| Action Date |
Action |
Description |
DEC Staff |
| 9/30/1983 |
Update or Other Action |
Engineering-Science reviewed records on file at the Bioenvironmental Engineering Office and interviewed shop personnel to determine the types of hazardous materials, waste quantities, and disposal methods. Drain outfalls were consequently identified as potential sources of environmental contamination because of the nature of compounds thought to have been discharged down floor drains in the building. Records show that from 1970 through 1983, approximately 200 gallons per year of *PD680 (stoddard solvent) have been discharged to floor drains and a dry well.
Source SD31 were considered to have a moderate and low potential for environmental contamination respectively.
*NOTE: Each item the Govt. orders must have an N.S.N, a National Stock Number, unless the Agency gets special permission to local purchase the item. Each N.S.N. item goes out for bid and has an
associated minimum specification. The specification for PD680, aka. Stoddard Solvent, back in the 1980's and before was for a petroleum based degreaser with a specified flashpoint. No
requirement for non-halogenated existed. Besides that, because Alaska was so far from venders that supplied the Govt., many federal agencies in Alaska purchased solvents locally. There were no qualifications on those solvents and most often halogenated solvents worked with less effort than pure petroleum distillates, so they were preferred.
NSNs ordered through the PD680 specs had some batches with TCE, Methylene chloride, etc; it depended on who the supplier to the Govt.was at the time. So as a result between 1980 and 1983,
some PD680 batches were in fact halogenated. For historical releases it pays to be aware that chlorinated solvents may be associated with releases from PD680 or Stoddard Solvent.
|
Louis Howard |
| 8/2/1988 |
Update or Other Action |
Operable Units' source areas that correspond to RCRA SWMUs from the RCRA RFA. SD30 IS-8 Bldg. 32-060 Floor Drain. This site is used as the aerial delivery facility and is used to wash off equipment. - 55 gal of PD-680/3 months.
Recommended Actions for sites IS-1 - IS-8, Building floor drains : A plan will describe in t he RFI work plan to determine the presence of plume(s) of contamination resulting from the operation of the floor drains and the extent of soil and GW impact from the operations. This study will include a geophysical survey to be conducted in the area surrounding each of the subject bldg. to determine surrounding each of the subject building to determine the location of the dry well. In addition, soil and GW monitoring wells will be sampled and analyzed to delineate the extent of contamination. Field permeability tests must also be performed to determine the chactotistics of the uppermost aquifer. |
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 |
| 12/29/1989 |
Document, Report, or Work plan Review - other |
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 Elmendorf Air Force Base, October 1989.
SITE IS-8
Paragraph 5.2.2.13 states that the floordrains are incorporated into dry wells as part of the drain system. The Department requests the floordrain system be upgraded to abandon the
floordrains and meet Alaska water quality discharge regulations and permit requirements. |
Ron Klein |
| 12/30/1989 |
Site Added to Database |
Petroleum contaminants in soils, chlorinated and petroleum Contaminants of Concern (COCs) in groundwater (GW). |
Louis Howard |
| 1/31/1990 |
Update or Other Action |
In 1988, Black & Veatch placed a soil boring, collected soil samples at 20 and 25 ft. bgs, and finished the boring as a monitoring well (IS8-01). Black & Veatch then collected a water sample from the monitoring well. One groundwater sample collected was found to have TPH at 2.0 mg/L and TCE at 6.8 ug/L. A sheen and odor was found on the sample, which exceeds Alaska drinking water criteria. Manganese exceeded the secondary drinking water standards.
A ground penetrating radar (GPR) survey was conducted at Source SD31 to determine the location of any dry wells. This survey concluded that one (1) dry well was located underneath the building near the west wall. Four geophysical anomalies were encountered during this survey: one pipe exit that terminated at a structure, two pipe exits that terminated a short distance from bldg. 32-060, and one isolated structure. |
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.
SD31 (formerly IS-8) Bldg. 32-060 Floor Drain. This site is used as the aerial delivery facility and is used to wash off equipment. 55 gallons of PD-680 every three months is used. Recommended action-A plan will describe in the RFI work plan to determine the presence of plume(s) of contamination resulting from the operation of the floor drains and the extent of soil and groundwater impact from the operations.
This study will include a geophysical survey to be conducted in the area surrounding each of the subject bldgs. to determine the location of the dry well. In addition soil and groundwater monitoring wells will be sampled and analyzed to delineate the extent of contamination. Field permeability tests must also be performed to determine the characteristics of the uppermost aquifer.
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 |
| 7/20/1992 |
Interim Removal Action Approved |
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.
UST void area discovered during the LFI; void may dry well or septic tank. Sludge in void area sampled and contamination above action levels reported. USAF is planning to do a Removal Action of sludge and possible backfill with gravel or other material in void due to safety hazard (heavy equipment use area). USAF may remove sludge from all three IRA dry well locations (SD24, SD28, SD31). Consensus for SD31: IRA. Potential IRA Alternatives: 1. No Action 2. Remove sludge, void structure and obvious "hot spots" contaminated soil and disposal. 3. Removal sludge, void structure, "hot spots", disposal, and construct surface cap.
Need to assume quantity of sludge and soil in order to do cost analysis. For IRA planning for all 3 dry wells with contents for removal, reference existing contamination in dry wells which may or may not include all sludge present at the time of the Limited Field Investigation. |
Jennifer Roberts |
| 9/16/1992 |
Update or Other Action |
USAF letter to Jennifer Roberts regarding "Revisions to Elmendorf AFB Federal Facility Agreement (FFA) Scope of Work for Operable Units (OU) 4 and 7." As a result of the 1992 field investigation, the USAF requests to move SD31 from OU4 to OU3. Geographically, SD31 is more closely aligned with the sources in OU3. Delete the requirement of an interim remedial action (IRA) at OU4. Based on the LFI, the remedial project managers identified the dry wells at SD24, SD28, and SD31 as potential IRAs. However, further review of the results of the LFI, indicate only the sludge at the bottom of the dry well at these sources were sampled and no soil samples were obtained. At this time there is no evidence of soil contamination in the immediate vicinity of the dry wells. Without additional investigation of these wells, it does not appear an IRA is warranted. Instead of an IRA, we will pursue funding to remove the sludge in each dry well. ADEC project manager Jennifer Roberts signed document to show its concurrence. |
Jennifer Roberts |
| 11/30/1992 |
Update or Other Action |
Disposition of Source SD31: None of the IRA selection criteria were met at source sampling locations SBSD31D or SBSD31B. Subsequently, NFA is recommended for these two locations.
At sampling location SBSD31A, the risk based criteria for diesel range organics (DRO) and gasoline range organics (GRO) were exceeded and all other IRA selection criteria were met. DRO at sampling location SBSD31A12 was 1,800 mg/kg, GRO was 440 mg/kg and 320 mg/kg. Comparision criteria exceeded = AK POL Guidelines-100 mg/kg GRO and 200 mg/kg DRO. Therefore, an IRA should be recommended for this location, but since the USAF has requested that Attachment I to the FFA be modified to remove the requirement to implement IRAs, no IRAs will be implemented at OU4 source areas. A removal action will be implemented at this location, and after the material from this dry well has been removed and disposed of, additional RI activities will be conducted to determine if the contaminated sludges found at this location have affected adjacent soils.
During the LFI, few other potential contaminant source areas were identified in the vicinity of Source SD31 that would be upgradient of monitoring well IS8-01. The most probable sources of groundwater contamination identified were those associated with OU 3. According to information presented in the Basewide Investigation work plan, waste solvents were disposed of at Source area SD 16. Volatile organic compounds have been detected in groundwater at SD 16, and solvents have been identified in groundwater samples collected from monitoring well IS8-01, which is downgradient of Source Area SD 16.
The USAF has requested that EPA and ADEC revise Attachement 1 to the FFA and transfer Source Area SD31 from OU 4 to OU 3. This change has been requested because SD31 is closer to the facilities within OU 3. |
Louis Howard |
| 6/30/1993 |
Update or Other Action |
A dry well located on the northeast side of building 32-060/Hangar 5 was removed during the summer of 1993. The area surrounding the dry well was excavated and the impacted soil removed. |
John Halverson |
| 7/16/1993 |
Update or Other Action |
RI/FS Mgt. Plan for OU 3 provided per paragraph 20.5(b) of the FFA between the AF, ADEC and EPA. Summary of data gaps and deficiencies relevant to the characterization of Source SD31 has been compiled based on work conducted during previous investigations. The groundwater flow direction and gradient should be verified at the site specific level to allow for adequate positioning of downgradient wells. Locations for downgradient wells should not be selected on the basis of inferred groundwater gradient. The fate of PD680 usage and spills and the potential for off-source migration has not been adequately characterized. The name P-D-680 is actually a form of military "slang" and is derived from the Federal Specification designation that governs its procurement. Throughout industry, it is more commonly referred to as stoddard solvent, dry cleaning safety solvent, naphtha safety solvent, or mineral spirits. A clear liquid with a kerosene-like odor, it is mixture of hydrocarbons that is derived through the refinement of crude oil. Because it is a petroleum solvent, P-D-680 is very efficient at dissolving and removing most greases and oils from metal and plastic parts. Federal Specification P-D-680B, "Dry Cleaning and Degreasing Solvent," identifies three general types of the solvent that are classified according to their flash point [in degrees Fahrenheit (oF)]: Type I > 1000F Type II > 1400F Type III > 2000F In addition to these three general types of P-D-680, there are also Types IA and IIA which are low residue derivations of Types I and II respectively.
Hydraulic conductivity estimates developed from regional aquifer tests have been used to characterize the site hydrogeologically, instead of source-specific measured values. The vertical and horizontal extent of soil and groundwater contamination has not been fully delineated. Recoverable metals detected in groundwater which exceeded federal/state action levels have not been discussed. |
Jennifer Roberts |
| 8/30/1993 |
Meeting or Teleconference Held |
Unit 3 (OU 3) Management Plan to more adequately characterize contamination at possible source areas within the operable unit and to fill existing "data gaps" in the base-wide groundwater monitoring program. The changes summarized below were agreed upon by base personnel (Ms. Lisa Morris), AFCEE representatives, the United States Environmental Protection Agency (Ms. Marcia Combs), and the Alaska Department of Environmental Conservation (Ms. Jennifer Roberts and Mr. John Halverson).
The OU 3 Management Plan proposed that reflection seismic be used at OU 3 to determine the lateral and vertical extent of the Bootlegger Cove Clay Formation. In order to fully characterize the clay interval, reflection as well as refraction techniques were used at sites across the operable unit. Two existing groundwater monitoring wells were scheduled to be abandoned (W-11 and W-
12). Well W-ll was abandoned in July; however, Well W-12 could not be located and therefore was not abandoned.
The locations of hydropunch borings were modified so that groundwater could be investigate on an "operable unit-wide" basis rather than a "source area" basis. The locations of
groundwater monitoring wells were modified based on data acquired from the hydropunch investigation and to provide groundwater level information in areas of the base with limited
groundwater data.
The OU 3 Management Plan stated that 3 base supply wells would be sampled in June (02, 16, and 52). However, well 16 was inaccessible due to the presence of a pump housing and
was not sampled. The OU 3 Management Plan stated that four existing groundwater monitoring wells would be sampled during the first groundwater sampling event in June (W-10, W-13, BH-06, and IS8-01). Wells W-10 and W-13 could not be developed due to inadequate well construction and, therefore, were not sampled. These wells were subsequently abandoned in July.
Source Area SD31-The investigation at this site was designed to characterize the potential impacts of a dry well located northeast of Hanger 5. Previous to any subsurface investigation activities, a decision was made by the base to excavate the area of the dry well. The excavation work was performed by base personnel. During the excavation, the soil was screened for volatile
organic vapors. Upon completion of the removal activity and before backfill, eight confirmation soil samples were collected from the excavation and delivered to a laboratory for analysis.
Since the dry well was removed, the planned soil gas survey was no longer necessary and changes were made to the locations of soil borings, hydropunch borings, and groundwater monitoring wells. A hydropunch boring was drilled down gradient of the excavation to identify any groundwater impacts of the dry well. Additional hydropunch borings and groundwater monitoring wells were installed north and east of Hanger 5. The hydropunch borings were used to locate the groundwater wells. The groundwater wells were installed to monitor other possible groundwater impacts in this area. |
Jennifer Roberts |
| 1/24/1994 |
Site Ranked Using the AHRM |
Site ranking reviewed by Harwood. |
Dennis Harwood |
| 1/24/1994 |
Update or Other Action |
Fac2 changed to reflect proper operable unit. Was OU-4. |
Louis Howard |
| 3/8/1995 |
Risk Assessment Report Approved |
RI/FS with risk assessment final version received and approved. Since all of the soil areas of interest are encompassed within either one or two groundwater areas of interest at OU3, the discussion of analytical results, nature and extent of contamination, and potential sources of contamination is divided into two areas:
OU3 East: including soils areas of interest SD16, SS21, east intersource area (including SD31), and the east groundwater area; and OU3 West: including soils areas of interest SD52 and west intersource area and the west groundwater area.
The carcinogenic evaluation for the worst-case scenario (residential-RME) showed a total risk of 1.3 x 10-4 for source SS21. No other exposure scenarios were associated with a risk in excess of 1.0 x 10-4. The evaluation of the potential for noncarcinogenic effects produced a hazard index of 1.3 at SS21 under the residential RME scenario only. All other scenarios have hazard indices of less than 1.0. Site remediation goals for Superfund sites have generally been in the range of 10-4 to 10-6 risk for carcinogens.
Ecological Assessment: Ecological Quotient (EQ) less than 1.0 indicates that the adverse effect being evaluated is unlikely to occur. EQ greater than 1.0 indicates that an adverse effect is possible. Caveat: due to the health conservative methodology used in the assessment, an EQ of greater than 1.0 DOES NOT indicate an adverse effect WILL occur. No EQs for moose, merlin, or peregrine falcon exceeded 1.0. Meadow vole EQs for several inorganics exceeded 1.0 at one or more source areas. However, the upper threshold limit of the background concentrations for the contaminants also cause the EQ to exceed 1.0. Therefore the EQs are probably overestimating the impacts to meadow voles. Exposures for black-capped chickadees, masked shrews and meadow voles feeding in the vicinity of Cherry Hill Ditch may be significant. However, due to the small areal extent of contamination, significant populations of these indicator species or other animals most likely are not threatened by the contaminants. |
Jennifer Roberts |
| 3/8/1995 |
CERCLA RI Report Approved |
Remedial Investigation/Feasibility Study final version received and approved.
Table 4-18 Summary of GW Screening Results from monitoring wells in OU3 East Intersource area (which includes SD31) TCE sample results as follows: MW-02 11.5 ug/L and MW-25 6.71 ug/L.
There are currently no receptors of groundwater in OU3 East (SD16, SS21 SD31). Groundwater modeling results indicate that contaminant plumes within OU3 will naturally attenuate before reaching sensitive receptors within OU5. Excavation at source SD31. The low levels of VOC and SVOC contamination detected at the excavation site at SD31 are most likely associated with minor residuals of sewer derived waste formerly disposed of in the dry well.
No obvious contaminant sources were identified for localized occurrences of these contaminants in the soil at the east intercourse area. Since the contaminated soil was removed from SD31, no relationship between soil and groundwater currently exists. The elevated TCE in the groundwater samples from well MW2 (located in the east intersource area) may be associated with a localized source of TCE in the overlying soil
Groundwater monitoring data will be collected from monitoring wells at OU3 to ensure that groundwater from OU3 will NOT impact the sensitive receptors at OU5. The Basewide groundwater monitoring plan describes the monitoring locations, sampling frequency, analytical parameters, and reporting format.
Since potential future impacts will be monitored, no further action for soil is planned for this site. (Section 7.6.5 Conclusions). |
Jennifer Roberts |
| 6/20/1995 |
CERCLA Proposed Plan |
Proposed Plan lists SD31 (dry well at maint. hangar) in the vicinity of the East Intersource Area contaminated with PAHs in the soil and TCE, PCE, benzene, methylene chloride, BEHP, cadmium, and lead in the GW above MCLs. Soils proposed for no further action and GW monitoring will be conducted for the COCs. Modeling shows that after 5 years the plume will have moved south of OU3 with a concentration of 1 ppb. After 15 years the model predicts the concentration of solvents will be below detectable levels.
*Since all of the soil areas of interest are encompassed within either one or two groundwater areas of interest at OU3, the discussion of analytical results, nature and extent of contamination, and potential sources of contamination is divided into two areas: OU3 East: including soils areas of interest SD16, SS21, east intersource area (includes SD31), and the east groundwater area; and OU3 West: including soils areas of interest SD52 and west intersource area and the west groundwater area. |
Jennifer Roberts |
| 12/11/1995 |
Update or Other Action |
John Halverson provided comments on the Draft Final Record of Decision for OU3 to USAF Joe Williamson and Larry Underbakke. ADEC concurs with EPA's comments with additional comments of its own. It is ADEC's understanding that the treatability study will be completed before finalizing the ROD and that if bioremediation turns out to not be a feasible remedial alternative, the ROD will be revised and anther draft final will be submitted. Text states a review will be conducted five years after completion of the remedial action. A five year review is required if waste is left in place. It is not clear if the review is proposed based on the PCBs at SS21, contaminants at other source areas, or both. Alternative 5 is to excavate the soil and treat it on site. Another alternative is to excavate and dispose of at another location on Base if the disposal area is already covered by institutional controls limiting future land use. Also if exposure to and migration of contaminants (PCBs) is limited by the site conditions. If the bioremediation treatability results are negative this may be an acceptable alternative that is not currently included in the ROD. If implementation of the remedial action results in the agreed upon cleanup level for PCBs (5 mg/kg) being met, then a five year review may not be necessary for soil action at SS21. The ROD does not include any reference to PCB impacts to and disposal of the concrete pads at the site.
The ROD refers to institutional controls (ICs) to limit use of groundwater from the shallow aquifer. It does not include any reference to ICs on management of soil that may be excavated from OU3 source areas during future construction projects. Ultimately, no further action decisions will be approved for each source area based on calculated risks in current and estimated future exposure scenarios. However, these decisions do not address identification, characterization, and management of the soil that may be excavated during future development. Real estate records or other appropriate land records should include documentation on where contaminated soil has been identified and remains in the ground. This would help land planners identify potential contaminated areas when proposing development on Base and may help in avoiding future compliance problems or contractor down time. |
John Halverson |
| 3/13/1996 |
Update or Other Action |
Action 3/13/97, based on Relative Risk Evaluation worksheet dated 8/16/95. Worksheet states that site was cleaned up in 1993 - no contaminants in the soils, however GW will require monitoring for natural attenuation at OU3. |
John Halverson |
| 9/12/1996 |
Meeting or Teleconference Held |
EPA's Meeting summary of the September 12, 1996 meeting-Decisions reached by Air Force (AF), U.S. Environmental Protection Agency (EPA), and Alaska Dept. Environmental Conservation (ADEC).
1. AF/EPA/ADEC agree that institutional controls (ICs) are necessary to ensure that contaminated shallow groundwater aquifer is not used. There is now a basewide prohibition (AF please cite) on use of the shallow aquifer which appears to be an adequate IC, therefore no additional ICs area required specific to OU3. OU3 ROD will note the need for ICs and the existence of the basewide ICs and groundwater monitoring program, and that since they are in place, no further action is necessary under the OU3 ROD.
In summary, the ROD will say:
a. All sources have been addressed;
b. No current receptors for contaminated groundwater;
c. No potential receptors in OU3 areas;
d. Potential receptors are in OU5 area, which has a remedy in place to deal with them, plus ICs and a monitoring program;
e. Basewide ICs and groundwater monitoring are in place and will continue until MCLs have been achieved.
2. AF/EPA/ADEC will research whether the actions that have taken place at SD52, SD16, etc. allow for unrestricted use. If not, some ICs may be necessary. This includes consideration of whether deep contamination remains at levels which would pose unacceptable risk in the event of future excavation, and if so, whether some ICs should be added to protect in the event of such an occurrence.
3. In addition, ADEC raised the question of ICs on deep soils with high concentrations (didn't show risk because no curren exposure/receptors; concern is for proper handling/disposal in event of future excavation). |
John Halverson |
| 9/16/1996 |
Update or Other Action |
ADEC letter to USAF RE: Draft Final ROD for OU3 August 1996. The department received the Draft Final Record of Decision (ROD) for OU3 on August 30, 1996. We previously reviewed and provided comments, in a December 11, 1995 letter, on the October
1995 draft-final ROD. A few comments in that letter are no longer relevant, since the treatability study showed bioremediation was not feasible. However the rest of the comments were not
addressed and are listed again below.
1) Statutory Determinations - It states a review will be conducted five years after completion of the remedial action. A five-year review is required if waste is left in place. It is not clear if the review is proposed based on the PCBs at SS21, contaminants at other source areas, or both. Please clarify this issue.
2) Section 2.1, page 2-1 - The SD31 description states, "... floor drains which connected to dry wells. A dry well... designated as SD31." The current wording is not clear regarding the number of dry wells that may have been present. If only one dry well was present, the "s" should be removed from "wells" in the first sentence above, otherwise it implies that more dry wells may exist.
3) Section 3.1, page 3-4 - The last paragraph states, "the list was further refined by removing affected analytes associated with analytical methods that were determined to be non-representative of site conditions..." Please clarify the meaning of this statement or reword the sentence.
4) Tables 3-1, 3-2 and 3-3 - The tables are titled "Soil Contaminants/Standards .. .", "Surface Water and Sediment Contamination/Standards ... ", and "Groundwater Contamination/Standards. . ." The associated text refers to several groups of contaminants (VOC's, SVOC's, pesticides) detected in various source areas. However, all the contaminants described in the text are not listed in the tables.
The tables should include information on all the contaminants described in the text, or the heading on the tables should be changed to state that only COCs are listed (recommend adding the other contaminants to the tables to more clearly present information on residual contaminants
).
5) Table 3-4 should include a footnote defining "SS", which is used in the exposure frequency for the current, on-site, occupational scenario.
6) Section 4.0 - The first sentence states, "The following subsections discuss.. . and presents...." The "s" should be removed from presents.
9) Section 5.0, page 5-2 - The last sentence refers to a five-year review. If implementation of the remedial action results in the agreed upon cleanup level being met, a five-year review should not be necessary for soil at SS21.
10) General Comment - The ROD does not include any reference to the PCB contaminated cement at SS21 or its disposal. This should be added to the document.
11) General Comment - The ROD refers to institutional controls to limit use of groundwater from the shallow aquifer. It does not include any reference to institutional controls on management of soil that may be excavated from OU3 source areas during future construction projects. Ultimately, nofurther action decisions will be approved for each source area based on calculated risks in current and estimated future exposure scenarios.
However, these decisions do not address identification, characterization, and management of residual contaminated soil that may be excavated during future development. Real estate records or other appropriate land records should include documentation on where contaminated soil has been identified and remains in the ground. This would help planners identify potential contaminated areas when proposing development on the base and may help in avoiding future compliance problems or contractor downtime.
3) Section 2.2, page 2-2: The first paragraph states the site was divided into seven operable units (OUs). The second paragraph describes six OUs and states that the ROD for OU6 will finalize all CERCLA activities at the base. The text should describe what happened with OU7. Also, please see EPA's comment on rewording the sentence on finalizing CERCLA activities.
4) Section 3.2, page 3-10: The last sentence, which tates, 'Therefore, OU3 will not cause an impact to sensitive receptors", should be deleted and replaced with a statement that the modeling results will be compared with monitoring data to ensure negative impacts to sensitive receptors do not occur.
5) Section 5.1.2, page 5-2: The Safe Drinking Water Act MCLs and MCLGs should be listed as relevant and appropriate. Alaska Air Quality Control Regulation 18 AAC 50.050(f) for dust suppression should be listed as relevant and appropriate.
6) Response to comments, page III-ii: The response to comment number seven states that all soil with PCB concentrations greater than 5 mg/kg is present within the top six inches of soil. Please
verify that this statement is correct. |
John Halverson |
| 1/3/1997 |
Cleanup Level(s) Approved |
the GW beneath the site is impacted and will be monitored for COCs as a part of the Base wide groundwater monitoring with institutional controls on groundwater use in the shallow aquifer of the outwash plain. |
Louis Howard |
| 1/3/1997 |
CERCLA ROD Approved |
ROD signed on 1/3/97 memorializing no further action for SD31. Soils removed with dry well in 1993, RI/FS conducted shows remaining contamination is not at levels that are not protective of human health and the environment.
Operable Unit 3 ROD Requirements: " Although organic constituents (e.g. , TCE) are present above Maximum Contaminant Levels (MCLs) in the shallow groundwater aquifer beneath OU 3, the concentrations are generally low, there are no current receptors, and institutional controls at the base exist for the shallow aquifer to prevent use. Metals were also identified above MCLs. The Safe Drinking Water Act is not an ARAR for this remedy, since no further action is necessary for groundwater under the OU 3 ROD. However, it is the ARAR for the groundwater action selected in the OU 5 ROD to protect groundwater receptors. If further action to protect groundwater is ever necessary, it will be done pursuant to the OU 5 or OU 6 RODs." The groundwater contamination will be addressed by monitoring as a part of the base wide monitoring effort for OU5. |
Lynn Kent |
| 1/3/1997 |
Institutional Control Record Established |
Groundwater beneath the site is impacted above maximum contaminant levels (MCLs) for drinking water regulatory program and will be monitored for COCs as a part of the Base wide groundwater monitoring with institutional controls on groundwater use in the shallow aquifer of the outwash plain.
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. |
Louis Howard |
| 1/3/1997 |
Conditional Closure Approved |
The ROD memorialized the soils in the vicinity of SD31 in the East Intersource area as requiring no further remedial action. Dry well and surrounding soils were removed in July 1993 and sampling indicated it was mainly sewer derived wastes with a minor amount of petroleum compounds.
However, the GW beneath the site is impacted and will be monitored for COCs as a part of the Base wide groundwater monitoring with institutional controls on groundwater use in the shallow aquifer of the outwash plain. |
Louis Howard |
| 10/1/1998 |
Document, Report, or Work plan Review - other |
Five Year Review received. OU3 consists of three sources and one receptor area. At SD16, waste solvents from Building 31-260 were disposed of in open trenches. At SD31, floor drains from Building 32-060 (Hangar 5) were discharged into dry wells and septic systems. The septic system and dry wells at SD31 were excavated in 1993. SS21 is an area where transformers containing polychlorinated biphenyls (PCBs) were stored. SD52, Cherry Hill Ditch, is a receptor for the stormwater from a major portion of the base. In 1994, low levels of PCBs were capped in the bottom of Cherry Hill Ditch (SD52) and a stormwater diversion project was completed at this receptor area. SD16, SD31, and SD52 were determined to be NFA sources in the OU3 ROD.
The ROD was signed on 01/03/1997 memorializing no further action for SD31. Soils removed with dry well in 1993 and the RI/FS conducted shows remaining contamination is not at levels that are not protective of human health and the environment. Operable Unit 3 ROD Requirements: " Although organic constituents (e.g. , TCE) are present above Maximum Contaminant Levels (MCLs) in the shallow groundwater aquifer beneath OU 3, the concentrations are generally low, there are no current receptors, and institutional controls at the base exist for the shallow aquifer to prevent use. Metals were also identified above MCLs. The Safe Drinking Water Act is not an ARAR for this remedy, since no further action is necessary for groundwater under the OU 3 ROD. However, it is the ARAR for the groundwater action selected in the OU 5 ROD to protect groundwater receptors. If further action to protect groundwater is ever necessary, it will be done pursuant to the OU 5 or OU 6 RODs." The groundwater contamination will be addressed by monitoring as a part of the base wide monitoring effort for OU5. The ROD memorialized the soils in the vicinity of SD31 in the East Intersource area as requiring no further remedial action. Dry well and surrounding soils were removed in July 1993 and sampling indicated it was mainly sewer derived wastes with a minor amount of petroleum compounds. However, the groundwater beneath the site is impacted and will be monitored for COCs as a part of the Base wide groundwater monitoring with institutional controls on groundwater use in the shallow aquifer of the outwash plain.
As a requirement of previously signed RODs for EAFB, ICs have been established to restrict the use of the shallow aquifer in the outwash plain. 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. The GW monitoring of selected wells located within OU3 is included as part of OU5 GW monitoring. In addition, all construction projects and other activities also undergo an environmental review. This review helps ensure compliance with GW use restrictions. For these reasons, it was determined that remedial action is not required for GW at OU3. |
Jennifer Roberts |
| 6/7/2013 |
Exposure Tracking Model Ranking |
Initial ranking with ETM completed for source area id: 71615 name: auto-generated pm edit Elmendorf OU3 SD31 Bldg. 7309 |
Louis Howard |
| 4/1/2015 |
CERCLA PA |
Preliminary Assessment received for multiple U.S. Air Force (Air Force or USAF) and Air National Guard (ANG) Fire Training Areas (FTAs) to determine probable environmental release of perfluorinated compounds (PFCs). Specifically, HGL is completing PA activities consistent with the U.S. Environmental Protection Agency (USEPA) Guidance for Preparing Preliminary Assessments under the Comprehensive Environmental Response, Compensation, and Liability Act of 1980 (CERCLA) (USEPA, 1991) to determine potential releases of PFCs at 82 Air Force and ANG installations from FTAs and other known and suspected PFCs or aqueous film-forming foam (AFFF) usage or storage areas.
AFFF testing in this area was performed from 2010 to 2012. Testing occurred on the designated
paved surface. Because annual testing using 5 to 10 gallons of AFFF concentrate was conducted
on the eight emergency vehicles equipped with AFFF in two locations, the total (up to 80 gallons
of concentrate annually) volume of AFFF is believed to have been divided between the two areas
during this time. Other additional small-scale testing may have been performed as needed in these areas. Following testing in this area, foam was observed in the drainage ditch located along the north side of Fifteenth Avenue (Bakker, 2015, personal communication; Appendix C).
Recommendation is to initiate a site inspection. A SI is defined as an investigation to collect and analyze waste and environmental samples to support an evaluation (USEPA, 1992). |
Louis Howard |
| 4/11/2016 |
Document, Report, or Work plan Review - other |
Staff commented on the draft site inspection for PFCs. The most stringent values should be used for screening criteria. Correction, the 3.04 mg/kg and 2.03 mg/kg are proposed human health values not migration from soil to groundwater. These values are based on cleanup values for dermal contact with soil, ingestion, of soil using a childhood age-adjusted to account for varying levels of soil ingestion depending on age, and exposure to soil through inhalation of both volatiles and particulates. Values for the three pathways are then totaled to produce a single, cumulative risk-based value (i.e. human health value).
The proposed migration to groundwater cleanup values, which are also to be considered “relevant” for this PFC Site Inspection, are even more stringent: PFOS (0.571 mg/kg) and PFOA (0.142 mg/kg). The PFOS and PFOA cleanup values are expected to be promulgated in the winter of 2016.
For determining presence or absence of PFOS and PFOA using solely risk based screening levels is not acceptable to ADEC. If the migration to groundwater cleanup level is adopted by ADEC and it exceeds for PFOS or PFOA, a release is confirmed and it is deemed to be contaminated by ADEC. 18 AAC 75.990 Definitions. (23) “contaminated soil” means soil containing a concentration of a hazardous substance that exceeds the applicable cleanup level determined under the site cleanup rules.
If AFCEC chooses to proceed with risk based values (as it is apparent upon review of Table 10-2 Steps 2, 4, & 5), then ADEC reserves the right to require further investigation/cleanup under 18 AAC 75 for all areas of concern/source areas where AFCEC determined no addition action was necessary at an area of concern/source area, but the PFC levels detected exceed migration to groundwater cleanup levels for PFCs.
See site file for additional information. |
Louis Howard |
| 6/1/2017 |
Update or Other Action |
Site inspection (SI) at aqueous film forming foam (AFFF) areas on JBER-E and JBER-R waa received for review and comment. The purpose of the SI was to determine the presence or absence of perfluorooctanoic acid (PFOA) and perfluorooctane sulfonate (PFOS) in the environment. These compounds are a class of synthetic fluorinated chemicals used in industrial and consumer products, including defense-related applications. This class of compounds is also referred to as per- and polyfluorinated alkyl substances (PFAS).
AFFF Area #18 Hangar 5 (Bldg. 7309) AFFF Spray Test Area soil results detected PFOS above the migration to groundwater cleanup level. PFOA and PFOS were detected at concentrations above the EPA HA and the ADEC cleanup level.
See site file for additional information. |
Louis Howard |
| 6/13/2017 |
Document, Report, or Work plan Review - other |
Staff reviewed the Draft SI Report for AFFF Areas on JBER-E and JBER-R sites. H5-1 Sheet 2 of 2 (Page 390): 30’ bgs – Headspace 62.9 ppm. Soil Description: moderate hydrocarbon odor. Headspace reading at 35’ bgs 21.0 ppm. Headspace 191.4 ppm at 38.5’ bgs.
It appears analysis for BTEX, GRO, DRO, RRO, PAHs (8270-SIM), VOCs (8260 w/methanol and low-level) are warranted from this monitoring well associated with Boring H5-1 either under CERCLA or as part of a further site characterization effort as required by 18 AAC 75.335. PFOS and/or PFOA were detected in soil at concentrations above the ADEC MTGW cleanup levels. PFOA and/or PFOS were detected in groundwater at concentrations above the ADEC cleanup level.
It appears there are documented releases of PFOS and/or PFOA at these areas which require additional investigation through a remedial investigation/feasibility study under CERCLA or as required by 18 AAC 75.335 Site Characterization.
See site file for additional information. |
Louis Howard |
| 7/17/2017 |
Document, Report, or Work plan Review - other |
EPA received the Draft Site Inspection Report for Aqueous Film Forming Foam Areas, Joint Base Elmendorf-Richardson, Alaska, May 2017 for review the week of June 2, however Appendix B2 (App B2) laboratory data was not included. EPA received App B2 for review the week of June 20. EPA preliminary comments were sent to the Air Force on July 17, 2017.
EPA Office of Research and Development staff, as well as EPA Region 5 Laboratory chemists, reviewed App B2. EPA has asked the Air Force for clarification regarding what level of report and data review was done by the government prior to submittal of the report to EPA and have not received a clear response. EPA’s initial review has identified a number of data quality issues and that the government data review should be completed and submitted to EPA before we are asked to finalize our comments. The comments submitted reflect only those requiring clarification on the narrative or figures and are not inclusive of review of the laboratory data, and therefore cannot substantiate any conclusions drawn on the presence/absence of PFAS at the 26 AOCs.
EPA review of the laboratory data packages has raised a number of concerns with deviations from workplan approved standard operating procedures, laboratory methods, and data validation.
EPA requests the Air Force clarify the level of governmental data review conducted on the JBER Site Inspection laboratory packages, and provide a copy of the Air Force data review to EPA.
Additional EPA comments on the laboratory data are pending receipt of the Air Force data review.
See site file for additional information. |
Louis Howard |
| 11/21/2017 |
Update or Other Action |
Per AFCEC email: A memo from the USACE summarizing issues found in their review should be in hand on the 4th of December. |
Louis Howard |
| 11/30/2017 |
Update or Other Action |
Draft VI report received for review and comment. Building 7309 is an operational commercial/industrial use facility that consists of a former aircraft hangar converted into a physical training facility with offices, storage areas, and a large indoor running track/workout area on the ground floor. Building 7309 is located partially within
the ST037 groundwater contamination plume boundary and TCE is the only COI. The depth to
groundwater is approximately 15 feet bgs.
Based on the maximum detected indoor air results, the total HI was below 1 at 0.4 and the
cumulative cancer risk was equal to 1x10-6 (see Table 10.1) for an indoor worker at Building
7309. Regarding short-term exposure to TCE in indoor air, the maximum detected concentration
(3.4 µg/m3) is above the USEPA Accelerated Response Action Level (industrial) for a 10-hour
work day (7 µg/m3).
TCE was detected in indoor air during FSE1 and FSE2, and in soil gas during FSE1. The highest
TCE concentration in soil gas was located in the southern portion of the central hangar (location 7309-SG003), which is collocated with the highest indoor air results. The consistent detections of TCE in soil gas and indoor air suggest the presence of a complete VI pathway.
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 confirm that women of child bearing age do not work at the facility, all users intermittently occupy building 7309 and whether there are any institutional controls established to ensure that people only occupy the building intermittently.
See site file for additional information. |
Louis Howard |
| 2/8/2018 |
CERCLA SI |
SI responses to ADEC's comments are satisfactory and may be incorporated into the final report. with the exception of lack of clarity in the response on which program the PFAS contamination will be investigated under at JBER: RI/FS in accordance with CERCLA as new source areas under the Federal Facility Agreements OR as new sites under State Authority (i.e. 18 AAC 75).
ADEC is requesting specific responses as to which path the investigation will occur (RI/FS per the FFA or Site Characterization per 18 AAC 75..335). Please respond. Additionally, ADEC is reviewing the Data Quality Evaluation Report AND the Technical Memorandum for Data Quality Findings Perfluorinated Compound Site Inspection for Joint Base Elmendorf-Richardson |
Louis Howard |
| 1/15/2019 |
CERCLA ROD Periodic Review |
Fifth draft five-year review received which does not directly address sites with AFFF contamination (PFOS/PFOA). Site Interviews: Generally, comments regarding the overall remediation process at JBER-E were positive, with the following comments applicable to JBER-E CERCLA sites as a whole: Reporting of groundwater (GW) monitoring results is often delayed by 1 or 2 years following a sampling event, which could result in missed opportunities to react or change procedures in subsequent monitoring events. Perfluorooctane sulfonate (PFOS)/ perfluorooctanoic acid (PFOA) contamination was recently detected in soil & GW above ADEC cleanup levels & GW contamination above EPA Health Advisory levels. *Note: PFOS/PFOA sampling was conducted at JBER in 2016. These activities are briefly noted in this FYR (Section 6.5.3); however, results were not available at the time of the report, & results will be addressed in the next FYR (March 2024).
In 2014, a Preliminary Assessment (PA) was performed at FT023 and, in 2016, a follow-up site
inspection was conducted into the presence of PFOS/PFOA at JBER locations where aqueous
firefighting foams (AFFFs) were historically used (ADEC, 2018a). Final results from the site
inspection were not available at the time of this FYR and will be addressed in the next FYR (March 2024).
See Site file for additional information. |
Louis Howard |
| 2/14/2019 |
Document, Report, or Work plan Review - other |
Staff provided comments on the Five Year-Review. PFAS investigation is needed to delineate the nature and extent of contamination at this source area (CS DB Hazard ID 636) in Operable Unit 3. In 2016, soil sample results detected PFOS at concentrations below EPA RBSL and ADEC human health cleanup level, but above the ADEC MTGW cleanup level. [Promulgated as of November 6, 2016] PFOA and PFOS were detected in groundwater at concentrations above the EPA HA and the ADEC cleanup level.
See site file for additional information. |
Louis Howard |
| 3/30/2020 |
Update or Other Action |
JBER sent list of sites that have been validated for future funding to investigate PFAS contamination at both JBER-E and JBER-R. They may be included in an end-of-year centrally-funded investigation. Right now, the scope is for a “PFAS General RI,” with an option of adding any installation-specific requirements later. Additionally, there may be end-of-year Expanded Site Investigations, and some of the other [JBER PFAS] sites that haven’t yet been validated may be included there.
JBER-E
SS135P C17 Debris Yard [AFFF Area #06]
SS136P Current AFFF Test Area [AFFF Area #07]
SS137P Corrosion Control [AFFF Area #08]
SS138P Current Fire Training Facility [AFFF Area #09]
SS139P Former AFFF Test Area [AFFF Area #12]
SS144P Hangar 5 Test Area [AFFF Area #18]
SS145P Hangar 6 [AFFF Area #19]
SS146P Hangar 10 [AFFF Area 21]
SS147P Hangar 16 [AFFF Area #22]
SS148P Hangar 17 [AFFF Area #23]
SS150P Cesna Crash Site [AFFF Area #26]
SS155P Hangar 18 [AFFF Area #24]
SS156P Hangar 8 [AFFF Area #20]
JBER-R
SS044P FTRS-044 [AFFF Area #05]
SS149P Ruff Road [AFFF Area #01] |
Louis Howard |
| 7/2/2021 |
Document, Report, or Work plan Review - other |
Reviewed and provided comments on the Draft Phase I Remedial Investigation Management Plan/UFP-QAPP, dated May 2021. The document provides the Work Plan, Field Sampling Plan, and the Quality Assurance Project Plan for the Phase I Remedial Investigation (RI) for PFAS at JBER. |
William Schmaltz |
