| Action Date |
Action |
Description |
DEC Staff |
| 9/2/1983 |
Update or Other Action |
September 1983 Phase I Records Search, EAFB by ES Engineering Science. Priority Ranking: IS-6, Bldg. 43-450 Floor Drains 1950s to present (1983) score=47 top score is 66 for SP-5 JP-4 Bulk Storage Tank Spill Mid 1960s. Document states: The areas determined to have a low potential for environmental contamination. Shop Name: Fuel Cell Repair Bldg. 43-450 Past bldg. numbers: 32-129, 42-400. Waste Material JP-4 1,200 - 1,500 gallons per year and PD-680 55 gallons per year.
Other buildings which housed aircraft maintenance shops in the past include buildings 32-179, 32-209, 32-060, 43-250, 43-450 and 32-050. The quantity of waste generated at each of these facilities was not known. It is, however, suspected that the types of waste potentially generated at these facilities include engine oil, hydraulic fluid, AVGAS, JP-4 and cleaning solvents. The method of disposal of these wastes was likely the same as the methods employed at other similar facilities in use at the time.
Many of the outlying hanger facilities, where aircraft maintenance was conducted, have floor drains which discharged to dry wells beneath or adjacent to the buildings. These dry wells received many of the wastes generated in the facility as well as any spills which may have
occurred. The facilities which still discharge to floor drains leading directly to dry wells are as follows: 42-400, 42-425, 43-550, 42-300, 43-410, 43-450, 21-900 and 32-060.
Site IS-6 Building 43-450 Floor Drains: Building 43-450 (Hangar 15) is used for aircraft maintenance. There is no washrack in the hangar. Therefore, the primary waste which may have entered the floor drains would have been fuels originating from minor fuel spills. The floor drains in this building are also connected to a dry well (Site IS-6).
|
Louis Howard |
| 11/2/1983 |
Update or Other Action |
USAF William R. Hanson, P.E. Director, Engrg. & Envmtl. Planning to DEEV (Mr. Hostman) 21 CSG/DEEV RE: Memorandum of Understanding (MOU) between DOD and EPA.
1. The attached guidance has been received from HQ USAF/LEE (atch 1). It is subject to change as time progresses. It is important to note that all actions affected by this agreement will be implemented within the overall guidance of the Installation Restoration Program.
2. All queries or requests for action received from Federal or State agencies concerning releases from former Air Force installations (MOU para 3.2) or other releases for which the Air Force is a responsible party(MOU para 3.3) will be referred to HQ AAC/DEEV for forwarding to HQ USAF/LEEV. HQ USAF will task appropriate commands and/or staff agencies for response action. Any requests received from the State of Alaska or other Federal agencies will be reported by phone to this office, autovon 552-4151. All pertinent information will be provided to assist HQ AAC/DEEV in determining the exact nature of the information requested and required for the reply. The information requested will include any information on pending legislation or other enforcement actions that may have an effect on the situation.
Letter from Gary Alkire Brigadier General USAF Deputy Director, Directorate of Engineering & Services to ALMAJCOM/DE/SG/JA.
1. The attached MOU regarding implementation of the Comprehensive Environmental Response, Compensation, and Liability Act of 1980 is provided for your information. It deals, in general, with DoD and EPA responsibilities and procedures to be followed in identifying, evaluating, and controlling releases of hazardous pollutants from currently active and former DoD facilities and third party facilities at which DoD is a responsible party.
2. This letter provides interim implementation guidance concerning the MOU.
3. All Air Force actions in response to this MOU will be conducted within the framework of the existing Installation Restoration Program.
4. Affected major commands will continue to be responsible for releases from currently active Air Force installations (MOU para 3.1).
5. All queries or requests for action received from Federal or State agencies concerning releases from former Air Force installations (MOU para 3.2) or other releases for which the Air Force is a responsible party (MOU para 3.3) will be referred to HQ USAF/LEEV. HQ USAF will task appropriate commands and/or staff agencies for response action. See site file for additional information. |
Louis Howard |
| 8/2/1988 |
Update or Other Action |
RCRA FACILITY ASSESSMENT REPORT: PRELIMINARY REVIEW AND VISUAL SITE INSPECTION ELMENDORF AIR FORCE BASE IDENTIFICATION NUMBER AK8570028649 (ADEC).
Operable Units' source areas that correspond to RCRA SWMUs from the RCRA RFA. SD29 IS-6 Bldg. 43-450 Floor Drain. This site was used for aircraft maintenance, release would have included spent fuel.
Site IS-6, Building 43-450 Floor Drains
a. Operation: This site is used for aircraft maintenance;the primary waste entering the floor drain system would have been fuels originating from minor fuel spills.
b. Contaminant Potential: This site has a contaminant migration potential due to the methods of discharge from the building drains.
|
Louis Howard |
| 3/18/1989 |
Update or Other Action |
Dept. of Air Force letter to Sue Curtin Black & Veatch.
Per your telephone request with Capt Godsave, we submit the following
information:
1. Storm sewer system maps for SP15, SP5/5A, SP7/10, IS-1: Attached.
2. Jet Fuel Supplier: Jet fuel is supplied per one year contracts. Presently, the majority of fuel is supplied by ARCO. Their contact person is Ms Candy Stallings, 213-486-2824. Other suppliers are Tesoro (Contact - Mr Raymond Measles at 907-561-5521), Chevron (415-944-6250), and Mapco (contact - Ms Bonnie Garner at 907-276-4100).
3. Buildings 42-400, 42-425, 43-550, 42-300, 43-410, 43-450, 32-060 floor drains: Originally, minor spillage and products operations in these facilities were washed into floor drains to dry wells. Present conditions are below. Since as-builts clear, this information may not be totally correct. 21-900, and from cleaning and from there are old and not
a. IS-1, Building 42-400: Floor drains run into two oil-water separators.
b. IS-2, Building 42-425: Sanitary sewer runs along side of building, unclear whether floor drains run into it or not.
c. IS-3, Building 43-550: Sanitary sewer runs along side of building, do not know whether floor drains run into it or not.
d. IS-4, Building 42-300: Floor drains run into an oil-water separator and then into the storm drain on the east and west side of the building.
e. IS-5, Building 43-410: Floor drains are connected to septic tank and leach fields at south side of building.
f. IS-6, Building 43-450: Floor drains probably go to the septic tank and leach pits east of the building and across the railroad track.
g. IS-7, Building 21-900: The floor drains run through sumps to remove sand and grit and dump right into the storm drain on the north side of the building. The floor drains for the mechanical room run out the south side of the building and into a seepage pit. There is also a catch basin on the south side of the building that runs into a seepage pit.
h. IS-8, Building 32-060: Although sanitary sewers run near the building, it appears that floor drains go directly to dry wells.
4. How close can wells be put to the runway? If top cover of wells are flush with the ground surface, there should not be a problem. If above ground surface and within 1000 feet of the runway, the well will require a waiver. If within 500 feet of the runway, well may also be required to be frangible.
5. If well is near the runway, can piping go underground beneath a taxiway to a treatment facility? That should not be a problem if taxiway is tunneled under.
6. What is the frost depth for Elmendorf AFB? The Building Code says 42 inches.
7. Does DRMO recycle fuel? DRMO does have a contract to recycle fuel.
8. At Site D-16, can soil at the site be used for grading? If soil is within acceptable levels for contaminants, yes. However, trees should be left as much as feasible.
9. How much would a contractor be required to pay the government for electricity? The government normally supplies contractors reasonable amounts of electricity at no cost. The government also requests that contractors, in this case, practice conservation.
Signed
Thomas Ritz Major, USAF
Acting Chief, Engineering & Environmental Planning Branch. |
Jennifer Roberts |
| 3/30/1989 |
Meeting or Teleconference Held |
Stage 3 RI/FS - Appendix H EDB levels detected at EAFB.
TELEPHONE MEMORANDUM
USAF
Elmendorf AFB
EDB Levels Detected at Elmendorf AFB
B&V Project 13833
B&V File
April 6, 1989
To:Max Schewenne
Company:Alaska Department of Environmental Conservation
Phone:(907) 563-6529
Recorded By:J.L. Frizzell
I talked with Max regarding the levels of EDB detected at Elmendorf AFB. There are no drinking water regulations regarding the level of EDB in drinking water. The State of Alaska requires an excess cancer risk 6 calculation be calculated. If the excess cancer risk is less than 10 , it
is probable that6the EDB concentration is not of concern. If the level is greater than 10 , a site by site review will be conducted by the Alaska Department of Environmental Conservation.
JLF:lpc
cc: VM Reid |
Max Schwenne |
| 11/15/1989 |
Document, Report, or Work plan Review - other |
Installation Restoration Program, Stage 3 Remedial Investigation/Feasibility Study Elmendorf Air Force Base, Alaska comments to USAF (Col. E. Mabry) from ADEC (R. Klein).
A. Investigative Methods
1. Paragraph 4.1.2.1 discusses the use of six wells to establish background levels for heavy metals. The data presented for the 6 background wells indicates silver in 1 well & mercury in 3 wells. Neither of these elements are common in uncontaminated GW; consequently, some of the wells may not represent actual background levels. In addition, the average iron concentration of 23,000 mg/kg is very high. It is suspected carbon steel well casings are in use & the wells were not purged sufficiently prior to sampling. If the wells were not purged sufficiently all of the background data is suspect.
2. Paragraph 4.1.2.2 discusses many reasons why monitoring well data is of questionable validity. However, the questionable data has been used to establish 95% confidence intervals for determining when contamination is present above background. We feel the 95% C.I. is useless because the data used to develop the confidence interval will probably not withstand a QA review.
3. Ground-penetrating radar may not be successful for locating buried objects in glacial till.
4. Several of the sites were not screened for PCB contamination. Given the past use of PCB containing material by the military it is possible for PCB contamination to be present at any site.
5. Paragraphs 4.2.3.3.2.3 & 4.2.4.3.2.3 state that contamination will not affect well 42 because of a steel well casing in the contaminated zone. This is a poor assumption. Many confined aquifers have been contaminated by contamination migration down the outside of well casings into the saturated zone. The artesian nature of the aquifer may slow down contaminant migration; however, concentration gradients act independently from the pressure gradients which may result in movement of contamination from a low pressure area to a higher pressure area.
6. Paragraph 4.2.13.3.2.3 states that well 16 will not be contaminated for the same reasons already discussed in paragraph 5 of this review. The same concerns stated in paragraph 5 apply.
7. Several references to use of an HNu for soil screening appear in the report. HNu readings of tenths of PPM are frequently cited. The HNu is not accurate to one tenth of 1 ppm & there is no indication regarding what span setting was used. If a 9.8, benzene, span setting was used the response of heavier hydrocarbons would be minimal. In addition, many natural substances can cause a one or two unit response in an HNu. Specifically paragraph 4.2.8.1.3.1 cites a 0.1 ppm HNu reading at site IS-6. Of what significance or use is this information? Paragraph 4.2.8.3 cites that "organic vapors" were detected with the HNu. The HNu responds to more than just organic vapors & there is no way to verify that organic or inorganic vapors are present.
APPLICABLE OR RELEVANT & APPROPRIATE REQUIREMENTS
Where there is GW contamination due to fuel products, the Air Force should use the volatile aromatic standards as listed on page 5-14 rather than the visible sheen criteria. The discussion on page 5-22 says the Air Force will use the target cleanup levels in Table 5-7. Then the next paragraph says the Air Force will use the visible sheen criteria. The Air Force should use the target cleanup levels. Cleanup to Water Quality Standards is required even if an aquifer is not being used for drinking water. As stated above, sites with petroleum contamination in the NFA category have to be re-evaluated with-respect-to the ARAR's. This may move them into the require further investigation category.
SELECTION OF REMEDIATION ALTERNATIVES
Sites IS-1 through IS-8, Hangar Floor Drains: Expedited action that would prevent further soil & GW contamination is requested. Steps must be taken to identify the discharge locations of floor drains when the discharge locations are unknown. If floor drains are found to be discharging to leachfields or dry wells actions need to be taken to cease the unpermitted discharge & direct it to the sanitary sewer (or storm drains if a sanitary sewer is not available). An oil/water separator will need to be installed & maintained at a point prior to discharge to the sanitary sewer or storm drain. The system must be designed to insure that solvents will partition from the water & be recovered. Please provide details on whether the hangar floor drains meet these requirements.
The Department would also like to request a list of all contaminated sites which have been identified on EAFB & notation of their current status within the IRP. The list can be provided as a table which lists the site & shows actions completed & actions scheduled to be completed with dates. The list will enable the Department to track Air Force progress assessing & remediating the sites. |
Ron Klein |
| 12/29/1989 |
Update or Other Action |
ADEC letter to Everett L. Mabry Colonel, Base Civil Engineer, HQ 21st Combat Support Group (AAC) RE: RI/FS Stage 4 Second Draft Work Plan (WP) EAFB October 1989.
1. For several sites the disposal method for soil contaminated with high levels of TPH is quoted as "the sanitary landfill (LF)". The only area LF that is permitted to receive petroleum contaminated soil is the Municipality of Anchorage (MOA) LF. The MOA LF will accept soils only if the TPH level is below 1000 mg/kg. In many cases the WP was referring to soils with TPH in excess of 1000 mg/kg. The issue of proper contaminated soil disposal has been brought up by ADEC several times (reference letters: Klein to Gerken, October 20, 1989 & Klein to Mabry, November 2, 1989).
ADEC requests clarification on the disposal method of soils contaminated with TPH over 1000 mg/kg & verification the proposed sanitary LF is the MOA LF. ADEC requests written notification regarding disposal of all contaminated soils. The notification should include: date of disposal, quantity of soil, location that soil originated, & final disposal method.
2. ADEC requests an expanded seasonal sampling schedule be established for selected monitoring wells (MW). In several sites (for example, well W-18 on site IS-1) there may be floating product. ADEC is concerned accurate data is not being collected based on an annual sampling schedule. Seasonal water table fluctuations can easily dilute or mask the true level of contaminate. Determinations on site status & remedial actions are being based on incomplete information.
3. In all the proposed borings/MW the WP calls for 2 soil samples per boring to be taken to determine the extent of vertical contamination. The exact depth of the sample is to be based on field screening results. Field screening techniques to determine the presences of TPH contamination is not reliable & it is not uncommon to miss contaminated zones using field screening in lieu of analytical lab analysis. Much of the contamination is from old fuel spills which may now be low in benzene & again would be very difficult to read on any field meter calibrated to benzene. ADEC requests additional soil samples be taken in soil borings/monitoring wells & recommends sampling be done on 5' or 10' intervals depending on the total depth of the boring.
4. Para. 2.2.1.2 & many other sections reference HNu readings of less than 1 ppm. Key data such as span setting, ambient HNu reading, & calibration gas used, need to be stated to interpret HNu data. Ambient levels of greater than 1 ppm at span 9.8 calibrated to benzene are common. Relying solely on HNu field screening may allow contaminated zones to be missed. Again ADEC requests that additional soil samples be taken in soil borings/monitoring wells.
5. In many sites 2 deep borings/MWs are proposed. The decision to drill the 2nd boring would be based on the results of the 1st deep boring. ADEC is concerned that using only 2 soils samples per boring to determine if contamination is present will allow layers of contamination to be missed. ADEC requests that additional soil samples be taken to determine the vertical location of contamination & that this additional sampling be used to determine the depth of the 2nd deep boring & the other shallow borings.
6. Para. 2.2.1.2 & 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 & 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, Para. 3.3.1.5 states that over 400 wells are in the EAFB area. Well casings can offer excellent conduits for contamination migration. ADEC requests information for each of the base drinking water wells : total depth, wells logs (if available) & how these wells are completed (screened or perforated zones, etc.).
7. Numerous floor drains are currently not hooked into an approved sanitary sewer, but go directly into storm sewers, septic systems or leach fields. These floordrain systems need to have an approved oil/water separator installed & the treated water may then be discharged under an ADEC industrial water discharge permit. As in earlier letters (Klein to Mabry, November 15, 1989, page 5) ADEC requests a complete inventory of floordrains be done to establish the current discharge status.
SITE IS-6: Para. 5.2.2.11 states the floordrains appear to discharge into septic tanks & leach pits E of the Bldg.. An oil water separator needs to be installed & an industrial waste water discharge permit is required or a holding tank must be installed. ADEC requests additional assessment borings be done in the location of the currently discharge area of the septic tanks & leach pits. |
Ron Klein |
| 12/30/1989 |
Site Added to Database |
Petroleum contaminant. |
Louis Howard |
| 7/2/1990 |
Update or Other Action |
AFOEHL REPORT 90-124EQ00687GHH Hazardous Waste Technical Assistance Survey EAFB (July 1990). Propulsion Shop (Hangar 15): Shop personnel maintain and repair propeller engines for the C-130
aircraft. One engine and two propellers are serviced per month. Oil (12 gallons/month) drained from the engines is stored in a 150-gallon bowser. When full, the bowser is taken to Hangar 12 and emptied into an UST. Hydraulic fluid (12 gallons/month) drained from the engines and the propeller is stored in 55-gallon drums. The shop has one 50-gallon PD-680 tank that is
changed out every two weeks; the waste is drummed and disposed through DRMO as hazardous waste. The drums are stored in the shop in drip pans. When full, the drums are transported to the 616 CAMS accumulation site. Absorbent pads are placed under the engines to contain small spills and leaks. The spent absorbent pads are taken daily to Hangar 12 and put into a drum. Simple Green
Soap (150 gallons/year) is used for cleaning the shop floors.
|
Louis Howard |
| 9/26/1990 |
Update or Other Action |
INTERIM GUIDANCE FOR SURFACE AND GROUNDWATER CLEANUP LEVELS SEPTEMBER 26, 1990
Interim cleanup guidance for contaminated surface and groundwater remediation is necessary to ensure that consistent cleanup levels are being applied by district and regional program staff. The following guidelines should be implemented under 18 AAC 75.140 which specifies that a "discharge must be cleaned up to the satisfaction of the Regional Supervisor or his designee.
Final cleanup levels shall be determined by the Regional Supervisor or his designee based on site-specific conditions. Staff should be aware that if a facility is regulated under RCRA, that RCRA corrective action and cleanup standards should enter into development of final site cleanup levels.
Groundwater should be cleaned up to levels not exceeding the more stringent of the final State or Federal Maximum Contaminant levels (MCLs) for Organic and Inorganic Chemicals. If final MCLs have not been adopted for a contaminant, then groundwater should be cleaned up to levels not exceeding proposed Federal MCLs. The group of compounds collectively identified as total petroleum hydrocarbons (TPH) should be cleaned, up to non-detectable levels as measured by EPA Method 418.1.
Final State MCLs are specified in 18 AAC 80.050 and final Federal MCLs are specified in 40 CFR 141 and 142. Proposed Federal MCLs are specified in the May 22, 1989, Federal Register Vol. 54, No. 97, pages 22155 - 22157 and the July 25, 1990, Federal Register Vol. 55, No. 143, pages 30408 - 30448. Appendix I provides a summary listing of State and Federal Final and Proposed MCLs for selected organic and inorganic contaminants.
For organic and in organic contaminants that have not been assigned a final or proposed MCL, cleanup levels should be based on criteria cited in EPA's Water Quality Criteria. 1986 using a health risk factor of 10-6. EPA's water quality criteria identify concentrations of elements and compounds which have toxic effects on aquatic organisms or toxic and carcinogenic effects on humans.
If groundwater is being used as a drinking water source and alternative water supplies or point of use water treatment cannot be provided, then final or proposed secondary maximum contaminant levels (SMCLs) may be used as cleanup target levels. SMCLs are based on aesthetic properties such as taste and odor, whereas MCLs are based on human health risks. For compounds such as xylenes, the SMCL maybe several hundred times lower than the MCL.
Surface waters used for drinking water should also be cleaned up to levels not exceeding the final or proposed MCLs for organic and inorganic chemicals, as specified above. Under the authority of 18 AAC 70.020, surface waters important to the growth and propagation of aquatic life should be cleaned up to the listed criteria which includes EPA's Water Quality Criteria. 1986. These criteria identify concentrations of specific elements or compounds which have toxic effects on aquatic organisms. The group of compounds collectively identified as total petroleum hydrocarbons (TPH) should be cleaned up to non-detectable levels as measured by EPA Method 418.1.
Alternative Cleanup Levels (ACLs) may be adopted for a site if a risk assessment approved by the department is performed and cleanup to levels identified above is technically infeasible. Risk assessments will not by themselves establish ACLs. Determination of cleanup levels is a risk management decision that the department must make based on results of a quantitative risk assessment and other pertinent information.
The responsible party (RP) may prepare at its own expense a risk assessment which shall include an assessment of both human health and environmental risks. Specific components of the risk assessment should include an exposure assessment, toxicity assessment, risk characterization, and justification of ACLs. A general description of these risk assessment components is provided in Appendix II.
General technical requirements for risk assessments should be based on EPA risk assessment guidance for superfund sites. A site specific risk assessment procedure must be prepared by the RP and submitted to the department for review and approval prior to conducting a risk assessment. The RP, at the department's discretion, must agree to reimburse the department for expenses incurred by the department if it chooses to contract for a risk assessment review. |
Louis Howard |
| 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.
Historically, the focus of the investigation at OU 4 had been to determine if a release had occurred via the building floor drains. Each building was considered as a unique "source area", and multiple stages of investigations were conducted at these areas. Ten source areas were included as part of OU 4, including SD24, SD25, SD26, SD27, SD28, SD29,. SD30, SD31, SS18, and SS63.
SD29 (formerly IS-5-01 IS6-01) Bldg. 43-450 floor drain. This site was used for aircraft maintenance, release would include spent fuel. SD29 is in OU4 East. The OU 4 East boundary, as drawn, is approximately 1500 by 2500 feet, or 85 acres. There are two principal buildings located within the OU 4 East boundary. These include Hangar 15 and Building 43-410. These buildings, along with the ADSA, make up the former source areas located within this study area. Both soil and groundwater contamination were formerly detected at OU 4 East.
Like OU 4 West, a thorough evaluation of the potential sources of contamination present at OU 4 East was conducted during the preparation of the Conceptual Site Model. Potential sources included POL lines and the POL system, former spills, USTs, dry wells, the leach field to the east of Hangar 15, and the waste practices at the former Asphalt Drum Storage Area. POL lines and USTs were tested in 1993, and no significant leaks were detected.
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 Base wide 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 |
| 5/20/1992 |
Update or Other Action |
Summary of Possible Drainage Outfall Targets Identified by GPR: SD-29 Bldg. 43-450 1 A = 115 ft. West/~15' North of Northeast corner, pipe termination and four other candidate targets identified by GPR (Arnold Orange Associates). |
Jennifer Roberts |
| 7/20/1992 |
CERCLA PA |
Memorandum for a meeting held at CH2MHILL/ANC on July 8, 1992 subject: OU4 IRA Planning. Purpose was to discuss the preliminary results of the OU4 Limited Field Investigation (LFI) field work and reach consensus among the project managers on which OU4 source areas would be appropriate for an Interim Remedial Action (IRA). General criteria for an Interim Remedial Action (IRA):
1) contamination verified above action levels (EPA and ADEC guidance levels);
2) point source contamination defined and accessible;
3) IRA implementable;
4) IRA won't interfere with final remedy; and
5) IRA should prevent further release of contaminants.
SD29 Building 43-450: Source area is already scheduled in RI due to groundwater contamination documented from previous investigations; LFI confirmed leachfield area does contain contamination and should be included in the RI; Consensus: No IRA.
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.
Interim Actions
The purpose of the IA-OUs at the EAFB are to achieve early actio using remedial authority at
those sites which meet the IA deneral principles that are discussed in the NCP. If at anytime the information submitted to suppo-t the IA is found to be equivalent to that obtalned during an Rl/FS and the OU is separable, then he IA may be upgraded to an early final action.
The Preamble of the NCP, 55 Federal Register 8703-8706 (March 8, 1990) states that to Implement
an early action under remedial authority, an operable unit for which an interim action is appropriate is identified. IA decisions are intended for straightforward sites that are limited in scope.
Data sufficient to support the interim action decision is extracted from the ongoing RI/FS or from previous studies and an appropriate set of alternatives is evaluated. Few alternatives and in some cases only one should be developed for interim actions. A completed basellne risk assessment generally will not be available or necessary to justify an interim action." |
Jennifer Roberts |
| 11/30/1992 |
Update or Other Action |
Final OU4 LFI Report Vol. 1 November 1992 received.
The two locations that were recommended for RI/FS activities for floor drain outfalls include:
SBSD25A-2, GRO, and total benzene, toluene, ethylbenzene, and xylene (BTEX) were exceeded at this suspected dry well location. This sampling location is a poorly identified pipe exit at Building 42-425. This location was not recommended for an IRA because: (1) a defined
point source was not identified and there is evidence to conclude that the contamination identified could be the result of a leaking UST, or (2) because the samples were possibly collected from below the water table, therefore, these data may represent the degree of contamination in the saturated zone, and not the unsaturated vadose zone.
SBSD29A-ADEC risk-based criteria for DRO were exceeded at this location. This sampling location is situated at the septic field for Hangar 15/ Building 43-450. This building has already been selected to receive an RI/FS because groundwater contamination was observed downgradient
of the building without any other upgradient sources of contamination being present. Samples were collected at SBSD29A to assess whether the Hangar 15 septic field would be included in the Hangar 15 RI/FS.
OU4 Source Name SD29 aka IS6, current bldg. no. 43-450 (constructed 1957), other bldg. name Hangar 15, Current USAF Shops occupying bldg: Explosive Ordnance Disposal Branch, Aircraft Field Maintenance Branch. General activities: Aircraft maintenance. Waste products of concern: POLs, solvents, metal bearing wastes.
Suspected location of dry wells: Septic system east of bldg. source of information: As-built, visual observation.
ADEC cleanup matrix score calculated "Level B" DRO 200 mg/kg, GRO 100 mg/kg, Benzene 0.5 mg/kg, total BTEX 15 mg/kg.
During the completion of the LFI, potential contaminant sources in the vicinity of SD28 other
than sampling location SBSD28A were identified (Table 3.15). These sources included USTs and OU 4 Source SD29. The largest USTs include a 2500-gallon JP-4 UST, a 4000-gallon mogas UST, and a number of other unspecified USTs. The two larger USTs are currently in use, but they lie slightly northwest of the monitoring well and apparently downgradient of the monitoring well. All of the other tanks are actively used, with the exception of USTs 448 and 449, which have been permanently closed. Tanks 450 and 451 have been tightness tested, and according to the USAF UST inventory, both tanks passed and are not leaking.
There is a discrepancy between the UST inventory and information obtained during onsite interviews. The UST inventory indicates that three USTs are situated approximately 30 feet
north of Building 42-410 as shown on Figure 3.6, but onsite interviews indicate that the USTs
north of Building 42-410 have been removed to accommodate USTs that have been recently
installed as part of the oil/water separator system for Building 42-410. It does not appear
that Source SD29 could be a source of upgradient groundwater contamination because according to the flow net presented in Figure 1.7, it appears as if SD29 is parallel to, and not upgradient of, SD28. Determining the source of TPH contamination found in monitoring well IS5-01 will require refining groundwater flow directions in the vicinity of SD28 during future RI/FS activities.
3.7.1 Building 43-450/Hangar 15 Background Information
Historically, Hangar 15 was a restricted access area used for aircraft maintenance. The primary
wastes that may have entered the floor drains at Building 43-450 would have been fuels originating from minor spills and PD680 (Engineering-Science 1983). The building was constructed in 1957 (USAF 17 April 1992 memorandum to CH2M HILL and EMO). Black & Veatch (1990) reports that the floor drains originally discharged to dry wells, but later, were discharging to a septic tank and leaching pits east of the building in 1988. Base personnel report that the floor drains are currently connected to a French drain, and the latrines are connected to the septic tank.
During the field inspection, the CH2M HILL team noted that Building 43-450 is composed of two hangars separated by a wall; each hangar is a mirror image of the other. Along the west side of the building, in both hangars, is a single, grated floor drain running the length of the hangar.
The floor drain does not appear to be connected between hangars, and the grating is about 18 to 24 inches wide. The field team noted that, in both hangars, portions of the bottom of the drains were wet; however, no flow was observed. The direction of the potential flow could not be determined. Site personnel said they had been told there were major problems with the drain system in the building, but that current activities in the hangars would not use the drains, except for very minor runoff from snowmelt.
See site file for additional information. |
Louis Howard |
| 3/26/1993 |
Update or Other Action |
DOD and ADEC joint Technical Memorandum of understanding signed concerning the Base wide Groundwater (GW) signed by: ADEC Jennifer Roberts RPM and USAF Joseph Williamson Chief Environmental Programs & Restoration. Due to the base wide GW study and the FY92 field work that occurred at Operable Units (OUs) 1, 2, and 5 it appears a large portion of the GW flows into OU5 (attach. 1-contour map). Based on this fact, Elmendorf (EAFB) will move all upgradient GW into the OU5 Feasibility Study, Proposed Plan and Record of Decision (ROD). This means addressing all GW from upgradient sources (CERCLA (ST20, OUs 3 and 4) and OUs 1 and portions of OU2) and SERA) at OU5 instead of at each individual source area (see attach. 2-Area Map). Sites with free phased product would be looked at to see if there is an available technology to clean them up in a cost effective way. Soil contamination would be addressed at the source areas. NOTE: addressed at the source areas is interpreted by ADEC as removal through excavation or active treatment systems (e.g. high vacuum extraction, bioventing, etc...).
Also included in the file is the AF memo: Restricted Use of the Shallow Aquifer on EAFB signed by William R. Hanson P.E. GM-14 Chief Environmental Flight dated October 17, 1996 Memorandum for 3 SPTG/CEC/CEO from 3 SPTG/CEV
1) Due to the contamination and commitments to EPA/DEC the use of the shallow aquifer for any purpose on is not allowed. Attached Facilities Board minutes-03/29/1994 0930 Item 9 has Mr. William Hanson, briefing the Board on the policy to not use the shallow aquifer due to contamination. The Board approved this policy. Minutes approved by Thomas R. Case Brigadier General USAF Commander. The IRP has RODs for OUs 3 and 6 which require, the aquifer remain unused. 2) Personnel in the review process within CES must be aware of these policies and review them on a recurring basis. It is imperative this restriction be recognized and observed during engineer reviews and operations. |
Jennifer Roberts |
| 8/1/1994 |
CERCLA RI Report Approved |
1994 RI/FS Report received. The soil gas screening in the Hangar 15/Building 43-410 Area indicated 4 small areas of soil gas contamination in the area of interest. Two of the areas were in the vicinity of USTs & fueling stations located in the area. Both of these areas contained TVHC in the soil gas samples collected. The 3rd area was an isolated hit of TVHC located north of the hangar. The 4th area contained both chlorinated solvent: contamination & TVHC contamination. The potential source of this contamination is unknown.
Higher levels of ethylbenzene, toluene, & xylenes (up to 1,160 ug/kg) were detected in boring SB-49, located adjacent to two USTs. Levels were greatest between 2.5 & 4.5 feet bgl. & decreased in deeper samples. In boring SB-50, also located adjacent to several USTs, levels of BTEX compounds as high as 1,020 ug/kg were detected in the surface soil sample. Levels in this boring also decreased with depth. GRO in this surface soil sample was 131,000 ug/kg. This level also decreased with depth. BTEX compounds were detected in the boring drilled for the upgradient well (Boring SB-051), up to 3,380 ug/kg &, "Gasoline" at 11,800 ug/kg in the shallowest sample collected (4-6 feet bgl). None of these analytes were detected at greater depths.
Low levels of several VOCs were detected in boring SB-49, adjacent to several USTs. This would indicate either that the tanks are leaking or that surface spills resulting from improper filling, use, or testing practices with the tank have occurred. Because the contamination was localized & limited to the upper few feet of the soil, surficial spills are the most likely source. Boring SB-50 contained much higher levels of GRO & some BTEX constituents. Again, because the contamination was observed in surface or near surface samples, surface spills are the likely source.
Boring SB-51 contained small amounts of several BTEX constituents. This was at a supposedly upgradient location. A vehicle maintenance shop was at one time located very close to this location & may be the source of the low levels observed in this boring. Tetrachloroethene was detected at low levels in boring SB-43 near a dry well originating in Hangar 15. Although these detections were at relatively low levels, they were anomalous in that this compound was detected in only one other boring in OU 4. This may indicate that this dry well is a potential source of chlorinated solvents into the subsurface. This dry well is reportedly still in use; however, Hangar 15 is scheduled to be hooked up to a sewer system within one year.
The HVOC plume identified at the south end of Hangar 15 consisted of PCE & TCE in roughly equal proportions. The maximum PCE detected was in the GW grab sample from SB-43 at 28 ug/L. The maximum TCE detected was found in the grab sample from SB-42 at 11 ug/L. The detection of this HVOC "plume" was confirmed by the gradual decrease in constituent levels away from these locations. Low levels of TCE & PCE were found in the downgradient HydroPunchTM location EH-15.
An attempt was made to collect an upgradient grab sample to assist in confirming the source of the HVOC plume in this area. Due to the extremely difficult drilling conditions encountered at the site & the relatively low levels of the plume identified, a decision was made by the USAF, AFCEE, the USEPA & ADEC to abort further attempts at drilling/sampling east of Hangar 15.
In addition to the TCE & PCE detected in this area, trace levels of trichloroethane & carbon tetrachloride were found in HydroPunch'" locations located upgradient of the HYOC plume. A GW grab sample was not collected from SB-49 due to the difficult drilling conditions encountered. Also chloroform, a common laboratory contaminant, was found at very low levels in nearly every sample.
The laboratory analytical results from each of the three GW sampling rounds were fairly consistent. The organic results confirmed the GW screening results in the area of HVOC contamination. This plume trended in the same direction & at a similar concentration as the plume identified by the screening results. Elevated HVOCs, including PCE & TCE, were identified in only one well (IS6-01), at concentrations of 18 & 23 ug/L, in the third sampling round, respectively.
The HVOC estimated extent of the plum extends approximately 400 feet west under the taxiway from IS6-01 & is approximately 100 feet wide. The westernmost extent of the plume is defined by OU4E-3, where no HVOCs were detected. This representation of the plume is drawn without consideration of the GW screening results. While the GW screening results are not of sufficient quality to use in the quantification of risk, they can be useful in helping to discriminate the lateral extent of contaminant plumes by increasing the size of the data set.
See site file for additional information. |
Louis Howard |
| 9/15/1994 |
Risk Assessment Report Approved |
Risk assessment combined with Remdial Investigation/Feasibility Study (RI/FS) final version received and approved. The carcinogenic risk to a future resident, exceeded 1.0E-06 for both soil and groundwater at the Hangar 15 jBuilding 43410 Area. This scenario assumes the
maximum exposure and is therefore highly conservative, resulting in the highest human health risk values. The m of 1 (noncarcinogenic) was not exceeded for soil or groundwater in this area.
The carcinogenic risk threshold for soil was only slightly exceeded. None of the constituents
in the soil individually contributed greater than 1.0E-06 to the carcinogenic risk. Three constituents were contributors to the risk in groundwater having calculated individual
risks greater than 1.0E-06. There are currently no residences in OU 4, and no water supply wells installed in the shallow aquifer in the Hangar 15/Building 43-410 Area.
Copper 95% UCL concentrations were sufficient in both surface and subsurface soils in this area to cause the EQ for meadow voles to exceed 1.0. However, the upper threshold limit of the background concentrations for copper would also cause the EQs to exceed 1.0. This indicates that the modeled doses or reference criteria are probably overestimating impacts. Actual exposures to the subsurface soils would be less than those modified and could reduce the EQs below 1.0.
Soils at the Hangar 15/Building 43410 Area slightly exceeded the 1.0E-06 carcinogenic threshold for human health risk. No constituents were identified as individual contributors of greater than 1.0E-06 to the soil risk in this area of interest. One interval of soil contamination was also identified in the Hangar 15/Building 43-410 Area with concentrations exceeding potential regulatory levels. Both surface and subsurface contamination exceeded potential regulatory levels at that location.
Two constituents, benzo(a)pyrene and gasoline, exceeded potential regu.latory levels in the soil. Since the soils at the Hangar 15/Building 43-410 Area exceeded the risk criteria, and also exceeded potential regulatory levels, they should be evaluated for the feasibility of remedial action in the FS; and Groundwater in this area of interest exceeds the human health criteria for carcinogenic risk.
Three constituents were identified as significant groundwa~r risk contributors. Two groundwater plumes (NHVOC and HVOC) were also identified with three constituents having concentrations exceeding potential regulatory levels. Because of this, groundwater at the Hangar IS/Building 43410 Area should also be evaluated in the FS.
*NOTE TO FILE: 1,4-Dioxane, referred to as an "Emergent Chemical", is a manmade compound primarily used as an industrial solvent or solvent stabilizer for chlorinated solvents or volatile organic compounds (VOCs). About 90% of the dioxane produced is used to stabilize 1,1,1-trichloroethane.
Additional Industrial and Commercial Uses of 1,4-Dioxane: Solvent in paper manufacturing, as a wetting & dispersing agent in textile process, Paints, lacquer, and varnish remover, In microscopy, Stain and printing compositions, as a purifying agent in pharmaceuticals, In liquid scintillation counters, In resins, oils, waxes, and cements, In deodorants, shampoos & cosmetics, In fumigants, Impregnating cellular acetate, as an additive in aircraft deicing fluid formulations, ‘inert’ ingredients of pesticides ,as an additive in antifreeze, and as a by-product formed during esterification of polyester (Sources: Montgomery, 1996; Beernaert et al, 1987; Mackison et al, 1981; US EPA, 1979; ILO, 1979; NCI/DCE,1985);
Releases of chlorinated solvents, or spent solvents disposed of improperly, can be a primary source of 1,4-Dioxane in the environment. 1,4-Dioxane has a high potential for entering the environment due to its volatility and solubility in water. 1,4-Dioxane has been detected in surface and ground waters throughout the United States.
Hangar 15/Bldg 43-410 Area: Soil Remedial actions should be evaluated for the soil pathway for the following reasons:
• Excess lifetime cancer risks to a future residential receptor exceeded 1.0E-06 in the soil at the Hangar 15/Building 43-410 Area; and
• One area was identified with soil potential regulatory level exceedances within the Hangar 15/Building 43-410 Area. Semivolatile organic compounds and gasoline exceeded potential
regulatory levels in the soil.
Grouadwater--Remedial actions should be evaluated for the groundwater pathway for the following reasons:
Excess lifetime cancer risks to a future residential receptor exceeded 1.0E-06 in the groundwater at the Hangar 15/Building 43-410 Area; and
A groundwater plume was identified in the Hangar 15/Building 43- 410 Area with compounds exceeding potential regulatory levels. HVOCs and aluminum exceeded potential regulatory levels in this plume. |
John Halverson |
| 9/15/1994 |
Site Characterization Report Approved |
Final version of the remedial investigation/feasibility study (RI/FS) received and approved. |
John Halverson |
| 4/11/1995 |
Proposed Plan |
Proposed Plan lists hangar 15 (a.k.a. SD29 or Building 43-450) with GW contamination (TCE and tetrachloroethene). Preferred alternative for GW contamination is institutional controls with intrinsic remediation(IC/IR). All shallow soils will be treated through IC/IR. Maximum concentration (ug/L) 19.5 Tetrachloroethene (cleanup level 5 ug/L) and TCE 23 ug/L (cleanup level 5 ug/L). Hangar 15 Soil risks-Shallow Soil (<5') Residential RME=2.1 x 10-6 from fuels and fuel residues. Current occupational is < 10-6. Deep soils > 5' is < 10-6. Groundwater risk-Hangar 15 Residential RME: 1.5 x 10-6 Future occupational is <10-6. Chemicals driving risk: TCE, chloroform and chloromethane.
The preferred alternatives were chosen on the basis that assumptions behind the human health risk calculations are very conservative. However, no alternative will be selected until after the public comment period. It is extremely unlikely that future residents would use contaminated water from the upper aquifer for drinking and showering. Upper aquifer wells are not being used for any purpose, and they are not expected to be used in the future. It is also highly unlikely that residences would be constructed in these areas, since they are adjacent to hangars and runways.
In summary, the preferred alternatives are expected to provide the best balance of tradeoffs among all of the possible alternatives with respect to the National Contingency Plan criteria. Therefore, the USAF, EPA, and ADEC believe the preferred alternatives would:
Protect human health and the environment;
Comply with ARARs;
Be cost effective; and
Use permanent solutions and alternative technologies or resource recovery to the maximum extent practicable. |
Jennifer Roberts |
| 6/15/1995 |
Site Ranked Using the AHRM |
Initial ranking. Action code added because it wasn't when the site was originally ranked. |
Louis Howard |
| 10/10/1995 |
Cleanup Level(s) Approved |
Groundwater is contaminated with tetrachloroethene and trichloroethene above MCLs (5 ug/L). |
Louis Howard |
| 10/10/1995 |
Institutional Control Record Established |
Record of Decision (ROD) in 1995 designated long term monitoring for tetrachloroethene and trichloroethene contaminated groundwater and institutional controls until it achieves remedial action objectives. Environmental staff and land planning staff control all activities by AF personnel and contractors when any soil moving activities or invasive activities are planned.
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 |
| 10/10/1995 |
Record of Decision |
ROD lists institutional controls and intrinsic remediation (IC/IR) for shallow soils and GW contamination.
The major components of the selected remedy include:
Groundwater
* Institutional controls on land use and water use restrictions will restrict access to the contaminated groundwater throughout OU 4 until cleanup levels have been achieved.
* Groundwater will be monitored semi-annually to evaluate contaminant migration and timely reduction of contaminant concentrations by intrinsic remediation. If cleanup levels are not being achieved, further remedial action will be evaluated. Five-year reviews will also assess
the protectiveness of the remedial action, as long as contamination remains above cleanup levels.
* All groundwater is expected to be cleaned up within thirteen years.
Soil
* Institutional controls on land use will continue to restrict access to the contaminated shallow soils throughout OU 4 until cleanup levels have been achieved.
* Deep soils at the FTA, the ADSA, and Hangar 11 will be treated with bioventing to accelerate degradation of contaminants in those locations. Deep soils at other source areas will be allowed to degrade through intrinsic remediation.
* Both shallow and deep soils will be monitored bi-annually to evaluate contaminant migration and timely reduction of contaminant concentrations by bioventing and intrinsic remediation. 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, as long as contamination remains above cleanup levels. When concentrations in the bioventing areas are below cleanup levels, bioventing will be discontinued.
* All soils are expected to be cleaned up within eleven years.
NOTE TO FILE: § 300.430 Remedial investigation/feasibility study and 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 and the environment. Remedial actions are to be implemented as soon as site data and information make it possible to do so. Accordingly, EPA has established the following program goal, expectations, and program management principles to assist in the identification and 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 and deed restrictions to supplement engineering controls as appropriate for short- and 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) and implementation of the remedial action and, where necessary, as a component of the completed remedy. The use of institutional controls shall not substitute for active response measures (e.g., treatment and/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.
Because the remedy will result in contaminants remaining on-site above health based levels, a review will be conducted within five years after commencement of remedial action. The review will ensure that the remedy continues to provide adequate protection of human health and the environment.
Applicable or Relevant and Appropriate Requirements (ARARs)
Chemical-Specific ARARs -- Chemical-specific cleanup levels for OU 4 are: Groundwater-hangar15/bldg. 43-410 tetrachloroethene 5 ug/L (max conc. 19.5 ug/L), trichloroethene 5 ug/L (max. conc. 23 ug/L). The Maximum Contaminant Levels (MCLs) established for drinking water under State and Federal laws are applicable to groundwater contaminants of concern at OU 4 as a chemical-specific regulation. For petroleum contaminated soil that will be remediated, soil cleanup level D from the Alaska Cleanup Matrix, 18 Alaska Administrative Code (AAC) 78.315, is applicable.
Location-Specific ARARs -- There are no specific ARARs which must be met because of the location of the contamination and remedial actions at OU 4.
Action-Specific ARARs -- The selected remedy will comply with those ARARs applicable or relevant and appropriate to construction and operation of the bioventing system, and to the monitoring activities conducted at all source areas. Clean Air Act -- 42 USC Section 7401
National Primary and 40 CFR Establishes standards for ambient Remedial actions must not
Secondary Ambient Air Part 50 air quality to protect public health result in exceedence of
Quality Standards and welfare. ambient air quality standards. There could be air emissions
from bioventing.
|
Louis Howard |
| 9/26/1996 |
Update or Other Action |
INTERIM GUIDANCE FOR SURFACE AND GROUNDWATER CLEANUP LEVELS SEPTEMBER 26, 1990
Interim cleanup guidance for contaminated surface and groundwater remediation is necessary to ensure that consistent cleanup levels are being applied by district and regional program staff. The following guidelines should be implemented under 18 AAC 75.140 which specifies that a "discharge must be cleaned up to the satisfaction of the Regional Supervisor or his designee.
Final cleanup levels shall be determined by the Regional Supervisor or his designee based on site-specific conditions. Staff should be aware that if a facility is regulated under RCRA, that RCRA corrective action and cleanup standards should enter into development of final site cleanup levels.
Groundwater should be cleaned up to levels not exceeding the more stringent of the final State or Federal Maximum Contaminant levels (MCLs) for Organic and Inorganic Chemicals. If final MCLs have not been adopted for a contaminant, then groundwater should be cleaned up to levels not exceeding proposed Federal MCLs. The group of compounds collectively identified as total petroleum hydrocarbons (TPH) should be cleaned, up to non-detectable levels as measured by EPA Method 418.1.
Final State MCLs are specified in 18 AAC 80.050 and final Federal MCLs are specified in 40 CFR 141 and 142. Proposed Federal MCLs are specified in the May 22, 1989, Federal Register Vol. 54, No. 97, pages 22155 - 22157 and the July 25, 1990, Federal Register Vol. 55, No. 143, pages 30408 - 30448. Appendix I provides a summary listing of State and Federal Final and Proposed MCLs for selected organic and inorganic contaminants.
For organic and in organic contaminants that have not been assigned a final or proposed MCL, cleanup levels should be based on criteria cited in EPA's Water Quality Criteria. 1986 using a health risk factor of 10-6. EPA's water quality criteria identify concentrations of elements and compounds which have toxic effects on aquatic organisms or toxic and carcinogenic effects on humans.
If groundwater is being used as a drinking water source and alternative water supplies or point of use water treatment cannot be provided, then final or proposed secondary maximum contaminant levels (SMCLs) may be used as cleanup target levels. SMCLs are based on aesthetic properties such as taste and odor, whereas MCLs are based on human health risks. For compounds such as xylenes, the SMCL maybe several hundred times lower than the MCL.
Surface waters used for drinking water should also be cleaned up to levels not exceeding the final or proposed MCLs for organic and inorganic chemicals, as specified above. Under the authority of 18 AAC 70.020, surface waters important to the growth and propagation of aquatic life should be cleaned up to the listed criteria which includes EPA's Water Quality Criteria. 1986. These criteria identify concentrations of specific elements or compounds which have toxic effects on aquatic organisms. The group of compounds collectively identified as total petroleum hydrocarbons (TPH) should be cleaned up to non-detectable levels as measured by EPA Method 418.1.
Alternative Cleanup Levels (ACLs) may be adopted for a site if a risk assessment approved by the department is performed and cleanup to levels identified above is technically infeasible. Risk assessments will not by themselves establish ACLs. Determination of cleanup levels is a risk management decision that the department must make based on results of a quantitative risk assessment and other pertinent information.
The responsible party (RP) may prepare at its own expense a risk assessment which shall include an assessment of both human health and environmental risks. Specific components of the risk assessment should include an exposure assessment, toxicity assessment, risk characterization, and justification of ACLs. A general description of these risk assessment components is provided in Appendix II.
General technical requirements for risk assessments should be based on EPA risk assessment guidance for superfund sites. A site specific risk assessment procedure must be prepared by the RP and submitted to the department for review and approval prior to conducting a risk assessment. The RP, at the department's discretion, must agree to reimburse the department for expenses incurred by the department if it chooses to contract for a risk assessment review. |
Louis Howard |
| 3/13/1997 |
Update or Other Action |
Action 3/13/97, based on Relative Risk Evaluation worksheet dated 8/17/95. Drainage system is diverted to septic tank and leaching pits east of building. Soil and water contamination. Pathway: Site is gravelly with some boulders and sand. GW at about 65 feet with some contamination. No surface water/sediment nearby. Receptors: Industrial area on flight line with restricted access. |
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 |
| 7/24/1998 |
Update or Other Action |
6/98 Remedial Action report states groundwater contaminated with tetrachloroethene and trichloroethene will be remediated in 7 years. Remedy is operational and functional with ICs performing as planned. |
Louis Howard |
| 11/8/1999 |
Update or Other Action |
The location of a former 500-gallon UST (tank 31-338) that was primarily used to store JP-4 jet fuel waste from fuel truck maintenance activities. The UST was removed in August 92, and replaced with a 1,200-gallon UST (31-338A) in an adjacent location.
The depth to groundwater in well 49WL01 located approximately 150 feet south-southwest of the site, was measured at 13.59 feet below ground surface (bgs). The depth to groundwater in the bioventing vent well was measured at 11.53 feet bgs. Shallow groundwater is not currently used as a drinking water source and is unlikely to be used as one in the future. Contaminant of concerns (COCs) with initial contamination levels are as follows:
Initial Contamination Levels for Soil Water
Diesel Range Organics (DRO) 860 mg/kg 9,700 ug/l
Gasoline Range Organics (GRO) 3,600 mg/kg 9,700 ug/l 9 Benzene .033 mg/kg 740 ug/l
Toluene 1.3 mg/kg 35 ug/l
Ethylbenzene 4.9 mg/kg 95 ug/l
Total xylenes 80 mg/kg 1,300 ug/l
STATEMENT OF BASIS-This decision is based on the following attached references:
a. Site ST71 from SERA Phase I Corrective Action Plan (CAP), Final, Apr 95
b. Alaska Department of Environmental Conservation's (ADEC) 27 Feb 97 Ltr
c. Table 4-17, Basewide Annual Groundwater Report, Final, Mar 98 (49WL01)
d. Site Closure Report for Site ST71, Nov 96 (refer to your copy)
e. Table 5-8, Basewide Annual Groundwater Report, Final, Jun 99 (49WL01)
f. Table 2-4, Basewide Monitoring OU4-Round 1, Aug 99 (49WL01)
DESCRIPTION OF THE SELECTED REMEDY-No further remedial action remedy is based on the field sampling conducted on 28 May 96 pursuant to closure of site ST71 on base. All of the laboratory analytical results for vadose zone soil were below ADEC (1995) Category A soil cleanup levels for all analytical methods. These results indicate that petroleum hydrocarbons in the vadose zone soil at the site have been remediated to the applicable matrix cleanup levels during the operation of the bioventing system.
Monitoring well 49WL01 has been added to the OPERABLE UNIT (OU)4 monitoring program. With the exception of benzene concentrations in groundwater at down gradient well 49WL01 (14.9 ug/l), GRO (930 mg/kg at 49BH07-12 and 500 mg/kg at 49BH08-13), and DRO (1,600 mg/kg at 49BH07-12) concentrations in saturated soil samples, this site meets all applicable state cleanup goals. Contaminated soil below the watertable is not effectively remediated through bioventing.
The vadose zone soil was below ADEC (1995) Category A soil cleanup levels for all analytical methods. This has allowed the bioventing system at this site to be turned off in 1997 and will be removed in the future. The groundwater contamination is under the cleanup levels in Table C using the criteria outlined by 18 AAC 75.345 (b)(2)(A)&(B). In addition, the wetland remediation system constructed on the Ship Creek flood plain prevents ST71 contamination from leaving the base property boundary. Therefore, there is no further requirement for tracking conditions at ST71. Monitoring well 49WL01 has been added to the OPERABLE UNIT (OU)4 (Basewide) monitoring program.
If any information is presented in the future that indicates contamination from this project area is present (above established cleanup levels) and/or poses a risk to the public's health or the environment, then additional assessment and corrective action may be necessary. The location of this monitoring well is useful to track trends of trichloroethene (TCE), dichloroethene (DCE), and chloride concentrations in the outwash plain. The remedy of no further remedial action under the ERP is selected because the contaminant levels at the site present no significant threat to human health or the environment; thus, no treatment is necessary. |
Louis Howard |
| 8/28/2002 |
Meeting or Teleconference Held |
STATUS MEETING MINUTE ELMENDORF BASEWIDE MONITORING PROGRAM AUGUST 28, 2002 Attendees: Joe Williamson (USAF), Cindy Hood (AFCEE), Terry Beach (AFCEE), Kevin Oates (EPA), Louis Howard (ADEC), Cory Hinds (URS), Russ Beck(URS)
Agenda: Review of soil gas surveys and new well locations, Recommendation for treatment of TCE at OU5 Seeps 9, 10, and 11 in the existing Wetland Remediation System, Well sampling frequencies for 2003
2003 Monitoring Well Sampling Frequencies
URS presented the new proposed Basewide decision guide for determining sampling frequencies for monitoring wells. Proposed monitoring frequencies are based on position of plumes relative to environmental receptors. Plumes immediately upgradient of a receptor were proposed for annual sampling. Plume not immediately upgradient of a receptor were proposed for sampling every 2 to 5 years.
EPA pointed out that this guide is only appropriate for stable plumes and suggested that we add a box to include a decision for unstable plumes. Unstable plumes should be sampled semi-annually if upgradient of a receptor or within the early warning line in OU 5.
URS presented the new sampling frequency table, which is based on plumes rather than program areas. EPA and ADEC agree that it makes sense to organize on a plume-by-plume basis instead of by program area. The Air Force mentioned that there will be additional wells required for the early warning system at OU5, and that some of the early warning sampling will be conducted using passive diffusion bags. Use of the passive bags may mean that it is feasible to sample in the winter. EPA, ADEC, and URS agreed on modification of sampling frequencies. In general, sampling frequencies were increased when the plumes were close to a receptor (i.e., Ship Creek) or the concentrations of contaminants were increasing. A list of the agreed sampling frequencies is attached.
Additional items discussed:
• WP14: Air Force mentions reducing number of wells. ADEC mentions an early warning system. These will be discussed later.
• Air Force will investigate the floating product at OU4 West.
|
Louis Howard |
| 3/25/2005 |
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 OU 4 East Plume (includes IS-6 a.k.a. SD29) should focus on monitoring TCE and PCE concentrations. Monitoring activities should be performed to verify that TCE concentrations maintain a decreasing trend and that PCE concentrations also exhibit a decreasing trend over time. To optimize performance monitoring at this plume, it is recommended that the following evaluations be performed on the OU 4 East Plume:
Well replacement: As was noted in Section 4.7.2, well IS6-01 is damaged, no longer serviceable, and in need of a replacement. No more than one well is required to monitor this plume. It is recommended that a new well be installed within 5 feet of the current location of IS6-01.
COC monitoring: COC monitoring for this plume is currently performed at one in-source well, IS6-01. Modeling and network optimization activities are not currently recommended at this plume. When the new well is installed, network optimization should be performed by using the decision guides in Appendix H.
Contaminant mass calculations: Contaminant mass calculations cannot be determined at this plume with any high degree of accuracy because the OU 4 East Plume has been a one-well plume. It will remain a one-well plume when the replacement well is installed. Therefore, it is recommended that contaminant mass calculations not be performed at the OU 4 East Plume.
MNA monitoring: It is recommended that MNA monitoring at the OU4 East Plume be discontinued. MNA assessments cannot be accurately performed at one-well plumes.
Cleanup date predictions: The OU 4 ROD allows remedial activities to proceed at this plume until the predicted cleanup date of 2008. The linear regression trend line indicates TCE levels will be reduced to the cleanup level of 5 µg/L by this date. There is not enough data to establish a trend for PCE. It is recommended that a cleanup date be calculated for this plume by using SourceDK Tier 1 to check the accuracy of the date predicted by the linear regression trend line. Milestones should be established manually once this date is known.
Remedy protectiveness summary: MNA is the selected remedy at the OU4 East Plume. This remedy should be considered protective of human health and the environment. COC concentrations are decreasing; plume expansion is not occurring; and potential downgradient receptors are not being exposed to groundwater contaminants.
It is recommended that a replacement well be installed at this plume for COC monitoring and that MNA sampling be discontinued. In addition, a revised cleanup date for the OU 4 East Plume should 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 |
Update or Other Action |
The Alaska Department of Environmental Conservation (ADEC) received the 2004 RPO 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 |
| 3/6/2006 |
Document, Report, or Work plan Review - other |
Staff reviewed and commented on the 2005 draft Phase I RPO report. The text states if significant downgradient migration were to occur, the contaminants found at SD29 would be detected at downgradient sites. ADEC requests the text include reference to exactly which specific sites are downgradient of SD29 that are monitoring these same COCs. The OU 4 ROD identified TCE and PCE as the COCs in groundwater at SD29. Currently, these COCs are being monitored in the OU 4 East Plume.
|
Louis Howard |
| 2/26/2007 |
Exposure Tracking Model Ranking |
|
Louis Howard |
| 3/7/2008 |
Update or Other Action |
Zone 2 Remedial Process Optimization Report received. The current remedies for Site SD29 of LUCs and MNA remain protective. The monitoring well network in place at SD29 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 4 ROD; exposure assumptions, toxicity
data, cleanup levels, and RAOs used at the time of the remedy selection are still valid.
Monitoring data show that TCE concentrations remain above the ROD-specified cleanup level of 5 µg/L (USAF, 1995a). Monitoring of this site is ongoing in accordance with the ROD, 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 (USAF, 2003c).
The recommendations for the SD29 plume are as follows:
Short-Term (FY08-FY09)
• Continue monitoring per Figure 1.4.
Long-Term (FY10 or Longer)
• Start dialogue with regulators regarding NFA determination.
• Abandon existing monitoring wells.
• No action.
• Complete minor site letter or ESD documenting NFA determination. |
Louis Howard |
| 10/15/2008 |
Update or Other Action |
5 YR Review
OU4 consists of 10 source areas including maintenance facilities, a fire training area, and an asphalt drum storage/processing area. During 1993 and 1994, asphalt and asphalt-containing soils at SS10 were removed. The ROD focused on monitoring to assess contaminant migration and natural attenuation progress and LUCs to attain cleanup levels in shallow groundwater, and
shallow soils and in-situ bioventing to treat deep soils. Soils are monitored to evaluate migration and timely reduction of contaminants by the remedy. A memorandum to the site file established a decision guide for monitoring well sampling frequency in 2003. At SS10, cleanup goals were met, the bioventing system was shut down and the site was closed in 2006.
LUCs (at all active sites), groundwater monitoring and natural attenuation (FT23, SD24, SD25, and SD29), and bioventing (FT23) efforts are ongoing. Soil sampling is conducted at the remaining bioventing site (FT23) as required in preparation for closure.
COC concentrations are decreasing in groundwater at FT23, SD24 and SD29, and trend analysis predicts that concentrations will reach cleanup levels by 2009 (USAF, 2008a). This is only one year beyond the ROD-estimated end date of 2008, and indicates that the natural attenuation remedies at these sites are operating successfully.
SD28 well IS5-01 was last sampled in 1993, and concentrations of the COCs TCE and PCE were below cleanup levels. COC concentrations in nearby wells OU4-E1 (upgradient of SD28) and OU4-E3 (downgradient of SD28 and SD29) were similarly below cleanup levels. Well OU4-E3 was last monitored in 2002.
Recommendations
Because groundwater at SD24 and SD29 is expected to meet cleanup levels by 2009, increase monitoring frequency from once every five years to annually in accordance with the monitoring frequency decision guide (Attachment F, Figure F-1). This will document attainment of cleanup levels and expedite closure of these sites.
Site Inspection
OU4 (SD24, SD25, SD28 and SD29). All active monitoring wells were located and were in good condition. There are no active monitoring wells for SD28. There was no evidence of unauthorized wells or site disturbance.
Recommendations/Follow-up Actions
Increase monitoring frequency of wells OU4MW-04 and IS6-01 to annually to document attainment of cleanup levels and expedite closure of these sites.
The remedy at OU4 is expected to be protective of human health and the environment upon attainment of soil cleanup levels through bioventing at one remaining site (FT23) and attainment of groundwater cleanup levels through natural attenuation at sites FT23, SD24, SD25 and SD29. In the interim, exposure pathways that could result in unacceptable risks are being controlled. |
Louis Howard |
| 3/17/2009 |
Update or Other Action |
Cover letter to the EPA's Five-Year Review signature sheet sent to Richard J. Walberg, Colonel, US Air Force Vice-Commander from EPA Region 10 Office of Environmental Cleanup Daniel D. Opalski, Director. The Environmental Protection Agency (EPA) has completed their review of the third Five-Year Review report for the United States Air Force (USAF) Elmendorf Superfund site, in Anchorage Alaska.
EPA reviewed this report for technical adequacy, accuracy, and consistency with EPA guidance. In general, EPA agrees with the protectiveness determinations in this report. However, I understand that all parties to the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) Section 120 Federal Facility Agreement (FFA) are aware of a potential new source that has not been fully characterized, namely SS-022. It is also my understanding that while the Five-Year Review identifies this potential new source, the USAF has not adequately discussed the interim measures it has already taken to ensure protectiveness as site characterization proceeds, such as Institutional Controls (ICs) at SS-022 and the ongoing Remedial Investigation.
Therefore, we recommend that within ninety (90) days (by June 15, 2009), USAF supplement the Site File and Administrative Record with a Memorandum to document the ICs (e.g., installation of a fence, signage, and notation on the Environmental Restoration Program Atlas) that have been implemented for the protection of human health and the environment at SS-022. The Memorandum should also mention the Installation-wide ICs (including restriction of ground water use) already in place.
In addition, EPA agrees with USAF's recommendation for further action at the OU-l landfill area for the trichloroethylene (TCE) groundwater contamination, and requests that the Program Managers meet to discuss the timeline for completion of the groundwater contamination characterization and establish deadlines and, as appropriate, target dates for subtasks, as required under the FFA.
|
Louis Howard |
| 4/14/2010 |
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 SD29 as a Green priority site because the remedy was on track to reach the specified cleanup level by 2009 (USAF, 2008). The PCE concentration was below the 5 µg/L cleanup level in 2009, and the TCE concentration was only slightly above the cleanup level (Figure 7.2). TCE concentrations exhibit an overall decreasing trend with a relatively high correlation coefficient (R2 = 0.87). Therefore, the Green priority designation for SD29 remains appropriate. |
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 of concem (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 cleanu levels in the annual re orts and will discuss in subsequent 5-Year Reviews. The benefit ofthis 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 |
| 8/9/2010 |
Document, Report, or Work plan Review - other |
Staff reviewed and commented on the 2010 Environmental Compliance Work Plan Elmendorf Air Force Base, July 2010.
14.11 Worksheet #14K – Building 16716 Sampling Tasks Page 14-15
The text states: “Analytical samples will be collected from the locations with the highest PetroFLAG screening result.” See comment at Section 14.5 regarding the minimum required number of soil samples if field screening is negative or below a preset limit.
Worksheet #15 – Reference Limits and Evaluation Table Pages 15-5 to 15-9
ADEC requests the Air Force correct the table’s Project Action Limits to reflect current cleanup levels in 18 AAC 75.
DRO in the table was taken from “Over 40 Inch Zone” and the correct cleanup level (Project Action Limit) in soil is 250 mg/kg for migration to groundwater in the “Under 40 Inch Zone”. RRO in the table was taken from the “Over 40 Inch Zone” and the correct cleanup level (Project Action Limit) is 10,000 mg/kg for ingestion in the “Under 40 Inch Zone”.
1,1,1,2-Tetrachloroethane CAS # for this is 630-20-6 not 71-55-6 which is 1,1,1-Trichloroethane. 1,1,1,2-Tetrachloroethane does not have a Method Two cleanup level so ADEC requests the Air Force use the EPA’s "Regional Screening Levels for Chemical Contaminants at Superfund Sites" screening level/preliminary remediation goals (residential soil) at http://www.epa.gov/reg3hwmd/risk/human/rb-concentration_table/index.htm
The project action limit for 1,1,1-Trichloroethane CAS # 71-55-6 is 0.82 mg/kg or 820 ug/kg (Migration to Groundwater Table B1).
The project action limit for 1,1,2,2-Tetrachloroethane CAS # 79-34-5 is 0.17 mg/kg or 170 ug/kg (Migration to Groundwater Table B1) not 1.7 ug/kg.
The following do not have a Method Two cleanup level so ADEC requests the Air Force use the EPA’s "Regional Screening Levels for Chemical Contaminants at Superfund Sites" screening level/preliminary remediation goals (residential soil) at http://www.epa.gov/reg3hwmd/risk/human/rb-concentration_table/index.htm
1,1-Dichloropropene CAS # 563-58-6
1,2,3-Trichlorobenzene CAS # 87-61-6
1,2-Dibromo-3-Chloropropane CAS # 96-12-8
1,3-Dichloropropane CAS # 142-28-9
2,2-Dichloropropane CAS # 594-20-7
2-Chlorotoluene CAS # 95-49-8
2-Hexanone CAS # 591-78-6
4-Chlorotoluene CAS # 106-43-4
4-Isopropyltoluene CAS # 99-87-6
Bromobenzene CAS # 108-86-1
Chlorobromomethane CAS # 74-97-5
It appears the project action level in ug/kg is off by an order of magnitude when compared to Table B1 Method Two most stringent cleanup levels. Please correct table to reflect the proper cleanup level. |
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.
A groundwater sample was collected from well IS6-01 on 16 June 2010. The sample was submitted to a fixed-base laboratory for analysis of VOCs. The TCE concentration measured in the sample from IS6-01 in 2009 (5.1 µg/L) slightly exceeded the groundwater cleanup level of 5 µg/L.
Biogeochemical indicator parameters measured in samples from IS6-01 using field methods indicate an aerobic environment (Table 1.3). The range of individual parameter values and the corresponding interpretation of the active electron acceptor processes for 2010 are consistent with findings from previous monitoring events, indicating that the dominant contaminant degradation processes are not changing over time. PCE and TCE do not readily degrade under aerobic conditions, which means that attainment of cleanup goals at this site will occur due to other natural attenuation mechanisms including dispersion, adsorption, and dilution.
The 2007 RPO evaluation identified Site SD29 as a Green priority site because the remedy was on track to reach the specified cleanup level by 2009 (USAF, 2008). The PCE concentration at well IS6-01 was below the 5 µg/L cleanup level in 2009 and 2010. The TCE concentration at IS6-01 (5.1 µg/L) was slightly above the cleanup level of 5 µg/L in 2010 (Figure 7.2). TCE concentrations exhibit an overall decreasing trend with a relatively high correlation coefficient (R2 = 0.90). Therefore, the Green priority designation for SD29 remains appropriate. |
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.
Groundwater - Restrict access to the contaminated groundwater throughout OU 4 until cleanup levels have been achieved. OU4 is designated "Airfield Use Area" for aircraft operations and maintenance, to include active and inactive runways, taxiways, and parking aprons for aircraft.
Soil- Institutional controls on land use (also called LUCs) will continue to restrict access to the contaminated shallow soils throughout OU 4 until cleanup levels have been achieved.
Evaluation - A land use control inspection was performed and land use controls are in place and continue to be effective at SD29.
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 proj ects 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 |
| 3/16/2011 |
Update or Other Action |
Draft Annual Report Monitoring of Compliance Restoration Program Sites received. Groundwater monitoring well 16716MW-IN was sampled. The sample was analyzed by an analytical laboratory for DRO. DRO was detected in the sample with a concentration below the cleanup level. Soil samples were also collected for this site in 2010. Soil samples were collected by a separate contractor and results are being provided in a separate report. Conclusions and recommendations for this site are provided in a closure sampling report prepared under separate cover. |
Louis Howard |
| 5/2/2011 |
Update or Other Action |
Staff received the 2010 Closure Sampling Summary Report Compliance Program Sites ST410, ST509, ST532, and Building 16716 JBER-Elmendorf, Alaska. This report presents the results of closure soil samples collected in 2010 at sites ST410, ST509, ST532, and Building 16716. In addition, the report summarizes previous sampling activities conducted at each site to support a closure determination.
The purpose of this project was to advance and sample one soil boring at each site (ST410,
ST509, ST532, and Building 16716) and evaluate the analytical results against the Alaska
Administrative Code (AAC), Title 18, Chapter 75, Method Two criteria (ADEC 2008) to
assess whether cleanup is complete. Annual compliance monitoring of groundwater quality
from 2006 to 2009 has indicated no contaminants remain above the ADEC cleanup levels in
groundwater at these sites; therefore, only soil samples were collected in September 2010 and
analyzed as recommended in the 2009 Annual Report: Monitoring of Compliance Program
Sites.
Building 16716 is located on Talley Avenue, north of the east/west runway (Figure 6-1). DRO
was released from leaks that occurred while filling the 20,000-gallon underground heating oil tank (HOT) located just outside the boiler room. During the UST removal in 2003, 225 tons of contaminated soil were also removed.
In September 2010, sampling was conducted at Building 16716 to determine if remediation
was complete. Soil samples were analyzed for the previously detected constituent (DRO), as
well as GRO, RRO, VOCs, BTEX, and PAHs.
Soil boring BLD16716-BH01 was drilled to 54 feet bgs (Figure 6-1) in the source area and
sampled in accordance with the Work Plan (USAF 2010a). PetroFLAG® screening samples
were collected and analyzed every 5 feet. Three analytical soil samples were collected from
the boring: one from the upper 10 feet bgs (0 to 5 feet bgs), one from a depth between the
surface and the water table (40 to 45 feet bgs), and one at or near the water table (50 to 54 feet bgs). The analytical sample from the interval between the surface and the water table was
collected from the location with the highest PetroFLAG® screening result.
In 2003, the sources of contamination, including the UST and contaminated soil associated
with the UST, were removed and soil samples were collected to determine if all
contamination had been removed; DRO was detected above the cleanup level on the west end
of the excavation area.
Monitored natural attenuation was the final remedy of choice for Building 16716. Groundwater was monitored annually from 2006 to 2009 and samples were analyzed for DRO; no sample results exceeded ADEC cleanup level. As recommended in the 2009 Annual Report Monitoring of Compliance Program Sites (USAF 2010b), soil samples from a single boring advanced to groundwater were analyzed for all COPCs in 2010 to determine if cleanup was complete.
All parameters were nondetect or below the ADEC cleanup levels. Because the most recent groundwater and soil sampling events revealed no contaminants above the ADEC cleanup levels, Building 16716 is recommended for cleanup complete status.In 2003, the sources of contamination, including the UST and contaminated soil associated with the UST, were removed and soil samples were collected to determine if all contamination had been removed; DRO was detected above the cleanup level on the west end of the excavation area.
Monitored natural attenuation was the final remedy of choice for Building 16716. Groundwater was monitored annually from 2006 to 2009 and samples were analyzed for DRO; no sample results exceeded ADEC cleanup level.
As recommended in the 2009 Annual Report Monitoring of Compliance Program Sites (USAF 2010b), soil samples from a single boring advanced to groundwater were analyzed for all COPCs in 2010 to determine if cleanup was complete. All parameters were nondetect or below the ADEC cleanup levels. Because the most recent groundwater and soil sampling events revealed no contaminants above the ADEC cleanup levels, Building 16716 is recommended for "cleanup complete" status. |
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 SD29 consists of one plume (OU4 East Plume) located between Taxiway F and Talley Way.
Hangar 15, which is located east of the plume, was used for aircraft maintenance. Probable
sources of contamination for the OU4 East Plume include a dry well, leach fields, pipelines, and
valve pits east of Hangar 15. Site SD29 was investigated and a remedy implemented as part of
the OU4 cleanup. A ROD was signed for OU4 in 1995. No COCs were identified for soil; the
COCs in groundwater at Site SD29 include PCE and TCE. Currently, one groundwater
monitoring well (IS6-01) is located at the site.
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 |
| 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.
OU4:
Site SD29
Groundwater - Restrict access to the contaminated groundwater throughout OU 4 until cleanup levels have been achieved. OU4 is designated "Airfield Use Area" for aircraft operations and maintalance, to include active and inactive runways, taxiways, and parking aprons for aircraft.
Soil- Institutional controls on land use (also called LUCs) will continue to restrict access
to the contaminated shallow soils throughout OU 4 until cleanup levels have been achieved.
Evaluation - LUCs are in place and continue to be effective at SD29. 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 from 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 2011 Annual Monitoring report received for Zones 1, 2, & 3.
Currently there are ten active sites within the Zone 2 Management Area: FT23, SD15, SD24, SD25, SD28, SD29, SS43, ST32, ST48, and ST68. Impacted media at the Zone 2 Management Area sites includes soil and groundwater. COCs identified for Zone 2 sites include fuel constituents and chlorinated solvents.
A groundwater sample was collected from well IS6-01 on 16 September 2011. The TCE concentration measured in the sample from IS6-01 in 2011 (5.8 µg/L) slightly exceeded the groundwater cleanup level of 5 µg/L. The PCE concentration measured in the sample (4.4 µg/L) was slightly below the groundwater cleanup level of 5 µg/L.
The 2007 RPO evaluation identified Site SD29 as a Green priority 4027 site because the
remedy was on track to reach the specified cleanup level by 2009 (USAF, 2008g). The PCE concentration at well IS6-01 has been below the 5 µg/L cleanup level since 2009. The TCE concentration at IS6-01 remains slightly above the cleanup level of 5 µg/L (Figure 3.14). TCE concentrations exhibit an overall decreasing trend with a relatively high R "squared" (0.917). Therefore, the Green priority designation for SD29 remains appropriate.
|
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.
Groundwater - Restrict access to the contaminated groundwater throughout OU 4 until cleanup levels have been achieved. OU4 is designated "Airfield Use Area" for aircraft operations and maintenance, to include active and inactive runways, taxiways, and parking aprons for aircraft.
Soil - Institutional controls on land use (also called LUCs) will continue to restrict access
to the contaminated shallow soils throughout OU 4 until cleanup levels have been achieved.
Evaluation -Inspection conducted on 30 Aug 12 and LUCs are in place and continue to be effective at SD29. |
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, groundwater monitoring well IS6-01 was sampled for VOCs only. TCE (5.3 µg/L)
exceeded the OU4 ROD cleanup criterion but was lower than the 2011 result. PCE was below
OU4 ROD cleanup criterion. Results for all other analytes were below cleanup criteria. Table 11-
1 presents a summary of the results. Historic results are presented on Figure 11-1.
A LUC inspection performed at SD029 on 30 August 2012 did not identify any issues at the site.
Site Summary
Based on the 2012 groundwater analytical data the PCE concentration at well IS6-01 has
continued to be below the 5 µg/L cleanup level since 2009. The TCE concentration at IS6-01
remains slightly above the cleanup level, but concentrations exhibit an overall decreasing trend
based on an analysis preformed in 2012. TCE levels are anticipated to continue decreasing and
reach the cleanup level.
Continued groundwater monitoring is proposed for this site until COCs remain below OU4 ROD
cleanup criteria for two consecutive events. 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.
11.4 SD029 Site Summary
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 |
| 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 SD029 on 25 September 2013 and did not identify any issues at the site. The PCE concentrations at well IS6-01 have been below the OU4 ROD cleanup level in annual sampling since 2009. The TCE concentration was below OU4 ROD cleanup level for the first
time in 2013. Continued annual groundwater monitoring is proposed at well IS6-01 for this site
until both COCs remain below OU4 ROD cleanup criteria for two consecutive events, anticipated to occur during the 2014 sampling event. |
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 and and dig permits issued within the last 12 months. The Site Inspection Checklist should refer reader to photo 42 for SD029 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 |
Louis Howard |
| 11/5/2014 |
Document, Report, or Work plan Review - other |
EPA provided comments on the draft CERCLA Report.
Comment: It would be useful to discuss the proximity of SD029 to the F22 Weapons Release Shop (SS109).
Comment: OU4 ROD Table 4-1 lists 14 COCs in groundwater. Table 5-2 defines TCE and PCE are specific to Hangar 15/Bldg 43-410. Please clarify the suite of COCs
Comment: Soils at this site were not contaminated. Do IC restrictions at this site include soils? Please correct if necessary.
Comment: Groundwater statistics will be necessary to determine closure, not just two samples below cleanup levels. EPA guidance (2014) suggests attainment will be determined when a minimum of 8 data points result in a mean GW concentration below the 95% UCL.
Comment: Why were 2012 data omitted from Figure 11-1? Results from 8/30/12 were TCE 5.3; PCE 3.6. |
Louis Howard |
| 7/23/2015 |
Update or Other Action |
Draft Annual Field Activities Report received for review and comment.
SITE SUMMARY AND RECOMMENDATIONS
The PCE concentrations at well IS6-01 have been below the OU4 ROD cleanup level in annual
sampling since 2009. The TCE concentration was below OU4 ROD cleanup level for the first
time in 2013, but exceeded the cleanup level in 2014. Continued annual groundwater monitoring
is proposed at well IS6-01 for this site until both COCs remain below OU4 ROD cleanup levels
for two consecutive events.
Five-Year Review
Areas in OU 4 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 SD029 documented during the first or second five-year review period.
The third five-year review report recommended increasing the monitoring of well IS6-01 to annually to document the attainment of cleanup levels. The fourth five-year review report recommended that a sampling event be conducted to identify if concentrations of 1,4-dioxane exist and determine whether or not there is an unacceptable risk at the site.
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
The 2007 RPO evaluation identified Site SD029 as a Green priority site because the remedy was
on track to reach the specified cleanup level by 2009. The PCE concentration at well IS6-01 has been below the 5 µg/L cleanup level since 2009. The TCE concentration at IS6-01 remains slightly above the cleanup level of 5 µg/L. TCE concentrations exhibit an overall decreasing trend with a relatively high R2 (0.917). Therefore, the Green priority designation for SD029 remains appropriate.
Per the March 3, 2015 meeting with AFCEC, ADEC, EPA, and WESTON the sample frequency for SD029 may be increased to quarterly events in support of evaluating groundwater concentrations statistically. If the first 2015 quarterly sample shows an increase in concentration above the last analytical sample result, then the sample frequency will remain annual for this site. If the first quarterly sample for 2015 shows a decrease in concentration below the last analytical sample result, then quarterly sampling will continue. |
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 sample groundwater for 1,4-dioxane associated with TCE contamination. |
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.
The 2007, RPO evaluation identified Site SD029 as a Green priority site because the remedy was
on track to reach the specified cleanup level by 2009 (USAF, 2008b). The TCE and PCE
concentrations in groundwater from IS6-01 remain slightly above cleanup goals. TCE concentrations exhibit an overall decreasing trend with a relatively high R2 value (0.96). Therefore, the Green priority designation for SD029 remains appropriate. It is recommended to continue groundwater monitoring at IS6-01 for this site until both COCs are measured below OU4 ROD cleanup goals. In addition, it is recommended to continue LUC inspections until the site is cleanup complete
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: The parking area on the south side of Building 16716 was under construction with paving activities and utility installation. The old parking area was demolished and the entire ground surface has been disturbed. A new bolt was placed on well 1S6-01. One bolt hole is stripped out, but the outer casing is secure with one bolt.
See site file for additional information. |
Louis Howard |
| 1/8/2018 |
Document, Report, or Work plan Review - other |
Draft Vapor Intrusion study received for review and comment.
Main comments were to have statements made regarding the purpose of the sampling which was to help address the Operable Unit 4 protectiveness deferred statements in the Fourth Five-Year Review.
See site file for additional information. |
Louis Howard |
| 2/9/2018 |
Document, Report, or Work plan Review - other |
Staff commented on the draft annual report for CERCLA sites. Main comment was on TCE in groundwater which has a range of detections from 8.38 to 8.71 ug/L. The revised 18 AAC 75 Table C cleanup level of 2.8 µg/L (November 7, 2017) is more stringent than 5 µg/L listed in the 1995 OU4 ROD. Please evaluate any changes to cumulative risk as a result of this more conservative cleanup level and any impacts to remedy protectiveness during the next Five Year Review. This comment applies to all source areas with this contaminant in groundwater above current cleanup levels. |
Louis Howard |
| 1/15/2019 |
Update or Other Action |
Draft 5 Year Review received for comment which include Operable Unit 4 Source Area SD029. Cancer risks exceed 1 x 10-4 or have an HQ greater than 1 for the following
chemicals in soil: cyanide, naphthalene, and total xylenes.
Recommendation: Investigate, by conducting a sampling event, the following
chemicals for potential inclusion as remedy COCs: cyanide, naphthalene, and
total xylenes. Soil sampling should be conducted to assess current concentrations.
Document any changes to COCs in a decision document.
Limited natural attenuation of COCs in groundwater is occurring at the site, and RAOs were not be achieved within the projected time frame. Recommendation: Conduct additional studies to optimize the approach to achieve remediation goals . Other studies may include, but are not limited to: site characterization, ecological assessment, focused feasibility studies, groundwater modeling, treatability studies, and/or sampling.
|
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 to continue annual sampling and analyses for COCs and LUC inspections is recommended until the results of two successive sampling events are below cleanup goals. ADEC does not recognize the use of statistics by EPA or the Air Force to demonstrate that cleanup levels for groundwater are met. Compliance will be based on the maximum concentrations of a hazardous substance detected in groundwater.
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 |
| 1/18/2024 |
Document, Report, or Work plan Review - other |
DEC provided comments regarding the SD029 – Building 16716 Floor Drains Supplemental Remedial Investigation/ Feasibility Study Management Plan Draft, dated November 2023. The work plan describes the proposed methods for the sampling and analysis of volatile organic compounds (VOCs) in soil, gas, and water samples surrounding building 16716, located on the Joint Base Elmendorf- Richardson (JBER), Anchorage, Alaska. Additionally, a human health risk assessment is included in the scope of work for this investigation. The primary screening levels for the proposed work are EPA RSLs for residential soil, residential tapwater, and commercial indoor air with a target risk of 1×10-6, and a Hazard Quotient of 0.1. |
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 |
| 5/1/2024 |
Document, Report, or Work plan Review - other |
DEC provided responses to comments regarding the SD029 – Building 16716 Floor Drains Supplemental Remedial Investigation/ Feasibility Study Management Plan Draft, dated November 2023. |
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 |
| 8/1/2024 |
Document, Report, or Work plan Review - other |
DEC approved the SD029 – Building 16716 Floor Drains Supplemental Remedial Investigation/ Feasibility Study Management Plan Final, dated July 2024. The work plan describes the proposed methods for the sampling and analysis of volatile organic compounds (VOCs) in soil, gas, and water samples surrounding building 16716, located on the Joint Base Elmendorf- Richardson (JBER), Anchorage, Alaska. Additionally, a human health risk assessment is included in the scope of work for this investigation. The primary screening levels for the proposed work are EPA RSLs for residential soil, residential tapwater, and commercial indoor air with a target risk of 1×10-6, and a Hazard Quotient of 0.1. |
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 71613 Surface release. |
Ginna Quesada |
