| Action Date |
Action |
Description |
DEC Staff |
| 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 |
| 10/20/1987 |
Update or Other Action |
DAF USAF Occupational and Environmental Health Laboratory, Brooks Air Force Base Memorandum - Subject Preservation of Installation Restoration Program (IRP) Monitoring Wells. To all MAJCOM/DEEV.
1. This letter is in response to a HQ USAF/LEEV letter dated 10 Jul 87, same subject, and a subsequent letter from ATC/DEEV to USAFOEHL requesting that we comply as their service center for IRP work. Since this guidance affects all of our command customers, we are addressing this issue with all commands.
2. The HQ USAF/LEEV guidance letter on IRP monitoring well installation and abandonment is very practical and judicious. The USAFOEHL technical approach for IRP is consistent with this guidance. As a matter of fact, we have followed this approach since the inception of the IRP.
3. We have successfully negotiated with many states and US EPA regional offices on the use of PVC as well material for IRP Confirmation and Quantification studies in lieu of Teflon (PTFE) or stainless steel. Since most of the wells will be destroyed or abandoned during the IRP Phase IV clean-up effort or after the initial IRP studies are complete and they are not suitable for long-term monitoring (LTM) purpose, the PVC well system is the most cost effective.
We believe the National Sanitation Foundation-grade PVC suits
our purpose for ground water sampling. However, we do recommend stainless steel for LTM or RCRA Part B Permit wells deeper than 200 feet or Teflon for wells less than 150 feet.
4. The decision for above-ground completion of monitoring wells rests with the installation commander. Our Statement of Work (SOW) allows either aboveground or flush-with-ground completion. We recommend that wells be located on the side of road hedge facing away from thoroughfares or be painted a color
that blends with the base surroundings.
The color should be determined by the installation point of contact (POC). All wells, either above-ground or flush-with-ground, are installed in a manner to prevent surface runoff from entering into the well. As a rule, the rise pipe is located above a 25-year
flood stage, preferably a 100-year flood stage. A steel protective casing and lock are standard prescription for all wells, and the master key will be delivered to the base POC. Guard posts will be installed where the base POC thinks necessary to prevent the damage caused by moving equipment.
5. After well completion, USAFOEHL always requests the Air Force contractor to survey its coordinates and elevation using a certified land surveyor. This survey result is transmitted to the base. If the base requests, the surveyor can locate the wells immediately on the Base Comprehensive Plan.
6. Proper abandonment of monitoring wells is crucial in ground water pollution prevention. Even if we know that the wells will be destroyed during IRP Phase IV excavation, they should be properly abandoned beforehand. Identifying well abandonment procedures according to state regulations is a standard clause in our SOW. Physical abandonment must be initiated in later contract efforts or be carried out by the base.
7. We always weigh both the cost and the technical soundness before establishing a monitoring and/or sampling well system. USAFOEHL strives to serve the Air Force by following the HQ USAF guidance on Preservation of IRP Monitoring Wells. |
Jennifer Roberts |
| 1/25/1988 |
Update or Other Action |
USEPA Assistant Administrator J. Winston Porter (OSWER) Memorandum for the record to Regional Administrators I-X Subj: Enforcement Actions under RCRA and CERCLA at Federal Facilities. Statutory language makes it clear that Federal facilities must comply both procedurally and substantively with RCRA and CERCLA in the same manner as any non-Federal entity. The purpose of this memo is to lay out the statutory authorities under RCRA and CERCLA that EPA may use at Federal facilities to achieve compliance and expeditious cleanup.
EPA (The Agency) is viewing the Section 120 Interagency agreement as a comprehensive document to address hazardous substance response activities at a Federal facility from the remedial investigation/ feasibility study (RI/FS) through the implementation of the remedial action. All such interagency agreements must comply with the public participation requirements
of Section 117. The timetables and deadlines associated with the RI/FS and all terms and conditions associated with the remedial actions (including operable units or interim actions) are enforceable by citizens and the States through the citizen suit provisions of Section 310 of CERCLA. In addition, Section 122(1) of CERCLA authorizes the imposition of civil penalties against Federal agencies for failure to comply with interagency agreements under Section 120. Procedures for imposing these penalties are provided for in Section 109 of CERCLA.
Executive Order 12580 clarifies that EPA is authorized to issue Section 104 and Section 106 administrative orders to other Federal agencies, with the concurrence of the Department of
Justice. Section 4(e) of the Executive Order provides that: Notwithstanding any other provision of this Order, the authority under Section 104(e)(5)(A) and Section 106(a) of the Act to seek information, entry, inspection, samples or response action from Executive Departments and agencies may be exercised only with the concurrence of the Attorney General.
States also have a variety of enforcement authorities under CERCLA, so the exercise of EPA's enforcement authorities should be closely coordinated with the States.
First, Section 121(e) (2) of CERCLA authorizes States to enforce ANY Federal or state standard, requirement, criteria or limitation to which the remedial action must conform under CERCLA.
Second, Section 310 authorizes citizen suits to require Federal agencies to comply with the standards, regulations, conditions, requirements, or orders which have become effective pursuant to CERCLA including IAGs under Section 120 of the Act.
Third, Section 120(a)(4) clarifies that State laws concerning removal and remedial action, including State laws regarding enforcement, are applicable at Federal facilities not included on the NP. In addition, Section 120(i) states that nothing in CERCLA Section 120 shall affect or impair the obligation of the Federal agency to comply with the requirements of RCRA, including corrective action requirements (see section IV.C., "Importance of the States as a Party to the IAG"). EPA enforcement actions against Federal agencies should therefore be carefully coordinated with States to avoid potentially duplicative or conflicting exercises of authority.
All RCRA Subtitle C permits issued after November 8, 1984, will contain provisions for implementing the corrective action requirements of 40 CFR Part 264 Subpart F (or authorized state requirements), and Section 3004(u) and (v) of RCRA. For facilities that have or are seeking a RCRA permit, the requirements for a "CERCLA" remedial investigation and cleanup could be met by implementing these requirements through RCRA corrective action. It is important to keep in mind, however, that the extent of coverage of the RCRA permit is generally limited to hazardous wastes/constituents (e.g., some CERCLA hazardous substances such as radionuclides are not RCRA hazardous constituents and, therefore, the permit may not be able to address all of the releases at a facility).
The corrective action authority under Section 3008(h) of RCRA can be used at RCRA interim status facilities to address releases from RCRA regulated units and other solid waste management units. At a Federal facility that has interim status, a RCRA corrective action order could address the investigation and clean-up of releases in. lieu of a "CERCLA" response action or as an interim measure. Again, the extent of coverage in the RCRA corrective action order is limited to RCRA hazardous wastes/constituents.)
CERCLA Section 106 can be used to address releases from RCRA units or CERCLA sites when an "imminent and substantial endangerment" is shown. A Section 120 IAG could be drafted to incorporate all RCRA corrective action requirements and CERCLA statutory requirements. Where some or all of a Federal installation has been listed on the NPL, the CERCLA Section 120 IAG is required for remedial action by statute. |
Louis Howard |
| 8/2/1988 |
Update or Other Action |
Elmendorf Operable units' source areas that correspond to RCRA SWMU(s) from the RCRA RFA (New Number & Old Number)
WP14 D-15: POL Sludge Disposal site #1 - 1000 ft. North of Highway 05 center line 4800 ft.
from West end of Highway 05, east of Knik Arm and north of Cherry Hill Quarters, west side of EAFB between the bluff and the POL Tank Farm, less than one acre, and approx. 1/4 mile west of
site SP-5. Used from 1964-1968 for disposal of sludges from petroleum, oil and lubricants tank clean outs. This site is a low priority for addressing investigation actions. |
Louis Howard |
| 2/24/1989 |
Meeting or Teleconference Held |
Telephone Memorandum for the file by Black & Veatch Project: 13833 at 10:15 a.m. with Jim Hayden ADEC. Call to Jim to find out if he could recommend any soil cleanup levels. He said that the "most likely set of standards or guidelines to be used were the California Leaking Underground Fuel Tank (LUFT) manual tables. He also said that a meeting would be held in about three (3) weeks to go over the proposed cleanup levels for the State. Black & Veatch asked if his office would be overseeing operations at Elmendorf and he replied "that they most likely would." |
Jim Hayden |
| 10/20/1989 |
Update or Other Action |
ADEC Ron Klein, Supervisor, Contaminated Site Investigations, sent letter to Captain Brad Gerken, Dept. of Air Force, 5099th Civil Engineering Operations Squadron (AAC) Subject: Response to September 27, 1989 Letter; Requirements for Temporary Storage of Petroleum Contaminated Soil.
Enclosed is a copy of the Southcentral Region Office's interim policy for storage and disposal of waste oil contaminated soil.
The guidance also applies to storage of soils contaminated with clean fuels if they are to be stored off the site where they were generated or stored on-site longer than thirty (30) days. The guidance document will be revised shortly to make that explicit. Petroleum contaminated soils generated on-site and stockpiled onsite for less than thirty (30) days must be placed on a bermed liner and covered. The liner and cover must be at least 6 mil reinforced polyethylene.
Alaska Department of Environmetal Conservation Southcentral Region Office - Interim Policy For Storage and Disposal of Waste Oil Contaminated Soil
The Southcentral Regional Office solid waste program has been working on an interim policy for storage and disposal of waste oil contaminated soil. Currently the Region has approved the removal of waste oil contaminated soil to a facility permitted to properly handle the contamination. With the exception of the Municipality of Anchorage (MOA) Landfill and Alaska Pollution Control Palmer Facility (pre-treatment for landfill disposal) all of these
facilities are located in the contiguous United States.
Currently, if the waste oil contaminated soil does not meet MOA Landfill criteria the only disposal option is to send the contaminated soil out of Alaska. Soil disposal under this method is costly due to handling, shipping, and facility fees. In discussions with Responsible Parties (RP) there appears to be a strong move to develop other local disposal methods that would meet with agency approval. Therefore the Regional solid waste program has developed interim storage guidelines for waste oil contaminated soils.
These guidelines include the following:
1. An approved design for a low-maintenance or maintenance free storage liner and cover that will be able to withstand winter conditions and is petroleum resistant. This will include a schedule to monitor the storage facility to verify that the integrity of the liner and cover is maintained through out the storage period.
2. Obtain a solid waste storage plan approval for onsite storage of waste oil contaminated soil from ADEC prior to storage construction.
3. The Responsible Party may propose to remove the waste oil contaminated soil to an off-site storage location if long term on-site storage is not practical. This location must be approved of by the Department prior to any transfer of the soils. The storage site must meet, ADEC design criteria and the RP must obtain an off-site; solid waste storage plan approval prior to transfer of the soil. All transfer of soil off-site must be done under a Bill of Lading and copies provided to ADEC.
4. The maximum allowable storage time is one (1) year. |
Ron Klein |
| 11/2/1989 |
Document, Report, or Work plan Review - other |
ADEC AWDO Ron Klein, Supervisor, Contaminated Site Investigations, sent USAF Colonel Everett L. Mabry, HQ 21st Combat Support Group (AAC) letter RE: Elmendorf Air Force Base Petroleum Contaminated Soil. Thank you for your 17 October, 1989 response to my September 1989 letter. The following are answers to the questions detailed in your letter:
1. What State of Alaska regulations cover the treatment of soil contaminated with petroleum product?
The State has no detailed regulations on petroleum contaminated soil treatment. According to the oil pollution regulations (18 AAC 75.140, Cleanup), Immediately upon becoming aware of a discharge of a hazardous substance to the water or land of the state, persons responsible for that discharge shall clean up and dispose of the material collected using methods for which prior approval, oral or written, has been given by the regional supervisor or his designee.
Under this section the Department reviews soil treatment plans to insure that the treatment method proposed is effective and will not result in the contamination of other sites.
Petroleum contaminated soil is also classified a solid waste under State solid waste management regulations. See 18 AAC 60.910 (53) for the definition of solid waste. According to the solid waste regulations a permit is required for solid waste facilities. The solid waste regulations also provide guidance in 18 AAC 60.075 for landspreading operations.
Depending upon the petroleum contaminated soil treatment method selected other regulations may apply such as our Air Quality Control (18 AAC 50) and Wastewater Disposal (18 AAC 72)
regulations.
2. What are the State of Alaska cleanup standards for soil contaminated with petroleum products?
According to 18 AAC 75.130 (Disposal of Hazardous Substances) prior approval by the Department is required for the ultimate disposal of a hazardous substance, and soil, cleanup materials, or other substances contaminated with a hazardous substance. Chapter 75 classifies oil as a hazardous substance (see 18 AAC 75.900 (05)).
Ultimate cleanup levels depend upon what the proposed disposal alternative is. At a minimum soil needs to be cleaned up to a level which will not pose a risk to the lands and waters of the disposal site. The beneficial use of petroleum contaminated soils is encouraged. For example, processing petroleum contaminated soil through a hot mix asphalt plant for use as non-spec asphalt base. |
Ron Klein |
| 4/14/1990 |
Site Added to Database |
Petroleum contaminant. |
Louis Howard |
| 9/26/1990 |
Update or Other Action |
National Priorities List Details and Hazard Ranking System Scoring Results for Elmendorf AFB (dated 1/1/1989) received by ADEC Anchorage/Western District Office. Elmendorf Air Force Base covers 13,100 acres in the Greater Anchorage Area Borough immediately north of Anchorage, Alaska. The base is bounded to the west by Knik Arm of the Cook Inlet, and to the east by Fort Richardson Army Base. Ship Creek flows along the southern perimeter. In operation since 1940, this base now hosts the 21st Tactical Fighter Wing.
Elmendorf is participating in the Installation Restoration Program (IRP). Under this program, established in 1978, the Department of Defense seeks to identify, investigate and clean up contamination from hazardous materials. As part of IRP studies, the Air Force identified 12 areas where hazardous materials had been generated, stored, used, or disposed of. All require further investigation.
Initially, the Air Force focused on five areas. In the past, landfills D-5 (now closed) and D-7 (still active) received a variety of hazardous wastes, including lead acid batteries and waste solvents. The landfills, unlined and unbermed, are in sandy and gravelly soils. Shop wastes, including solvents and paint thinners, were disposed of in a naturally occurring unlined trench designated as Site D-17. Site IS-1 is where fuel in Building 42-400 spilled into floor drains that feed into gravel-bottom dry wells. The last of the five areas included in the initial investigation is site SP5, where approximately 60,000 gallons of aviation fuel JP-4 spilled, of which only 33,000 gallons were recovered.
During IRP activities in 1983-87, trichloroethylene, tetrachloroethylene, 1,1,2,2-tetrachloroethylene, trans-, 2-dichloroethylene, 1,1-dichloroethane, 1,1,1-trichloroethane, and lead were detected in on-site monitoring wells. An estimated 121,000 Elmendorf employees and residents of Anchorage obtain drinking water from wells within 3 miles of hazardous substances on the base.
EPA is reviewing the Air Force's workplan for a remedial investigation/feasibility study to determine the type and extent of contamination at the base and identify alternatives for remedial action. The final workplan is expected to be completed in the fall of 1989.
General description of the facility (e.g., landfill, surface impoundment, pile, container; types of hazardous substances; location of the facility; contamination route of major concern; types of information needed for rating; agency action, etc.):
The Department of Defense owns and operates Elmendorf Air Force Base. Elmendorf AFB is located immediately north of Anchorage, Alaska. The base is bounded to the west by Knik Arm of the Cook Inlet, and to the east by Fort Richardson Army Base. Ship Creek flows along the southern perimeter. Elmendorf operates and maintains several landfill areas, D-5 and D-7, which in the past have been used as repositories for a variety of wastes including lead acid batteries and waste solvents. Shop waste disposal was performed in a naturally occurring, unlined trench designated as site D-17. Wastes at Site D-17 include solvents and paint thinners.
In addition, waste disposal (spilled fuel) occurred through floor drains in building 42-400 (Site IS-1). These drains feed into gravel-bottom, dry wells. An aviation fuel spill (Site SP 5) released approximately 60,000 gallons of JP-4, of which, only 33,000 gallons were recovered. The landfills are operated as unlined and unbermed disposal areas in sandy and gravelly soil. The landfills are covered with native soils. Past spills and landfill disposal practices have caused the potential for both groundwater and surface water contamination.
The landfill disposal units (D-5, D-7, and D-17), the spill site (SP-5), and the floor drains (IS-1) have been aggregated for the purpose of this HRS evaluation. The basis for this aggregation is: all sites have the same owner/operator, contaminants for all sites can impact the same groundwater sources, and similar wastes were deposited in each of the sites.
The groundwater in the Anchorage vicinity is an extremely important resource. The groundwater occurs in two distinct aquifers. The upper aquifer is an unconfined, water table system. The lower aquifer is partially confined by a semi-permeable layer, and behaves as an artesian system. The majority of the groundwater used for domestic purposes is extracted from the lower aquifer. The downward vertical hydraulic gradient from the upper aquifer provides a pathway for contaminant migration into the lower aquifer which is hydraulically connected to the upper aquifer. |
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 |
| 10/31/1991 |
Update or Other Action |
CH2MHILL project ANC31026.D6.10 site summary of previous investigations recommended the following since the source was inadequately characterized: conduct a detailed soil boring program with soil gas survey to determine horizontal extent of TPH contamination and other parameters, investigate buried metal anomaly with soil boring program, install and sample the required # of monitoring wells to determine depth to groundwater and flow, determine potential contamination from off-source surface water runoff, and determine if there is groundwater interaction with Knik Arm due to large tidal fluctuations. |
Jennifer Roberts |
| 11/12/1991 |
Enforcement Agreement or Order |
Federal Facility Agreement under Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) signed for docket # 1089-07-19-120. The agreement ensures that the environmental impacts associated with past and present activities at the Base are thoroughly investigated and appropriate removal and/or remedial action(s) taken as necessary to protect human health and the environment. Elmendorf Federal Facility Agreement signed.
The general purposes of this Agreement are to: (a) Ensure that the environmental impact associated with past and present activities at the Site are thoroughly investigated and appropriate removal and/or remedial action(s) taken as necessary to protect the public health, welfare, and the environment.(b) Establish a procedural framework and schedule for developing, implementing, and monitoring appropriate response actions at the Site in accordance with CERCLA, the NCP, Superfund guidance and policy, RCRA, RCRA guidance and policy, and applicable state law.
The FFA divided the CERCLA study source areas at Elmendorf AFB into the following seven operable unites (OUs), on the basis of geographic proximity and similar source characteristics or contaminants:
- OU1 Landfills (LF05, LF07, LF13, LF59, OT56)
- OU2 Tank Spill Sites (ST20, ST41, including the ST41 Sludge Disposal Area)
- OU3 Central Containment Area (SD16, SD31, SD52, SS21)
- OU4 Northern Containment Area (SD24, SD25, SD28, SD29, FT23, SSl0)
- OU5 Southern Containment Area (ST37)
- OU6 Surface Disposal Sites (LF02, LF03, LF04, SD15, SD73, WP14)
- OU7 Limited Field Investigation (SS19)
Proposed listing on NPL was 07/14/1989 and Final listing on NPL was on 08/30/1990.
CERCLA Source Area RW17
Source area RW17, formerly called RD-1, is located approximately 1.5 miles north of the north end of the north/south runway. This low-level radioactive waste disposal site was suspected of containing small quantities of cyanide and radium, which were buried in the ground.
Radioactive analysis using a Geiger counter found that no radioactivity above background levels was detected. Materials were exhumed and disposed of by offsite contract disposal; thus risks associated with this source area do not exist. Following completion of initial Base studies, this site was determined to pose no threat to the environment or human health. This determination was also made by ADEC during its Federal facilities Resource Conservation and Recovery Act (RCRA) inspection. Source Area RW17 was closed and became an official NFA site when the Federal Facilities Agreement (FFA) was signed in November 1991.
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 |
| 12/31/1991 |
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 |
| 4/9/1992 |
Update or Other Action |
EPA Memorandum April 9, 1992 Reply to the ATTN of ES-098. Subject Toxicity of Fuels. From Carol Sweeney Toxicologist Health and Environmental Assessment Section. To Wayne Pierre Federal Facilities Superfuend Branch (HW-124). A response has been provided to the frequently-asked question of whether a reference dose or other toxicity information can be provided for fuel mixtures so that these mixtures can be addressed quantitatively in Superfund risk assessments. The memo from ECAO Cincinnati is attached (last attachment). They have developed reference doses for gasoline, JP-5/kerosene, and JP-4, and a cancer potency factor for gasoline. The memo emphasizes that these are provisional numbers and that considerable uncertainty is involved in this quantitative assessment, because of data limitations, and because inhalation studies were used to calculate oral reference doses.
I typed up a summary table showing the numbers (first attachment) and calculated some risk-based concentrations (second attachment). On the risk-based concentration table, I also
included ordnance compounds, because I hadn't made a table of those before that I can remember. The risk-based concentrations were calculated the same way as table II-1 and II-2 of the Region
10 Supplemental guidance; for soil, the same limitations apply, that the numbers presented do not consider pathways other than soil ingestion.
Toxicity Reference Vaules for Fuel Mixtures EPA Region 10 4/9/1992 Non-cancer effects-Gasoline (unleaded) RfD (mg/kg-day) Oral: 2.0E-1, Uncertainty Factor-Oral:1000, Level of Confidence-Oral: Low. Toxicity Data Source-Oral RfD: Memo 3/92. Carcinogenicity-Cancer Potency/(mg/kg/day): Oral 1.7E-3, Unit Risk (/ug/m3) 4.8E-7, Cancer Weight Of Evidence-C, Toxicity Data Source-Oral SF and Inhal. SF: Memo 3/1992.
Kerosene/JP-5 RfD2.0E-2, UF Oral: 10,000, LOC Oral: low, TDS Oral RfD: Memo 3/92
JP-4 RfD 8.0E-2, UF Oral: 10,000, LOC Oral: low, TDS Oral RfD: memo 3/92.
Screening Values for Water RBCs based on Ingestion, Residential
Gasoline-Risk = 10-6 (ug/L) 50, 10-4=5000 HI=1 (ug/L) 7000
JP-5 Kerosene Risk 10-6 10-4=NA HI = 1 (ug/L) 700
JP-4 Risk 10-6 10-4 = NA, HI = 1 (ug/L) = 3,000
Screening Values for Soils- RBCs Based on Soil Ingestion Residential
Gasoline-Risk = 10-6 (mg/kg) 400, 10-4 (mg/kg) 40,000, HQ = 1 (mg/kg) 50,000
JP-5 Kerosene Risk 10-6 10-4 NA, HQ =1 5,000
JP-4 Risk 10-6 10-4 NA, HQ = 20,000
IARC concluded that gasoline is possibly carcinogenic to humans (Group 2B). IARC concluded that marine diesel fuel is possibly carcinogenic to humans (Group 2B), but light diesel fuels and jet fuels are not classifiable as to their carcinogenicity in humans (Group 3). |
Jennifer Roberts |
| 3/26/1993 |
Update or Other Action |
DOD & ADEC joint Technical Memorandum of understanding signed concerning the Basewide Groundwater (gw) signed by: ADEC Jennifer Roberts RPM & USAF Joseph Williamson Chief Environmental Programs & Restoration. Due to the basewide gw study & the FY92 field work that occurred at Operable Units (OUs) 1, 2, & 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 & Record of Decision (ROD). This means addressing all gw from upgradient sources (CERCLA (ST20, Ous 3&4) & OUs 1 & portions of OU2) & 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...). |
Louis Howard |
| 10/4/1993 |
Update or Other Action |
Conceptual site model received. Site is located a few hundred feet to the east of Bluff Landfill LF04. Used from 1965-1968 to dispose of sludge generated from POL tank cleanout operations. Horizontal and vertical extent of soil contamination and nature and extent of groundwater contamination has not been adequately investigated. Depth to groundwater and groundwater flow direction in source area WP14 is unknown since no monitoring wells were installed at the site. Stratigraphy has been inadequately characterized, hydraulic properties of the aquifer are unknown. The buried metallic geophysical anomalies and other geophysical anomalies were not investigated. |
Jennifer Roberts |
| 11/3/1993 |
Update or Other Action |
MEMORANDUM OF UNDERSTANDING BETWEEN THE DEPARTMENT OF DEFENSE AND THE ENVIRONMENTAL PROTECTION AGENCY FOR THE IMPLEMENTATION OF P.L. 96-510 THE COMPREHENSIVE ENVIRONMENTAL RESPONSE, COMPENSATION, AND LIABILITY ACT OF 1980 (CERCLA) - The Department of Defense (DOD) and the Environmental Protection Agency (EPA) are entering into this agreement to clarify each Agency's responsibilities and commitments for conducting and financing response actions authorized by the Comprehensive Environmental Response, Compensation, and Liability Act of 1980 (CERCLA) and specifically delegated by Executive Order 12316.
This agreement does not redelegate any responsibilities set out in Executive Order 12316. Rather, it seeks to clarify respective operational roles, responsibilities, and procedures. This agreement does not create any substantive or procedural rights in other parties, does not affect enforcement rights and remedies with regard to any party, and is intended only for Federal administrative purposes of EPA and DOD.
These responsibilities and procedures are guided by the following:
-DOD facilities are defined as government-owned,
-Government operated facilities controlled by DOD; and
-Government-owned land controlled by DOD that are either contractor-operated or leased to other parties.
DOD is generally responsible for financing actions taken in response to releases from DOD facilities, or assuring that another party finances such actions. DOD and EPA will conduct response actions consistent with response procedures established by the National Oil and Hazardous Substances Pollution Contingency Plan (NCP). At DOD's request and in its discretion, EPA will provide DOD with technical assistance to support the response actions conducted by DOD. Civil works activities of the Department of Army Corps of Engineers are not subject to the terms of this agreement.
DOD will consult with EPA concerning the best techniques and methods available for the prevention, control, and abatement of environmental pollution.
CERCLA provides a comprehensive framework for response to the release orpotential release of hazardous substances, pollutants, and contaminants. Section 104 of CERCLA and Executive Order 12316 place authority for responding to releases from DOD facilities with the Secretary of Defense. These response actions must be conducted in accordance with the NCP as amended by EPA under section 105 of CERCLA.
For purposes of this agreement, releases of hazardous substances are divided into three categories: Releases from current DOD facilities; Releases from former DOD facilities; and Other releases for which DOD is a responsible party.
For each category, section 3 describes procedures to be followed by DOD and EPA in determining which Agency will conduct and/or finance the response action consistent with CERCLA, the requirements of Executive Order 12316, and the NCP. At DOD's request and in its discretion, EPA will provide technical assistance or serve in an advisory role when DOD conducts a response.
DOD facilities with on-facility contamination and no off-facility contamination: When there is contamination on a DOD facility and no off-facility contamination, DOD will conduct and finance the response action or assure that another party does so. At DOD's request, EPA will provide technical assistance or serve in an advisory role. This section does not apply to releases for which DOD is not a responsible party under section 107(b) of CERCLA (e.g., "midnight dumping").
DOD facilities with off-facility contamination: When there is off-facility contamination and clear evidence that a DOD facility is the sole source, DOD will conduct and finance the response action or assure that another party does so. At DOD's request, EPA will provide technical assistance to DOD.
When there is off-facility contamination and no clear evidence that a DOD facility is the sole source, EPA will finance and conduct investigations and studies off-facility to determine the source and extent of the contamination and recommended response action. DOD will finance and conduct investigations and studies on the DOD facility to determine the source and extent of the contamination and the recommended response action. DOD and EPA will coordinate these efforts and resulting decisions to minimize costs and duplication of activities, and will exchange all reports, studies, and other relevant site information.
If after DOD and EPA review these investigations, it is determined that the DOD facility is the sole source of the contamination, DOD will conduct and finance the response action or assure that another party does so and will reimburse EPA for costs EPA expended at the site.
If after DOD and EPA review these investigations, it is determined that the DOD facility is one of two or more sources of the contamination, EPA and DOD will jointly determine the most appropriate response and financing methods. |
Ron Klein |
| 12/12/1994 |
Meeting or Teleconference Held |
Restoration Advisory Board meeting held to discuss Environmental remediation program overview, Source area updates
Development of the Restoration Advisory Board, membership selection processes, application status, nomination procedures
Relative risk site evaluation process overview. |
Ray Burger |
| 1/9/1995 |
Update or Other Action |
OU5 Groundwater Modeling Report received. The objectives of the modeling task were to: Evaluate the movement of contaminants across Elmendorf AFB and within Operable Unit (OU) 5; Predict contaminant migration over the next 30 years; and Determine if selected receptor points along Ship Creek and an unnamed beaver pond will be impacted by contamination. A 3 dimensional finite element model (SALT) developed at the University of Waterloo was selected because of its versatility in handling complex geology and boundary conditions. Radian Corporation modified the model to improve the program's efficiency and to include contaminant decay and site specific boundary conditions along Ship Creek. This modified version called SALT 3, consists of groundwater flow and contaminant transport models. The hydrogeology of the modeled area was evaluated using lithologic data collected from all available boreholes within the modeled area and water level data collected from shallow water table monitoring wells in March and September 1993.
After a review of the groundwater quality data from September 1993 groundwater sampling and available OU 1, 2, and SERA site data, benzene and trichloroethene were selected as representative compounds for this modeling effort. Benzene and TCE were selected due to their potential health impacts. As metals and semivolatile compounds were only sporadically detected at concentrations near maximum contaminant levels (MCLs) they are not constituents of environmental concern in much of the aquifer beneath EAFB and were not modeled.
Concentrations in the recharge over the water table was set to zero except for at source areas. Since improvement in soil quality is expected over time, the sources were assumed to cease contributing benzene and TCE to groundwater afar five years. All concentrations in the recharge zone were therefore set to zero at the end of the first five years.
The conclusions of the base case simulations show that benzene and TCE will migrate toward the south. However, the concentrations of these contaminants will decline over time. Because of infiltration, there may be some localized areas that experience a temporary increase in concentration as a "pulse" migrates toward the south. Benzene will be detectable in groundwater for over 20 years, however, the concentrations in groundwater base wide should be below the MCL after 15 years (1993-2008). TCE concentrations will be detectable in groundwater after 30 years (2023) and should be less than the MCL base wide after 20 years (2013).
Benzene and TCE will spread and migrate toward the south from identified source areas. Concentrations in groundwater flowing toward Ship Creek and the unnamed beaver pond should not exceed 1 ug/L over the period modeled. The model predicts that the concentrations of these compounds in groundwater near surface water bodies will be approximately 1 ug/L after 5 years (1998) and will then steadily decline over time. The results of the groundwater modeling effort indicate that the groundwater can be remediated naturally (MNA) in all OUs without any predicted increase impact to sensitive receptors in OU5. The model predicted, that in five years, benzene and TCE concentrations in OU5 from upgradient sources will be above 1 ug/L but less than 10 ug/L. In 10 years (2003), the concentration of these compounds is predicted to be less than 1 ug/L in OU5, indicating a measurable improvement in water quality over time. |
Ray Burger |
| 6/15/1995 |
Site Ranked Using the AHRM |
Initial ranking. Action code added because it wasn't when the site was originally ranked. |
Louis Howard |
| 12/22/1995 |
Meeting or Teleconference Held |
The purpose of this confirmation notice is to convey the significant decisions reached and pertinent issues discussed during the above referenced meeting. The meeting was held to address final questions regarding the selection of the preferred alternatives for OU 6.
The soil contamination at WP14 was discussed. In a meeting on 30 November 1995, the consensus preferred alternative for soils at WP14 included bioventing for the deep soils at Area 1 (there are no ACM exceedances in the shallow soils at Area 1), and no further action at Area 2 (deep and shallow soils). A re-evaluation of the Alaska cleanup matrix scoring for WP14 was also discussed during this meeting, such that site-specific and not general scores could be applied to that source area.
During the 13 December meeting, it was noted that all of the contamination in the deep soils at Area 1 is in the smear zone (NOTE: The smear zone is the area where free product occurred in the soil and was then smeared across the soil when the water table fluctuated between historic high and low water table elevations.), and as such require no soil action. It was reiterated that there were no ACM exceedances in the shallow soils at Area 1, and therefore no action is required for the shallow soils in this area. Because
all of the deep soil contamination at Area 1 was in the smear zone, the decision made in the earlier meeting to biovent those deep soils was not valid. It was agreed that no specific action for soils (such as excavation or bioventing) would be taken with the Area 1 soils, and that the deep contamination would be addressed as part of the groundwater alternatives.
There are relatively low levels of soil contamination at Area 2. However, in an effort to be more protective of the groundwater at WP14 (in light of the fact that no removal action will be conducted at Area 1) it was decided that some action was necessary for soils at Area 2. The mutually agreed upon decision to take action
at Area 2 was contrary to the direction planned as a result of the 30 November meeting, but was based upon new and more complete information.
It was agreed that the preferred alternative for addressing deep and shallow Area 2 soils would be excavation, low thermal treatment, backfilling, and bioventing. Soils will be cleaned up to comply with ACM Level B criteria. Therefore, the re-evaluation of the Alaska cleanup matrix at WP14 was not conducted. Excavation, treatment and backfilling would be conducted at the two surface locations which exceeded Level B criteria (SS-057 and SB-04). Bioventing of deep soils would also be conducted at two locations which exceeded Level B criteria (SB-01 and SB-03). This action would be protective of groundwater, as it addresses potential sources of contamination, and would also be favorable to the public.
|
Ray Burger |
| 1/1/1996 |
Update or Other Action |
Elmendorf AFB OU6 RI/FS Addendum January 1996. The 1995 investigation of the WP14/LF04 pipelines included a check on existing records of pipeline locations, a 70 point soil gas survey along portions of the lines within Elmendorf AFB boundaries
that had not been previously investigated, and the installation of one soil boring.
In addition, two of the 1994 RI wells were resampled to confirm previous analytical results for phthalates and five pairs of wells upgradient of and within areas of fuels contamination were sampled for remediation-related parameters. Analyses for these samples consist of dissolved oxygen, oxidation/ reduction potential,
common anions, sulfide, ferrous iron, methane, nitrite, ammonia, and total kjeldahl nitrogen (TKH). Finally, a groundwater seep associated with a July 1995 landslide near Building 30-790
was sampled and analyzed.
Soil gas data indicate no significant fuels contamination in most of the areas investigated along the abandoned pipelines. The only
area where soil gas data indicated contamination above the 100 ppb screening criteria is at the base of the bluff slope south of the pumphouse, near the boundary between the Base and the Port facilities.
Soil boring SB-100 was installed in this area of soil gas contamination at point SG-21. Soil boring SB-100 confirmed the presence of BTEX and UGRO in subsurface soils between 2 and 12 feet bgs. A groundwater grab sample was collected
from soil boring SB-100 and sent to the laboratory for analysis, but the boring was not converted to a monitor well. Contaminants detected in the groundwater sample from SB-100 included 676 pg/L total BTEX (473 ug/L benzene), 1710 ug/L UDRO, and 2820 ug/L UGRO. Additional investigation of this area of soil and groundwater contamination may take place in 1996 pending discussions between Base officials and POA personnel.
The best evidence supporting the occurrence of intrinsic remediation by both aerobic and anaerobic processes is provided by the soil gas data from 1994 and 1995. The 1994 and 1995 soil gas results show that methane concentrations corelate
with areas of elevated hydrocarbon contents in the groundwater, while the 1995 results for areas south of LF04 show a somewhat weaker correlation between carbon dioxide and hydrocarbons in the soil gas. Methane concentrations greater than one percent
are found in all of the areas where total BTEX in the soil gas exceeds 10,000 ppbv.
1995 data for hydrocarbons, methane and carbon dioxide for the area along the pipelines south of LF04 show high concentrations of methane in the most contaminated areas which suggest
that anaerobic degradation is the primary means of intrinsic remediation in the groundwater. The rate of hydrocarbon degradation cannot be estimated from this data since the flux of
methane and carbon dioxide is not known. Respiration tests which flush soil gases out with atmospheric air and then monitor the soil gas composition as carbon dioxide and methane reequilibrate
could provide estimates of the total rate of aerobic and anaerobic intrinsic remediation in the soils and groundwater at LF04 and WP14. |
Jennifer Roberts |
| 1/2/1996 |
Risk Assessment Report Approved |
Risk assessment incorporated as part of the final remedial investigation/feasibility study which was received and approved. Baseline risk assessment: soils at both contaminated areas at Source WP14 exceeded the 1x10-6 carcinogenic and the 1.0 non-carcinogenic hazard index (HI) for the future residential RME exposure scenario, which is the most conservative scenario. The major carcinogenic and non-carcinogenic contributors in soil are arsenic (risk of up to 1.8 x 10-5) and manganese (HI of 2.5). However, both arsenic and manganese are present at concentrations near or below the background UTLs. For the residential RME scenario, groundwater in aquifer 1 has a carcinogenic risk of 2.4 x 10-3, largely due to benzene (2x10-3), and a non-carcinogenic HI of 18.6, primarily due to toluene (12.0). The carcinogenic risk in aquifer 2 groundwater equals 1.2 x 10-5, with 1,2-dichloroethane and benzene being the largest contributors.
For visitor and subsurface occupational scenarios, the highest carcinogenic risks were 1.1 x 10-6 and 2.7 x 10-7 respectively, both due to arsenic in soil.
Ecological quotients greater than 1.0 were calculated for the black-capped chickadee, masked shrew, and meadow vole for selenium in soil. The highest selenium EQ equaled 180 for the masked shrew. However, substantial uncertainty may be associated with the selenium results since this metal was only analyzed by ICPES and is susceptible to interferences at concentrations close to the detection limit. |
Jennifer Roberts |
| 1/2/1996 |
Site Characterization Report Approved |
Remedial investigation for site detected gasoline range organics from Area 1 at a maximum concentration of 2,270 mg/kg in SB-07 to 3,150 mg/kg in SB-09. Soil samples from 15-17 feet below ground surface in MW-06 had 6,670 mg/kg. Jet fuel was found at 15-17 feet below ground surface at 2,050 mg/kg.
State of Alaaka Cleanup Level for Non-UST soil. Elmendorf OU 6 site. have been ranked as: LF02, LFO3, LF04, WP14, and SD73- Level B; and SDI5 - Level C.
Groundwater contamination maximum concentrations: benzene 2,100 ug/L SB-01, chlorobenzene 120 ug/L SB-07, ethylbenzene 2,100 ug/L SB-01, toluene 10,000 ug/L, xylenes 11,200 ug/L. Differences in composition of fuels contaminating the groundwater at different areas of WP14 suggest that several leaks have occurred over a period of years. Fuels in the groundwater at MW-06 are identified as unidentified gasoline range organics (UGRO) suggesting that some weathering of the fuel has taken place and that the release is several years old. Two rather distinct perched aquifers were identified underlying WP14: Aquifer 1 (shallow aquifer) and Aquifer 2 (deeper aquifer). The soils are divided up into two areas: Area 1 to the north encompassing wells MW-05, MW-06 and MW-12 and Area 2 to the south encompassing MW-15 and MW-46.
Recommendations: 2 principal sources of contamination at WP14.
1) Waste management practices conducted at the site. Residual fuels and solvents were made available to leach into the soil and groundwater as a result of disposal of tank sludge and weathering of fuel filters.
2) Active and inactive POL lines as well as other POL facilities such as valve pits were identified at WP14 in close proximity to the contaminated soil areas. DRO, GRO, BTEX were identified as COCs in soil for area 2. Area 1 had DRO, GRO and BTEX exceeding ACM standards however, it has been associated with the "smear zone" (The smear zone is defined as the range of depths within which the groundwater will fluctuate under normal seasonal conditions, and therefore, in which free product would move and “smear” the soil in response to these seasonal changes in the water level elevation. The smear zone soils may therefore be saturated or unsaturated with groundwater at any given time.) of Aquifer 1 and should therefore be considered as part of the groundwater contamination rather than the soil contamination. This smear zone contamination coincides with locations SB-07, SB-09, MW-06, MW-12. BTEX were detected in Aquifer 1 exceeding MCLs. Bis(2 ethylhexyl)phthalate, which was found to exceed 1.0 x 10-4 carcinogenic risk threshold, the 1.0 HI and MCL, has not been designated as a COC. BEHP is believed to be a degradation product (at 4,130 ug/L) of the sampling pipe in the presence of elevated concentrations of fuels, rather than being related to prior waste disposal activities at WP14. The isolated occurrence of this compound supports this interpretation. Aquifer 2 was found not to exceed the 1.0 x 10-4 to 1 x 10-6 acceptable risk range or HI threshold of 1.0 so no COCs were identified from a risk point of view.
*NOTE: Diesel range organics, gasoline range organics, BTEX contamination at levels exceeding the Alaska cleanup matrix in soil at Area 1 is associated with the smear zone of Aquifer 1 and should therefore be considered as part of the groundwater contamination. |
Jennifer Roberts |
| 4/2/1996 |
Proposed Plan |
WP14 (the Petroleum, Oil, and Lubricant [POL] Sludge Disposal Site No. 1) Sludge from cleaning
POL storage tanks was disposed in this approximately 300 feet by 400 feet area from 1964 to 1968. Fuel filters and pads were left on the ground to evaporate the fuel they contained over
time. In addition, some abandoned and some active underground fuel lines run through this site and were identified as sources of contamination. The area was covered with a layer of clean soil, and is currently covered with low alder growth.
Because of the geographical closeness and the similarity in contamination, WP14 and LF04 South are treated as a single unit in some places in this document, and are then referred to as LF04 South/WP14.
GW contaminant levels for fuel constituents, metals, solvents were above MCLs. Contaminants of concern: benzene 1,390 ug/L, (5 ug/L), ethylbenzene 1410 ug/L (700 ug/L), toluene 3,190 ug/L (1,000 ug/L), bis(2-ethylhexyl)phthalate 4130 ug/L (6 ug/L), cadmium 7.15 ug/L (5 ug/L).
Soil was also contaminated above action levels found in the Alaska cleanup matrix. DRO shallow soil: 555 mg/kg (200 mg/kg), deep soil: DRO 2,050 mg/kg (0.5 mg/kg), benzene: 1.83 mg/kg (0.5 mg/kg), BTEX 142 mg/kg (15 mg/kg), & GRO 6,690 mg/kg (100 mg/kg).
Groundwater preferred alternative: Long-term Monitoring with Institutional Controls & Oily Contaminant Removal is the preferred alternative for the groundwater at LF04 South/WPl4 Institutional controls will prohibit the use of the contaminated aquifer as a water supply, & annual monitoring will be conducted to track the progress of contaminant degradation & dispersion, as well as to provide an early indication of unforeseen environmental or human health risk.
This monitoring will be protective of Knik Arm because it will monitor the quality of the groundwater being discharged into it from these areas. Five-year reviews of contaminant levels will provide an additional safety net for human health & the environment. With this alternative, any detected amounts of oily contaminants on the groundwater will be regularly removed. This alternative is the only practical alternative in terms of implementability, due to the size & instability of the bluff, & it meets all of the other requirements. Furthermore, because the current & likely future use of groundwater at this site is not for drinking, & because contaminants in the groundwater are expected to decrease below regulatory levels within the next 30 years without active treatment, the cost-effective alternative is long term monitoring & institutional controls to ensure that the groundwater is not used for drinking water.
Soil-To support the implementation of long-term monitoring with institutional controls & oily contaminant removal at LF04 South/WP14, active treatment of the contaminated soils at WP14 will be conducted to prevent the possible movement of any of the soil contaminants into the groundwater in the future. Soil Alternative 4, Excavation, Low Thermal Treatment, Backfilling, & Bioventing, is preferred. Shallow soils containing unwanted fuel-type contaminants will be excavated & treated. At WPI4, a soil action is necessary to prevent direct contact with contaminants, & to remove the contaminants before they can reach the groundwater.
This will help restore the affected groundwater in a reasonable time frame. This process is the most rapid & cost-effective technology available, & as an active treatment, will prevent the movement of the shallow soil contaminants into the groundwater. Deep soils, also containing fuel & fuel by-product contaminants, will be cleaned by bioventing. This combined alternative for soils is the most protective to humans & animals, among the most easily implemented. & a permanent means of removing the contaminants from this source area.
Removal of Surface Debris was recommended as the preferred alternati ve for the LF04 North/Beach soils (Soil Alternative 6). At LF04 North/Beach, a variety of other alternatives were considered to address the exposed landfill material on the beach, such all capping or stabilization. However, due to the instability of the bluff slope, the overall size of the landfill area, & the fact that tidal action will continually cause slope erosion, slope capping & stabilization were considered impracticable. Annual removal of the landfill debris was considered reasonable, since it would prevent the accumulation of excessive debris on the beach & would reduce the chances of contact between the debris & humans or animals. This limited action is considered acceptable since the risks at the beach were low & the contaminants found were at low levels. Any hazardous contaminants from the landfill which might bc encountered on the beach will be handled appropriately. |
Louis Howard |
| 10/17/1996 |
Update or Other Action |
Air Force memo: Restricted Use of the Shallow Aquifer on dated October 17, 1996 Memorandum for 3 SPTG/CEC/CEO from 3 SPTG/CEV. 1) Due to the contamination & commitments to EPA/DEC the use of the shallow aquifer for any purpose on is not allowed. 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 Brigadier General USAF Commander.
The IRP has RODs for OUs 3 & 6 which require, the aquifer remain unused. 2) Personnel in the review process within CES must be aware of these policies & review them on a recurring basis. It is imperative this restriction be recognized & observed during engineer reviews & operations.
|
Louis Howard |
| 1/3/1997 |
Update or Other Action |
The risks for contaminated GW beneath OU 3 are above maximum contaminant levels (MCLs) however; ICs exist at the base for the shallow aquifer & GW monitoring of selected wells located within OU 3 is included as part of OU 5 GW monitoring. Therefore, action is not required for contaminated GW beneath OU 3 under this ROD. The IC against use of shallow GW at the base is through the Elmendorf Air Force Base Facility Board.
ARARS: The Safe Drinking Water Act is not an ARAR for this remedy since no further action is necessary for contaminated GW under the OU 3 ROD. However, it is the ARAR for the GW actions selected in the OU 5 ROD to protect GW receptors.
If further action to protect GW (beneath OU 3) is ever necessary, it will be done pursuant to the OU 5 or OU 6 RODs. OU6 Record of Decision: ICs on land use & water use, as specified in the Base Comprehensive Plan, will restrict access to the contaminated GW. Installation of wells in the contaminated plume for residential, industrial, & agricultural use will be prohibited by the Base Comprehensive Plan until cleanup levels have been achieved.
GW will be monitored semi-annually & evaluated annually to determine contaminant migration & to track the progress of contaminant degradation & dispersion, as well as to provide an early indication of unforseen environmental or human health risk. Five-year reviews will also assess the protectiveness of the remedial action, including an evaluation of any changed site conditions, as long as contamination remains above cleanup levels.
Recoverable quantities of free product found on top of the water table will be regularly removed during GW monitoring events. GW monitoring will be discontinued if contaminant levels are below cleanup levels during two consecutive monitoring events. In that case, no further action for GW will be required.
During the final round of monitoring, samples will be collected & analyzed for ALL constituents that exceeded MCLs during the [remedial] investigation including [but not limited to] VOCs, SVOCs, & metals. These results will be evaluated before a final determination is made that GW meets all cleanup requirements.
OU3 RI
OU3 EAST GW Area (cleanup level)
SD16
TCE 140 ug/L (5 ug/L)
PCE 9.37 ug/L (5 ug/L)
Toulene 1,019 ug/L (1,000 ug/L)
Tetrachloroethene 9.37 ug/L (5 ug/L) MW-11 Appendix R Lab Data (RI/FS OU3)
Intercourse Area-East
TCE 11.5 ug/L (5 ug/L)
1,4-DCB 161 ug/L (75 ug/L)
Benzene 47.9 ug/L (5 ug/L)
Carbon Tetrachloride 29.5 ug/L (5 ug/L)
TCE 35.3 ug/L (5 ug/L)
PCE 33.8 ug/L (5 ug/L)
Bis(2-Ethylhexyl)phthalate 1,150 ug/L (6 ug/L) MW-11 Appendix R Lab Data (RI/FS OU3)
SS21 Table 4-17
TCE 10 ug/L (5 ug/L)
The maximum concentrations of TCE in OU 3 east were found in the groundwater from monitoring wells MW11 and MW12, located at source SDI6. MW11l, which was screened across the water table at the bottom of the aquifer, contained up to 2.98 ug/L cDCE and 140 ug/L TCE. MW12, which is located adjacent to MW11 but is screened at the top of the aquifer, contained 6.46 ug/L cDCE and 44.4 ug/L TCE. Samples from neighboring well MW13 also contained up to 26.9 ug/L TCE. These three wells defined an area of significantly higher TCE concentrations than in surrounding wells to the east and west (up to about 6.ug/L TCE). Elevated TCE concentrations (up to 19.8 ug/L) were also detected in samples from well MW2, which is located approximately 2500 feet south-southeast of wells MW11 and MW12. The presence of cDCE in the groundwater correlates in general with the
presence of TCE, with an elevation in concentrations being present primarily at wells MW13 (up to 14.2 ug/L) and MW12 (up to 6.46 ug/L). Another significantly higher cDCE concentration than in surrounding areas was noted at well MW2 (up to 11 ug/L). which also coincides with an elevation in TCE levels in the groundwater. Concentrations of TCE and/or cDCE exceeding 1 J1.gfL were found as far east as MW15, and as far southwest as MWl6 in the east intersource area with few to no non-detects in between.
The wells at SS21 (MW5R and MW6) were sampled for PCBs; two rounds of sampling did not detect PCB contamination in the groundwater. Benzene was found in the groundwater samples from 12 wells in OU 3 East. The highest concentrations were detected at wells MW12, MW13 and MW14 at source SD16 (maximum of 6.17 ug{L at MW13). roughly coinciding with the maxima observed for TCE and cDCE. |
Louis Howard |
| 1/27/1997 |
Cleanup Level(s) Approved |
Groundwater: benzene 5 ug/L, ethylbenzene 700 ug/L and toluene 1000 ug/L (*NOTE cadmium and chromium were not identified as contaminants of concern since they marginally exceeded MCLs but they did not contribute to significant risk or were determined to be statistically below background levels).
Soils were originally identified to contain fuel constituents in excess of Alaska cleanup matrix level B guidelines (100 mg/kg GRO, 200 mg/kg DRO, 2000 mg/kg RRO, 0.5 mg/kg benzene and 15 mg/kg Total BTEX). During preparation of the ROD, ADEC, EPA, USAF determined that level C criteria would be more appropriate at WP14. Shallow soils did not exceed level C so no action was needed for these soils. Deep soils had DRO, GRO, benzene and BTEX exceeding cleanup guidelines.
A treatability study conducted at WP14 in August 1996 determined that this contamination is in the "smear zone" (The smear zone is defined as the range of depths within which the groundwater will fluctuate under normal seasonal conditions, and therefore, in which free product would move and “smear” the soil in response to these seasonal changes in the water level elevation. The smear zone soils may therefore be saturated or unsaturated with groundwater at any given time.).
Because smear zone soil contamination is believed to be the result of groundwater contaminants adhering to the exposed soil particles during periods where the water table is low, these contaminants are indistinguishable from groundwater contamination. Therefore, smear zone contamination will be addressed as part of the groundwater remedy. Data collected during the RI showed that there was no deeper soil contamination beneath the smear zone thus, there are no COCs for deep soils at WP14.
ROD: "During the final round of monitoring, samples will be collected and analyzed for ALL
constituents that exceeded MCLs during the 1994 investigation including VOCs, SVOCs, and metals. These results will be evaluated before a final determination is made that groundwater meets all cleanup requirements."
MCL Exceedances 1994 RI Table 10
"Jet Fuel" 554,000 ug/L (exceeds 2,200 ug/L GRO and 1,500 ug/L DRO)
Benzene 1,390 ug/L (5 ug/L)
Ethylbenzene 1,410 ug/L (700 ug/L)
Toluene 3,900 ug/L (1,000 ug/L)
2-Methylnaphthalene 630 ug/L (150 ug/L)
bis(2-Ethylhexyl)phthalate 4,130 ug/L (6 ug/L) |
Jennifer Roberts |
| 1/27/1997 |
Institutional Control Record Established |
Institutional controls (ICs) on land use and water use, as specified in the Base Comprehensive Plan (BCP) will restrict access to the contaminated GW throughout WP14. Installation of wells in the contaminated plume for residential, industrial and agricultural use will be prohibited by BCP until cleanup levels have been achieved. GW will be monitored semi-annually and evaluated annually to determine contaminant migration and to track the progress of contaminant degradation and dispersion, as well as to provide an early indication of unforeseen environmental or human health risk. 5-year reviews will also assess the protectiveness of the remedial action including an evaluation of any changed site conditions, as long as contamination remains above cleanup levels. Recoverable amounts of free product found on top of the water table will be regularly removed during GW monitoring events. During the final round of monitoring, samples will be collected and analyzed for all constituents that exceeded MCLs during the 1994 investigation including VOCs and SVOCs and metals. These results will be evaluated before a final determination is made that GW meets all cleanup requirements. All GW is expected to be cleaned up within 14 years. |
Louis Howard |
| 1/27/1997 |
Long Term Monitoring Established |
Installation of wells in the contaminated plume for residential, industrial and agricultural use will be prohibited by BCP until cleanup levels have been achieved. GW will be monitored semi-annually and evaluated annually to determine contaminant migration and to track the progress of contaminant degradation and dispersion, as well as to provide an early indication of unforeseen environmental or human health risk.
Five year reviews will also assess the protectiveness of the remedial action including an evaluation of any changed site conditions, as long as contamination remains above cleanup levels. These periodic reviews are a NCP requirement under CERCLA since waste remains in place at the source area at levels which preclude unrestricted use. Recoverable amounts of free product found on top of the water table will be regularly removed during GW monitoring events. During the final round of monitoring, samples will be collected and analyzed for all constituents that exceeded MCLs during the 1994 investigation including VOCs and SVOCs and metals. These results will be evaluated before a final determination is made that GW meets all cleanup requirements. All GW is expected to be cleaned up within 14 years. |
Louis Howard |
| 1/27/1997 |
CERCLA ROD Approved |
ROD memorializes NFA for the soils at WP14. Level C criteria applies and the shallow soils do not exceed this criteria. The deep soils listed in the PP as being contaminated with DRO, GRO, BTEX.
However, a treatability study in August 1996 showed the contamination was in the "smear zone" (The smear zone is defined as the range of depths within which the groundwater will fluctuate under normal seasonal conditions, and therefore, in which free product would move and “smear” the soil in response to these seasonal changes in the water level elevation. The smear zone soils may therefore be saturated or unsaturated with groundwater at any given time.) present at the soil/groundwater interface. Because the smear zone soil contamination is believed to be the result of GW contaminants adhering to exposed soil particles during periods where the water table is low and rises during periods of high groundwater.
The smear zone contamination will be addressed as part of the GW remedy. NFA designation will be assigned for deep soils, too. ICs on land use and water use, as specified in the Base Comprehensive Plan (BCP) will restrict access to the contaminated GW throughout WP14.
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 sub-stances, 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.
Installation of wells in the contaminated plume for residential, industrial and agricultural use will be prohibited by BCP until cleanup levels have been achieved. GW will be monitored semi-annually and evaluated annually to determine contaminant migration and to track the progress of contaminant degradation and dispersion, as well as to provide an early indication of unforeseen environmental or human health risk. 5 year reviews will also assess the protectiveness of the remedial action including an evaluation of any changed site conditions, as long as contamination remains above cleanup levels. Recoverable amounts of free product found on top of the water table will be regularly removed during GW monitoring events. During the final round of monitoring, samples will be collected and analyzed for all constituents that exceeded MCLs during the 1994 investigation including VOCs and SVOCs and metals. These results will be evaluated before a final determination is made that GW meets all cleanup requirements. All GW is expected to be cleaned up within 14 years. |
Louis Howard |
| 3/13/1997 |
Update or Other Action |
Action 3/13/97, based on Relative Risk Evaluation worksheet dated 8/18/95. Local soil used to cover the site when it was closed. Vegetative cover is mixed with some stressed areas. Several active/abandoned POL lines cross the site. Pathways: No contact by human or ecological receptors with contaminated soil and/or use of contaminated groundwater. Currently no drinking water wells within or downgradient of the aquifer below site. Two aquifers were detected below the site, shallow aquifer contaminated (BTEX, fuels, metals). Aquifers merge downgradient. Off-site migration of contaminated GW to LF04 is not apparent. Soil contaminated with fuels and metals. Receptors: Area is remote and undeveloped, but is used recreationally. Workers also use area when servicing/maintaining the POL lines. Moose, bear, smaller mammals inhabit the area. Incidental use by migratory waterfowl not impacted by contamination since it is underground. |
Louis Howard |
| 4/2/1997 |
Meeting or Teleconference Held |
Restoration advisory board meeting held and announced beforehand in the Anchorage Daily News 3/28-30/97 and the Sourdough Sentinel 3/28/97. |
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 |
| 8/24/1998 |
Update or Other Action |
8/98 remedial action report states that the benzene, ethylbenzene, and toluene impacted groundwater will meet MCLs in 14 years. |
Louis Howard |
| 11/4/1999 |
Update or Other Action |
OU6 Round 2 1999 sampling results in for groundwater monitoring. Free product found during sampling in monitoring wells MW-12, MW-18, MW-63 and MW-77. MW-77 consistently contained the most free product and the thickness of product during the spring 1999 event was measured at 0.45 feet which was an increase from previous sampling events. NOTE to File: “free product” means a concentration of a hazardous substance that is present as a nonaqueous phase liquid; for purposes of this paragraph, a “nonaqueous phase liquid” is a liquid that is not dissolved in water. OU6MW-06 benzene levels increased from 400 in round 1 to 620 ug/l in round 2. |
Louis Howard |
| 9/5/2000 |
Document, Report, or Work plan Review - other |
Staff reviewed and commented on the work plan for a supplemental remedial investigation. Main comments centered on identification of applicable, or relevant and appropriate requirements from the OU6 management plan. Include provisions for recommendations of recovery of any free product found during the course of investigation at the site. |
Louis Howard |
| 10/24/2000 |
Update or Other Action |
John Bauer PERP spill staff received fax from EAFB staff Mario Frisby regarding product found in monitoring well on October 6, 2000. Suspected pipeline (North Jet Pipeline) was shutdown and samples taken for product fingerprinting. |
John Bauer |
| 10/25/2000 |
Update or Other Action |
Staff received data from pipeline pressure testing conducted on 10/20/2000. 2 mile section buried underground 12 inch diameter 24 hour test at 376 to 389 psi. Test results showed 6.89 gallons unaccounted for during the 24 hour period. Lab testing for fingerprinting was inconclusive, whether it was "fresh" product, but identified it as jet fuel like product. Next step is to conduct some type of tracer (vapor) testing to pinpoint the leak from the pipeline and then dig it up. |
Louis Howard |
| 3/20/2001 |
Update or Other Action |
Memo on PDBs being used as a "Beta Test" at Elmendorf AFB & Eielson AFB. The “Kick-off” meeting in Seattle, 20 March 2001, is intended to introduce the Remedial Process Optimization (RPO) process & the Passive Diffusion Bag Samplers (PDBS) guidance document “beta test” project at Elmendorf AFB & Eielson AFB, AK. The HQ Air Force Center for Environmental Excellence (AFCEE) is conducting an exhaustive “beta test” of the Guidance Document for Use of Polyethylene-Based Passive Diffusion Bag Samplers to Obtain Volatile Organic Compound Concentrations in Wells, described below, & provide feedback to the PDBS workgroup to update the Interagency PDBS Guidance Document for Installation Restoration Program (IRP) managers. The RPO & PDBS guidance document “beta test” will incorporate remediation programs at Elmendorf AFB & Eielson AFB, AK.
Passive diffusion bag (PDB) samplers are suitable for obtaining representative concentrations of volatile organic compounds in ground water in observation wells. A typical PDB sampler consists of a low-density polyethylene lay-flat tube closed at both ends & containing deionized water. The sampler is positioned at the target horizon by attachment to a weighted line. The PDB samplers equilibrate within approximately 48 hours for several tested volatile organic compounds, however vinyl chloride & some chloroethanes may require between 96 & 168 hours to equilibrate. The samplers should be allowed to remain in the well a minimum of two weeks prior to recovery to allow the well water to restabilize following sampler deployment. Recovery consists of removing the samplers from the well & immediately transferring the enclosed water to 40-milliliter sampling vials for analysis.
The method has both advantages & limitations. Advantages include the potential for PDB samplers to eliminate or substantially reduce the amount of purge water associated with sampling. The samplers are relatively inexpensive & easy to deploy & recover. Because PDB samplers are disposable, there is no downhole equipment to be decontaminated between wells & there is a minimum amount of field equipment required. The samplers also have the potential to delineating contaminant stratification in the open or screened intervals of observation wells where vertical hydraulic gradients are not present.
A possible disadvantage of the samplers is that they integrate concentrations over time. Depending on the compound of interest, this time may range between about 48 to 168 hours. The samplers are not applicable for all compounds. They are not effective for inorganic ions, for highly soluble organics such as methyl-tert¬-butyl ether, or poorly soluble organic compounds. An additional disadvantage is water must be freely flowing through the well screen for the samplers to be effective. VOC concentrations in PDB samplers represent concentrations in the vicinity of the sampler within the well screen or open interval. This may be a limitation if the ground-water contamination is above or below the screen, or not in the interrogated sample intervals. If there are vertical hydraulic gradient in the well, then the concentrations in the sampler represent the concentrations in the water flowing vertically past the sampler rather than in the formation immediately adjacent to the sampler. Multiple PDB samplers may be needed in chemically stratified wells or where flow patterns through the screen change as a result of ground-water pumping or seasonal fluctuations.
|
Louis Howard |
| 6/29/2001 |
Document, Report, or Work plan Review - other |
Staff reviewed and commented on the site evaluation for WP14. The text states that there were no contaminants of concern for soil. This is mostly correct, however ADEC requests the text include additional language “...no contaminants of concern exceeding Alaska Cleanup Matrix Level C guidelines in soil.” The no further action decision was based on no contaminants of concern being identified which exceeded Level C guidelines in place at the time of the finalization of the Record of Decision.
The text states NA = No Record of Decision cleanup level was established for the following analytes in soils: benzene, ethylbenzene, toluene, total xylenes. Pages 2-23 and 2-34 of the OU 6 ROD states that a consensus was reached between ADEC, USEPA, and USAF that the ACM Level C guidelines is more appropriate for the site conditions at WP14. ACM Level C would be protective of human health and the environment and is more stringent than the level being used at similar sites elsewhere. Level C guidelines at the time the ROD was signed listed total BTEX (benzene, toluene, ethylbenzene, and total xylenes) at 50 mg/kg and benzene at 0.5 mg/kg. Please correct Table 1-1 to reflect the 0.5 mg/kg cleanup level in soils. ADEC concurs with the recommendations and requests the OU 6 ROD cleanup levels for soils be used. Specifically, Alaska Cleanup Matrix values identified in the ROD were ACM Level C guidelines: diesel range organics (DRO)-1,000 mg/kg, gasoline range organics (GRO)- 500 mg/kg, Total BTEX-50 mg/kg and benzene-0.5 mg/kg. |
Louis Howard |
| 2/21/2002 |
Document, Report, or Work plan Review - other |
Staff reviewed and commented on the base-wide annual groundwater monitoring report.
Regulatory Levels
ADEC requests removing the word “Potential” from the heading “Potential Regulatory Level” in the tables throughout the document. Listing the word “Potential” gives the reader the impression that compliance with the levels listed is optional or not required (e.g. Tables 4-7, 4-11, 4-15, 4-20, 4-25, 4-29, 4-32, and 6-2).
Free Product
Please note 18 AAC 75.325(f) states: A responsible person shall to the maximum extent practicable,
(A) use permanent remedies;
(B) recover free product in a manner that minimizes the spread of contamination into an uncontaminated area by using containment, recovery, and disposal techniques appropriate to site conditions.
ADEC recognizes that in some cases it may not be technically practicable to implement an active or passive recovery system for free product. The Elmendorf Remedial Action Report for Operable Unit (OU) 2 (September 1998) set a precedent for defining what is meant by “technically practicable” for free product recovery. Section 2.4.1 Product Recovery Endpoints at the 1st bullet on page 10 states: “As designed and constructed, the ST41 ground water treatment system cannot recover floating product when there is less than a measurable thickness of 0.1 feet of product. Therefore, as an endpoint for product recovery, if less than 0.1 feet is sustained for one year, recovery at that source can be discontinued. Floating product will be measured monthly. When product thickness falls below 0.1 feet for one year, the recovery of product at that source will not be considered “technically practicable”.
Therefore, where free product is greater than 0.10 feet, ADEC expects corrective action (active or passive) to be implemented for free product recovery. Currently, free product was found to exceed 0.10 feet or more in SERA Phase I well 43-WL-11. This well had the highest level of free product measured at 0.86 feet. The presence of measurable free product is generally not considered conducive for intrinsic (natural) attenuation. ADEC requests the identity of the free product be described in the text at each source area that it is found (e.g. gasoline, diesel, or chlorinated solvents).
3.3.4 Target Analytes Pages 3-10 and 3-11
Benzene and TCE are identified as target analytes to evaluate contaminant of concern (COC) trends in detail and be consistent with the Base-wide Groundwater model. ADEC concurs, however, focusing on these two analytes does not accurately reflect whether diesel range organics (DRO) and gasoline range organics (GRO) plumes are migrating, expanding, steady state, or receding (especially for wells noted to have either free product or fuel odor and/or sheen being observed during sampling). Benzene can be at low levels or even non-detectable while concentrations of DRO and GRO remain above cleanup levels (1.5 mg/L and 1.3 mg/L respectively). Please see the following examples below of where benzene was below the 5 ug/L cleanup level, but DRO and GRO are above cleanup levels.
OU 4
Round 1 sampling at well 49-WL-01 detected benzene at 0.11 ug/L and DRO at 2,400 ug/L and well OU4W-11 detected benzene at 4.3 ug/L while GRO was detected at 3,000 ug/L and DRO was detected at 6,100 ug/L.
OU6
Round 1 sampling at well OU6MW67 detected benzene at 2.8 ug/L, GRO at 2,500 ug/L and DRO at 1,700 ug/L during round 1 sampling. During round 2 sampling, well OU6MW-91 detected GRO at 25,000 ug/L and DRO at 9,500 ug/L while benzene was found to be non-detectable.
See site file for additional information. |
Louis Howard |
| 7/28/2002 |
Enforcement Agreement or Order |
ADEC (CS Program S. Bainbridge, Leslie Pearson PER Program) and Air Force (Daniel Barnett) signed the Operational Agreement (OA) concerning presumptive remedies for cleanup of certain petroleum oil and lubricant releases on the outwash plain portion of Elmendorf AFB, Alaska. This OA establishes and describes pre-approved presumptive remedies but does not establish an exclusive set of cleanup options and nothing in the memorandum prohibits EAFB from seeking or obtaining ADEC approval to implement alternative release response and remedial action plans.
For new POL spills in the outwash plain that occur in areas with no operational restrictions or interference from surrounding structures, ADEC approves immediate remediation of contaminated media after free product has been recovered in a manner that minimizes the spread of contamination into an uncontaminated area by using containment, recovery, disposal techniques appropriate to site conditions. The presumptive remedy for new POL spills on the outwash plain consist of excavation, treatment, and disposal of all impacted soil.
On a case-by-case basis, ADEC will evaluated the need for recovery of free product from the water table. Finally groundwater monitoring and ICs placed on the shallow aquifer restricting its use as a drinking water source will be required until such a time that the appropriate groundwater remedial goals are met. If additional institutional controls are required, these controls will be developed by EAFB in consultation with ADEC.
The OA does not apply to spills impacting surface waters. Nothing in the OA relieves, extends or changes the applicable requirements of 18 AAC 75 and 78 for the proper treatment, storage or disposal of contaminated media that result from the implementation of this OA. |
Steve Bainbridge |
| 8/28/2002 |
Meeting or Teleconference Held |
STATUS MEETING MINUTES 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 ofTCE at OUS 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 semiannually
ifupgradient 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 |
| 1/14/2003 |
Meeting or Teleconference Held |
Attendees: Joe Williamson (USAF), Gary Fink (USAF), James Klasen (USAF), Kevin Oates (EPA), Louis Howard (ADEC), Cory Hinds (URS), Paul Dworian (URS), Kristin Paul (URS)
Agenda: Discuss ADEC’s request to add the analyses of Diesel Range Organics (DRO) and Gasoline Range Organics (GRO) to several Operable Units at Elmendorf.
Summary of Discussion:
1. URS summarized recent (year 2000) ADEC risk assessment guidance that shows that DRO and GRO themselves can cause noncarcinogenic human health risks. This information was not known during preparation of the risk assessments and RODs for Elmendorf Operable Units. Therefore, addition of DRO/GRO to the sampling scheme for Elmendorf was recommended.
2. The Air Force agreed to add DRO/GRO, but cannot add funding to cover the additional analysis until 2004.
3. The following was decided on implementation:
A. This decision will be documented in the 5-Year Review. The addition of DRO/GRO to the program should be introduced in the 5-Year Review under mention of new issues affecting protectiveness.
B. The Air Force will NOT add DRO/GRO as a CERCLA ARAR, but will compare DRO/GRO results to ADEC cleanup levels in the annual reports and will discuss in subsequent 5-Year Reviews. The benefit of this is that if CERCLA COCs meet ARARs, the Air Force can achieve a partial delisting.
C. The Air Force will add DRO and GRO to the suite of analyses at monitoring wells associated with fuel plumes starting in 2004.
D. The Air Force will not pursue a decision document with ADEC on DRO/GRO until more data is gathered on the extent of the problem.
E. Until a decision document is signed with ADEC, GRO and DRO concentrations will be compared to ADEC regulations in 18 AAC 75 (Table C, Groundwater Cleanup Levels; 1,500 µg/L for DRO, 1,300 µg/L GRO).
F. Sampling frequency for DRO/GRO will follow the latest Decision Guide for Sampling Frequency (see 2002 Basewide Annual Report). “Immediately upgradient” means within a 2-year warning line, similar to that generated for OU5.
G. ADEC GRO/DRO criteria apply to groundwater, not to seeps which daylight as surface water. Criteria in 18 AAC 70 (TAH, TaqH) apply to surface water.
(NOTE to file: 18 AAC 70 Alaska Water Quality Criteria: Total aqueous hydrocarbons (TAqH) in the water column may not exceed 15 ug/l (See note 8). Total aromatic hydrocarbons (TAH) in the water column may not exceed 10 ug/l. Samples to determine concentrations of total aromatic hydrocarbons (TAH) and total aqueous hydrocarbons (TAqH) must be collected in marine and fresh waters below the surface and away from any observable sheen. Concentrations of TAqH must be determined and summed using a combination of: (A) EPA Method 602 (plus Xylenes) to quantify monoaromatic hydrocarbons and to measure TAH; and (B) EPA Method 610 to quantify polynuclear aromatic hydrocarbons.
Use of an alternative method requires department approval. The EPA methods referred to in this
note may be found in 40 C.F.R. 136, Appendix A, as amended as of February 14, 1996, adopted
by reference. They may be reviewed at the department or are available from the Office of
Monitoring Systems and Quality Assurance, Office of Research and Development, United States
Environmental Protection Agency, Washington, D.C. 20460.) |
Louis Howard |
| 9/25/2003 |
Update or Other Action |
Memorandum to the Site File signed for OU 6. The purpose of this document (Memorandum to the Site File) is to present non-significant or minor changes to the Record of Decision (ROD) signed for OU 6 and Source Area SS 19 at EAFB. The minor changes to the OU 6 ROD involve modifying the sampling frequency of groundwater wells and the inclusion of portions of the shallow soils at SD 15 in a high-vacuum extraction (HVE) treatability study. Other components to the OU 6 selected remedy will not be affected by this minor change.
This minor revision to the ROD changes the sampling frequency for groundwater monitoring.
Data collected semi-annually over the past seven years has provided an understanding of the
nature and extent of contaminant migration and the effectiveness of intrinsic (natural)
remediation. In many instances continuation of the semi-annual sampling would not provide any
useful new data as compared to less frequent monitoring.
The second component of the minor revision to the ROD includes implementing a high-vacuum
extraction treatability study for shallow soils at SD15. Approximately 170 yd3 of fuel contaminated soil was excavated and treated during the implementation oft.he selected remedy in
1996. Confirmation samples indicate that two of the four areas have elevated levels of
contamination and will, therefore, be included in the high-vacuum extraction treatability study.
Further soil excavation will be determined after evaluation of treatability study results.
Sampling changed from semi-annually to a frequency determined by the Decision Guide for WP 14.
The changes to the sampling frequency will continue to provide sufficient data to assess
contaminant migration and timely reduction of contaminant concentrations by intrinsic
remediation as required by the ROD. The revised monitoring frequency will also streamline the
groundwater reporting process and reduce monitoring costs.
The changes to the sampling frequencies were discussed in the 28 Aug 02 meeting between the
USAF, Region X of the EPA and the ADEC. The high vacuum extraction treatability study for shallow soils at SDl5 was agreed upon at the 11 Jun 03 Remedial Project Manager Meeting between the USAF, Region X of the EPA and the ADEC. Both EPA and ADEC project managers concurred with the proposed changes. This change in the ROD does not significantly change or fundamentally affect the remedy selected in the ROD; therefore, no public comment is required. |
Louis Howard |
| 1/27/2004 |
CERCLA ROD Periodic Review |
Second Five Year Review for EAFB signed by ADEC. Table 4-22 in the Five Year review incorrectly described the land use controls at WP14. WP14 is not a landfill or disposal site and there are no "Restricted Use Area" land use controls. The only land use controls at WP14 pertain to groundwater restrictions.
Second Five Year review received. Land use controls restrict access to contaminated groundwater throughout the site. Installation of wells in the contaminated plume for residential, industrial, or agricultural use will be prohibited until cleanup levels have been achieved. |
Louis Howard |
| 2/3/2005 |
Meeting or Teleconference Held |
Meeting minutes from RPM meeting February 3, 2005, ADEC and EPA agreed to decrease the frequency of quarterly reports to semi-annual or twice a year. Elmendorf FFA XIII. REPORTING 13.1 USAF shall submit to the other Parties quarterly written progress reports. The reports will include, but not be limited to, the following information: (a) A detailed summary of all of the remedial, removal, and investigation activities during the previous quarter, including any analytical results, any community relations activities, and any community contacts or inquiries related to the hazardous substance contamination at the Site; (b) An outline of the planned activities for the upcoming quarter;(c) A detailed statement of the manner and the extent to which the timetables and deadlines are being met;(d) The status of efforts to obtain rights-of-entry necessary for monitoring and well installation off base; and(e) The status of any other activities proposed or underway that may affect any phase of the activities described in the Attachments.
13.2 The quarterly written progress reports shall be submitted on the tenth (10th) day of each calendar quarter following the effective date of this Agreement.
Groundwater (GW) Remedial Process Optimization (RPO) Recommendations (Mr.Fink). Mr. Fink explained that we asked an outside team to look at the Fairchild and Slammer TCE plumes. Previous modeling efforts left data gaps and too many uncertainties. It was unclear if monitored natural attenuation (MNA) was progressing at the rate required to meet our projected cleanup dates. Additionally, we asked the team to review the recently developed long-term monitoring plan for DP98, to determine if we were taking the correct approach. We also asked the team to look at ST36/66 since we are considering shutting down bioventing systems at these sites. In summary, the team suggested that we would not be able to meet the 2025 proposed cleanup dates for the Fairchild and Slammer plumes. The team suggested more of a risk-based approach, specifically at the seeps. Mr. Fink stated that he was not really comfortable with the
suggested approach.
The team suggested cutting back on sampling within the plume and increasing sampling down gradient. Additionally, they suggested that we use a mass based or I-dimensional model instead of a complex numerical model. We intend to run the simpler models, and we expect that our projected cleanup dates will change. EPA remarked that it doesn't really matter what model we use and emphasized that compliance sampling is really the bottom line. Mr. Williamson agreed but pointed out that we need an accurate prediction of cleanup times so that we can effectively develop our budget for the out-years. He also pointed out that we have leases that may expire,
without the possibility of renewals, and we need to plan accordingly. Mr. Fink discussed
the team's suggestion of changing the allowable limits of contamination into Ship Creek.
EPA stated that this would be a move in the wrong direction since Elmendorf has always taken an aggressive protective stance towards Ship Creek, which has been appreciated and well-received in the local community. As far as DP98 is concerned, the RPO team suggested some sampling well points but no outstanding recommendations.
For ST36/66, the team stated that existing sentry wells seemed sufficient and indicated that nothing was leaving the perched aquifer. They didn't think that revamping the bioventing system in an attempt to reach the contaminated lens was worthwhile. They suggested that a vapor test might provide enough additional information to justify shutting down the bioventing system. The team suggested changing the clean-up goals basewide, but Mr. Mayer stated that he rejected that proposal and would only consider the possibility of cleanup goal changes on a site-by-site basis. EPA asked where steps Elmendorf intended to take in light of the team's suggestions. Mr. Fink stated that we plan to implement mass based modeling, establish "best guess" cleanup dates, focus on the Slammer plume, determine if TCE is leaving the beaver pond, and determine if creating a new mulch barrier is needed for the beaver pond.
Quarterly Progress Reports (QPRs) (USAF). EPA and ADEC confirmed that the information they receive in the report, in its current format, is quite useful to them when they are briefing their higher headquarters. Both agreed that we could reduce submittals to semi-annual reports, which will be submitted in December and May of every year. ADEC requested that we continue to break sites out by Operable Unit since that is the way their database has been designed to track. |
Louis Howard |
| 3/31/2005 |
Update or Other Action |
2004 Phase I Remedial Process Optimization (RPO) annual report received. The WP14/PL81 North Plume is located on the western portion of Elmendorf AFB above the Knik Arm Bluff near the intersection of 26th Street and the Knik Bluff Trail. The WP14/PL81 North Plume runs primarily northeast to southwest, as shown in Plate 1. The known extent is up to 800 feet in length, with a width of approximately 400 feet. The source of this plume was determined to be Valve Pit 11, which is part of a now abandoned pipeline designated PL81. It should be noted that there are numerous documented sources within the WP14/PL81 North Plume vicinity, including WP14 and LF04.
Three groundwater monitoring wells and two seeps associated with the WP14/PL81 North Plume. Wells 14MW-120 and 14MW-121 had benzene at 13 and 8.1 ug/L respectively. Wells 14MW-121 and OU6MW-91 had GRO at 2,200 ug/L and 4,500 ug/L respectively. OU6MW-91 was the only well to have DRO at 2,500 ug/L. Both seep sample locations were below TAH and TAqH criteria in 2004. Sample LF04-SP04 had had benzene at 5.4 ug/L and TAH levels at 97.7 ug/L. TAqH was never analyzed for in either seep location.
Although natural attenuation does not appear to be removing contaminant mass from this plume, this decreasing COC trend exists. It is uncertain whether natural processes will lower COC concentrations to below ROD cleanup levels by the 2011 cleanup date. As a result of this uncertainty, no wholesale performance monitoring changes are recommended for the WP14/PL81 North Plume at this time.
The OU 6 ROD mandated that 5-year reviews be performed at the WP14/PL81 North Plume to evaluate the performance of the selected remedy (land use controls and MNA) and to determine whether the selected remedy is protective of human health and the environment. The next 5-year review is due to be performed in 2008. Although it is uncertain whether cleanup levels will be achieved by 2011, this remedy should be considered protective. Plume expansion is not occurring, and potential downgradient receptors are not being exposed to groundwater contaminants. |
Louis Howard |
| 5/19/2006 |
Update or Other Action |
Future well maintenance recommendations from the 2005 Annual Basewide Groundwater Monitoring Field Report. The Zone 1 sentry seeps are located north of the WP14/PL81 North Plume along the bluff above Knik Arm. Three seeps, LF04SP-05, LF04SP-06, and LF04SP-07, are sampled on an annual basis during monitoring events. Seep monitored by LF04SP-06 priority 2 needs the PVC casing needs to be replaced or re-installed. |
Louis Howard |
| 2/26/2007 |
Exposure Tracking Model Ranking |
|
Louis Howard |
| 4/12/2007 |
Update or Other Action |
2007 Zone 1 Remedial Process Optimization (RPO) Report received for comment.
PL81
For the OU6MW-46 plume in 2007, in well OU6MW-46, the highest benzene concentration (377 µg/L) was well above the action limit of 5 µg/L, & the highest ethylbenzene concentration (862 µg/L) was above the action limit of 700 µg/L. This well was sampled by PDB in addition to in-well pumping at 1 & 20 feet bswl. The PDB sample at 1 foot bswl had much lower COC concentrations than those collected by in-well pumping, & the two in-well pumping samples were nearly identical. The deep PDB sample results were the highest for both benzene & ethylbenzene & matched the concentrations of both pump samples.
The discrepancy between the shallow PDB sample & the collocated pumped sample is readily explained: The PDB sampled the static water column, which at this depth contained only low COCs; the collocated pumped sample sampled deeper water that was brought up during purging . Although low-flow protocol was observed during purging to facilitate only lateral flow to the pump intake, subsequent investigation revealed that the well is screened only in its lower 10 feet. Thus, the shallow pumped sample actually drew water from approximately the same depth as the deep pumped sample.
The second well associated with the OU6MW-46 plume (OU6MW-15) was found to be essentially free of contamination. Although no precise top-of-casing elevation exists for this well, its static water level was estimated at 135 feet above msl, compared to 188.65 feet msl for OU6MW-46. The difference of approximately 53 feet indicates that the two wells are completed in separate aquifers, with OU6MW-46 perched above OU6MW-15. The absence of contamination in the lower aquifer downgradient of the plume indicates that the plume is stationary.
For the PL81 South plume in 2007, the GW results for benzene (0.55 µg/L), GRO (246 µg/L), & DRO (ND, with a method-detection limit of 1,220 µg/L) were below the action limits (5, 1,300, & 1,500 µg/L, respectively), as were concentrations of benzene, TAH, & TAqH in the seep & its downgradient extension
Recommendations:
• For the PL81 South plume, eliminate sampling at LF04SP-02DG. This location is on the stream that originates at seep LF04SP-02, along which substantial attenuation of COCs occurs; LF04SP-02DG has always tested lower than cleanup levels, even when COC concentrations at the seep were quite high (2004 & 2005). COC concentrations in LF04SP-02DG have been ND in each of the past 2 years & are likely to remain ND, given the apparent shift in plume dynamics to much lower concentrations.
• If results in 2008 for PL81 South remain below cleanup levels, pursue closure of this site in accordance with the OU6 ROD.
• Remove OU6MW-15 from the monitoring program. Contaminants were not detected in this well in 2007. Migration from the upgradient plume is not likely as this well is completed in a lower portion of the aquifer. This well should be considered for decommissioning.
The OU6MW-46 plume is scheduled for sampling next in 2009. To minimize costs, PDBs should be used & MNA & field parameters omitted. If benzene & ethylbenzene remain at their current levels, the remedy should be reevaluated at that time. If extended MNA is selected, the monitoring interval could be as long as 5 years, to minimize monitoring costs. MNA parameters also should be collected every 5 years & should include pH, ORP, DO, & ferrous iron. If an active remedy is selected, extensive & comparatively costly characterization will be required.
See site file for additional information. |
Louis Howard |
| 4/17/2007 |
Update or Other Action |
PL81 PLUME: 2006 Annual Phase I RPO report (Draft) received.
Remedial Action Objectives: Although Site PL81 was not formally identified as a site until after the OU6 ROD was signed, the PL81 area is within the GW contamination area addressed by the OU6 ROD. In addition, the two plumes at Site PL81 are thought to be commingling with LF04 GW, which is addressed in the OU6 ROD; therefore, GW at Site PL81 is addressed under the OU6 ROD. The OU6 ROD did not include an RAO for surface water; therefore, the GW RAO for Site PL81 is as follows: Prevent the ingestion, dermal contact, & inhalation of vapors from GW having benzene, toluene, ethylbenzene, 1,2-DCA, & methylene chloride in excess of MCLs &/or resulting in a cancer risk greater than 1.0E-6 or hazard index greater than 1.0.
In 2002, the monitoring program was reevaluated, eliminating those contaminants that had never exceeded cleanup levels in the OU6MW-46 & PL81 South plumes & adding criteria for the seeps in order to be protective of surface water. The OU6MW-46 plume is monitored for benzene, ethylbenzene, & free product in GW; the PL81 South plume is monitored for benzene, GRO, DRO, & free product in GW, & benzene, TAH, TAqH, & sheen in water collected from the seeps.
The remedy selected in the OU6 ROD for PL81 GW is LUCs & LTM with free-product removal, with attenuation of contaminants to less than cleanup levels within 14 years (USAF 1997). LUCs restrict access to contaminated GW & prohibit installation of wells in the contaminated plume for residential, industrial, or agricultural use until cleanup levels are met.
For the OU6MW-46 plume, the 2006 results for benzene & ethylbenzene declined in concert from the 2005 results but fell within the range of previous results, indicating that there has been no significant attenuation of these contaminants. Instead, ethylbenzene has occasionally exceeded its cleanup level of 700 µg/L, & benzene has averaged near 500 µg/L, far above its cleanup level of 5 µg/L. The levels of these two contaminants are highly correlated, showing similar increases & declines. Field parameters suggest conditions are probably favorable for biodegradation & some biodegradation is occurring, but the rate of biodegradation is apparently too low to make a perceptible difference. The continued high levels suggest the selected remedy for the OU6MW-46 plume will not meet the 14-year cleanup target of 2011 & should be reassessed.
For the PL81 South plume in 2006, GRO continued its declining trend below its cleanup level of 1,300 µg/L for the first time. Benzene, with a cleanup level of 5 µg/L, dropped to its lowest level yet (2.27 µg/L), following a high result of 10 µg/L in 2005. DRO, with a cleanup level of 1,500 µg/L, jumped back up to 2,360 µg/L, following two years of results near 900 µg/L & a post-1999 high of 6,900 µg/L.
Field parameters suggest that conditions are not favorable for biodegradation in the immediate vicinity of the well (negligible DO at 0.04 mg/L) but that some biodegradation is occurring nearby to maintain elevated conductivity (363 µS/cm), strongly reducing ORP (-278.2 mV), & a high concentration of ferrous iron (24.0 mg/L).
See site file for additional information.
|
Louis Howard |
| 4/17/2007 |
Update or Other Action |
2006 Annual Phase I RPO report (Draft) received.
The monitoring objectives for Site WP14 are as follows: Reduce POL COC concentrations in groundwater and surface water to OU 6 ROD-specified cleanup levels. Verify that plume expansion is not occurring and that the monitoring network is sufficient for that purpose. Recover floating product if it is encountered on groundwater.
Recommendations: Review measures to protect casual visitors from contaminated surface water. Survey elevations of the WP14 seeps to facilitate evaluation of the hydraulic gradient across the WP14 plume. Measure groundwater levels in all site wells within a 48-hour period to provide a synoptic view of the water table. Use PDBSs to collect groundwater samples for lab analysis of VOCs. Develop a physical CSM for the plume to explain recent data and evaluate remedial options. Review alternatives for active remedation (such as biosparging) for cost-effectiveness.
Final Report: WP14 — Because DRO is a COC in this plume, conventional groundwater sampling is
required, and sampling VOCs separately via PDBs would increase rather than decrease
labor costs. Thus, PDB sampling has been eliminated at WP14.
See site file for additional information. |
Louis Howard |
| 5/14/2007 |
Update or Other Action |
Draft 2006 Zone 1 Annual Remedial Process Optimization Report, April 2007 received on April 18, 2007. Based on the data presented in the report and any pending U.S. EPA comments, ADEC will approve the document as submitted. |
Louis Howard |
| 5/23/2007 |
Document, Report, or Work plan Review - other |
EPA comments on the Zone 1 RPO Report to Glen Verplancke 3 CES/CEVR Email message:
Great report. I agree with the changes to sampling frequency, fewer MNA parameters and water level measurements. Also the geometric regression may yield better predictions. I also think the use of the geoprobe for deep samples at DP 98 is a good idea.
This was a well written report, I especially like the site overview figure at the end. There are valuable observations made in this report , together with some changes to technique(PDBS), so it will be IMPORTANT for future work to revisit this info. I noted that at a couple sites they observed that we may need downgradient sentry wells to follow the plume, lets revisit that someday also.
Sorry I was late. Again, a very professional report. |
Louis Howard |
| 8/2/2007 |
Update or Other Action |
Staff received the Explanation of Significant Differences (ESD) which documents refinements to the original remedy at Operable Unit (OU) 6 at Elmendorf Air Force Base (AFB), Alaska.
OU 6 is composed of three former landfills (LF02, LF03, and LF04), two sludge disposal pits (SD15 and WP14), a surface disposal area around a rock testing laboratory (SD73), and a former storage bunker (SS19).
The Record of Decision (ROD), signed by the United States Environmental Protection Agency (USEPA) on 4 December 1996, by the Alaska Department of Environmental Conservation (ADEC) on 2 January 1997, and by the United States Air Force (USAF) on 27 January 1997, presents the selected remedial actions for OU 6 (Elmendorf AFB, 1997). This ESD updates the selected remedial actions based on data collected during remedy implementation and was prepared in accordance with Section 117(c) of the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) and Chapter 40 of the Code of Federal Regulations (40 CFR) Sections 300.435(c)(2)(i) and 300.825(a)(2) of the National Oil and Hazardous Substances Pollution Contingency Plan (NCP).
ORIGINAL REMEDY Groundwater-
• Institutional controls on land and water use, as specified in the Base Comprehensive Plan, will restrict access to the contaminated groundwater throughout WP14. Installation of wells in the contaminated plume for residential, industrial, and agricultural use will be prohibited by the Base Comprehensive Plan until cleanup levels have been achieved.
• Groundwater will be monitored as indicated by the Basewide Monitoring Program Well Sampling Decision Guide (Decision Guide) in Appendix A (frequency changed by the Memorandum to the Site File [Elmendorf AFB, 2003]) and evaluated on an as-needed basis to determine contaminant migration and to track the progress of contaminant degradation and dispersion, as well as to provide an early indication of unforeseen environmental or human health risk. Five-year
reviews will also assess the protectiveness of the remedial action, including an evaluation of any changed site conditions, as long as contamination remains above cleanup levels.
• Recoverable quantities of free product found on top of the water table at WP14 will be regularly removed during groundwater monitoring events.
• Groundwater monitoring will be discontinued if contaminant levels are below cleanup levels during two consecutive monitoring events. In that case, no further action for groundwater will be required.
• During the final round of monitoring, samples will be collected and analyzed for all constituents that exceeded MCLs during the 1994 investigation including VOCs, SVOCs, and metals. These results will be evaluated before a final determination is made that groundwater meets all cleanup requirements.
• All groundwater is expected to be cleaned up within 14 years.
Soil
• No further action will be required for soil at WP14.
Institutional controls on land use and water use, as specified in the Base General Plan, will restrict access to the contaminated groundwater throughout WP14. Installation of wells in the contaminated plume for residential, industrial, and agricultural use will be prohibited by the Base General Plan. Clarification on how LUCs are implemented. |
Louis Howard |
| 9/18/2007 |
GIS Position Updated |
61.2502 N latitude and -149.8728 W longitude |
Louis Howard |
| 11/20/2007 |
Update or Other Action |
2007 Zone 1 Remedial Process Optimization (RPO) Report received for contaminated sites and associated underlying groundwater for the western portion of EAFB. This area, referred to as Zone 1, includes: DP98, ST36/66, ST41, ST61, ST69, LF04 North, PL81, WP14, and LF02. Site WP14 is located in the westcentral part of EAFB, north of Site PL81. The site is a former sludge disposal site, consisting of a broad area of vegetated soil used from 1964 to 1968 to weather old filters, pads, and sludge from POL tank cleanup operations. The abandoned PL81 pipeline crossed the site and contributed to soil and groundwater contamination. The former location of PL81 Valve Pit 11 was excavated in 2005, as outlined in the decision document for that location.
The WP14 plume encompasses groundwater contamination from Site WP14 and PL81 Valve Pit 11. The plume extends west from source areas to two seeps overlooking Knik Arm, a distance of approximately 1,000’. This plume is administered under its own section in the OU6 ROD. Although the plume underflows a portion of the OU6 LF04 site, all detected contaminants have been POL related, indicating no discernable influence from the old landfill. The currently monitored contaminants for Site WP14 include benzene, ethylbenzene, GRO, and DRO in groundwater and benzene, TAH, TAqH, and sheen in water collected from the seeps.
GRO is the primary in-plume contaminant. Concentrations in the three in-plume wells range from 1,670 to 3,780 µg/L, in excess of the cleanup level of 1,300 µg/L. In-plume well OU6MW-91 contained the highest GRO concentration and the only benzene exceedance, at 11.5 µg/L, significantly exceeding the cleanup level of 5 µg/L. OU6MW-67 defines the northern downgradient edge of the plume with a moderate GRO exceedance. Well 14MW-120, with low levels of all COCs, is interpreted to lie just outside the plume and defines the upgradient edge. The downgradient boundary is defined by the two seeps. Both are heavily contaminated, greatly exceeding the cleanup levels for benzene, TAH, and TAqH.
The southern seep (LF04SP-03) contained the highest benzene levels encountered anywhere in the plume; benzene there accounted for most of the TAH and TAqH values. The northern seep (LF04SP-04) contained benzene slightly in excess of its cleanup level as well as substantial xylenes, elevating the TAH result, and naphthalene, elevating the TAqH result. South of the plume, well OU6MW-13 in the lower aquifer was ND for most COCs and contained GRO at only a very low level. In the past, the plume had been drawn to encompass this well. No free product was encountered in any of the site wells during sampling or water-level measurements although sheen and droplets were noted in purge water from well 14MW-121.
Recommendations:
• Survey the elevations of the WP14 seeps to facilitate evaluation of the hydraulic gradient across the WP14 plume.
• Install signs at the WP14 seeps warning casual visitors to avoid contact with the water. Casual site visitors should be warned that groundwater discharging at the seeps contains contaminants in excess of groundwater and surface water cleanup levels.
• Reinstate annual monitoring for seeps LF04SP-03 and LF04SP-04. These seeps are the focal points of groundwater discharge from the WP14 plume and are expected to exhibit exceedances of cleanup levels until groundwater is remediated. Past ND results probably reflect sampling difficulties rather than fluctuations in plume dynamics. Continued monitoring of the seeps is important for awareness of potential effects on ecological receptors.
• Reduce the sampling frequency of 14-MW120, MW14-121, and OU6MW-13 to every 5 years, sampled next in 2012. Because the first two wells are considered in-source wells in a shrinking portion of the plume, a 5-year interval is consistent with the 2003 decision guide. The third well is a distant sentry well.
• Sample OU6MW-92 and OU6MW-93 annually for 5 years beginning in 2008. These wells, located in the downgradient half of the plume, along the crosscutting roadway, will provide insights into the behavior of a major portion of the plume that has not been monitored in recent years. Because contaminants are expected to persist the longest in this portion of the plume, understanding its behavior is a key to forecasting a date for plume cleanup.
• Increase the sampling frequency of OU6MW-67 from every 4 years to every 2 years. This well had been depicted as a sentry well in the 2006 RPO Report, but the 2007 results show that it is an in-plume well.
• Continue collecting synoptic water levels in all site wells in conjunction with groundwater sampling. All water levels should be measured within a 48-hour period. Given the recent disturbances to the site related to Port of Anchorage construction, verifying the water table geometry annually is recommended. |
Louis Howard |
| 10/15/2008 |
Update or Other Action |
5 YR Review
OU6 Remedy Implementation Status
GW at WP14
Institutional controls (also known as LUCs) on land & water use, as specified in the Base General Plan, will restrict access to the contaminated GW throughout WP14. Installation of wells in the contaminated plume for residential, industrial, & agricultural use will be prohibited by the Base General Plan.
Implemented in August 1998. LUC procedures were updated & clarified in the 2007 ESD.
GW will be monitored & evaluated on a frequency determined by the “Basewide Monitoring Program Well Sampling Frequency Decision Guide” to determine contaminant migration & to track the progress of contaminant degradation & dispersion, as well as to provide an early indication of unforeseen environmental or human health risk. Five-year reviews will also assess the protectiveness of the remedial action, including an evaluation of any changed site conditions, as long as contamination remains above cleanup levels.
Monitoring is ongoing to evaluate natural attenuation. Monitoring frequency decision guide was adopted in 2003. Five-year reviews were conducted in 1998, 2003 & 2008
Recoverable quantities of free product found on top of the water table at WP14 will be regularly removed during GW monitoring events.
Ongoing. No recoverable quantities of free product have been detected since 2005.
GW monitoring will be discontinued if contaminant levels are below cleanup levels during two consecutive monitoring events. In that case, no further action for GW will be required. During the final round of monitoring, samples will be collected & analyzed for ALL constituents that EXCEEDED MCLs during the 1994 investigation including VOCs, semivolatile organic compounds, & metals. These results will be evaluated before a final determination is made that GW meets all cleanup requirements
GW monitoring is ongoing at all sites as required by the OU6 ROD.
All GW is expected to be cleaned up within 14 years.
GW cleanup is ongoing & current trends predict it will be completed in 16 years (2013).
Soils
No further action will be required for soil at WP14.
Operable Unit 6 Monitoring Recommendations
Recommendations for changes to OU6 monitoring program include:
• If free product continues to be absent from WP14 well OU6MW-77, reincorporate the well
into the GW monitoring program.
Each of the contaminants & their new soil cleanup standards are discussed below:
• Jet fuel was detected in soil at 2050 mg/kg at WP14 at the time of the ROD. The RRO cleanup standard is 2000 mg/kg. The natural attenuation remedy for WP14 is generally working & petroleum hydrocarbon concentrations are decreasing in GW. GW is routinely monitored for VOCs (including BTEX), GRO & DRO. The natural attenuation remedy should be effective for the jet fuel contamination in soil, & the current GW monitoring program provides adequate data to evaluate the effectiveness of the remedy.
Issues
Cleanup Schedules: Monitoring shows that the natural attenuation remedies are generally decreasing COC concentrations. At several sites, the process is slower than anticipated in the ROD. For most of the affected sites, the slower attenuation rates are limited to a few
individual wells or just a few additional years until cleanup goals are met. The slower rates of natural attenuation have the largest impact at OU5, where natural attenuation may take several
additional decades to reach cleanup levels. OU5 has a large monitoring program & a relatively expensive treatment system for contaminants discharging at seeps, so the impact on cleanup costs could be significant. In the interim, LUCs are in place to ensure protectiveness.
Recommendations/Follow-up Actions
Cleanup Schedules: Continue monitoring until cleanup levels are met. Continue to use trend
analysis to evaluate the natural attenuation remedies. Adjust estimated dates for achieving
GW cleanup in accordance with trend projections. For OU5, attempt to identify sources
of TCE contamination for Fairchild Avenue, OU5MW-02, SP1-02 Kenney Avenue, & Slammer Avenue plumes. If sources can be identified, evaluate alternative remedial strategies to accelerate attainment of the TCE cleanup level in OU5 GW. LUCs shall remain in place to ensure protectiveness until cleanup goals are met.
Incorporate well OU6MW-77 back into the monitoring program for WP14 once free product is no longer present in the well. This well has historically had some of the highest COC concentrations & is important for trend analysis estimates for meeting cleanup levels.
The remedies at LF04 South, WP14 & SD15 are expected to be protective of human health & the environment upon attainment of GW cleanup goals through natural attenuation. In the interim, exposure pathways that could result in unacceptable risks are being controlled. |
Louis Howard |
| 3/17/2009 |
CERCLA ROD Periodic Review |
Cover letter to the EPA's Five-Year Review signature sheet sent to Richard J. Walberg, Colonel, US Air Force Vice-Commander from EPA Region 10 Office of Environmental Cleanup Daniel D. Opalski, Director. The Environmental Protection Agency (EPA) has completed their review of the third Five-Year Review report for the United States Air Force (USAF) Elmendorf Superfund site, in Anchorage Alaska.
EPA reviewed this report for technical adequacy, accuracy, and consistency with EPA guidance. In general, EPA agrees with the protectiveness determinations in this report. However, I understand that all parties to the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) Section 120 Federal Facility Agreement (FFA) are aware of a potential new source that has not been fully characterized, namely SS-022. It is also my understanding that while the Five-Year Review identifies this potential new source, the USAF has not adequately discussed the interim measures it has already taken to ensure protectiveness as site characterization proceeds, such as Institutional Controls (ICs) at SS-022 and the ongoing Remedial Investigation.
Therefore, we recommend that within ninety (90) days (by June 15, 2009), USAF supplement the Site File and Administrative Record with a Memorandum to document the ICs (e.g., installation of a fence, signage, and notation on the Environmental Restoration Program Atlas) that have been implemented for the protection of human health and the environment at SS-022. The Memorandum should also mention the Installation-wide ICs (including restriction of ground water use) already in place.
In addition, EPA agrees with USAF's recommendation for further action at the OU-l landfill area for the trichloroethylene (TCE) groundwater contamination, and requests that the Program Managers meet to discuss the timeline for completion of the groundwater contamination characterization and establish deadlines and, as appropriate, target dates for subtasks, as required under the FFA.
|
Louis Howard |
| 2/25/2010 |
Update or Other Action |
Dept. of Army Installation Management Command, HQ U.S. Army Garrison Fort Richardson, Office of the Garrison Commander sent letter to ADEC.
This letter serves as formal notice under Paragraph XXXII, Transfer of Property, of the Fort Richardson, Alaska (FRA) Federal Facility Agreement (FFA), that the property under the jurisdiction of the U.S. Army will be transferred to the Joint Base Elmendorf-Richardson (JBER) effective October 1, 2010.
This letter also serves as formal notice that effective October 1, 2010, responsibility for the FRA FFA, dated December 15, 1994, will be transferred to the senior official of the JBER Supporting Component, United States Air Force (USAF). This transfer of responsibility is in accordance with the Memorandum of Agreement (MOA) between the USAF and United States Army (USA), and was signed by the Vice Chief of Staff for the USAF and the Vice Chief of Staff for the USA on October 9, 2009.
Based on the MOA and previous discussions with US EPA (reference March 2009 FRA FFA meeting in Seattle with representatives of the EPA Region 10, Elmendorf AFB and Fort Richardson), it is our understanding your agency agrees the management and oversight of the FRA FFA may properly transfer to the JBER Restoration Project Manager (RPM), and such transfer does not constitute a significant change, such as to require formal renegotiation of the Agreement or the preparation of an amendment to the Record of Decision.
If you have any questions or concerns about this matter, please contact Therese Deardorff, Chief, Environmental Division, U.S. Army Garrison Fort Richardson, Alaska 907.384.3074. |
Louis Howard |
| 2/25/2010 |
Update or Other Action |
2009 Zone 1 Field Activities Report received for comment.
PL81 is the former location of an abandoned 10-inch pipeline that extended from the Port of Anchorage to Valve Pit 14 on EAFB. The pipeline was abandoned in 1964 after the Good Friday earthquake & removed in 1997. Although PL81 was not formally identified as a site until after the OU6 ROD was signed, the PL81 DD states that all GW contamination attributable to PL81 will be managed by the OU6 ROD. Therefore, GW contamination associated with PL81 is monitored as part of the LF04 South & WP14 GW monitoring program.
One plume is monitored at LF04 South by well OU6MW-63 & seeps LF04SP-02 & -02DG. Additionally, the WP14 plume extends across LF04 South & a mixing zone for LF04 South COCs occurs before the WP14 plume discharges at seeps LF04SP-03 & -04. Some of the LF04 South monitoring wells & seeps have been associated in previous reports with PL81 (OU6MW-46 & -63 & seeps LF04SP-02 & -02DG).
Recommendations for future monitoring at LF04 South:
• Change the frequency of sampling for well OU6MW-63 to every 5 years, per the decision tree for upgradient wells. OU6MW-63 can now be considered an upgradient well due to the lack of contamination since 2006. The next planned sampling event for well OU6MW-63 is in 2010. However, based on the lack of COCs, sample collection at this frequency is not necessary, & the next sample should be scheduled for 2012 to coincide with other wells in the area on a 5-year schedule.
• Sample well OU6MW-67 for WP14 COCs only & change the frequency of sampling to every 5 years, per the decision tree for upgradient wells. The 2009 sample results for LF04 COCs confirmed methylene chloride & 1,2,-DCA do not exceed the cleanup levels & are no longer a concern in this well. The well now can be considered an upgradient well for WP14 due to the lack of WP14 COCs since 2000. The next planned sampling event for well OU6MW-67 is in 2011. However, based on the lack of COCs, sample collection at this frequency is not necessary, & the next sample should be scheduled for 2012 to coincide with other wells in the area on a 5-year schedule.
• Sample well OU6MW-61 for LF04 South COCs. This well had the highest concentration of benzene & 1,2-DCA during the last monitoring event in September 1994. This well is perched in a shallow aquifer but is included as part of LF04 South. Sample collection could be scheduled in 2012 or sooner, in order to provide data for the next 5 yr. review.
See site file for additional information.
|
Louis Howard |
| 3/3/2010 |
Update or Other Action |
Zone 1 Field Activities Report received. The remedy selected for groundwater cleanup at WP14 is LUCs and groundwater monitoring with free-product removal. Attenuation of contaminants to less than cleanup levels was expected within 14 years. Activities for the WP14 monitoring task include:
Groundwater will be monitored as indicated by the Decision Guide and evaluated on an as-needed basis to determine contaminant migration and to track the progress of contaminant degradation and dispersion, as well as to provide an early indication of unforeseen environmental or human health risk. Five-year reviews willalso assess the protectiveness of the remedial action, including an evaluation of any changed site conditions, as long as contamination remains above cleanup levels.
Recoverable quantities of free product found on top of the water table at WP14 will be regularly removed during groundwater monitoring events.
Groundwater monitoring will be discontinued if contaminant levels are below cleanup levels during two consecutive monitoring events. In such case, no further action for groundwater will be required.
During the final round of monitoring, samples will be collected and analyzed for all constituents that exceeded MCLs during the 1994 investigation, including VOCs, SVOCs, and metals. These results will be evaluated before a final determination is made that groundwater meets all cleanup requirements.
Diesel range organics (DRO) and gasoline range organics (GRO) were monitored in wells at WP14 through 2007, even though they were not listed as COCs for these sites.
NOTE TO FILE: In a January 22, 203 meeting, the Air Force agreed to add DRO and GRO analyses in groundwater to suite of analyses at monitoring wells associated with fuel plumes starting in 2004. 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.
As of 2009, only COCs identified in the ROD are tracked in the monitoring program (Benzene, ethylbenzene, toluene) (2007 RPO Report: GRO is the primary in-plume contaminant. Concentrations in the three in-plume wells range from 1,670 to 3,780 µg/L, in excess of the cleanup level of 1,300 µg/L. In-plume well OU6MW-91 contained the highest GRO concentration and the only benzene exceedance, at 11.5 µg/L, significantly exceeding the cleanup level of 5 µg/L. OU6MW-67 defines the northern downgradient edge of the plume with a moderate GRO exceedance.)
High ferrous iron (>3.3 mg/L), typical of in-plume conditions for fuel spills, was found in
monitoring wells OU6MW-67, -91 and -92, but oddly not in well OU6MW-93. Table 4-4 shows that benzene exceeded the groundwater cleanup level in only one monitoring well in the WP14 plume (OU6MW-92). Concentrations of all other COCs were below the cleanup levels in the WP14 plume. In the OU6MW-46 plume, benzene concentrations remained two orders of magnitude above the cleanup level of 5 µg/L, but ethylbenzene concentrations fell below the cleanup level of 700 µg/L.
The northern and southern boundaries of this plume appear to be shrinking. While COC concentrations are falling at the edges of the plume, the plume boundaries are depicted for benzene in this report and are not directly comparable to the plume boundaries reported in previous years. Previous plume boundaries reflected GRO concentrations.
Although not measured in 2009, concentrations of other fuel-related contaminants
in this monitoring well were predicted, in 2007, to clean up by 2010 (DRO) and 2016 (GRO)
(USAF 2008b). The development of a decreasing trend for benzene concentrations coupled
with cleanup date predictions based on DRO and GRO levels provides evidence that the
southern border of this plume is shrinking. Additional monitoring is needed to confirm this
conclusion.
|
Louis Howard |
| 3/12/2010 |
Document, Report, or Work plan Review - other |
The Alaska Department of Environmental Conservation (ADEC) has received the draft monitoring report for review & comment on March 3, 2010. Below are ADEC’s comments regarding the report which covers eight sites: LF02 (CS DB Hazard ID 2770), LF04 (CS DB Hazard ID 1804), WP14 (CS DB Hazard ID 639), ST36/66 (CS DB Hazard ID 1793), ST41 (CS DB Hazard ID 429), ST61 (CS DB Hazard ID (2747), ST69 (CS DB Hazard ID 1795), DP98 (CS DB Hazard ID 2595) & ten GW plumes in Zone 1.
4.2 WP14 Monitoring Objectives Page 4-2: The text states: “DRO and GRO were monitored in wells at WP14 through 2007, even though they were not listed as COCs for these sites.” See comments above regarding documenting the change in monitoring for DRO and GRO despite a January 2003 meeting to the contrary to monitor for DRO and GRO in groundwater for source areas associated with fuel plumes.
Table 4-1
Contaminants of Concern and Cleanup Levels in Groundwater at WP14 Page 4-2: See comments above regarding the removal of OU6 ESD as a basis for cleanup level at WP14. WP14 does not have 1,1,2,2-tetrachloroethane in groundwater and the OU6 ESD only clarified LUCs at WP14. . ADEC requests the Air Force add ADEC Table C (18 AAC 75) as a Basis for Cleanup Level in Table 4-1.
4.2 2009 Site Activities At WP14 Page 4-5: The text states: “Diesel-range organics (DRO) and gasoline-range organics (GRO) were monitored in wells at WP14 through 2007, even though they were not listed as COCs for these sites. Changes made to the 2009 sampling program align the monitoring activities to the OU6 ESD. As of 2009, only COCs are tracked in the monitoring program.”
ADEC requests the Air Force include text as follows:”Diesel-range organics (DRO) and gasoline-range organics (GRO) were monitored in wells at WP14 through 2007, even though they were not listed as COCs in the OU6 Record of Decision (CERCLA) for these sites. They were added as a result of the meeting with ADEC, USAF and EPA in January 2003. The changes made to the 2009 sampling program align the monitoring activities to the OU6 ESD. As of 2009, only COCs listed in the OU6 Record of Decision (CERCLA) are tracked in the monitoring program.”
The ESD did not specifically exclude GRO and DRO from analysis of groundwater samples under the [Basewide] monitoring program. Please note the Basewide Monitoring Program was established to integrate [all] the needs of multiple environmental programs and compliance issues included in the FFA, State-Elmendorf Environmental Restoration Agreement (SERA) [i.e. contaminants such as gasoline range organics, diesel range organics, and residual range organics which are regulated under 18 AAC 75 and 18 AAC 78], CERCLA regulations and the Resource Conservation and Recovery Act (RCRA).
ADEC will require the Air Force to resume monitoring DRO, GRO as COCs for the groundwater monitoring program as is required under State of Alaska 18 AAC 75 contaminated regulations at WP14.
Table 4-2
2007 Versus 2009 Sampling Program at WP14 Page 4-6: ADEC requests the Air Force ensure that water quality parameters are monitored (TAH and TAqH) at the two seeps at LF04SP-03 as a part of the LF04 South monitoring. It is not apparent from the table whether or not these parameters are being monitored as required by 18 AAC 70. Monitoring the seeps for TAH and TAqH in addition to PAHs and VOCs would be consistent with the cleanup standard applied to seeps associated with OU5.
See comments above in Table 3-3 regarding OU6MW-46 and PDB sampling in wells with screens longer than five feet (this screen length information should always be in documents where PDBs are used as well as saturated interval). It is not known whether or not this is of concern for OU6MW-46 by reading the draft report.
The table shows for OU6MW-46 monitoring well the interval for 2009 Sampling Program is two (2) years for COCs (ROD COCs under CERCLA) via PDB. Please confirm if in fact the PDB sampling devices are left in the well for two years before re-sampling, the saturated interval, and the total well screen length. The 2009 Zone 1 Work Plan states: “PDBs will be left in the wells for approximately 2 weeks and then removed and used to fill VOC sampling bottles.”
The 2009 Zone 1 Work Plan notes that the OU6MW-46 is screened below the water table, with the PDB at screen level (approximately 37 feet below top of casing). This may not be optimal for sampling of benzene, toluene or ethylbenzene. ADEC requests the Air Force, EPA and ADEC RPMs discuss this matter at the next RPM meeting. |
Louis Howard |
| 3/24/2010 |
Document, Report, or Work plan Review - other |
EPA has reviewed the Draft Zone 1 Field Activities Report, February 2010, Elmendorf A.F.B., Alaska and has the following comments:
General: There appear to be several significant issues that need further discussion among the RPMs as a result of interpretations and conclusions made in this Report or practices described in this Report. The proper use of PDBs and the rationale for their use seems to be unclear. There also could be an issue with the consistency of their use. The purpose of a Base-wide Monitoring Program should be to integrate all info on all contaminants and not deal with CERCLA COCs, alone. This Report seems to take" liberties" with the interpretation of the OU6 ESD; EPA agrees with the ADEC clarification of the purpose of the ESD in their comments on the above Report. The QA Lab reports, as an Appendix to this Report outline flagged issues dealing with sample temperature and volatile organic analysis (VOA) collection discrepancies that compromise the data in this Report and cast doubt on adherence to Management Plan SOPs.
Specific:
1.1 2009 Zone 1 Project Objectives Page 1-1 EPA agrees with the comments made by ADEC . The Zone or "Basewide Monitoring Plan" should deal with all programs, otherwise we would have only OU Monitoring Plans.
1.3.1 Ground Water and Surface Water Sampling Page 1-7 Since technique and consistency of sampling appears to be an issue, EPA agrees with ADEC suggestions to include SOPs as an appendix to work plans. This section calls into question the value and use of PDB sampling. This is a topic for FFA discussion and possibly consultant briefing.
Table 4-1 Contaminants of Concern and Cleanup Levels in Groundwater at WP14 Page4-2: The ESD did not change cleanup levels at this site, it only clarified ICs.
4.2 2009 Site Cleanup Activities at WP14 Page 4-5: See comments on GRO and DRO as "Basewide" monitoring analytes.
Table 4-2 2007 vs. 2009 Sampling Program at WP14 Page 4-6: The Report causes concern on the location, depth and use of PDB Samplers. Similar to comments made in the Zone 3 Report , a description of screen length and depth and well survey info is needed in each Report to give the reader a clear picture of the info presented and its relevance to site conditions.
Again, the use of PDB samplers and how long they remain in the well and their condition is a discussion topic for the RPMs and USAF technical consultants.
4.5.1 Implications of Contaminant and Geochemical Monitoring Pages 4-9 and 4-10: Sampling of DRO and GRO to verify plume decrease seems necessary at this location. |
Louis Howard |
| 3/25/2010 |
Update or Other Action |
Letter from Lt. General Dana T. Atkins, Commander, Eleventh Air Force to EPA Region 10 Deb Yamamoto Environmental Cleanup Office and ADEC, Jennifer Roberts Fed. Fac. Environmental Restoration Program.
This letter serves as formal notice to the Environmental Protection Agency Region 10 and the State of Alaska that on 1 October 2010, the U.S. Air Force will assume the U.S. Army's obligations under the 1994 Federal Facility Agreement for Fort Richardson (Docket No. 1093-
05-02-120) and any amendments thereto (hereinafter collectively referred to as "the FFA").
The Air Force assumes these authorities and obligations as the Army's successor at Fort
Richardson in accordance with subsection 2.1(i) of the FFA.
This is a transfer of responsibility for carrying out the terms and responsibilities of the FFA;
it is not a transfer of property covered by Section XXXII of the FFA or Section 120(h) of the
Comprehensive Environmental Response, Compensation and Liability Act (42 U.S.C. §9620(h)). This transfer of responsibility is in accordance with the Base Realignment and Closure Act of 2005 and the Joint Base Elmendorf-Richardson Installation Support Memorandum of Agreement between the Army and the Air Force, dated 9 October 2009.
On and after 1 October 2010, the Air Force and, to the extent necessary, the Department of
Defense will fund all activities required by and subject to the FFA.
The following administrative changes shall be effective 1 October 2010:
1. Para 8.11 - The Air Force representative on the Technical Review Committee (currently
referred to as Community Environmental Board) shall be the Joint Base Elmendorf-Richardson
(JBER) Remedial Project Manager (RPM).
2. Para. 8.13 - The chair of the Technical Review Committee (currently referred to as Community Environmental Board) shall be the Vice Commander, 673rd Air Base Wing.
3. Para 9.1 - The JBER RPM shall be Mr. Gary Fink, who is currently the Chief of the Restoration Section at Elmendorf Air Force Base. Mr. Fink's contact information is:
3 CES/CEANR 6326 Arctic Warrior Drive Elmendorf AFB AK 99506 Phone number is (907) 552-2875
4. Para. 14.2 - The Air Force point of contact shall be Mr. Fink. Please see the preceding
paragraph for his contact information.
5. Para 21.5 - The Air Force's designated member on the Dispute Resolution Committee shall be the Director, Air Force Center for Engineering and the Environment.
6. Para 21.7 - The Air Force's representative on the Senior Executive Committee shall be the Deputy Assistant Secretary of the Air Force (Energy, Environment, Safety, and Occupational Health).
7. Para 27.3 - The source of funds for activities required by the FFA shall be funds authorized and appropriated annually by Congress under the Environmental Restoration, Air Force (ER,AF) appropriation in the Department of Defense Appropriations Act.
8. Attachment 1, Para 3.8: Records of decision shall be signed by the following Air Force designee: Commander, 673rd Air Base Wing.
If you have any questions about this matter, please contact Mr. Gary Fink at (907) 552-2875.
Signed Dana T. Atkins Lieutenant General, USAF, Commander |
Louis Howard |
| 4/1/2010 |
Update or Other Action |
Timothy R. Prior, Colonel, U.S. Army sent letter to EPA RPM Bill Adams and ADEC RPM L. Howard. This letter serves as formal notice to the Environmental Protection Agency Region 10 (EPA Region 10) and the State of Alaska Department of Environmental Conservation, (ADEC) that on 1 October 2010 the U.S. Air Force will assume the U.S. Army's obligations under the 1994 Federal Facility Agreement for Fort Richardson (Docket No.1 093-05-02-120) and any amendments thereto (hereinafter collectively referred to as "the FFA"). The Air Force assumes these authorities and obligations as the Army's successor and assignee for the environmental restoration program at Ft. Richardson in accordance with subsection 2.1 (i) of the FFA.
This is a transfer of responsibility between the Military Departments for the purpose of carrying out the terms and responsibilities of the FFA; it is not a transfer of property subject to the requirements of Section 120(h) of the Comprehensive Environmental Response, Compensation and Liability Act (42 U.S.C. §9620(h)). This transfer of responsibility is in accordance with the Base Realignment and Closure Act of 2005 and the Joint Base Elmendorf-Richardson Installation Support Memorandum of Agreement between the Army and the Air Force, dated 9 October 2009.
On and after 1 October 2010" the Air Force and, to the extent necessary, the Department of Defense will fund all activities required by and subject to the FFA.
This letter replaces our earlier letter dated 17 February 2010. If you have any questions about this matter, please contact Mr. Mark Prieksat at (907) 384-2716. |
Louis Howard |
| 4/28/2010 |
Document, Report, or Work plan Review - other |
Memorandum for ADEC. SUBJECT: Response to ADEC Comment on Draft 2009 Zone 1 Field Activities Report (Ref: ADEC Memo, 12.Mar 10)
1. This memorandum is in response to ADEC's concern as to why diesel-range organics (DRO) and gasoline-range organics (GRO) at select groundwater plumes were not sampled in 2009 as
previously agreed in a January 14, 2003 meeting. Specifically, ADEC's comment (Attachment 1) is in reference to Section 3.7.1 Implications of Contaminant and Geochemical Monitoring, Page 3-17 of the draft 2009 Zone 1 Field Activities Report, which stated:
"The text states: When these parameters were monitored from 1999 to 2007, GRO concentrations in this monitoring well exceeded cleanup levels while DRO concentrations hovered near the cleanup level. ADEC requests the Air Force provide an explanation or a memorandum to the site file as an appendix to the document on why DRO and GRO were eliminated from the monitoring program as previously agreed to in a January 14, 2003 meeting with ADEC, USAF and EPA."
2. The analytes in question were not included in the Zone 1 groundwater monitoring program
for FY09 due to an administrative oversight. The agreement to monitor for DRO and GRO was
captured in meeting minutes (Attachlnent 2), not in a more formal mechanism such as a decision
document or memorandum to the·site file. In preparation for programming of project
requirements, we reviewed the governing documents for the Zone 1 sites. None of the governing
documents for Zone 1 sites identified GRO/DRO as a contaminant ofconcem (COC); therefore,
GRO/DRO sampling was not programmed or conducted in 2009.
3. The U.S Air Force agrees with ADEC's request to continue sampling for diesel-range organics (DRO) and gasoline-range organics (GRO) for CERCLA sites with fuel-related plumes. Minutes of a 14 Jan 03 meeting with EPA, ADEC and DRS, provided with the above referenced ADEC memo, documents that the Air Force agreed to add DRO/GRO into the sampling program under the following conditions:
a. The decision will be documented in the 5-Year Review. The addition of DRO/GRO to the program should be introduced in the 5-Year Review under· mention of new issues affecting protectiveness.
b. The Air Force will NOT add DRO/GRO as a CERCLA ARAR, but will compare DRO/GRO results to ADEC cleanup levels in the annual reports and will discuss in subsequent 5-Year Reviews. The benefit of this is that if CERCLA COCs meet ARARs, the Air Force can achieve a partial delisting.
c. The Air Force will add DRO and GRO to the suite of analyses at monitoring wells associated with fuel plumes starting in 2004.
d. The Air Force will not pursue a decision document with ADEC on DRO/GRO until more data is gathered on the extent of the problem.
e. Until a decision document is signed with ADEC, GRO and DRO concentrations will be compared to ADEC regulations in 18 AAC 75 (Table C, Groundwater Cleanup Levels; 1,500 ug/L for DRO, 1,300 ug/L GRO).
f. Sampling frequency for DRO/GRO will follow the latest Decision Guide for Sampling Frequency (see 2002 Basewide Annual Report). "Immediately up gradient" means within a 2-year warning line, similar to that generated for OU5.
g. ADEC GRO/DRO criteria apply to groundwater, not to seeps which daylight as surface water. Criteria in 18 AAC 70 (TAH, TAqH) apply to surface water.
4. The fact that these analytes were not included in the Zone 1 groundwater monitoring program
for FY09 is attributed to an oversight. The USAF will add DRO/GRO into the suite of analyses
at monitoring wells associated with fuel-related plumes for Zone 1 (LF04 South and WP14) and
will prepare a memo to the site file to prevent this type of oversight from occurring in the future.
The USAF strategy will be to compare DRO/GRO and total aromatic hydrocarbon (TAH)/total
aqueous hydrocarbon (TAqH) sample results as contaminants of interest with current ADEC
regulations in 18 AAC 75 - Table C - Groundwater Cleanup Levels and 18 AAC 70 for surface
water. Should you have any questions, please feel free to contact me at (907) 552-2875.
Signed Gary Fink YF-02 Chief, Environmental Restoration. |
Louis Howard |
| 11/17/2010 |
Meeting or Teleconference Held |
meeting of the remedial project managers (RPMs) convened at 0900 on 17 November 10 at
the Joint Base Elmendorf-Richardson (JBER)-Richardson Conference Room in Building 658.
Attendees included: Mr. Bill Adams - Environmental Protection Agency (EPA); Mr. Louis
Howard - Alaska Department of Environmental Conservation (ADEC); Mr. Robert Shirley - Air
Force Center for Engineering and Environment (AFCEE) Western Region Environmental Office;
Mr. Nick Muszynski - AFCEE Restoration - Program Management Office (R-PMO); Mr. Rafael
Vazquez - AFCEE R-PMO; Mr. Jim Klasen - lith Air Force Environmental Attorney;
Ms. Renee Wright - Environmental Restoration Community Relations Coordinator; and CEANR
personnel - Mr. Gary Fink, Mr. Mark Prieksat, Ms. Donna Bawnler, Mr. Don Aide, Mr. Tim
Plucinski, Mr. Dick Nenahlo, and Ms. Cynthia Tomlinson.
At WP14, seep LF04SP-03 exceeded cleanup level for benzene for 2 consecutive sampling events (2009/2010). |
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 - Institutional controls on land use and water use, as specified in the Base
General Plan, restricts access to the contaminated groundwater throughout WP14. Installation of wells in the contaminated plume for residential, industrial, and agricultural uses are prohibited by the Base General Plan.
Evaluation -A land use control inspection was performed and land use controls are in place and continue to be protective at WP14.
The Air Force ensures compliance with LUCs by conducting periodic monitoring and completing site inspections. Separate controls are in place and enforced by the Air Force to prevent inappropriate soil and groundwater exposure at these sites. The Air Force currently requires all projects resulting in soil disturbance of greater than four inches below ground surface to follow 3r Wing Instruction 32-1007, Safeguarding Utilities from Damage, dated 17 Aug 07 and 3rd Wing Instruction 32-7003, Land Use control Management, dated 16 Feb 07. Both instructions require the proponent to obtain an approved Base Civil Engineer Work Clearance Request (3 WG Form 3) prior to conducting work on the Base. |
Louis Howard |
| 2/7/2011 |
Exposure Tracking Model Ranking |
Initial ranking with ETM completed for source area id: 71618 name: Surface release |
Bianca Reece |
| 2/10/2011 |
Update or Other Action |
Zone 1 Draft Field Activities Report received. The only MNA parameter collected from OU6MW-92 was ferrous iron due to a low recharge rate that caused it to be purged dry. Well OU6MW-77 was not sampled due to the presence of 0.46 feet of free product. The MNA parameters in monitoring well OU6MW-93 showed low DO (1.79 mg/L) and elevated conductivity (420 µS/cm) but oxidizing ORP (117.8 mV) and a low ferrous iron concentration (0.04 mg/L). High ferrous iron (>3.3 mg/L), typical of in-plume conditions for fuel spills, was found in monitoring well OU6MW-92.
In OU6MW-92, benzene and ethylbenzene exceeded their cleanup levels, whereas all COCs were below their cleanup levels in OU6MW-93. Fuel product (0.46 feet) was found in monitoring well OU6MW-77 and removed with a bailer. Approximately 2 gallons of water mixed with product was segregated for disposal. OU6MW-77 did not contain product in 2007 or 2009; however, it has a history of accumulating free product.
Monitoring results from 2010 continue to define a plume in the shallow aquifer extending
from the WP14 site to points of discharge at seeps LF04SP-03 and -04 on the bluff
overlooking Knik Arm. Well OU6MW-77, in the core of the plume, contained free product
and therefore was not sampled. Well OU6MW-92, downgradient of OU6MW-77, contained benzene and ethylbenzene (59 µg/L and 800 µg/L) in excess of their cleanup levels.
Benzene concentration was slightly lower than in 2009, but ethylbenzene has increased over time.
Presently, dissolved benzene and ethylbenzene concentrations are probably maintained by the
ongoing dissolution of residual product in the contaminated smear zone and will continue to
be present at similar levels until the residual product attenuates and disappears. A meaningful
cleanup date cannot be predicted until decreasing trends are established.
Contaminant concentrations in monitoring well OU6MW-93 remained below cleanup levels.
The 2010 sampling data reinforces the assumption that OU6MW-77 and OU6MW-92 are
within the COC plume boundary and that OU6MW-93 is outside of it.
Downgradient of the WP14 plume (in the northern portion of the LF04 South area) COCs in
seep LF04SP-04 remain below cleanup levels for the third year in a row (Figure 4-2b).
However, the benzene concentrations in this seep have not exhibited an overall decreasing
trend over time, preventing prediction of a cleanup date. COCs in seep LF04SP-03 show
variability over time, but the ND results from 2003 through 2006 are likely due to sample collection at locations downgradient of the true seep.
The seep was rediscovered in 2007 and has been correctly sampled since that time. These seeps are expected to continue to exhibit variability in benzene concentrations while the core of the WP14 plume attenuates and possibly migrates westward. Benzene is the only COC to exceed cleanup levels at these seeps. No other LF04 South or WP14 COCs have been present here since monitoring began in 2002.
Recommendations for future monitoring at WP14 are as follows:
Continue with the 2010 groundwater monitoring program as outlined in Table 4-2.
Install and sample a new monitoring well downgradient from OU6MW-46 to determine the extent and stability of this portion of the plume. This recommendation was made in 2009 but scheduling difficulties prevented installation of the well during the 2010 field season.
Increase seep sampling for LF04SP-03 from annually to quarterly per Appendix A of the OU6 Memorandum to the Site File.
Reduce sampling frequency of OU6MW-93 per Appendix A of the OU6 Memorandum to the Site File due to 2 clean sample rounds for CoCs.
Sample GRO at OU6MW-67, -91, -121, and -120 and DRO at OU6MW-67 and TAH/TAqH at LF04SP-04 until two consecutive clean rounds have been collected. |
Louis Howard |
| 2/24/2011 |
Document, Report, or Work plan Review - other |
Staff reviewed and approved the recommendations in the draft field activities report for this source area in Operable Unit 6. |
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).
After JBER-Elmendorf was placed on the USEPA NPL, environmental restoration activities were separated into three separate management zones. Environmental Restoration Program Zone 1 Management Area covers the comparatively sparsely developed portions of JBER-Elmendorf to the west, north, & east of the airfield & administrative core of the base. Eleven sites are now managed under Zone 1: LF02, LF03, LF04, WP14, ST36/66, ST41, ST61, ST69, SS83, & DP98. LF02 & LF03 are located in the southeastern portion of the base, near the Boniface gate, whereas the remaining nine sites are distributed throughout the northwestern portion of the base, between the airfield & Knik Arm. GW contamination is tracked in nine plumes at these sites, & exposed landfill debris is of concern at LF04.
Six sites (LF02, LF03, LF04, WP14, ST41, & DP98) are administered under the Comprehensive Environmental Response, Compensation, & Liability Act (CERCLA), with USEPA oversight, & are governed by ROD. The five remaining sites (ST36/66, ST61, ST69, & SS83) are regulated according to State of Alaska requirements. GW COCs for most of the sites (WP14, ST36/66, ST41, ST61, & SS83) are fuel constituents (one or more of benzene, toluene, ethylbenzene, xylenes, or diesel-range organics [DRO]). These sites were contaminated by pipeline & storage tank leaks & past practices. The primary sources have been removed, leaving secondary sources comprised of residual fuel distributed in contaminated smear zones at the water table. Two sites have chlorinated-solvent GW COCs: LF04 (1,2-dichloroethane & methylene chloride, as well as fuel constituents), & DP98 (chlorinated solvents). The chlorinated solvents occur in shallow GW as dissolved contaminants at LF04 & in conjunction with a DRO contaminated smear zone at DP98.
WP14 is a 400-foot by 300-foot area located a few hundred feet east of LF04 South. Petroleum hydrocarbon contamination at this site originated during 1964 to 1968 when the area was used for fuel-tank sludge disposal generated from POL tank cleaning operations.
The Zone 1 Management Area sites are located throughout the western, northern, and eastern
portions of JBER-Elmendorf. Nine sites on JBER are managed under Zone 1: LF02, LF04, WP14, ST36/66, ST41, ST69, SS83, and DP98. COC are tracked in all nine GW plumes at these sites, and are listed below. LF04 also contains an inactive landfill where debris is monitored and fallen debris removed.
• Site LF02 - 1,1,2,2-tetrachloroethane (PCA)
• Site LF04 - Benzene, ethylbenzene, toluene, methylene chloride, 1,2-dichloroethane
(DCA)
• Site WP14 - Benzene, ethylbenzene, toluene
• Site ST36/66 - diesel range organics (DRO)
• Site ST41 - benzene, toluene, ethylbenzene, and xylenes (BTEX)
• Site ST69 - Benzene
• Site SS83 - DRO
• Site DP98 - tetrachloroethene (PCE), Trichloroethene (TCE), 1,1-dichloroethene, cis-1,2-
dichloroethene, vinyl chloride (VC)
The overall objectives of RA-O activities within the Zone 1 Management Area are to monitor the COCs & geochemical parameters affecting natural attenuation in GW plumes, & to detect contaminant migration patterns & provide early indication of unforeseen environmental or human health risks. Data quality objectives directly linked to Zone 1 project objectives are defined in the FSP & UFP-QAPP, within the SAP (Appendix A). Additional Zone 1 Management Area project objectives in 2011 include:
Evaluate & maintain the integrity of monitoring wells;
Evaluate GW flow characteristics while continuing to study trends in GW level with the monitoring wells; &
Evaluate erosion rates & characteristics of the LF04 bluff.
The activities to be performed under this TO include:
Collect & analyze GW & surface water samples;
Conduct GW level survey;
Perform maintenance of existing wells, as needed;
Install a maximum of 2 new/replacement GW wells;
Decommission a maximum of 5 damaged/redundant wells; &
Conduct LF04 erosion survey & debris removal. |
Louis Howard |
| 2/2/2012 |
Update or Other Action |
Memorandum for 2010 Annual Land Use Control (LUC) Monitoring Letter for DP98 and OUs 1, 2, 4, 5, and 6.
References:
(a) DP98 Record of Decision, Section 12.2.3.4, dated May 2004
(b) OU6 Explanation of Significant Differences, Section 4.3.1.3, dated Mar 2007
(c) Memorandum to the Site File for OUs 1,2,4, and 5, Section 4, dated Jan 2010
1. This letter serves as the annual monitoring report on the status of LUCs in place at DP98 and
at OUs 1,2,4,5 and 6. The specific LUCs in place at each site are provided below. An
evaluation of the implementation of these requirements is provided in bold following each
specific LUC.
OU6:
Site WP14
Groundwater - Institutional controls on land use and water use, as specified in the Base
General Plan, restricts access to the contaminated groundwater throughout WP14.
Installation of wells in the contaminated plume for residential, industrial, and agricultural
uses are prohibited by the Base General Plan.
Evaluation - LUCs are in place and continue to be effective at WP14. 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 |
2011 Zones 1, 2, 3 draft annual report received.
Two plumes (WP14 & OU6MW-46) are managed within WP14. The WP14 plume encompasses GW contamination derived from WP14 & PL81. The plume migrates westerly towards LF04 & discharges at two seeps overlooking Knik Arm, a distance of approximately 1,000 ft from the WP14 & PL81 source areas. The PL81 DD states that all GW contamination attributable to PL81 will be managed by the OU6 ROD. Therefore, GW contamination associated with PL81 is monitored as part of the LF04 South & WP14 GW monitoring program. The second plume (OU6MW-46) is a smaller plume cross-gradient from the WP14 source area & is monitored with one well OU6MW-46) in a perched GW aquifer.
Benzene & ethylbenzene exceeded their cleanup levels in well OU6MW-46. In OU6MW-92, benzene exceeded the cleanup level, whereas all COCs were below their cleanup levels in OU6MW-91 & OU6MW-93. COC concentrations did not exceed cleanup levels in well OU6MW-67 or the nearest seep (LF04SP-04), but benzene levels exceeded the cleanup level of 5 µg/L in seep LF04SP-03.
Monitoring results from 2011 are consistent with the plume defined in the shallow aquifer extending from the WP14 site to points of discharge at seeps LF04SP-03 & -04 on the bluff overlooking Knik Arm. In OU6MW-92, the concentration of benzene (39 µg/L) exceeded the cleanup level. Benzene was slightly lower than in 2010, & ethylbenzene has dropped below the cleanup level again after a spike observed in 2010. Presently, dissolved benzene & ethylbenzene are probably maintained by the ongoing dissolution of residual product in the contaminated smear zone & will continue to be present at similar levels until the residual product attenuates & disappears. A meaningful cleanup date cannot be predicted until decreasing trends are established.
Contaminant concentrations in monitoring well OU6MW-93 remained below cleanup levels. The 2011 sampling data reinforces the assumption that OU6MW-77 & OU6MW-92 are within the COC plume boundary & that OU6MW-93 is outside of it. Downgradient of the WP14 plume (in the northern portion of the LF04 South area) COCs in seep LF04SP-03 show variability over time (Figure 2.7A), but the ND results from 2003 through 2006 are likely due to sample collection at locations downgradient of the true seep. The seep was rediscovered in 2007 & has been correctly sampled since that time. COCs in seep LF04SP-04 remain below cleanup levels for the fourth year in a row.
However, the benzene levels in this seep have not exhibited an overall decreasing trend over time, preventing prediction of a cleanup date. These seeps are expected to continue to exhibit variability in benzene levels while the core of the WP14 plume attenuates & possibly migrates westward. Benzene is the only COC to exceed cleanup levels at these seeps. No other LF04 South or WP14 COCs have been present at this site since monitoring began in 2002
Monitoring well OU6MW-91 is on the southern boundary of the WP14 plume. In 2011, benzene concentrations were not detected but the data continue to show substantial scatter. Attenuation trends are fit with first-order decay curves using the statistical geometric regression approach (USAF, 2007a) to forecast a probable cleanup date. The geometric regression of the data from this monitoring well was unable to predict a cleanup date. The scatter in the data results in a poor correlation coefficient of 0.07. In 2007, the benzene data for this monitoring well did not exhibit a decreasing trend, so no cleanup prediction date was available.
Although not measured in 2009, levels of other fuel-related contaminants were predicted, in 2007, to clean up by 2010 (DRO) & 2018 (GRO) (USAF, 2008b). The subsequent nondetect result for benzene in 2011 supports the development of a decreasing trend for benzene, but the variance in the results, as reflected in the upper 95% confidence level curve, prevented prediction of a cleanup date. Coupled with cleanup date predictions based on DRO & GRO levels, the available data provide evidence that the southern border of this plume is shrinking. Additional monitoring is needed to confirm this conclusion.
|
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.
Site WP14
Groundwater - Institutional controls on land use and water use, as specified in the Base
General Plan, restricts access to the contaminated groundwater throughout WP 14. Installation of wells in the contaminated plume for residential, industrial, and agricultural uses are prohibited by the Base General Plan.
Evaluation -Inspection conducted on 29 Aug 12 and LUCs are in place and continue to be protective at WP14.
|
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) 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.
Acceptance criteria for this project are specified in the Draft Basewide UFP-QAPP, criteria specified in the analytical lab standard operating procedures (SOPs), & accepted analytical methods. Overall, the data have met the quality control acceptance criteria specified for this project. Nonconformances of data are identified, discussed, & qualified in this report. When possible, direction of potential bias is assigned.
During 2012, groundwater monitoring wells OU6MW-92, OU6MW-93, 14MW-120, 14MW-121 OU6MW-13 and seeps LF04SP-03, LF04SP-04 were sampled for VOCs only. Concentrations of benzene exceeded the OU6 ROD cleanup criteria for groundwater well OU6MW-92 (6.2 µg/L) and seep LF04SP-03 (7.4 µg/L). No analytical results for monitored contaminants exceeded cleanup criteria in the remaining wells or seeps. Table 14-1 presents cleanup criteria and results. A LUC inspection performed for WP014 on 29 August 2012 did not identify any issues.
Site Summary
The 2012 monitoring results are consistent with the plume defined in the shallow aquifer
extending from the WP014 site to points of discharge at seeps LF04SP-03 and -04 on the bluff
overlooking Knik Arm. In OU6MW-92, the concentration of benzene (6.2 µg/L) exceeded the
cleanup level, which is significantly lower than previous years and ethylbenzene has dropped
below the cleanup level again after a spike observed in 2010. Presently, dissolved benzene and
ethylbenzene concentrations are probably maintained by the ongoing dissolution of residual
product in the contaminated smear zone and will continue to be present at similar levels until the
residual product attenuates and disappears.
Downgradient of the WP014 plume (in the northern portion of the LF004 South area) COCs in seep LF04SP-03 show variability over time, but the ND results from 2003 through 2006 are likely due to sample collection at locations downgradient of the true seep. The seep was rediscovered in 2007 and has been correctly sampled since that time. The benzene levels were above clean-up criteria for the first quarter sample event and below clean-up criteria for the second quarter, exhibiting a decreasing trend from 2010. COCs in seep LF04SP-04 remain below cleanup criteria for the fifth year in a row. However, the benzene concentrations in this seep have not exhibited an overall decreasing trend over time. These seeps are expected to continue to exhibit variability in benzene concentrations while the core of the WP014 plume attenuates and possibly migrates westward. No other LF004 South or WP014 COCs have been present at this site since monitoring began in 2002.
Upgradient of the WP014 plume the sources have been removed and no additional upgradient sources are anticipated. The remaining contaminants appear to have moved past monitoring well 14MW-120 in 2007, suggesting it is on the upgradient edge of the plume. Analytical results for in-plume samples from WP014 benzene exceeded cleanup levels in the core of the plume, but ethylbenzene dropped below the cleanup level after an exceedance in 2010. Concentrations remain variable and do not yet show a downward trend. The northern and southern boundaries of the plume remain the same as depicted in 2009.
Current observations are consistent with the hypothesis that product remains in the contaminated smear zone at residual saturation and is now generally immobile and degrading and dissolving in place (USAF, 2008a). Contaminant fluctuations in the in-plume monitoring wells will continue as varying water levels control the degree of interaction with the contaminated smear zone, and minor mobility of residual product can lead to the accumulation of free product in monitoring wells.
Additional investigation is planned to be conducted under the new PBR contract at WP014. No changes to the remedial activities are being proposed for this site. |
Louis Howard |
| 7/3/2013 |
Document, Report, or Work plan Review - other |
EPA Sandra Halstead provided review comments on the 2013 Letter Work Plan Addendum.
1.0 Introduction
The 2012 Annual Report was not reviewed or finalized at the time of review of the draft 2013 LTM workplan. It is unknown if the tables are consistent with the recommendations. The table from 2011 was used as the basis for sampling location, COC group, and frequency.
2.1.2 LUC/IC Inspections
These site names are provided in Table 11-1 of the 2013 UFP-QAPP. It would be good to refer to that Table since some of the sites have changed names since the 2011 workplan.
Suggest using the same inspection sheet for both JBER-E and JBER-R LUC inspections. Attachment 1B provides more detailed information and is the preferred format.
2.1.3 OU5 WRS O&M
Add observer name to inspection form.
Table 1 JBER-Elmendorf CERCLA Regulated Sites
LF004 & WP014
What happened to well OU6MW-67? It was on a 2 year frequency for VOCs.
These wells were annual basis in 2011. Why the discrepancy in year if they are 5 year cycles?
FT023 & SD015
Well FP56 missing and well OU4MW-11 was not in the 2011 workplan. Are these the same?
Well OU6MW-18 is missing for annual sampling for VOCs.
ST037 Seeps
2011 Workplan lists BTEX as a constituent, not PAH for the Seeps.
Pump Stn #1, Ship Cr., Beaver Pond Area
2011 workplan included BTEX analysis for Pump Station #1, Ship Creek, Beaver Pond, and Wetland Treatment Cell samples.
Wetland Treatment Cell
No PAH in 2011 workplan; please make sure a sample is taken without MeOH preservative for SW8260 for soils/sediment. |
Louis Howard |
| 3/17/2014 |
Document, Report, or Work plan Review - other |
EPA Letter to Air Force regarding the 4th Five Year Review for JBER-Elmendorf.
The U. S. Environmental Protection Agency Region 10 has reviewed the Fourth CERCLA Five-Year Review report for Superfund sites, specifically for Operable Units (OU) 1, 2, 4, 5, 6 and DP98 associated with Elmendorf Air Force Base on Joint Base Elmendorf-Richardson, Alaska. The conclusions in this letter are based on the draft report from November 2013 and revised Response to Comments, Summary Form, and Sections 8 and 9 which were received by the EPA on March 12, 2014.
The EPA reviewed the report for technical adequacy, accuracy, and consistency with the National Contingency Plan and EPA guidance. The document provides a summary of the status and protectiveness for OUs for which Records of Decisions (RODs) have been completed and are not determined as No Further Action. It also identifies actions to be taken that ensure protectiveness of the selected remedies and on-going remedial actions and documents a schedule for completion of the recommended actions.
The following are the EPA’s protectiveness determinations for these OUs and the overall Site protectiveness that will be reported to Congress in the EPA’s annual report. Also included are additional recommendations and follow-up actions necessary to address issues raised in the Five-Year Review that affect or could affect protectiveness. In general, the EPA concurs with the protectiveness determinations in this Air Force report. Each OU is discussed individually below.
OU 6
The EPA concurs that the remedy for OU 6 is currently short-term protective of human health and the environment because Land Use Controls are preventing exposure to contaminated groundwater and soil. Groundwater contaminants at sites LF04 South, WP14, and SD15 are not showing decreasing trends, therefore the levels will not meet cleanup goals by 2020 as specified in the Record of Decision (ROD) by 2020. In order for the remedy to be protective in the long term, EPA agrees alternative remedies should be evaluated under the process established in the FFA to accelerate attainment of cleanup levels in groundwater at OU6.
Additionally, 2-methylnapthalene was detected in the groundwater at WP14 at a maximum level of 630 micrograms per liter (ug/L) in sampling prior to the ROD, however a cleanup standard for this compound did not exist at the time of the ROD in 1997. A cleanup level for 2-methylnapthalene of 150 ug/L was established in groundwater by the State of Alaska under 18 AAC 75, Table C Groundwater Cleanup Tables in 2009. Land Use Controls for OU6 prohibit access to contaminated groundwater as a source of drinking water. EPA agrees with the recommendation to assess current concentrations of 2-methylnapthalene in groundwater at WP14, and to discuss the results of groundwater concentrations with EPA and Alaska Department of Environmental Conservation to determine if additional action is warranted. |
Louis Howard |
| 5/14/2014 |
Update or Other Action |
Draft 2013 Annual Field Activities Report received. This report summarizes the 2013 annual long-term management activities, including remedial action-operation (RA-O) and Record of Decision (ROD) requirements, conducted at Joint Base Elmendorf-Richardson (JBER) Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) sites. The United States Air Force (USAF) has mandated a reduction of long-term environmental liabilities and life-cycle costs through accelerated cleanup of contaminated sites. As such, the Performance-Based Remediation (PBR) initiative has been developed to protect human health and the environment in a cost-effective manner, while at the same time reducing life-cycle costs.
In April 2012, Weston Solutions, Inc. (WESTON) was awarded a PBR contract from the Air Force Civil Engineer Center (AFCEC) (Contract Number FA8903-09-D-8589, Task Order No. 0016). The contract includes performing RA-O and ROD requirements at several JBER sites. The WESTON team performing the activities summarized in this report consists of WESTON and CH2M HILL Constructors, Inc. (CH2M HILL). WESTON executed project work on sites located within JBER-Elmendorf, while CH2M HILL executed project work on sites located within JBER-Richardson.
The 2013 monitoring results are consistent with the plume defined in the shallow aquifer extending from the WP014 site to points of discharge at seeps LF04SP-03 and -04 on the bluff
overlooking Knik Arm. Presently, dissolved benzene and ethylbenzene concentrations are probably maintained by the ongoing dissolution of residual product in the contaminated smear zone and will continue to be present at similar levels until the residual product attenuates and disappears. Benzene and ethylbenzene concentration trends in well OU6MW-46 are shown on Figure 14-2 and the benzene concentration trend in well OU6MW-92 is shown on Figure 14-3. Mann-Kendall trend tests show that there is a statistically significant decreasing trend at the 95% level of significance for benzene in both wells and an increasing trend for ethylbenzene in well OU6MW-46.
Downgradient of the WP014 plume (in the northern portion of the LF004 South plume area) COCs in seep LF04SP-03 show variability over time. The benzene level was above the cleanup criteria during one of four quarterly samples in 2013. The benzene concentration in seep LF04SP-04 was above the cleanup criteria for the first time since 2007. These seeps are expected to continue to exhibit variability in benzene concentrations while the core of the WP014 plume attenuates and possibly migrates westward. According to the Decision Guide in Attachment 1 of the OU6 Memorandum to the Site File (USAF, 2003b), seeps that exceed cleanup level should be sampled quarterly. It is therefore recommended that seep LF04SP-04 be sampled quarterly in 2014.
Upgradient of the WP014 plume, the sources have been removed and no additional upgradient sources are anticipated. The remaining contaminants appear to have moved past monitoring well 14MW-120 in 2007, suggesting it is on the upgradient edge of the plume.
Current observations are consistent with the hypothesis that product remains in the contaminated
smear zone at residual saturation and is now generally immobile and degrading and dissolving in
place (USAF, 2008b). Contaminant fluctuations in the in-plume monitoring wells will continue
as varying water levels control the degree of interaction with the contaminated smear zone, and
minor mobility of residual product can lead to the accumulation of free product in monitoring
wells.
Well OU6MW-67 had a benzene concentration of (5.2 µg/L) that exceeded the OU6 ROD in 2013, after being below the cleanup level since 1999. This well is also used to monitor groundwater at LF004. Although it is not currently scheduled to be sampled again until 2015, it is recommended to sample this well in 2014 to determine if benzene concentrations persist above the cleanup level. No other changes to the monitoring program are proposed for this site. |
Louis Howard |
| 8/12/2014 |
Update or Other Action |
Draft WP received for review and comment.
The primary objective of this UFP-QAPP Site Characterization Work Plan is to gather all necessary site-specific data needed to re-evaluate the original estimates for site contaminants to attenuate below the established cleanup goals, to re-evaluate plume stability, and to determine the “value” of identifying an approach to expedite reaching the cleanup goals at this site within the context of the CERCLA process. Note: With respect to the context of this document, “value” should be interpreted as reducing the life cycle costs (LCCs) for the project.
Scoping meeting where no regulators were in attendance (nor invited) produced the following consensus decisions:
Site-wide groundwater characterization should be added to the WP014 Site Characterization
Uniform Federal Policy-Quality Assurance Project Plan (UFP-QAPP) Work Plan (i.e. collect
groundwater samples for analytical analysis from all current in-program and out-of-program
monitoring wells).
Perform review of well screen intervals (using historical boring logs) to determine which
aquifer(s) are contributing source to groundwater samples collected from in-program and
out-of-program monitoring wells.
Investigate historical boundaries from Plume WP014.
Determine if practicable to remove additional free-phase product from any in-program and
out-of-program monitoring wells.
Perform a statistical plume stability analysis on Plume WP014 (i.e. run a Mann Kendall
analysis).
After evaluation of site-wide groundwater characterization, determine “value” of adding one
additional monitoring well in Plume WP014.
|
Louis Howard |
| 8/19/2014 |
Document, Report, or Work plan Review - other |
ADEC has reviewed the work plan and has no comments on the document. The work plan is approved. Please finalize the document.
ADEC’s review and comment on this work plan is to ensure that the work is done in accordance with State of Alaska environmental conservation laws and regulations. While ADEC may comment on other state and federal laws and regulations, our comments on the work plan does not relieve responsible persons from the need to comply with other applicable laws and regulations. The Air Force is responsible for the actions of contractors, agents, or other persons who perform work to implement the approved work plan. For any activity that significantly deviates from the approved plan, the Air Force shall notify the ADEC and obtain written approval in the form of a work plan amendment before beginning the activity.
|
Louis Howard |
| 11/5/2014 |
Document, Report, or Work plan Review - other |
EPA provided comments on the draft CERCLA Report.
Comment: Agree with the recommendation to sample OU6MW-67 in 2014 due to 'rebound' conditions. |
Louis Howard |
| 5/20/2015 |
Document, Report, or Work plan Review - other |
The Alaska Department of Environmental Conservation (ADEC) has received the Final Site Characterization Work Plan for WP014 JBER, Alaska dated May 2015 for WP014 (CS DB Hazard ID 639). ADEC has no further comments on the final version of the document and approves the document.
|
Louis Howard |
| 7/23/2015 |
Update or Other Action |
Draft Field Activities Report received for review & comment.
The 2014 monitoring results are consistent with the plume defined in the shallow aquifer extending from the WP014 site to points of discharge at seeps LF04SP-03 & -04 on the bluff overlooking Knik Arm. Presently, dissolved benzene concentrations are probably maintained by the ongoing dissolution of residual product in the contaminated smear zone & will continue to be present at similar levels until the residual product attenuates & disappears.
Downgradient of the WP014 plume (in the northern portion of the LF004 South plume area) COCs in seep LF04SP-03 show variability over time. The benzene level was above the cleanup levels during two of four quarterly samples in 2014. In 2013 the benzene concentration in seep LF04SP-04 was above the cleanup level for the first time since 2007; therefore this seep was sampled quarterly. In 2014 the benzene concentration continued to exceed the cleanup level in the third & fourth quarters. The seeps are expected to continue to exhibit variability in benzene concentrations while the core of the WP014 plume attenuates & possibly migrates westward.
According to the Decision Guide in Attachment 1 of the OU6 Memorandum to the Site File, seeps that exceed cleanup level should be sampled quarterly. It is therefore recommended that seep LF04SP-04 be sampled quarterly in 2015. Upgradient of the WP014 plume, the sources have been removed & no additional upgradient sources are anticipated. The remaining contaminants appear to have moved past monitoring well 14MW-120 in 2007, suggesting it is on the upgradient edge of the plume. Current observations are consistent with the hypothesis that product remains in the contaminated smear zone at residual saturation & is now generally immobile & degrading & dissolving in place.
Contaminant fluctuations in the in-plume monitoring wells will continue as varying water levels control the degree of interaction with the contaminated smear zone, & minor mobility of residual product can lead to the accumulation of free product in monitoring wells. The Mann-Kendall trend tests for benzene in well OU6MW-67 & seep LF04SP-03, ethylbenzene in well OU6MW-67, & toluene in wells OU6MW-67 indicated statistically significant decreasing trends at the 95% confidence level. No statistically significant trends were identified for benzene & ethylbenzene in wells OU6MW-92 & OU6MW-93, ethylbenzene in seep LF04SP-03, benzene or toluene in seep LF04SP-04, & toluene in well OU6MW-93.
While the Mann-Kendall trend test for toluene in seep LF04SP-03 indicated an increasing trend, high censoring (only three detections) makes the trend analysis unreliable & thus is considered not to be significant. Graph 14-1 presents the benzene trend in seep LF04SP-03.
See site file for additional information. |
Louis Howard |
| 1/13/2017 |
Update or Other Action |
ADEC received a GW monitoring report for several JBER sites which summarizes the 2015 annual long-term management (LTM) activities, including remedial action-operation (RA-O) & ROD requirements conducted at JBER CERCLA sites.
Site WP014 is identified as a Yellow priority since contaminant concentrations continue to exceed
ROD cleanup goals. Well OU6MW-67 exhibited a benzene concentration of 5.2 µg/L that exceeded the cleanup level in 2013 after being below the cleanup level since 1999; it was sampled in 2014 and 2015. This monitoring well is also used to monitor groundwater at LF004. It is recommended that this well be sampled annually to determine whether benzene concentrations significantly decrease. In 2016, monitoring well OU6MW-13 will be sampled for 2-methylnaphthalene in addition to VOCs, as recommended in the fourth five-year review. It is also recommended that if OU6MW-91 continues to have measurable product in the well then samples should be collected from OU6MW-94 as a replacement.
Additional characterization work for 2015 is being conducted at the WP014 site under the WP014
UFP-QAPP Limited Site Investigation Work Plan (USAF, 2015d). The results of the LSI are
anticipated to be finalized in 2016, additional recommendations will be provided after the results
are evaluated. |
Louis Howard |
| 1/13/2017 |
Update or Other Action |
ADEC received a GW monitoring report for several JBER sites which summarizes the 2015 annual long-term management (LTM) activities, including remedial action-operation (RA-O) & ROD requirements conducted at JBER CERCLA sites.
CG039 has been identified as a Yellow priority because the treatability study has substantially reduced contaminant concentrations in the target treatment zones; however, TCE daughter products, primarily cis-1,2-DCE, have increased substantially. Annual monitoring will continue to assess plume-wide & treatability target treatment zone concentration trends, as described below.
Specific recommendations for ongoing GW monitoring are as follows:
Annual GW monitoring will continue in accordance with the 2011 Memo to Site File (MTSF). Continue with annual GW monitoring (2016) of the treatability study wells to assess potential rebound of TCE, degradation of TCE daughter products, & persistence of reducing GW conditions. All requirements of the MTSF will continue to be monitored, but analytical & field parameters will be added as necessary so that the treatability study wells (AP-3744, AP-3747, AP-3983R, AP-3989, AP-4550, & AP-4551) continue to be monitored as outlined in Table 2 of the 2015 Remedial Action – Operations & Monitoring Letter Work Plan Addendum (USAF, 2015a) (LTM Work Plan).
The annual sampling will be modified as follows: Five wells will be sampled annually as prescribed by the MTSF: AP-3748, AP-4344, AP-4353, AP-5246, & AP-5683 (AP-4019 replacement well). Two wells identified for annual sampling in the MTSF will still be sampled as prescribed, with the addition of the treatability study parameters listed in Table 2 of the LTM Work Plan: AP-3747 & AP-4550. Two wells identified as Sentinel Wells to be sampled in the year preceding the Five-Year Review (2017) will also be sampled in 2016 for the treatability study parameters listed in Table 2 of the LTM Work Plan: AP-3744 & AP-3989.
Three wells that are not identified to be sampled in the MTSF, either annually or every 5 years, will be sampled for the treatability study parameters listed in Table 2 of the LTM Work Plan: AP-3983R, AP-4525, & AP-4551. The 2016 annual LTM Work Plan will formally outline this plan. The monitoring results from the seven treatability study wells will be reported in the 2016 annual GW monitoring report.
Based on the results of the additional treatability study GW monitoring, the following actions are recommended: Continue with another round of annual GW monitoring as outlined in Treatability Study Report CG039 – Poleline Road Disposal Area Joint Base Elmendorf-Richardson, Alaska (USAF, 2015e). Continue the treatability study to evaluate whether bioaugmentation can degrade cis-1,2-DCE & possibly 1,1,2,2-PCA to accelerate the remedial time frame at the site.
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 inner PVC casing of well OU6MW-46 was cut down so that the outer casing lid could be secured.
See site file for additional information. |
Louis Howard |
| 2/9/2018 |
Document, Report, or Work plan Review - other |
Staff commented on the Annual Report for CERCLA sites. Main comments were to request that GRO and DRO be monitored in groundwater in accordance with State regulatory requirements in accordance with the 2003 meeting minutes and 2010 Air Force memorandum regarding these COCs for fuel sources being monitored under CERCLA. If DRO, GRO, or PAHs are above current cleanup levels for groundwater, ADEC will require that they be analyzed for as part of the long-term monitoring of groundwater at WP014.
See site file for additional information. |
Louis Howard |
| 3/8/2018 |
Document, Report, or Work plan Review - other |
WP014 Limited Site Investigation Report received for review & comment. Source areas of POL contamination exist in the vicinity of SB-121 from historical POL sludge disposal & fuel filter weathering activities. Residual smear & saturated zone contamination at the upgradient PL081 site may be impacting GW contributing to the WP014 contamination. Additional information is needed to distinguish between the two sites. Further investigation at PL081 is needed to determine if residual smear zone contamination is contributing to the WP014 Plume.
• Typically, hydrocarbon contamination in soils is known to stabilize within a few years of being released. The appearance of free product in OU6MW-77 & OU6MW-91, 50 years after the original sludge disposal & fuel filter weathering activities, suggests a new source of contamination. Increasing dissolved phase concentrations in OU6MW-92 also supports a possible new source.
• The GW gradient in the northeast part of WP014 is southwest & in the central area, the gradient shifts to a more westerly gradient carrying GW contamination toward the Knik Arm bluff. Mixing between an intermediate semi-confined aquifer & the shallow aquifer exists along the edge of the bluff where GW daylights as distinct seeps.
• A recommendation was made in the Fourth Five-Year Review to resample 2-methylnaphthalene due to the potential risk associated with concentrations detected at the time of the ROD. The concentrations of 2-methylnaphthalene presented in this report are well below 18 AAC 75 Table C cleanup level.
• Bail-down tests conducted at OU6MW-77 & OU6MW91 indicate that there is insufficient recoverable light non-aqueous phase liquid (LNAPL) present to warrant a product removal system.
See site file for additional information. |
Louis Howard |
| 3/15/2018 |
Document, Report, or Work plan Review - other |
Staff commented on the draft LSI report and had the following comments: Since the contaminants of concern at WP014 (Operable Unit 6) are strictly petroleum [benzene, ethylbenzene, toluene and diesel range organics (DRO)/gasoline range organics (GRO)], it may be time for the EPA, AFCEC and ADEC to consider removing WP014 from the CERCLA program and place it under State of Alaska oversight and regulatory authority. The Record of Decision and model do not consider the presence of GRO and DRO in the groundwater which will need to be addressed under State authority when benzene, ethylbenzene and toluene achieve ROD cleanup levels. DRO is present above the solubility limit in wells OU6MW-12 and 14MW-121.
See site file for additional information. |
Louis Howard |
| 1/15/2019 |
Update or Other Action |
Draft Five year review received for Operable Unit 6 which includes source area WP014. Issue: Cancer risks exceed 1 x 10-4 or have an HQ greater than 1 for the following non-COC chemicals [in groundwater (GW)]: 1,2-DCA, 2-methylnaphthalene, chlorobenzene, naphthalene, TCE, vanadium, and total xylenes. Recommendation: Investigate, by conducting a sampling event, the following chemicals for potential inclusion as GW remedy COCs: 1,2-DCA, 2-methylnaphthalene, chlorobenzene, naphthalene, TCE, vanadium, and total xylenes. Document any changes to COCs in a decision document.
Issue: No soil COCs are identified. Cancer risks exceed 1 x 10-4 or have an HQ greater than 1 for the following chemicals in soil: benzene, chloroform, copper, ethylbenzene, naphthalene, thallium, and total xylenes. Recommendation: Investigate, by conducting a sampling event, the following chemicals to determine if soil COCs are warranted: benzene, chloroform, copper, ethylbenzene, naphthalene, thallium, and total xylenes.
Issue: Limited natural attenuation of COCs in GW and the anticipated date (2011) of achieving concentrations below cleanup levels was not achieved. Recommendation: Conduct additional studies to determine if the remedy, as is, will be able to achieve remediation goals within the estimated time frame. Other studies may include, but are not limited to, site characterization, ecological assessment, focused feasibilities studies, GW modeling, treatability studies, and/or sampling.
See site file for additional information. |
Louis Howard |
| 4/12/2021 |
Document, Report, or Work plan Review - other |
DEC submitted comments on Draft JBER Basewide UFP-QAPP dated February 2021. |
William Schmaltz |
| 5/19/2021 |
Document, Report, or Work plan Review - other |
DEC Reviewed and approved of Basewide Uniform Federal Policy - Quality Assurance Project Plan. QAPP summarizes general activities for a 5 year period on JBER. |
William Schmaltz |
| 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 |
| 2/7/2023 |
Document, Report, or Work plan Review - other |
DEC reviewed 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 |
| 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 |
| 4/25/2023 |
Document, Report, or Work plan Review - other |
DEC approved the 2023 Letter Work Plan Remedial Action Operations and Long-Term Management, Final, Dated April 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 |
| 1/29/2024 |
Document, Report, or Work plan Review - other |
DEC reviewed the 2022 Annual Remedial Action-Operations and Long-Term Management Report for Select CERCLA Sites, Draft, dated October 2023. The report describes the site inspections, maintenance activities, and groundwater monitoring, at multiple sites located on Joint Base Elmendorf- Richardson (JBER), Anchorage, Alaska. Site inspections and sampling were recommended to continue for all applicable sites to ensure that conditions remain protective of human health and the environment. |
Ginna Quesada |
| 7/2/2024 |
Document, Report, or Work plan Review - other |
DEC approved the 2022 Annual Remedial Action-Operations and Long-Term Management Report for Select CERCLA Sites, Final, dated June 2024. The report describes the site inspections, maintenance activities, and groundwater monitoring, at multiple sites located on Joint Base Elmendorf- Richardson (JBER), Anchorage, Alaska. Site inspections and sampling were recommended to continue for all applicable sites to ensure that conditions remain protective of human health and the environment. |
Ginna Quesada |
| 11/12/2024 |
Document, Report, or Work plan Review - other |
DEC approved the 2023 Annual Remedial Action-Operations and Long-Term Management Report for Select CERCLA Sites, Final, dated October 2024. The report describes the site inspections, maintenance activities, and groundwater monitoring, at multiple sites located on Joint Base Elmendorf- Richardson (JBER), Anchorage, Alaska. Site inspections and sampling were recommended to continue for all applicable sites to ensure that conditions remain protective of human health and the environment. |
Ginna Quesada |
| 1/30/2025 |
Document, Report, or Work plan Review - other |
DEC approved the 2025 Remedial Action–Operations and Long-term Monitoring Work Plan Addendum Final, dated January 2024.The work plan describes the site inspections, maintenance activities, and groundwater, seep, and surface water monitoring, activities that will be conducted at multiple sites located on Joint Base Elmendorf- Richardson (JBER), Anchorage, Alaska. The scope of work briefly summarizes the site locations, sampling/monitoring activities and schedules. This workplan will remain consistent with the procedures outlined in the 2023 Letter Work Plan Remedial Action-Operations and Long-Term Management. |
Ginna Quesada |
| 4/4/2025 |
Document, Report, or Work plan Review - other |
DEC provided comments regarding the Data Gap Study Management Plan For LF004, WP014, And DP098 Draft,
dated March 2025.The work plan describes the proposed investigation activities to address the data gaps identified in the Five-Year Reviews for LF004, WP014, and DP098 sites located on Joint Base
Elmendorf- Richardson (JBER), Anchorage, Alaska. The potential groundwater connectivity between
LF004, WP014 and an adjacent site PL081 will be evaluated in this effort. A clustered shallow/deep
monitoring well pair will be installed at across these sites to understand aquifer conditions, evaluate continuity between the plumes,and investigate the potential migration pathways present at the sites. Soil and groundwater samples will be collected. At WP014 samples will be analyzed for gasoline range organics (GRO), diesel range organics (DRO), residual range organics (RRO), and volatile organic compounds (VOCs). At DP098 samples will be analyzed for total organic carbon, DRO, RRO, and
VOCs. The collected data from this study will be used to model new remediation timeframes and to
inform potential adjustments to remediation efforts at the sites. |
Ginna Quesada |
