting requirements & site closure (9)(C), the Air Force will be required to retain a summary of the laboratory reports for the final verification samples collected at the site; the laboratory or responsible person [in this case, the Air Force] shall keep those reports & make them available to the department upon request for at
least 10 years' after submission of the summary to the department.
Finally, see Appendix C of the UST Procedure Manual "Laboratory Data Report Check 'Sheet" regarding the items to be kept on file at the lab for ten years after analysis. ADEC will require both a complete electronic copy as well as the hard C0PY reports for the final project data & decisions be submitted for its records.
SOP-5: GW Sampling
4. Responsibilities Page 1 of 14
The text states: "Minimum qualifications for sampling personnel require that one individual on the field team shall have a minimum of 6 months of experience with sampling monitoring wells. The field sampler &/ or task manager is re'sponsible for directly supervising the GW sampling procedures to ensure that they are conducted according to this procedure, & for recording all pertinent data collected during sampling." ADEC disagrees.
ADEC will require the Air Force to have sampling personnel meet the 18 AAC 75.990(100) de. finition of a "qualified person" or have a "qualified person" on site who will directly supervise the field team. The definition of a "qualified person" is not met by a person on a field team with a minimum of six months of experience~ampling monitoring wells.
5.3 MONITORING WELL GW SAMPLING PROCEDURES
5.3.4 Purging Equipment & Use Page 5 of 14
The text states: "Purging shall be considered complete when at least two consecutive field parameter measurements have stabilized within approximately 10 percent of one another. This criterion may not be applicable to temperature if a submersible pump is used during purging due to the heating of the 'water by the pump motor." ADEC disagrees with the Air Force regarding the number of parameters used to determine when purging is complete.
ADEC's draft Field Sampling Guidance (2010) states: "Water quality parameters are considered stable when three successive readings, collected 3-5 minutes apart, are within:
• ± 3% for temperature (minimum of ± 0.2 oC),
• ± 0.1 for pH,
• ± 3% for con,ductivity,
• ± 10 mv for.redox potential,
• ± 10% for dissolved oxygen (DO), &
• ± 10% for turbidity
See site file for additional information. |
Louis Howard |
| 7/15/2011 |
Update or Other Action |
Draft Work Plan Environmental Remedial Action-Operations & LTM & Maintenance received.
The purpose of this project is to perform RA-O & LTM activities for several JBER Programs. These programs include sites distributed across both JBER-Elmendorf & JBER-Richardson. This Work Plan addresses remedial activities in JBER-Elmendorf Zone 1, Zone 2, & Zone 3 Management Areas, JBER-Elmendorf Compliance Restoration Program (CRP) sites, the JBER Elmendorf Operable Unit (OU) 1 Landfill, JBER-Richardson Multiple Installation Restoration Program (IRP) Sites, & JBER-Richardson Poleline Road & OUE Armored Vehicle Maintenance Area (AVMA).
Currently there are ten active sites within the Zone 2 Management Area: FT23, SD15, SD24, SD25, SD28, SD29, SS43, ST32, ST48, & ST68. The OU4 ROD (USAF, 1995a) specifies the selected remedy for Sites FT23, SD24, SD25, SD28, & SD29. Currently, LUCs are used at all OU4 sites until cleanup levels are met, & GW monitoring is performed at Sites FT23 & SD25. At Site SD15, 149 an ESD; to the OU 6 ROD (USAF, 1997) transitioned the remedy for this site to monitored natural attenuation (MNA). The remedial approach for Site SS43 is described in the State-Elmendorf Environmental Restoration Agreement (SERA) Phase I Corrective Action Plan, & currently consists of natural attenuation with free product removal. The selected remedy for soils with contamination in excess of cleanup levels at Site ST32 is limited hot spot removal with off-site low-temperature thermal desorption.
A final remedy for GW at Sites ST32 & ST48 has not been established. The remedy for ST68 includes MNA & LUCs specified in a DD that was finalized in 2007. Impacted media at the Zone 2 Management Area sites includes soil & GW. COCs identified for Zone 2 sites include trichloroethene (TCE); tetrachloroethene (PCE); 1,1,1-trichloroethane (1,1,1-TCA); 1,1,2-TCA; 1,2-dichloroethane (1,2-DCA); 1,1-dichloroethene (1,1-DCE); 1,2-DCE; 1,1,2,2-tetrachloroethane (1,1,2,2-PCA); benzene, toluene, ethylbenzene, & total xylenes (BTEX); DRO; & gasoline-range organics (GRO).
The overall objectives of RA-O activities within the Zone 2 Management Area are to monitor the rate of natural attenuation within GW plumes, determine the effectiveness & protectiveness of the site remedies (currently MNA for all sites), & manage all waste according to state & federal regulations.
Site SD15 consisted of four separate 30-foot by 50-foot concrete pads and the surrounding area. From the early 1970s to 1983, the former concrete pads were used for weathering fuel filters and the disposal of tank sludge.
The Zone 2 Management Area sites are located throughout the central portion of JBER-Elmendorf. The southern boundary of Zone 2 is parallel to the southern edge of the east/west instrument runway. The WP presents the site locations, associated sources, & plumes. Ten sites & 12 GW plumes are located within this management area, as follows (analytes shown exceeded cleanup levels during the most recent monitoring event):
• Site FT23 (2 plumes) - TCE & PCE
• Site SD15 - benzene & TCE
• Site SD24 - benzene
• Site SD25 - toluene & benzene
• Site SD28 - TCE & PCE
• Site SD 29 - TCE & PCE
• Site SS43 - benzene, gasoline range organics (GRO), DRO
• Site ST32 (2 plumes) - benzene, GRO, & DRO
• Site ST48 - GRO
• Site ST68 (2 plumes) - benzene & GRO |
Louis Howard |
| 1/27/2012 |
Update or Other Action |
Summary of SD15 Limited Site Assessment received.
AECOM Technical Services, Inc. (AECOM) performed a limited site assessment at Site SD15 to define the nature and extent of remaining petroleum-contaminated soils and to determine if the release impacted groundwater. Assessment activities followed a systematic approach utilizing soil borings, soil samples, and two groundwater samples from existing wells in the vicinity to determine the extent of petroleum contamination.
A PID field screening criteria of 20 parts per million (ppm) was generally assumed to indicate soil contaminated above ADEC standards, and borings greater than 20 ppm were stepped out an additional 15 ft. Material with PID results below 20 ppm was examined for other indications of contamination such as petroleum smells or overt visual evidence.
In accordance with the ADEC-approved WP, the majority of soil samples were analyzed for DRO, GRO/RRO, and BTEX, with 10% of those samples also analyzed for PAHs. During the data validation process, it was observed that trichloroethylene (TCE) was present in some of the samples, so the laboratory provided TCE concentrations for certain samples by reviewing the chromatograms for those samples.
Three borings contained levels of GRO exceeding 18 AAC 75, Tables B-1 and B-2. For compliance purposes, the lowest value was chosen from values for the "Under 40 Inch Zone" direct contact, outdoor inhalation, or migration to groundwater. Contamination was found between 14–27 ft bgs and was generally centered around the assumed center of the 2009 excavation in the release area.
Three borings contained levels of DRO exceeding 18 AAC 75, Tables B-1 and B-2. For compliance purposes, the lowest value was chosen from values for the "Under 40 Inch Zone" direct contact, outdoor inhalation, or migration to groundwater. Contamination was found between 14–24 ft bgs and in a northwest to southeast linear pattern 60-ft long centering on the 2009 excavation.
Eight borings contained levels of Benzene exceeding 18 AAC 75, Tables B-1 and B-2. For compliance purposes, the lowest value was chosen from values for the "Under 40 Inch Zone" direct contact, outdoor inhalation, or migration to groundwater. Contamination was found between 14 45 ft bgs and was present throughout the release area and downgradient of the 2009 excavations.
Historical reports have noted that solvents may be present as additional contamination. Analytical results revealed three soil boring locations testing positive for TCE levels above 18 AAC 75, Table B 2. Solvents occur in a relatively linear pattern originating at the assumed center of the historical release moving southeasterly.
Results
Soil: SG-78-OU6(FD) 17-18' bgs: GRO 360 mg/kg, benzene 0.089 mg/kg J, DRO 440 mg/kg
NOTE: SW8260B detection limit for nearly every soil sample for 1,1,2-trichloroethane analysis was above ADEC clenaup level of 0.018 mg/kg. 1,2-Dichloroethane had elevated detection limits in sample SB-78-OU6 from 17-18' bgs.
SB-81-OU6 42-43' bgs 0.92 mg/kg, trichloroethene 0.13 mg/kg.
SB-84-OU6 44-45' bgs: 2.3 mg/kg benzene, 1.5 mg/kg TCE
SB-85-OU6 22-23' bgs: 0.15 mg/kg J Benzene
SB-89-OU6 39-40' bgs: TCE 0.039 mg/kg
SB-96-OU6 20-21' bgs: 0.03 mg/kg benzene
SB-97-OU6 26-27' bgs: 0.14 mg/kg benzene
SB-97-OU6 31-32' bgs 0.82 mg/kg benzene
SB-98-OU6 26-27' bgs 390 mg/kg GRO
SB-102-OU6 24-25' bgs 0.063 mg/kg benzene
SB-103-OU6 37-38' bgs 1.9 mg/kg benzene |
Louis Howard |
| 2/2/2012 |
Update or Other Action |
Memorandum for 2010 Annual Land Use Control (LUC) Monitoring Letter for DP98 and OUs 1, 2, 4, 5, and 6.
References:
(a) DP98 Record of Decision, Section 12.2.3.4, dated May 2004
(b) OU6 Explanation of Significant Differences, Section 4.3.1.3, dated Mar 2007
(c) Memorandum to the Site File for OUs 1,2,4, and 5, Section 4, dated Jan 2010
1. This letter serves as the annual monitoring report on the status of LUCs in place at DP98 and
at OUs 1,2,4,5 and 6. The specific LUCs in place at each site are provided below. An
evaluation of the implementation of these requirements is provided in bold following each
specific LUC.
OU6:
Site SD15
Perched aquifer groundwater - Institutional conlrols on land and water use, as specified in
the Base General Plan, restrict aa:ess to the contaminated groundwater throughout SD15.
Installation of wells in the contaminated plume for residential, industrial, or agricultural
use are prohibited by the Base General Plan.
Evaluation - LUCs are in place and continue to be effective at SD15. A land use control inspection was accomplished in Oct 2011. The inspection forms will be presented in Appendix B of the 2011 Zones 1, 2, and 3 Mgt. Area Annual Report.
2. The Air Force ensures compliance with LUCs by conducting periodic monitoring and
completing site inspections. Separate controls are in place and enforced by the Air Force to
prevent inappropriate soil and groundwater exposure at these sites. The Air Force currently
requires all projects resulting in soil disturbance of greater than four inches below ground surface to follow 3 Wing Instruction 32-1007, Safeguarding Utilities ftom Damage, dated 20 Aug 10 and 673d Wing Instruction 32-7003, Land Use control Management, dated 19 May 2011. Both
instructions require the proponent to obtain an approved Base Civil Engineer Work Clearance
Request (3 WG Form 3) prior to conducting work on the Base. |
Louis Howard |
| 4/10/2012 |
Update or Other Action |
Draft Annual Report received for Zones 1, 2, & 3
Water samples were collected from well OU6MW-17 on 16 September 2011. The sample was submitted to a fixed-base laboratory for analysis of VOCs. Table 3.12 provides the field and MNA parameters measured during sampling and Table 3.13 provides a summary of the results of the samples. Benzene concentrations measured in the groundwater sample from OU6MW-17 (100 µg/L) in 2011 exceeded the cleanup level of 5 µg/L (Figure 3.5 and Table 3.13). TCE concentrations in the well (8.1 µg/L) also exceeded the groundwater cleanup level of 5 µg/L.
A LUC inspection conducted on 13 October 2011 did not identify any LUC issues at Site SD15. An investigation of the site was occurring by a different contractor at the time of the inspection. A copy of the 2011 LUC inspection form for Site SD15 is provided in Appendix B.
Summary & Recommendations
The 2007 RPO evaluation identified Site SD15 as a Green priority site because the remedy was on track, as summarized in the ESD (USAF, 2007d). However, trend analysis performed for monitoring well OU6MW-17 in 2009 suggested that benzene concentrations in this location would not decline below applicable cleanup levels by the projected cleanup date of 2015. Based on this analysis, the priority designation for Site SD15 was changed from Green to Yellow in the recommendations of the 2009 Zone 2 Management Area Annual Report (USAF, 2010b). Benzene and TCE concentrations measured in 2011 at well OU6MW-17 were close to recent year’s concentrations.
Because benzene concentrations are not expected to degrade below cleanup levels in OU6MW-17 by 2015, the Yellow designation for Site SD15 remains appropriate. Benzene and TCE concentration trends in the 2011 abandoned well OU6MW-18 are presented in Figure 3.7.
During excavation of treatment system piping in 2008, approximately 10 cubic yards of potentially fuel-contaminated soil were encountered along the south side of the former concrete pad No. 2 (USAF, 2009a). The soil was left in place and marked with pin flags. Approximately 250 cubic yards of soil were subsequently removed from an excavation within the Site SD15 boundary in October 2009. The approximate diminsions of this excavation were 35 ft long, 35 ft wide, and 15 ft deep. The extent of contamination was not reached along the north sidewall, east sidewall, or bottom of the excavation.
The unlined excavation was filled with clean soil and the excavation extents were pin-flagged. The 2010 Zone 2 and Zone 3 Management Area Annual Reports (USAF, 2011b, 2011c) recommended additional characterization of the nature and extent of the remaining contamination adjacent to the October 2009 excavation. A limited site assessment was completed under a separate contract in 2011 and is being reported in a separate report. |
Louis Howard |
| 3/1/2013 |
Institutional Control Update |
2012 Annual LUC IC Monitoring memorandum received.
This letter serves as the annual monitoring report on the status of LUCs in place on JBER Elmendorf at DP98 and OUs 1, 2, 4, 5 and 6. The specific LUCs in place at each site are
provided below. An evaluation of the implementation of these requirements is provided in bold
following each specific LUC.
Perched aquifer groundwater - Institutional controls on land and water use, as specified in
the Base General Plan, restrict access to the contaminated groundwater throughout SDlS.
Installation of wells in the contaminated plume for residential, industrial, or agricultural
use are prohibited by the Base General Plan.
Evaluation -Inspection conducted on 29 Aug 12 and LUCs are in place and continue to be protective at SD15. |
Louis Howard |
| 5/30/2013 |
Update or Other Action |
Draft Annual Field Activities report received for review & comment.
This report summarizes the 2012 annual long-term management activities, including remedial action-operation (RA-O) & Record of Decision (ROD) requirements conducted at Joint Base Elmendorf-Richardson (JBER) Comprehensive Environmental Response, Compensation, & Liability Act (CERCLA) sites. The United States Air Force (USAF) has mandated a reduction of long-term environmental liabilities & life-cycle costs through accelerated cleanup of contaminated sites.
As such, the Performance Based Remediation (PBR) initiative has been developed to protect human health & the environment in a cost effective manner while at the same time reducing life-cycle costs. In April 2012, Weston Solutions, Inc. (WESTON) was awarded a PBR contract from the Air Force Civil Engineer Center (AFCEC) (Contract Number FA8903-09-D-8589, Task Order No. 0016) that includes remediation & related activities at several JBER contaminated sites. The contract includes performing RA-O & ROD requirements at those sites. The WESTON Team performing the activities summarized in this report consists of WESTON & CH2M Hill Constructors, Inc. (CH2M HILL). WESTON executed project work on sites located within JBER-Elmendorf (JBER-E) while CH2M HILL executed project work on sites located within JBER-Richardson (JBER-R).
During 2012, one groundwater monitoring well OU6MW-17 was sampled for VOCs. Analytical
laboratory results for TCE (11 µg/L) and benzene (110 µg/L) exceeded the OU6 ROD cleanup
criteria. All other analytical laboratory sample results were below OU6 ROD cleanup criteria.
Table 8-1 presents a summary of the results. Historic results are presented on Figure 8-1.
A LUC inspection performed at SD015 on 29 August 2012 did not identify any issues.
Site Summary
Based on the 2012 groundwater analytical data for well OU6MW-17, TCE and benzene concentrations have slightly increased since previous sampling events and have returned to levels prior to 2008. Analytical results for TCE and benzene are still above the cleanup criteria of
5 µg/L.
An additional investigation to characterize soil and groundwater contamination is planned for
LF015 in 2013 under the new PBR contract. No changes to the annual monitoring are being proposed for this site |
Louis Howard |
| 6/28/2013 |
Document, Report, or Work plan Review - other |
Staff provided comments on draft annual field activities CERCLA report.
Comment#1
ADEC is requesting that 1,4-dioxane be sampled for in groundwater where trichloroethylene (TCE) or 1,1,1- trichloroethane (TCA) contamination exists or was previously above cleanup levels at any site (CERCLA or State restoration or compliance). Please incorporate these comments into any basewide sampling plans (current/future).
AFCEE research has found 1,4-dioxane at Air Force sites contaminated with TCE. The study, titled "Co-Occurrence of 1,4-Dioxane with Trichloroethylene in Chlorinated Solvent Groundwater Plumes at US Air Force Installations: Fact or Fiction," found detections of 1,4-dioxane at sites with TCE, independent of TCA.
"Surprisingly, 64.4% of all 1,4-dioxane detections were associated with TCE independently," the researchers say in the abstract. "Given the extensive data set, these results conclusively demonstrate for the first time that 1,4-dioxane is a relatively common groundwater co-contaminant with TCE."
The study authors recommend site investigations consider 1,4-dioxane as a potential co-contaminant of TCE at groundwater plume sites. The study, which was published in the Integrated Environmental Assessment and Management journal last year, explicitly warns that new discoveries of 1,4-dioxane contamination could delay cleanup completions and require more costly revisions to existing remedies, noting that there is strong evidence suggesting that 1,4-dioxane "will migrate much further than chlorinated solvents."
ADEC has promulgated enforceable cleanup levels (not advisories) for 1,4-Dioxane in soil and groundwater (latest version 18 AAC 75 April 2012 Table B1 and Table C) effective since 2008 which has remained unchanged in 2012 revised regulations.
Soil Under 40 inch Zone
540 mg/kg direct contact
0.21 mg/kg migration to groundwater
0.077 mg/L (77 µg/L) Table C groundwater cleanup level
This comment regarding monitoring requirements for 1,4-Dioxane applies to JBER-Elmendorf and JBER-Richardson sites with current or past TCE or TCA contamination. The monitoring requirement is also applicable to the “Early Warning and Sentry Wells” which were established to provide early detection of contaminant plumes that may impact Ship Creek or other downgradient environmental receptors.
1,4-Dioxane readily leaches to groundwater, is not expected to adsorb significantly to soil particles, and is difficult to biodegrade. Due to these properties, a 1,4-Dioxane plume typically proceeds ahead of the chlorinated solvent plume, and will tend to impact an aquifer system to a much larger extent.
Suggested laboratory methods: SW-846 Method 5030C, SW-846 Method 5021, SW-846 Method 8261A, SW-846 Method 5031, SW-846 8270C SIM, LVI and isotope dilution (1.0 µg/L or 2.0 µg/kg reporting limits). Dioxane can be detected using EPA 8260; however, its high water solubility causes relatively high reporting limits.
Routine organic extraction procedures like those traditionally used for EPA 8270 analyses produce low recoveries (approximately 50% or less). Whatever laboratory method is proposed for 1,4-Dioxane by JBER, the laboratory method must be able to detect at or below the ADEC promulgated groundwater cleanup level in Table C and migration to groundwater cleanup level in soil.
Be aware that with ADEC’s regulatory revisions in 2014, the level for 1,4-Dioxane (as well as many other compounds) will go down substantially from its current promulgated levels for soil and groundwater. These changes in regulations will be available for public comment sometime this year.
Finally, the EPA May 2013 Regional Screening Levels for tapwater lists a lower screening level of 0.67 ug/L which equates to a 1x10-6 total risk as well as a noncarcinogenic screening level of 47 µg/L which equates to a HI of 0.1.
8.4 SD015 [Site] Summary
Add “Site” to SD015 Summary heading.
See comment #1 regarding 1,4-dioxane analysis in groundwater. This comment applies to JBER-E and JBER-E sites with current or past TCE or TCA contamination.
|
Louis Howard |
| 7/3/2013 |
Document, Report, or Work plan Review - other |
EPA Sandra Halstead provided review comments on the 2013 Letter Work Plan Addendum.
1.0 Introduction
The 2012 Annual Report was not reviewed or finalized at the time of review of the draft 2013 LTM workplan. It is unknown if the tables are consistent with the recommendations. The table from 2011 was used as the basis for sampling location, COC group, and frequency.
2.1.2 LUC/IC Inspections
These site names are provided in Table 11-1 of the 2013 UFP-QAPP. It would be good to refer to that Table since some of the sites have changed names since the 2011 workplan.
Suggest using the same inspection sheet for both JBER-E and JBER-R LUC inspections. Attachment 1B provides more detailed information and is the preferred format.
2.1.3 OU5 WRS O&M
Add observer name to inspection form.
Table 1 JBER-Elmendorf CERCLA Regulated Sites
What happened to well OU6MW-67? It was on a 2 year frequency for VOCs.
FT023 & SD015
Well FP56 missing and well OU4MW-11 was not in the 2011 workplan. Are these the same?
Well OU6MW-18 is missing for annual sampling for VOCs.
ST037 Seeps
2011 Workplan lists BTEX as a constituent, not PAH for the Seeps.
Pump Stn #1, Ship Cr., Beaver Pond Area
2011 workplan included BTEX analysis for Pump Station #1, Ship Creek, Beaver Pond, and Wetland Treatment Cell samples.
Wetland Treatment Cell
No PAH in 2011 workplan; please make sure a sample is taken without MeOH preservative for SW8260 for soils/sediment. |
Louis Howard |
| 3/17/2014 |
Document, Report, or Work plan Review - other |
EPA Letter to Air Force regarding the 4th Five Year Review for JBER-Elmendorf.
The U. S. Environmental Protection Agency Region 10 has reviewed the Fourth CERCLA Five-Year Review report for Superfund sites, specifically for Operable Units (OU) 1, 2, 4, 5, 6 and DP98 associated with Elmendorf Air Force Base on Joint Base Elmendorf-Richardson, Alaska. The conclusions in this letter are based on the draft report from November 2013 and revised Response to Comments, Summary Form, and Sections 8 and 9 which were received by the EPA on March 12, 2014.
The EPA reviewed the report for technical adequacy, accuracy, and consistency with the National Contingency Plan and EPA guidance. The document provides a summary of the status and protectiveness for OUs for which Records of Decisions (RODs) have been completed and are not determined as No Further Action. It also identifies actions to be taken that ensure protectiveness of the selected remedies and on-going remedial actions and documents a schedule for completion of the recommended actions.
The following are the EPA’s protectiveness determinations for these OUs and the overall Site protectiveness that will be reported to Congress in the EPA’s annual report. Also included are additional recommendations and follow-up actions necessary to address issues raised in the Five-Year Review that affect or could affect protectiveness. In general, the EPA concurs with the protectiveness determinations in this Air Force report. Each OU is discussed individually below.
OU 6
The EPA concurs that the remedy for OU 6 is currently short-term protective of human health and the environment because Land Use Controls are preventing exposure to contaminated groundwater and soil. Groundwater contaminants at sites LF04 South, WP14, and SD15 are not showing decreasing trends, therefore the levels will not meet cleanup goals by 2020 as specified in the Record of Decision (ROD) by 2020. In order for the remedy to be protective in the long term, EPA agrees alternative remedies should be evaluated under the process established in the FFA to accelerate attainment of cleanup levels in groundwater at OU6.
Additionally, 2-methylnapthalene was detected in the groundwater at WP14 at a maximum level of 630 micrograms per liter (ug/L) in sampling prior to the ROD, however a cleanup standard for this compound did not exist at the time of the ROD in 1997. A cleanup level for 2-methylnapthalene of 150 ug/L was established in groundwater by the State of Alaska under 18 AAC 75, Table C Groundwater Cleanup Tables in 2009. Land Use Controls for OU6 prohibit access to contaminated groundwater as a source of drinking water. EPA agrees with the recommendation to assess current concentrations of 2-methylnapthalene in groundwater at WP14, and to discuss the results of groundwater concentrations with EPA and Alaska Department of Environmental Conservation to determine if additional action is warranted. |
Louis Howard |
| 5/14/2014 |
Update or Other Action |
Draft 2013 Annual Field Activities Report received. This report summarizes the 2013 annual long-term management activities, including remedial action-operation (RA-O) and Record of Decision (ROD) requirements, conducted at Joint Base Elmendorf-Richardson (JBER) Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) sites. The United States Air Force (USAF) has mandated a reduction of long-term environmental liabilities and life-cycle costs through accelerated cleanup of contaminated sites. As such, the Performance-Based Remediation (PBR) initiative has been developed to protect human health and the environment in a cost-effective manner, while at the same time reducing life-cycle costs.
In April 2012, Weston Solutions, Inc. (WESTON) was awarded a PBR contract from the Air Force Civil Engineer Center (AFCEC) (Contract Number FA8903-09-D-8589, Task Order No. 0016). The contract includes performing RA-O and ROD requirements at several JBER sites. The WESTON team performing the activities summarized in this report consists of WESTON and CH2M HILL Constructors, Inc. (CH2M HILL). WESTON executed project work on sites located within JBER-Elmendorf, while CH2M HILL executed project work on sites located within JBER-Richardson.
A LUC inspection was performed at SD015 on 24 September 2013 and did not identify any
issues. The TCE and benzene concentrations continue to exceed the OU6 ROD cleanup criteria of
5 µg/L. The TCE and benzene concentration trends in well OU6MW-17 and the decommissioned well OU6MW-18 are shown on Figures 9-2 and 9-3. Mann-Kendall trend tests show that there is a statistically significant decreasing trend at the 95% level of significance for TCE in both wells and benzene in OU6MW-18 before it went dry and was decommissioned. |
Louis Howard |
| 6/4/2014 |
Document, Report, or Work plan Review - other |
Staff provided comments on the draft CERCLA GW report.
See comments regarding 1,4-dioxane analysis at sites with TCE contamination, dig permits issued within the last 12 months and ICs adequacy being reported as N/A.
The Site Inspection Checklist should refer reader to photo 22 for SD015 in the Comments section as was done for FT023 and DP098 previously. Also add recommendations for future annual LUC inspection in 2014 (e.g. September 2014). 2011 and 2012 Annual Reports both refer to other investigations or additional investigation to characterize soil and groundwater contamination. 2013 Annual Report does not reference the results of the 2011 limited site assessment under a separate contract nor the results from the additional investigation under the PBR contract. Please clarify and add a brief discussion in the annual report the results of these investigations. |
Louis Howard |
| 11/5/2014 |
Document, Report, or Work plan Review - other |
Comment: Has sampling of well OU6MW-90 been discontinued? What's the GW elevation for OU6MW-90? Add groundwater flow direction or groundwater elevation contours to the figure.
Comment: Why is the trend graph for OU6MW-18 included in a 2013 report if it went dry and has been abandoned?
|
Louis Howard |
| 7/23/2015 |
Update or Other Action |
Draft Annual Field Activities report received for review and comment.
SITE SUMMARY AND RECOMMENDATIONS
Five-Year Review
Areas in OU 6 that remain above cleanup goals are required to have CERCLA five-year reviews
conducted until such time as the cleanup goals are achieved. The purpose of the five-year review
is to evaluate the implementation and performance of the remedial actions. There were no
recommendations for SD015 documented during the first five-year review period. The second five-year review report recommended modification to the existing HVE system configuration to include SVE in shallow soils, minimize vacuum to deep soils, and increase groundwater extraction and HVE wells that exceed remediation goals.
Consistent with the 2007 ESD the third five-year review report recommended an MNA remedy
for the perched aquifer and use of trend analysis in order to evaluate the remedy and revise
estimated dates for achieving cleanup levels. The fourth five-year review report identified a decreasing trend for TCE but not benzene and recommended installation of a downgradient monitoring well to delineate plume boundaries.
NOTE TO FILE: Future five-year reviews for OUs 1, 2, 4, 5 and 6 and DP098 are necessary because contamination remains above levels that allow for UU/UE in these areas. The next five-year review is due on or before March 17, 2019.
Recommendations
SD015 is identified as a Yellow priority since contaminant concentrations continue to exceed ROD cleanup levels but do not show an increasing trend. Following the recommendations of the fourth five-year review a new monitoring well should be installed downgradient of the site to better define plume boundaries. |
Louis Howard |
| 8/10/2015 |
Document, Report, or Work plan Review - other |
Staff provided comments on the Annual CERCLA Report. Staff commented on the need to monitor groundwater for 1,4-dioxane which is associated with TCE and to install a downgradient well to better define plume boundaries. |
Louis Howard |
| 1/13/2017 |
Update or Other Action |
ADEC received a groundwater monitoring report for several JBER sites. The report summarizes the 2015 annual long-term management (LTM) activities, including remedial action-operation (RA-O) and Record of Decision (ROD) requirements conducted at Joint Base Elmendorf-Richardson (JBER) Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) sites.
Site SD015 is identified as a Yellow priority since contaminant concentrations continue to exceed
ROD cleanup goals but show a decreasing trend for TCE. Following the recommendations of the
fourth five-year review, a new monitoring well should be installed downgradient of the site to
better define plume boundaries.
See site file for additional information. |
Louis Howard |
| 11/7/2017 |
Update or Other Action |
Letter report received for CY2016 [January 1, 2016 - December 31, 2016] Annual Land Use Control (LUC) and Institutional Control (IC) Monitoring at Joint Base Elmendorf-Richardson (JBER). This letter serves as the annual monitoring report on the status of LUCs/ICs in place on JBER-Elmendorf (JBER-E) and JBER-Richardson (JBER-R). The Air Force ensures compliance with LUCs by conducting periodic monitoring and site inspections. Formal LUC/IC inspections occur annually on JBER during late spring through early fall and are typically conducted by contract. A total of 55 sites were formally inspected. Random site inspections are also conducted throughout the year by JBER Restoration staff.
Discrepancies: There was evidence of approximately 6 small fires located at the site. The fires appeared to have been small and most likely resulting from military training in the area.
See site file for additional information. |
Louis Howard |
| 2/9/2018 |
Document, Report, or Work plan Review - other |
Draft annual RA-O Monitoring report for CERCLA sites reviewed and commented on. Staff commented on gasoline range organics (GRO) and diesel range organics (DRO) which were COPCs but not carried through as COCs in the 1996 RI since they did not (at the time in 1996) have a groundwater cleanup level. Previous HVE system operations and natural attenuation may have reduced the source material for GRO and DRO in soil, but without any groundwater monitoring being conducted under CERCLA for GRO and DRO, it is difficult to state whether or not these contaminants exceed cleanup levels in 18 AAC 75.
ADEC also requests that analysis of groundwater at all wells associated with SD015 include GRO, DRO analysis as agreed to upon for sites with fuel related plumes (e.g. benzene) under CERCLA per the 2003 meeting minutes and 2010 DRO and GRO memorandum.
At such time in the future, when CERCLA requirements listed in the OU6 ROD are met and SD015 is assigned a no further action under CERCLA, ADEC may have additional monitoring requirements for petroleum contaminants will not be addressed by CERCLA groundwater monitoring.
See site file for additional information. |
Louis Howard |
| 1/15/2019 |
Update or Other Action |
Draft Five year review received for Operable Unit 6 which includes source area SD015. Issue: Cancer risks exceed 1 x 10-4 or have an HQ greater than 1 for the following non-COC chemicals [in groundwater (GW)]: vanadium and total xylenes; and (in soil) 1,1,2,2-PCA, 2-methylnaphthalene, arsenic, chloroform, naphthalene, thallium, and TCE. Recommendation: Investigate, by conducting a sampling event, the following chemicals for potential inclusion as remedy COCs: (in GW) vanadium and total xylenes; and (in soil) 1,1,2,2-PCA, 2-methylnaphthalene, arsenic, chloroform, naphthalene, thallium, and TCE. Document any changes to COCs in a decision document.
Issue: Limited natural attenuation of benzene and TCE in GW is occurring at the site, and the anticipated date (2015) of achieving concentrations below cleanup levels was not achieved. Recommendation: Conduct additional studies to optimize approach to achieve remediation goals. Other studies may include, but are not limited to: site characterization, ecological assessment, focused feasibility studies, GW modeling, treatability studies, and/or sampling.
Issue: Cancer risks exceed 1 x 10-4 or have an HQ greater than 1 for the following chemicals in soil: 1,1,2,2-PCA, 2-methylnaphthalene, benzene, chloroform, ethylbenzene, naphthalene, thallium, TCE, and total xylenes. Recommendation: Implement LUC restricting soil excavation or use at the site. Document this in a decision document.
See site file for additional information. |
Louis Howard |
| 8/21/2019 |
Document, Report, or Work plan Review - other |
Staff reviewed the annual monitoring report for select CERCLA sites. Main comments were on the recommendations made in this section as it had in previous comments made for SD015 on the 2016 RA-O Monitoring report to install a new monitoring well downgradient of SD015 to better define plume boundaries. ADEC requests the Air Force provide a schedule of when it will implement the recommendation for the downgradient monitoring well installation.
See site file for additional information. |
Louis Howard |
| 5/28/2021 |
Document, Report, or Work plan Review - other |
DEC Approved of Final LTM and LUC Inspection Work Plan for select CERCLA sites dated May 2021. |
William Schmaltz |
| 8/9/2021 |
Document, Report, or Work plan Review - other |
DEC staff reviewed and provided comments on Draft 2020 Land Use Control report for Select CERCLA sites dated June 2021. Report summarized LUC inspections performed in December 2020. Most sites were covered in snow and a full inspection could not be performed until spring 2021. DEC requested that the spring 2021 inspections are included in the 2020 report or as a separate cover because they are a continuation of the 2020 inspections and separate of the 2021 inspections. |
William Schmaltz |
| 2/16/2023 |
Document, Report, or Work plan Review - other |
DEC reviewed and provided comments regarding the 2023 Letter Work Plan Remedial Action Operations and Long-Term Management, Draft, dated January 2023.The work plan describes the site inspections, maintenance activities, and groundwater, seep, and surface water monitoring, at multiple sites located on Joint Base Elmendorf- Richardson (JBER), Anchorage, Alaska. The scope of work briefly summarizes the site locations, sampling/monitoring schedules, and activities such as free-product removal from monitoring wells and monitoring/maintenance activities at the Operable Unit 5 wetlands. The details regarding the procedures for the remedial action operations and long-term management activities will remain consistent with the 2021 Uniform Federal Policy Quality Assurance Project Plan (UFP-QAPP). |
Ginna Quesada |
| 4/20/2023 |
Document, Report, or Work plan Review - other |
DEC reviewed and provided comments for the 2021 Annual Remedial Action-Operations and Long-Term Management Report for Select CERCLA Sites, Draft, dated December 2023. The report describes the site inspections, maintenance activities, and groundwater monitoring, at multiple sites located on Joint Base Elmendorf- Richardson (JBER), Anchorage, Alaska. Site inspections and sampling were recommended to continue for all applicable sites to ensure that conditions remain protective of human health and the environment. |
Ginna Quesada |
| 1/29/2024 |
Document, Report, or Work plan Review - other |
DEC reviewed the 2022 Annual Remedial Action-Operations and Long-Term Management Report for Select CERCLA Sites, Draft, dated October 2023. The report describes the site inspections, maintenance activities, and groundwater monitoring, at multiple sites located on Joint Base Elmendorf- Richardson (JBER), Anchorage, Alaska. Site inspections and sampling were recommended to continue for all applicable sites to ensure that conditions remain protective of human health and the environment. |
Ginna Quesada |
| 7/2/2024 |
Document, Report, or Work plan Review - other |
DEC approved the 2022 Annual Remedial Action-Operations and Long-Term Management Report for Select CERCLA Sites, Final, dated June 2024. The report describes the site inspections, maintenance activities, and groundwater monitoring, at multiple sites located on Joint Base Elmendorf- Richardson (JBER), Anchorage, Alaska. Site inspections and sampling were recommended to continue for all applicable sites to ensure that conditions remain protective of human health and the environment. |
Ginna Quesada |
| 11/12/2024 |
Document, Report, or Work plan Review - other |
DEC approved the 2023 Annual Remedial Action-Operations and Long-Term Management Report for Select CERCLA Sites, Final, dated October 2024. The report describes the site inspections, maintenance activities, and groundwater monitoring, at multiple sites located on Joint Base Elmendorf- Richardson (JBER), Anchorage, Alaska. Site inspections and sampling were recommended to continue for all applicable sites to ensure that conditions remain protective of human health and the environment. |
Ginna Quesada |
| 3/18/2025 |
Exposure Tracking Model Ranking |
A new updated ranking with ETM has been completed for source area 71607 Surface release. |
Ginna Quesada |
