| Action Date |
Action |
Description |
DEC Staff |
| 6/8/1940 |
Update or Other Action |
The construction of Elmendorf Field on Fort Richardson began when 25 local men hired by Maj Edward M. George, U.S. Army Quarter Master Corps, began unloading equipment and supplies from four Alaska Railroad cars near the Whitney Station House, once located on the east side of Elmendorf AFB at the intersection of the Davis Highway and Talley Avenue. The train brought down four men, a RD-8 Caterpillar tractor and carry-all, a concrete mixer and four dump trucks from Ladd Field.
The construction effort created 1,000 jobs virtually overnight and the population of Anchorage swelled by a factor of four, creating a boomtown atmosphere and straining resources. |
Louis Howard |
| 1/30/1978 |
Update or Other Action |
Permit SC-16-78 application submitted by the USAF to ADEC for review. |
Louis Howard |
| 6/1/1979 |
Document, Report, or Work plan Review - other |
Permit# SC-16-78 issued to Elemendorf AFB for the landfill in the approach zone of Runway 23. |
Louis Howard |
| 6/23/1982 |
Update or Other Action |
Permit renewal request for Permit #SC-16-78 with expansion directly adjacent to the current
landfill as shown in figure attached to the request. |
Louis Howard |
| 7/1/1982 |
Update or Other Action |
Notification of receipt of Permit# SC-16-78 renewal request submitted by the USAF to ADEC. |
Louis Howard |
| 9/30/1982 |
Document, Report, or Work plan Review - other |
Permit #8221-BA011 issued to Elmendorf AFB to replace Permit # SC-16-78. |
Louis Howard |
| 7/29/1983 |
Update or Other Action |
The Department of Defense (DOD) has developed a program to identify and evaluate past hazardous material disposal sites on DOD property, to control the migration of hazardous contaminants, and to control hazards to health or welfare that may result from these past disposal operations.
This program is called the Installation Restoration Program (IRP). The IRP has four phases consisting of Phase I, Initial Assessment/Records Search; Phase II, Confirmation/Quantification; Phase III, Technology Base Development/Evaluation of Alternative Remedial Actions; and Phase IV, Operations/Remedial Actions.
Engineering-Science (ES) was retained by the Air Force Engineering and Services Center to conduct the Phase I, Initial Assessment/Records Search at Elmendorf AFB under Contract No. F08637-83-G0009, Call No. 5003, using funding provided by the Alaskan Air Command.
The basewide record search identified numerous sites needing further investigations. Table 4.5 Disposal Site Information Summary Site No. D-8 1965-1983 24 acres in size, construction debris disposal in a gravel pit area. At the time, no evidence of contamination was noted during the site visit.
LF59 (D-8) was one of several inactive disposal sites at Elmendorf AFB (Site D-6, Site D-8, Site D-9 and Site D-12) were used to dispose of construction rubble generated due to the changes in base operation and renovation of various areas on the base. All sites (except D-8) are presently closed. Based on a site inspection, the sites present no visual evidence of contamination. Due to the inert nature of the waste deposited at these locations, a potential for contamination does not exist. |
Jennifer Roberts |
| 9/1/1983 |
Update or Other Action |
IRP Phase I Records Search Engineering Science (ES) for USAF AFESC/DEV & AAC Elmendorf AFB. The Department of Defense (DOD) has developed a program to identify & evaluate past hazardous material disposal sites on DOD property, to control the migration of hazardous contaminants, & to control hazards to health or welfare that may result from these past disposal operations.
This program is called the Installation Restoration Program (IRP). The IRP has four phases consisting of Phase I, Initial Assessment/Records Search; Phase II, Confirmation/Quantification; Phase III, Technology Base Development/Evaluation of Alternative Remedial Actions; & Phase IV, Operations/Remedial Actions. Engineering-Science (ES) was retained by the Air Force Engineering & Services Center to conduct the Phase I, Initial Assessment/Records Search at Elmendorf AFB under Contract No. F08637-83-G0009, Call No. 5003, using funding provided by the Alaskan Air Command.
Utilization of shallow aquifer units as a source of potable water supplies has been limited because of contamination problems (reported in Barnwell, et. al., 1971; Selkregg, et. al., 1972 & Cederstrom, et. al., 1964). Formerly, the City of Anchorage obtained five mgd from an infiltration gallery located at Ship Creek within city limits, however its contamination by kerosene forced the closure of this facility. Nelson (1982) reported that the shallow aquifer beneath the Merrill Field municipal landfill was contaminated by leachate originating from that facility. At present, public supplies are obtained from surface waters, such as the headwaters of Ship Creek or through large diameter, high capacity wells finished into the artesian aquifer system, far below the shallow units.
At this time it is believed that some individual homes not served by municipal utilities obtain water supplies from small-diameter wells screened into the shallow zone. Other consumers using shallow aquifer derived water supplies include isolated military facilities not connected to the central water distribution system. The primary threat to shallow aquifer water quality in this situation is posed by septic tanks serving the same home or facility. The septic system discharges to the shallow aquifer, while a short distance away a shallow aquifer well withdraws water. The relatively short distances involved rarely permit adequate renovation of local water quality (Selkregg, et. al., 1972).
Base Water Supplies-Elmendorf AFB receives most of its water supplies from Ship Creek via the diversion structure at Fort Richardson. Additional supplies may be obtained as needed from standby wells. Facilities not connected to the base central water distribution system derive water supplies from individual wells. Twenty-one active base wells are listed on Table 3.3.
See site file for additional information.
|
Jennifer Roberts |
| 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.
|
Ron Klein |
| 4/12/1984 |
Update or Other Action |
Request for an amendment to Permit #8221-BA011 for disposal of asbestos in landfill. |
Louis Howard |
| 5/25/1984 |
Document, Report, or Work plan Review - other |
Permission to dispose of asbestos in landfill for Permit #8221-BA011 granted by ADEC. |
Louis Howard |
| 11/29/1985 |
Offsite Soil or Groundwater Disposal Approved |
License issued to Alaska Department of Transportation (ADOT) for gravel extraction from the Davis Highway Material Site (DACA 85-3-86-16) to an offsite location for road construction. ADOT authorized to remove up to 450,000 cubic yards of material at no cost to the State of Alaska for the Boniface Interchange. License was scheduled to expire in Nov 1987. |
Jennifer Roberts |
| 4/30/1986 |
Document, Report, or Work plan Review - other |
New license issued to ADOT for gravel extraction from the Davis Highway Material Site (DACA 85-3-86-62). ADOT authorized to remove 1,050,000 cubic yards of gravel from Elmendorf AFB at no
cost to the State of Alaska. Gravel was to be used in the Boniface Interchange, Glenn Highway Widening, and Boniface Parkway projects. License was to expire in Nov 1989. |
Jennifer Roberts |
| 8/29/1986 |
Update or Other Action |
1986 Characterization of contaminant distribution within landfill area was initially investigated in 1986 during the site investigation studies conducted by Dames and Moore. Four groundwater monitoring wells were installed and sampled and during construction of the wells, four subsurface soil samples were collected.
Of the samples collected, the only samples in which contaminants were detected were from a soil sample obtained 40 ft. below ground surface (BGS) in the borehole for monitoring well W-2. The sample from W-2 detected oil and grease at 0.025 mg/kg. |
Louis Howard |
| 11/5/1986 |
Document, Report, or Work plan Review - other |
Correspondence regarding violations of Permit # 8221-BA011 from ADEC to Air Force. Figure attached to correspondence by ADEC indicates that the active landfill permit area is only located in the southern portion of the OU1 area. |
Louis Howard |
| 8/7/1987 |
Update or Other Action |
Air Force sends a request for Permit #8221-BA011 extension. |
Louis Howard |
| 8/31/1987 |
Document, Report, or Work plan Review - other |
Permit extension granted by ADEC for Permit #8221-BA011. |
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 |
| 12/31/1987 |
Update or Other Action |
Air Force submits a renewal application for Elmendorf AFB landfill permit #8221 -BA011. |
Louis Howard |
| 1/4/1988 |
Update or Other Action |
Installation Restoration Remedial Investigation/Feasibility Study Stage 3 Work Plan USAF Contract F33615-85-D-4536, Order No. 3. (March 1988) by Harding Lawson Associates received. The shallow aquifer units and Ship Creek share a complex relationship. Substantial amounts of stream flow within Ship Creek, from its rise in the Chugach Mountain front to the Davis Highway, are lost through streambed percolation to the shallow aquifer (either alluvial fan or alluvial and outwash deposits).
The lower reach of Ship Creek, from the Davis Highway to Cook Inlet gains groundwater flow. Thus, Ship Creek is both a losing and gaining stream. Ship Creek gains the most shallow aquifer discharge where it is entrenched into Bootlegger Cove Clay which underlies both the stream in its lower reach and the shallow aquifer. Because of this entrenchment, unconfined groundwater is directed to the Creek first, and not permitted to discharge directly to Knik Arm, as one might expect. In practical terms, this means that contamination entering the shallow aquifer anywhere in the southern portion of the base would most reasonably be expected to be discharged to Ship Creek or to the Cherry Hill Ditch.
An inspection of installation geology indicates that most base geologic units are permeable at ground surface. In many cases, the permeable nature of base geologic units extends downward to the water levels present within shallow aquifer units. This is especially true where alluvial fan and outwash aquifers exist along the southern portion of the installation property. Contaminants entering these highly permeable zones would likely stratify. Discharge to Ship
Creek would be expected. |
Jennifer Roberts |
| 1/25/1988 |
Update or Other Action |
Henry Friedman ADEC Regional Solid Waste Manager sent letter to Mike Drewett USAF 21 CSG/DE. We have reviewed the renewal application for the Elmendorf landfill and have the following comments concerning the listed sections of the application:
Part I.B.5 and I.D. - Several waste types were marked "no" on the application form which are commonly accepted at most major landfills. Some of the items listed as unacceptable at the landfill include wood wastes, batteries, drums, tires, scrap metal, sewage sludge, junk vehicles, animal carcasses, infectious waste, and oily waste. How will these waste types be processed and where will they be taken if not accepted at the landfill?
Part II.B.10 - The active and closed portions of the landfill are incorrectly indicated on the blue print map submitted as Appendix 2a. A better delineation of the previously filled areas is indicated in the IRP Phase II Stage 2 report on page 30, Plate 7. Even the IRP report map is incomplete. We are aware of additional areas around the landfill that have been filled with waste. In addition, some of the wells indicated on the map are actually in a different location. I suggest we visit the site with blue prints in hand to clarify these discrepancies and gain a better understanding of the total landfilled area.
Part II.C.2.- The actual groundwater level is not clearly defined in proposed expansion area. The pit rim is indicated to be at elevation 200 feet above sea level. The pit is approximately 30 to 50*feet deep. Nearby well logs indicate that the groundwater level is approximately at the 35 foot level below the top of casing. This would put the water table at or near the gravel pit bottom. Please clarify the elevation level of the pit bottom and the proximity of groundwater.
Part II.D.lO.c.-The runoff and drainage control plan along will the fill plan needs to be clarified. Since a large pit is being filled, surface runoff is expected to flow to a low point in the pit. Past inspections have indicated that some ponding has occurred in the pit bottom. What will happen to the surface runoff? Will it percolate or continue to pond? How will waste be filled around the low point?
Part II.D.10.1- The IRP report indicates that explosive levels of methane gas were encountered while drilling some of the monitoring well in and around the landfill. Your application makes no mention of gas control. The control of decomposition gases should be addressed in the application plans.
Part II.E.4. - A discussion of the monitoring data was not included in the application. We would like to see the complete IRP Phase II, Stage 2 report. There is some indication of groundwater contamination from the landfill. What is the extent of contamination? What is the potential for generating additional leachate?
Part II.E.5. - It is the responsibility of the applicant to develop a monitoring plan. We do not develop a monitoring plan for the applicant. The solid waste permit usually refers to the monitoring plan developed by the applicant. In some instances a permit may require additional monitoring activities that were not proposed by the applicant. We are willing to work with you on the development of a suitable monitoring plan. |
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 & CERCLA at Federal Facilities. Statutory language makes it clear that Federal facilities must comply both procedurally & substantively with RCRA & CERCLA in the same manner as any non-Federal entity. The purpose of this memo is to lay out the statutory authorities under RCRA & CERCLA that EPA may use at Federal facilities to achieve compliance & 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 & deadlines associated with the RI/FS & all terms & conditions associated with the remedial actions (including operable units or interim actions) are enforceable by citizens & 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 & 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) & Section 106(a) of the Act to seek information, entry, inspection, samples or response action from Executive Departments & 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 & 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.
See Site file for additional information.
|
Ron Klein |
| 3/1/1988 |
Update or Other Action |
The Phase II, Stage 2 field evaluation of the Installation Restoration Program (IRP) consisted of investigations at the following 12 sites: Site D-5 - Sanitary Landfill; Sites SP-7 and SP-10 - Pumphouse No. 3; Site D-7 - Sanitary Landfill; Site SP-5 - JP-4 Tank Spill; Site SP-12 - JP-4 Fuel Line Leak; Site 0-17 - Shop Waste Disposal; Site SP-11 - JP-4 Fuel Line Leak; Site FT-1 - Fire Training Area; Site SP-2 - JP-4 Fuel Line Leak; Site SP-14 - MOGAS Spill; and Site IS-I - Building 42-400 Floor Drains. Two aquifers underlie Elmendorf AFB (EAFB), a shallow ground water (GW) system and a deep artesian system. These aquifers are typically separated by substantial thicknesses of confining materials such as the Bootlegger Cove Clay. Both aquifers contain very permeable sand and gravel units. The depth to the water table varies from zero to as much as 50’ to 60’. It appears the deep artesian aquifer is not in significant danger of contamination, but the shallow aquifer has been contaminated in the past and is vulnerable to contamination in the future.
Detectable levels of purgeable halocarbons were found in one base well (BW-1), one surface water sample (not confirmed because of presence in trip blank) and in monitor wells at Sites D-5, D-7, D-17, SP-11, and IS-1. Purgeable aromatics were detected in elevated concentrations at Sites SP-7 and SP-10. Petroleum hydrocarbons were found at Sites D-5, SP-7, SP-10, D-7, SP-2, SP-12, and SP-11. Three base water supply wells were sampled on October 15, 1986. Base well BW-1 had detectable levels of several purgeable halocarbons. Methylene chloride at 3.7 ug/L, tetrachlorethene at 0.77 ug/L, 1,1,1-trichloroethane at 0.63 ug/L, trichloroethene (TCE) at 1.2 mg/L, and trichlorofluoromethane at 0.83 ug/L were detected in water from this well. The pH was slightly lower, at 6.3, than the Secondary Drinking Water Standard (SDWS). The TDS in this sample was 130 mg/L. Lead and purgeable aromatics were not detected. BW-2 had a TDS level of 110 mg/L and a pH of 6.4, slightly below the SDWS. No other parameters were detected. In BW-52, chloroform was found at a level of 1.2 ug/L and TDS at 140 mg/L. The water sample from BW-52 had been chlorinated prior to sampling. No other analytes were detected. The trip blank which accompanied the base well samples was found to contain 32 ug/L of methylene chloride and 0.94 ug/L of trichlorofluroromethane.
Extent of Contamination at Base Supply Wells-The single sampling event of October 15, 1986, suggests that there is a water quality degradation in BW-1 and possibly BW-52. Although the analytical results for low levels of methylene chloride and trichlorofluoromethane may be discounted due to the presence of these substances in the accompanying trip blank, other purgeable halocarbons were found at low, but detectable, levels. BW-1 was found to contain tetrachloroethene, 1,1,1-trichloroethane, and TCE and BW-52 had a low level of chloroform. According to Elmendorf installation documents, BW-1 is finished at a depth of 16’ in the shallow aquifer and is a high yielding well (1350 gpm). BW-52 is finished at a depth of 166 feet in the artesian aquifer and yields 8 gpm. Both of these wells are located downgradient of landfills D-5 and D-7.
BW-52 is also located downgradient of Sites SP-11 and SP-14. In the case of BW-52, it is believed that the chloroform concentration of 1.2 ug/L (this concentration does not exceed the PDWS of 100 ug/L for total trihalomethanes) is due to the chlorination treatment of the water sample prior to sampling. For BW-1, the low levels of purgeable halocarbons are believed to be due to the location of this base well located within the plume(s) from the landfill area (Sites D-5 and D-7). The following purgeable halocarbons were detected in BW-1 and in landfill monitor wells. Tetrachloroethene was found in low concentrations in downgradient wells from Site D-5; 1,1,1-trichloroethane was found in one downgradient well from Site D-5; and TCE was found in downgradient wells from both Sites D-5 and D-7. The current evidence strongly suggests degraded water quality with the presence of low levels of contaminants rated as carcinogens [National Toxicology Program lists tetrachloroethene, 1,1,1-trichloroethane, TCE as compounds presenting clear evidence of carcinogenicity.
It is recommended that the three base water supply wells BW-1, BW-2, and BW-52 be resampled and that BW-16 should be included if it is actively used. The presence of purgeable halocarbons in BW-1, of chloroform in BW-52, and of an oily sheen on the water sample from BW-2 need to be reinvestigated. The current data strongly suggests that BW-1 is contaminated. It is not known if the time of sampling in October 1986, adequately reflected ambient contaminant concentrations detected in BW-1. The position of this well in the Ship Creek watershed and its construction as a high yield well make it a potential receptor for plumes from landfills D-5 and D-7. |
Jennifer Roberts |
| 8/1/1988 |
Site Visit |
RCRA Facility Assessment Report: Preliminary Review and Visual Site Inspection conducted by ADEC during July 19 and 20, 1988. Site D-5, Sanitary Landfill: Location: This site is located on the southwestern region of the base, west of Ammo Storage Area "B", east of Marketing and Redistribution, and north of Ship Creek, its size extimated at 65 acres.
This site warranted further study, due to the presence of hazardous waste and the porous nature of the gravel till at the site. The potential pathway for migration was identified as groundwater, encountered at approximately 37 feet below ground surface. Two monitor wells were installed southeast of the location of a large fuel seep (fuel jf was observed to seep into an area which was excavated, for fill). Borehole W-7 was located on the south side of Loop Road because of high explosimeter readings on the north side at the ground surface.
Fuel seeps were observed and a strong fuel odor was detected on the north side of the road. The boreholes were installed in an open field covered with low grasses. Explosimeter and HNU photoionization meter readings were at background levels at both borehole locations.
EAFB reported the potential receptors at this site as Base (drinking) water supply wells 1 and 52 located downgradient of the landfill. It is believed that the water quality degradation detected in well 1 is at least partially attributable to this site. Ground-water quality downgradient of Site D-5 is degraded with low levels of halocarbons, and evidence from well W-l suggests some degradation with petroleum hydrocarbons. |
Max Schwenne |
| 8/31/1988 |
Update or Other Action |
1988 Dames & Moore conducted additional field investigations at landfills (LF) 05 (fomer D-5 site) & LF07 (former D-7 site). These studies included performing a magnetometer survey, installing six addtional wells, sampling Ship Creek near OU1, and sampling groundwater from all existing groundwater monitoring wells. including Base Well 1. BW1 is located in the Ship Creek alluvium at the western extent of OU1.
Contaminant source areas LF05 (former D-5) and LF07 (former Site D-7) were surveyed by magnetometer to define the landfill limits and the configuration of burial areas, as indicated by the presence of buried ferrous materials. The surveys indicated that buried wastes were present in both areas.
During the Phase II, Stage 1 sampling, monitor wells W-l and W-2 were found to have low levels of TOX (53 ug/L and 34 ug/L, respectively), and low levels of oil and grease (4.0 mg/L and 4.6 mg/L, respectively). During the Phase II, Stage 2 analyses, the upgradient well GW-1A was found to have 180 mg/L TDS and 1.0 mg/L of petroleum hydrocarbons. No detectable concentrations of purgeable halocarbons, purgeable aromatics, or pesticides were found in this well. The pH concentration in this well was 6.1, slightly exceeding the SDWS. The downgradient wells were found to contain detectable levels of purgeable halocarbons. W-1 had a level of 3.2 ug/L of trans-1,2-dichloroethene, 0.2 mg/L of petroleum hydrocarbons, and a TDS of 130 mg/L. In W-2, trans-1,2-dichloroethene was detected at 1.3 ug/L, methylene chloride was at 0.57 ug/L, tetrachloroethene was at 0.48 ug/L, and TDS at 81.0 mg/L.
In well GW-1B, the following analytes and concentrations were detected: 1,1-dichloroethane, 4.7 ug/L; methylene chloride, 2.6 ug/L; tetrachloroethene, 0.49 ug/L; 1,1,1-trichloroethane, 32.0 ug/L; trichloroethene (TCE), 2.7 ug/L; trichlorofluoromethane, 0.60 ug/L; and TDS at 130 mg/L. The pH, 6.4 was slightly lower than the SDWS. In well GW-1C, the parameters detected and concentrations were: trans-1,2-dichloroethene, 1.1 ug/L; methylene chloride, 0.72 ug/L; tetrachloroethene, 0.58 ug/L; trichlorofluoromethane, 0.51 ug/L; and TDS, 140 mg/L. The pH concentration of 5.9 in GW-1C was below the SDWS.
Ground water quality downgradient of Site D-5 is degraded with low levels of purgeable halocarbons. Ground water from three monitor wells (GW-1A, GW-1B, and GW-1C) was more acidic than the range permitted by the SDWS (6.5 to 8.5). Of the seven purgeable halocarbons detected in the Site D-5 monitor wells, four [methylene chloride, tetrachloroethene, 1,1,1-trichloroethane, and trichlorethene (TCE)] are considered to be carcinogenic by the National Toxicological Program [(NTP) A.D. Little, 1985]. As stated in Section IV.B.1., these findings are significant as base water supply wells BW-1 and BW-52 are located downgradient of the landfills. It is believed that the water quality degradation detected in BW-1 is at least partially attributable to Site D-5. |
Jennifer Roberts |
| 9/1/1988 |
Update or Other Action |
Municipality of Anchorage Solid Waste Services: CONTAMINATED SOIL & SPILL RESIDUE DISPOSAL POLICY EFFECTIVE DATE: September 1, 1988 Applicability: This policy applies to the disposal of soils and residues from the spill of petroleum products or other chemicals. The policy should be used as a guideline to determine the acceptability of these materials for disposal at the Anchorage Regional Landfill. Due to the wide variety of petroleum products and chemicals that can potentially be encountered it will often be necessary to make specific case-by-case determinations on the acceptability of such soils and residues.
Prohibited Materials: A. No contaminated soil or spill residue will be accepted in any quantity that exhibits hazardous waste characteristics for ignitability, corrosivity, reactivity or toxicity or contains listed hazardous waste-as defined by the U.S. Environmental Protection Agency (EPA) or the Alaska Department of Environmental Conservation (ADEC).
B. No contaminated soil or spill residue will be accepted that contains detectable (>1 ppm) concentrations of Polychlorinated Biphenyls (PCBs). C. No contaminated soil or spill residue will be accepted that contains free liquids as defined by the EPA Paint Filter Test, including petroleum products, chemicals or water.
D. No contaminated soil or spill residue will be accepted in drums with a capacity of greater than 20 gallons. E. No sludge from tank bottoms will be accepted. F. No contaminated soil, spill residue or other solid wastes generated outside the boundaries of the Municipality of Anchorage will be accepted.
Limitations for Acceptance of Specific Pollutants-A. Contaminated soil or spill residue associated with petroleum products shall be acceptable for disposal at the Anchorage Regional Landfill provided the material is not prohibited in Part II above and all the following applicable limitations are not exceeded: 1. Petroleum Products Other Than Waste Oil-Total Petroleum Hydrocarbons (TPH): < 1,000 ppm via 418.1, Total BTEX < 100 ppm via 8020, Lead (leaded gasoline spills only) < 1,000 ppm via 3050/7421.
Waste Oil: TPH < 1,000 ppm via 418.1, Total BTEX < 100 ppm via 8020, Lead < 1,000 ppm via 3050/7421, Arsenic < 400 ppm via 7060/7061, Chromium < 500 ppm via 7190/7191 and Total Organic Halogens < 100 ppm via 8010.
B. The acceptability of disposal at the Anchorage Regional Landfill for any contaminated soil or spill residue associated with other chemicals shall be determined on a case-by-case basis.
See site file for additional information.
|
Ron Klein |
| 11/21/1988 |
Update or Other Action |
Draft Permit #8221 -BA011 requesting Air Force comment. Submittal letter from ADEC notes that
the current design and operation of the landfill barely complies with State Regulations. ADEC will only issue a permit for the landfill for a period of two years. In order to renew permit after that the Air Force would have to do substantial upgrades in the design of the landfill. |
Louis Howard |
| 12/30/1988 |
Update or Other Action |
License No. DACA 85-3-86-62 was amended. The amendment extends the period of time ADOT is allowed to remove gravel, and the amount of gravel for the Boniface Parkway project is increased to 300,000 cubic yards. This license was scheduled to expire in Nov 1990. |
Jennifer Roberts |
| 2/21/1989 |
Meeting or Teleconference Held |
Telephone Memorandum for the Record taken by Black & Veatch for the Air Force. Subject: Soil & Groundwater Cleanup Requirements B&V Project 13833 time 1700 hours phone conversation with Colleen Burgh. Colleen called back to inform B&V that no cleanup standards for soil exist. The state currenlty looks at each site on an individual basis and negotiates cleanup levels.
Currently there are no restrictions on the release of untreated off-gasses from vapor extraction systems. Colleen said that Jim Hayden is a good source for vapor extraction system information.
NOTE to file: 18 AAC 75.130. DISPOSAL OF HAZARDOUS SUBSTANCES. (a) Prior approval by the department is required for the ultimate disposal of a hazardous substances, and soil, cleanup materials, or other substances contaminated with a hazardous substance. Approval under this section may be granted orally by the regional supervisor or his designee.
(b) As used in this section, "ultimate disposal" includes disposal into or upon the waters or the surface or subsurface land of the state, and open burning. (Eff. 4/23/77, Reg. 62) Authority: AS 46.03.020(10)(A), AS 46.03.020(10)(E), AS 46.03.140, AS 46.03.710, AS 46.03.740
18 AAC 75.140. CLEANUP. (a) 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 cleanup 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. The discharge must be cleaned up to the satisfaction of the regional supervisor or his designee.
(b) Upon request, the department will waive (a) of this section if, in the opinion of the department, it is technically impracticable must be cleaned up the discharge, or if the cleanup effort would result in greater environmental damage than the discharge itself. (Eff. 4/23/77, Reg. 62) Authority: AS 46.03.020(10)(A). |
Colleen Burgh |
| 2/22/1989 |
Meeting or Teleconference Held |
Memo for the record of phone conversation by Black and Veatch with Jim Hayden (ADEC) RE: Vapor Extraction. Phone call with Jim Hayden to find out about: 1) The effectiveness of vapor extraction on total petroleum hydrocarbons (TPH); and 2) the effectiveness of vapor extraction on groundwater. He informed us that vapor extraction would work on the lighter ends of TPH, but would not be effective on the lower ends. Vapor extraction would not be effective on groundwater cleanup. Jim was asked if there were any soil cleanup requirements, he replied that there were not, but that the State loosely follows 100 ppm TPH and 10 ppm BTEX as standards. Each site is looked at on an individual basis. |
Jim Hayden |
| 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 |
| 3/1/1989 |
Document, Report, or Work plan Review - other |
Permit #8721 -BA025 issued to Elmendorf AFB to replace expired Permit #8221 -BA011. |
Louis Howard |
| 7/7/1989 |
Update or Other Action |
ADEC letter to Air Force Director of Engineering, 21st Combat Support Group/DE, RE: Elmendorf Landfill Inspection by Henry Friedman. An inspection of the Elmendorf landfill was conducted on June 6,1989. The inspection report is enclosed.
The landfill was very clean and well maintained. Inactive portions were adequately covered. The working face was consolidated and controlled. It is apparent that daily cover is applied as
required. A berm separates the municipal waste disposal area from the asbestos waste disposal area. An asbestos warning sign should be placed along the berm dividing the two waste areas to clearly identify the demarcation between the two sites.
The landfill entrance sign does not contain all the information required in the permit. A sign with the required information should be installed. The landfill operator on site appeared well informed and adequately maintained controlled use of the area.
An activity of primary concern is the current excavation occurring on the west side of the landfill. Excavation around the monitoring wells will affect the integrity of these wells and compromise the groundwater monitoring program. Monitoring wells GW2B, GW1B, and GW1C may no longer be suitable monitoring points and proper well abandonment may be necessary.
A new sanitary seal around the wells in the excavated area will obviously be needed if they are not abandoned. It may be necessary to develop new wells to replace these wells.
Furthermore, the development of a borrow pit in this area will collect precipitation and will probably affect the recharge to the groundwater in this area. The excavation should be addressed in the hydrology assessment and leachate potential analysis which is required by section F.2.c. of the permit. A revised monitoring plan is also required.
Please submit a brief explanation of the excavation plan around the landfill and address any changes in the monitoring structures which will occur. The excavation plan affecting the monitoring wells should have been sent to the Solid Waste Management Program prior to excavation. Please submit this report as soon as possible. |
Jennifer Roberts |
| 7/14/1989 |
Update or Other Action |
Conditions at proposal for listing on NPL (July 14, 1989): 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), established in 1978. Under this program, 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 (TCE), tetrachloroethylene, 1,1,2,2-tetrachloroethylene, trans-1,2-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 a blended water system that draws primarily from surface water but also uses wells within 3 miles of hazardous substances on the base on a standby basis.
EPA is reviewing the Air Force's workplan for a remedial investigation/feasibility study (RI/FS) 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. |
Jennifer Roberts |
| 8/6/1989 |
Site Visit |
Solid Waste Site Inspection Report for permit # 8721-BA025. Site was closed on Sunday with no exposed waste. Monitoring well GW1B was broken off and re-capped. Area along Davis Highway is being excavated for gravel source noted by Henry Friedman. |
Jennifer Roberts |
| 8/11/1989 |
Update or Other Action |
Everett L. Mabry Colonel, USAF Base Civil Engineer letter to Henry Friedman, ADEC, S.C. R. O. RE: Elmendorf Landfill Inspection.
1. This is in reponse to your 7 July 1989 letter concerning the 6 June 1989 inspection of the solid waste landfill at Elmendorf AFB.
2. Since your inspection a new sign has been installed at the entrance to the landfill. This sign contains all the information required by the permit. Also new signs have be placed around the asbestos cell.
3. The excavation area adjacent to Davis Highway is being developed as a new material site (see attached current excavation plan). The wells which were located in this area have been abandoned and new groundwater monitoring wells will be installed. At this time, the location of these new wells have not been determined.
We anticipate identifying new well locations as part of the FY 1990 Installation Restoration Program (IRP) work plan which is currently being developed. As part of the IRP, the hydrologic assessment and leachate potential analysis will be performed for this area and will be submitted to your office as required by Section F.2.c. of the solid waste disposal permit. The hydrologic assessment and leachate potential analysis will not be available until such time as site characterization is complete. |
Jennifer Roberts |
| 9/7/1989 |
Update or Other Action |
ADEC (B. Lamoreaux) to Air Force (Capt. Brad Gerken) 5099th CEOS/DEEP RE: Oil and Hazardous Substance Spill and Contaminated Site Investigations. During a recent meeting with Ron Klein and Jennifer Roberts, Alaskan Air Command and Elmendorf Air Force Base Environmental Staff requested clarification of which ADEC office is responsible for coordinating the review of Air Force oil and hazardous substance spill assessment and contaminated site (OHSS-CS) and remediation plans and reports. The Anchorage/Western District office is the designated office for coordinating Department review and comments of OHSS-CS plans and reports for U.S. Air Force
installations in Anchorage, Southwest Alaska and the Aleutian Islands. The designated contact is Ron Klein.
The Department requests that three copies of each plan be provided to Mr. Klein who will then coordinate the document review among district, regional and central office staff. The Department requests that it be provided with a minimum thirty (30) day review period for single site plans and reports and forty-five (45) day review period for multi-site plans and reports. Departures from these minimum review periods for specific documents will be considered upon request.
The Department is looking forward to maintaining a cooperative relationship with the U.S. Air Force in it's efforts to remedy its past and future environmental problems. |
Bill Lamoreaux |
| 9/7/1989 |
Update or Other Action |
Ron Klein (ADEC) sent letter to Captain Brad Gerken (Departrient of the Air Force). SUBJECT: Oil and Hazardous Substance Spill and Contaminated Site Investigations. During a recent meeting with Ron Klein and Jennifer Roberts, Alaskan Air Command and Elmendorf Air Force Base Environmental Staff requested clarification of which ADEC office is responsible for coordinating the review of Air Force oil and hazardous substance spill assessment and contaminated site (OHSS-CS) and remediation plans and reports. The Anchorage/Western District
office is the designated office for coordinating Department review and comments of OHSS-CS plans and reports for U.S. Air Force installations in Anchorage, Southwest Alaska and the Aleutian Islands.
The designated contact is Ron Klein. The Department requests that three copies of each plan be provided to Mr. Klein who will then coordinate the document review among district, regional and central office staff. The Department requests that it be provided with a minimum thirty (30) day review period for single site plans and reports and forty-five (45) day review period
for mrulti-site plans and reports. Departures from these minimum review periods for specific documents will be considered upon request.
The Department is looking forward to maintaining a cooperative relationship with the U.S. Air Force in it's efforts to remedy its past and future environmental problems. |
Ron Klein |
| 9/15/1989 |
Update or Other Action |
USAF Patrick Coullahan, Lt Col, USAF to B. Lamoreaux (ADEC) re: Interagency Coordination on US Air Force Activities. We appreciate your designation of a single point of contact within the Alaska Department of Environmental Conservation for coordinating communication. Working through Mr Ron Klein will allow us to provide necessary information in the most efficient manner. Additionally, we welcome a quarterly meeting between our organizations to discuss common concerns. My point of contact is Capt Bradley Gerken, Chief of Environmental Planning, 552-4854. |
Bill Lamoreaux |
| 10/3/1989 |
Update or Other Action |
USAF Letter received from Patrick M. Coullahan, Lt. Col, Commander to ADEC Subj: Requirements for Temporary Storage of Petroleum Contaminated Soil.
1. The USAF has several sites which are contaminated with petroleum products (POL) and require remedial action. Temporary storage and stockpile of contaminated soil is needed while remedial action is performed.
2. Request guidance from your office on regulatory requirements and ADEC policy for storage and stockpiling POL contaminated soil. Point of contact for the 5099th Civil Engineering Operations Squadron is Capt Gerken or Mr Cords at 552-4854. |
Ron Klein |
| 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 |
| 10/23/1989 |
Update or Other Action |
ADEC Bill Lamoreaux Regional Supervisor sent letter to Rastus O. Massey, Colonel USAF 21st Combat Support Group Commander. This is a follow-up letter to Col. Brown's February 7, 1989 response to a Notice of Violation Letter (NOV) transmitted to Elmendorf Air Force Base (EAFB) on January 6, 1989 as a result of a compliance inspection conducted of Elmendorf Air Force Base pursuant to Section 3007 (a) of the federal Resource Conservation and Recovery Act (RCRA) and Alaska Statutes Title 46, Chapter 03, Section 020 (AS 46.03.020). We have reviewed the response dated February 7, 1989, and find that it appears to be adequate for the violations noted, except for the violation pertaining to the underground storage tank, S-5 (ST20 North end of Bldg. 11-420).
As noted in 40 Code of Federal Regulations (CFR) 270.1(b), six months after the initial promulgation of the Part 261 regulations (i.e. six months from May 19, 1980), treatment, storage, or disposal of hazardous waste by any person who has not applied for or received a RCRA permit is prohibited. The facility has been storing hazardous waste in a tank beyond November 19, 1980 without specifying this hazardous waste process in Part A of their permit application. This is a violation of 40 CFR 270.71 and 18 Alaska Administrative Code (AAC) 62.510, whereby the facility shall not treat, store, or dispose of hazardous waste not specified in Part A of the permit application. A revised Part A application must be submitted to reflect this storage activity. EAFB failed to address this requirement in their response.
EAFB stated in the NOV response that the facility is pursuing closure and remediation activities at this site under the Air Force's Installation Restoration Program (IRP) as a Comprehensive Environmental Response Compensation (CERCLA) location. However, this tank is considered a RCRA hazardous waste management activity and must be addressed as such. A closure plan pursuant to 40 CFR 265.197, 40 CFR 265 subpart G, and 18 AAC 62.410(1) must be submitted because hazardous waste was stored in this tank beyond November 19, 1980.
This closure plan must describe removal or decontamination of all waste residues, contaminated containment system components, contaminated soils, structures and equipment contaminated with
waste, and include procedures used to manage this material as hazardous waste. The closure plan and closure activities must comply with all of the requirements specified in 40 CFR 265 subpart
G. The closure plan for the tank system must include both a plan for complying with paragraph (a) of 40 CFR 265.197 and a contingency plan for complying with paragraph (b) of 40 CFR
265.197.
The closure plan will subsequently be reviewed by both the Alaska Department of Environmental Conservation (DEC) and the Environmental Protection Agency (EPA). The final draft closure
plan must be public noticed to allow for public involvement. The facility will not be approved to initiate the closure plan activities until after the public comment and official approval of the plan. The closure plan must be submitted to both EPA and DEC within 60 days of receit of this notice. |
Bill Lamoreaux |
| 11/2/1989 |
Update or Other Action |
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 |
| 11/15/1989 |
Document, Report, or Work plan Review - other |
ADEC letter to USAF Colonel Everett L. Mabry Base Civil Engineer, HQ 21st Combat Support Group (AAC). Subject: Installation Restoration Program, Stage 3 Remedial Investigation/Feasibility Study Elmendorf Air Force Base, Alaska. Comments are detailed in four areas: 1. characterization contamination,of the nature and extent of 2. priority ranking of sites, 3. applicable or relevant and appropriate requirements, and 4. selection of remediation alternatives.
Ground-penetrating radar may not be successful for locating buried objects in glacial till. Several of the sites were not screened for PCB contamination. Given the past use of PCB containing material by the military it is possible for PCB contamination to be present at any site.
Several references to use of an HNu for soil screening appear in the report. HNu readings of tenths of parts per million are frequently cited. The HNu is not accurate to one tenth of one part per million and there is no indication regarding what span setting was used. If a 9.8, benzene, span setting was used the response of heavier hydrocarbons would be minimal. In addition, many natural substances can cause a one or two unit response in an HNu.
Specifically paragraph 4.2.8.1.3.1 cites a 0.1 ppm HNu reading at site IS-6. Of what significance or use is this information? Paragraph 4.2.8.3 cites that "organic vapors" were detected with the HNu. The HNu responds to more than just organic vapors and there is no way to verify that organic or inorganic vapors are present.
Certain landfill studies and plans are required by in Part F. of Appendix A of the Elmendorf solid waste permit. The permit requires these six IRP study items:1. geophysical evaluation of the landfill and definition of the boundaries, 2. landfill gas survey study and results, 3. hydrogeologic assessment and leachate plume estimate and leachate potential analysis, 4. water quality analysis results, 5. remedial action plan to prevent pollution, if water quality violations are evident, and 6. the final closure plan as revised.
The landfill sites NS-2, D-5, D-7, and D-13 are reviewed to determine if these requests are met. Sites D-5, D-7, D-13, and NS-2 are really all one site. The solid waste permit in effect applies to the entire area covered by these sites.
* The IRP study has completed the geophysical evaluation and boundary definition.
* The IRP study failed to complete a landfill gas study.
* The IRP study proposes to conduct additional evaluation of the leachate plume but fails to propose a leachate potential analysis or remedial action plan. Additional monitoring wells will be necessary beyond the ones proposed.
* The first round water quality analysis results were submitted in compliance with permit requirements.
* No final closure plan has been submitted.
Due to the above listed deficiencies, the IRP study does not conform to the requirements of the State's RCRA Subtitle D program. The requirements of the solid waste management permit number 8721-BA025 must be included in the IRP program.
Sites with petroleum contamination in the no further action category have to be re-evaluated with-respect-to the ARAR's. This may move them into the require further investigation category.
1. Site assigned "no further action" status need to be subject to periodic groundwater monitoring to ensure that contamination migration has not occurred and will not threaten drinking water supplies and/or surface resources.
Paragraphs 4.2.5.4 and 4.2.6.4 state that the sites were assigned a low priority because of the low toxicity associated with TPH contamination. There are two fallacies with this assumption. First, some very toxic substances, like benzene, are petroleum hydrocarbons. Second, the only analytes tested for were TPH and lead. How is it possible to state that only TPH is present when TPH was basically the only test performed? What reference cited the toxicity of TPH?
APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS
Where there is groundwater contamination due to fuel products, the Air Force should use the volatile aromatic standards as listed on page 5-14 rather than the visible sheen criteria. The discussion on page 5-22 says the Air Force will use the target cleanup levels in Table 5-7.
Then the next paragraph says the Air Force will use the visible sheen criteria. The Air Force should use the target cleanup levels. Cleanup to Water Quality Standards is required even if an aquifer is not being used for drinking water. As stated above, sites with petroleum contamination in the no further action category have to be re-evaluated with-respect-to the ARAR's. This may move them into the require further investigation category. |
Ron Klein |
| 12/29/1989 |
Document, Report, or Work plan Review - other |
ADEC letter to Everett L. Mabry Colonel, Base Civil Engineer, HQ 21st Combat Support Group (AAC) RE: RI/FS Stage 4 Second Draft Work Plan Elmendorf Air Force Base, October 1989.
GENERAL COMMENTS ON PROPOSED ASSESSMENT WORK-
For several sites the disposal method for soil contaminated with high levels of TPH is quoted as "the sanitary landfill". The only area landfill that is permitted to received petroleum contaminated soil is the Municipality of Anchorage (MOA) Landfill. The MOA Landfill will accept soils only if the TPH level is below 1000 mg/kg. In many cases the work plan was referring to soils with TPH in excess of 1000 mg/kg.
The issue of proper contaminated soil disposal has been brought up by ADEC several times (reference letters: Klein to Gerken, October 20, 1989 and Klein to Mabry, November 2, 1989). The Department requests clarification on the disposal method of soils contaminated with TPH levels over 1000 mg/kg and verification that the proposed sanitary landfill is the MOA Landfill. In addition, the Department requests written notification regarding disposal of all contaminated soils. The notification should include: date of disposal, quantity of soil, location that soil originated, and final disposal method.
The Department requests that an expanded seasonal sampling schedule be established for selected monitoring wells. In several sites (for example, well W-18 on site IS-1) there may be floating
product.
Numerous floor drains are currently not hooked into an approved sanitary sewer, but go directly into storm sewers, septic systems or leach fields. These floordrain systems need to have an approved oil/water separator installed and the treated water may then be discharged under an ADEC industrial water discharge permit. As in earlier letters (Klein to Mabry, November 15, 1989, page 5) ADEC requests that a complete inventory of floordrains be done to establish the current discharge status.
Paragraphs 2.2.1.2 & 2.2.1.3 and other paragraphs state that discharge of treated groundwater to storm sewers was recommended in the FS. Discharge water must meet ADEC Water Quality Regulations. In addition, an ADEC industrial waste water discharge permit is required for the discharge of treated groundwater into storm sewers and an NPDES permit may also be required.
SITE D-5, D-7, D-13, NS-2
Paragraph 5.2.2.6 Well Abandonment The Department requests that all wells destroyed by the gravel pit operation be abandoned according to State of Alaska regulations 11 AAC 93.140 (d).
The Department requests that a final closure plan be submitted as referenced in Klein to Mabry letter dated November 15, 1989.
BASE WELLS
Table 5-4 shows that the proposed analysis for the base drinking water wells is EPA method 601 and 602. Since these wells are used for drinking water, the Department requests analysis for base drinking wells be done by EPA drinking water method 502.2 or 524.2. |
Ron Klein |
| 2/16/1990 |
Meeting or Teleconference Held |
On 16 February 1990, a meeting was held to discuss Alaska Department of Environmental Conservation (ADEC) Stage 3 RI/FS and Stage 4 Work Plan review comments in their 15 November 1989 and 29 December 1989 letters. Those in attendance were:
Maj Lindsey C. Waterhouse AF, Capt Russell K. Godsave (Recorder) AF, lLt Walter Migdal AF, Mr Glenn Brown AF, Ms Susan A. Curtin Black & Veatch, Mr Doug Johnson EPA, Mr Ron Klein ADEC, Mr Vernon M. Reid Black & Veatch, Ms Jennifer L. Roberts ADEC, Mr Howard Weaver AF, Mr Joseph Williamson Air Force AF.
29 December 1989 Letter:
1. Page 1, GENERAL COMMENT #1: State mentions "several sites"; we requested in the future that the State identify sites. The 1,000 mg/kg total petroleum hydrocarbons (TPH) level was noted by the State of Alaska (State) to be a Municipality of Anchorage (MOA) landfill requirement only. It was suggested that Mr Mike Blair of the MOA be contacted in relationship to the MOA landfill accepting "mass balance" of soil to meet turn-in requirements. In relationship to this, Mr Doug Johnson noted that off-site disposal, as in the case of the MOA landfill, may include certain potential liabilities and the Air Force should be aware of these. Both the State and EPA stated that it may be better to treat contaminated soils on base.
Mr Williamson reinforced this, stating that pretreatment of soil will always be considered for each operable unit. The California "Leaking Underground Fuel Tank (LUFT) Manual" was noted by Major Waterhouse as guidance the State should consider adopting. In addition, the Air Force requested that State guidance be clear and promulgated. The State added the Air Force should strive for 100 ppm TPH for nongasoline removal or treatment.
2. Page 1, GENERAL COMMENT #2: The State requested seasonal sampling, they said, to get a better picture of hydrologic data, especially along Ship Creek. The intent is seasonal water level sampling, not full analytical sampling. In addition, the seasonal water sampling is intended to give us a good baseline for the future. The Air Force agreed. Seasonal sampling was noted to be two periods: our dry and wet seasons.
3. Page 2, GENERAL COMMENTS #3 AND #4: The Air Force and the contractor plan to take a minimum of two samples per boring. More will be taken as needed. The State and EPA indorsed collecting samples for routine laboratory analysis at every 2 to 5-foot interval of the bore holes in preference to using an HNu to screen the split spoon sample and sampling only those levels where a positive HNu reading was obtained.
4. Page 2, GENERAL COMMENT #5: Again, the State, mentions "many sites"; request in the future that State identify sites. Also, as discussed in the meeting, the contractor has based the location of new wells on logical data. The well locations, however, are general and will be sited more precisely as the study continues.
5. Page 2, GENERAL COMMENT #6: Although it was agreed upon that a possible route of contamination exists along well casings, at least the Air Force and contractor felt this risk was, at best, minimal. Still, Major Waterhouse pointed out that Bioenvironmental Engineering monitors all deep aquifer potable water wells. To date, no signs of contamination has been noted. Well #1 is a 16-foot shallow well (cistern) collecting water from the shallow aquifer. The identified volatile organic contaminants in this well are not indicative of the deep water aquifer water quality.
6. Page 3, GENERAL COMMENT #7: Capt Godsave asked the State what an "approved oil/water separator" was and what regulations are entailed. The State elected to defer their answer. Mr Johnson noted that this was a NPDS or RCRA issue and not a CERCLA issue. Major Waterhouse noted that a team from Occupational and Environmental Health Laboratory (OEHL) are coming to Elmendorf AFB soon to achieve an inventory of floor drains as requested by the State. The State requested that the OEHL team discuss their methodology with the State up front. Major Waterhouse agreed to this.
7. Page 3, GENERAL COMMENT #8: The State stated this comment was essentially for our information. Both the State and EPA stated that a industrial waste water permit is not required for the storm sewers, but that the Air Force should meet the intent of such a permit.
8. Page 3, GENERAL COMMENT #9: The Air Force has asked the contractor to better define and consistently use the terms "off-site" and "off-installation," and be more definitive on the potential for contamination migration. Contaminant migration should only be inferred when enough technical data has been obtained to support such a statement.
See site file for additional information. |
Ron Klein |
| 3/5/1990 |
Meeting or Teleconference Held |
Meeting held with USAF personnel (DEE staff, JA, and SGPB).
Based upon the results of the Black and Veatch study, the USAF
decided to require ADOT to sample and test all future gravel
prior to removing it from the gravel pit area. |
Jennifer Roberts |
| 4/4/1990 |
Update or Other Action |
Letter sent to ADOT which required sampling of material prior to
being transported from Elmendorf AFB. Letter stated no elevated
contaminant readings in soil had been detected but groundwater
beneath the bottom elevation of the gravel pit contained
contaminants at levels above the MCL. |
Jennifer Roberts |
| 4/16/1990 |
Meeting or Teleconference Held |
USEPA Memorandum Subject: Elmendorf AFB Deliverables and Operable Units (OU) from D. Johnson Environmental Scientist, AOO/A to George Hofer Chief Federal Facility Branch HW-074.
The following is a synopsis of two meetings that were held with staff members of ADEC and EPA. The first meeting was held on April 6, 1990 and the second was held on April 12, 1990. Attendees for the meetings from ADEC were Ron Klein, Max Schwenne, Colleen Burgh, Jennifer Roberts with Mary Siroki and Geoff Kany attending the first meeting. The following reflects the input from ADEC regarding the document deliverables, determination of operable units, and schedules for inclusion to the Elmendorf AFB Interagency Agreement. This information was discussed with Bub Loiselle during your absence.
Document Deliverables: It was determined by mutual agreement that the same document deliverables now proposed for the Eielson IAG be incorporated into the Elmendorf IAG without change. ADEC agrees that for consistency and simplicity reasons the document deliverables for all Alaska IAG's remain the same.
Operable Units: Operable unit determination was based upon a hierarchy which was derived by either geographic or site characteristic similarities. The listed order was determined by severity of contamination (worst first) based upon common knowledge of the meeting participants.
Operable Unit #1 (Million Gallon Hill Area)-Sites SP-5/5A, OT-1, D-15, D-16, D-17, NS-2.
Operable Unit #2 (Air Force High Priority Sites-Sites) S-5, D-4, D-10, FT-1
Operable Unit #3 (Landfills)-Sites D-5, D-6, D-7, D-8, D-9, D-11, D-12, D-13, NS-2
Operable Unit #4 (Hangar Floor Drains)-Sites IS-1, IS-2, IS-3, IS-4, IS-5, IS-6, IS-7, IS-8
Operable Unit #5 (Fuel Spill Sites)-Sites SP-1 thru SP-16, NS-3
Operable Unit #6 (UST/LUST Sites)-Approx. 35 known UST/LUST sites scattered around facility.
Operable Unit #7 (Misc. Sites)-Sites D-1, D-2, D-3, RD-1, S-l, S-3, S-4, S-6, S-7
Please note that of these operable units, the first three are probable definites for inclusion to the IAG. The last four have been included at this stage for discussion purposes and for understanding the perceived universe of sites at Elmendorf AFB.
Further refinement of this list and determination of schedules to be discussed on May 2, 1990 with ADEC. I will continue to discuss this subject with Bub as it develops, and would welcome any input you might have. |
Ron Klein |
| 4/17/1990 |
Meeting or Teleconference Held |
Meeting held with ADOT staff to discuss testing procedures. ADOT proposed testing extraction site, stockpiled material, and material in place on Boniface Parkway. USAF requested testing
program be submitted to Air Force for review and coordination. |
Jennifer Roberts |
| 4/23/1990 |
Update or Other Action |
ADOT letter to USAF RE: Air Force License #DACA85-3-86-62 Davis Pit / M.S. 41-1-044-1 Contaminant Testing. Testing of Davis Pit gravel for contamination will begin the afternoon of
Wednesday, April 25th. The enclosed plan prepared by Department of Transportation and Public Facilities (DOT&PF) consultant Shannon & Wilson, Inc. details this work. The two and one half miles of Boniface Parkway built with Davis Pit gravel last year is included for sampling under this plan.
Your letter of April 4, 1990 is of immediate concern as the Boniface Parkway construction placed 200,000 tons of Davis Pit gravel between Tudor and DeBarr Roads in 1989. An additional problem is DOT&PF's contractual obligation to Beta Construction. Our contract establishes Davis Pit as the aggregate source for the widening of Boniface Parkway. Thirty-six thousand tons ($135,000) of crushed aggregate is stockpiled in the pit and awaiting the resumption of construction in May. Approximately another 15,000 tons of pit run and 20,000 tons of material to be crushed for paving aggregate is required to complete the contract.
DOT&PF directed the Boniface Parkway contractor Beta Construction to procure an alternate gravel source on Friday, April 20, 1990. This decision is predicated on your April 4, 1990 letter and our contractors scheduled resumption of construction on April 30th. Although we ,are hopeful and optomistic that soil samples will reveal Davis Pit material devoid of contamination, prudence and time constraints necessitate procuring another site.
The testing plan is the culmination of DOT&PF's discussion and meetings with personnel from the Department of Environmental Conservation, Environmental Protection Agency, and your environmental staff. This plan is intended to insure the safe and expeditious testing of potentially contaminated soils.
Coordination will continue during the testing of Davis Pit material, with test results being made available to your staff. Once the test results are analyzed, and providing the material is not contaminated, it is our intention to use the stockpiled crushed aggregate on the project. |
Max Schwenne |
| 4/25/1990 |
Update or Other Action |
ADOT notified USAF that ADEC had expressed concern over use of gravel from an IRP site and indicated that no testing of the source or stockpile would be done. However, ADOT intended to
test the gravel already placed on Boniface Parkway. |
Jennifer Roberts |
| 5/4/1990 |
Update or Other Action |
ADEC letter to USAF and ADOT Subject: Site D-7 Landfill, Elmendorf Air Force Base. On April 12, 1990 a representative of the Alaska Department of Transportation and Public Facilities (ADOT), brought to the Department's attention ADOT's use of potentially contaminated soil excavated from Elmendorf Air Force Base (EAFB) Site D-7 Landfill, for the Boniface Parkway Road Construction Project.
According to Installation Restoration Program information previously submitted by EAFB, groundwater at Site D-7 has been found to be contaminated with volatile (Trichloroethylene-TCE and chlorinated organic compounds and total recoverable metals such as barium, chromium, copper, lead, vanadium and zinc (Black and Veatch, August 1989).
According to Department files the Air Force has been aware of potential contamination at the site from shop wastes as early as September 1983 (Engineering Science, September 1983). According to documents provided to the Department by ADOT, the Air Force has provided authorization to ADOT since November 8, 1985 to extract material from the site,for use on the Boniface Parkway Project. The Air Force apparently did not notify ADOT of the site contamination until April 4, 1990 (Mabry to Heinrich, Letter, April 4, 1990).
The Department is concerned that soil has been removed from this contaminated site for use on the Boniface Parkway Project without either party first confirming that the soil is not contaminated. According to 18 AAC 75.140 (Cleanup), persons responsible for a hazardous substance discharge shall clean up and dispose of contaminated material using methods for which prior approval has been given by the Department.
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. We are incredulous that the Air Force has provided a license to ADOT to remove soils from a site that has been identified as contaminated prior to conducting a satisfactory site investigation which would clear the soils for beneficial use.
Likewise, we are incredulous that the ADOT would have excavated landfill soils without first determining that they are clean. We are also concerned that site activities have destroyed the installed monitoring wells and altered the landfill hydrogeology.
According to AS 46.03.822 it appears that the ADOT may, along with the Air Force, now be considered a potentially responsible party (PRP) for on-site contamination and the Air Force and ADOT may be considered PRP's for any off-site contamination that may be identified on the Boniface Parkway Project.
According to the U.S. Environmental Protection Agency, EAFB is a proposed National Priorities List (NPL) Superfund site whose final listing will be accomplished in the near future. The excavation and removal action is a potential improper off-site disposal of Superfund waste. Sec 121 of CERCLA/SARA would mandate that all offsite disposal requirements be met. The activities at the site pose a potential CERCLA violation for improper disposal. Both ADOT and the Air Force may incur CERCLA liability for the actions.
The Department requests that the Air Force and ADOT take steps to ensure that all future activities at the site be consistent with State and Federal environmental statutes and take steps to identify, remove and properly dispose of any contaminated materials that may have been disposed of off site. The Department also requests that the Air Force cease providing licenses to public or private parties for activities which interfere with the proper investigation and remediation of contaminated sites. |
Bill Lamoreaux |
| 5/25/1990 |
Update or Other Action |
May 19, 1990 letter from ADOT to ADEC R. Klein received by ADEC Southcentral Regional Office. RE: Project FM-543(1) / 56493 Boniface Parkway, Tudor Rd. to DeBarr Rd. Soils Contamination
Your concerns voiced in meetings on May 10 and May 14, 1990 regarding the contamination detected in the gravels on Boniface Parkway have been addressed by the Department of Transportation and Public Facilities as follows:
Provided public notice on May 15, 1990, advising the community that contamination has been detected in gravel used to construct Boniface Parkway.
The project is being patrolled daily between the hours of 7:00 AM and 10:00PM to limit public contact with project soils.
Based on initial consultation with the Department of Labor, worker safety will be provided through use of gloves and dust masks, as required.
Dust will be controlled by watering, use of a dust palliative, or the spreading of a blanket of clean material.
All gravels that have been placed on the roadbed will be retained within the project limits.
DOT&PF is accomplishing a contamination assessment to identify the level and extent of contaminated soils on the project and to consider potential risk to groundwater. This assessment shall be conducted in a manner consistent with current Region 10 guidelines.
The As-Built plans for the project will note the presence of contaminated material and all rights of entry will contain notice of contamination.
Completion of the roadway in accord with the plans, providing for the paving or topsoil and seeding of all surface area, and an enclosed stormdrain system, will insure that runoff is directed away from contaminated areas.
All documentation concerning removal of gravel from Davis Pit on Elmendorf will be maintained.
Signed William T. Goodell Project Manager. |
Ron Klein |
| 6/11/1990 |
Update or Other Action |
Anchorage Western District Office received copy of the letter to the USAF from ADOT & PF Central Region Div. of Design & Construction Director's Office. May 4, 1990 letter from Colonel Everett Mabry 21st Combat Support Group commenting on the QA Plan submitted on April 23, 1990 is acknowledged.
Responding to your letter of April 4, 1990, the Department of Transportation and Public Facilities (DOT&PF) prepared a plan to test Davis Pit gravel for contamination. Concurrent submittal to both the Department of Environmental Conservation (DEC) and the Environmental Protection Agency (EPA) insured compliance with the stipulations in your letter of April 4, 1990.
The initial plan that was submitted for comment proposed testing Davis Pit gravel both at the site and in place on Boniface Parkway.
DOT&PF's $136,000 investment in crushing prompted selection of the stockpile of processed material in the Davis Pit for testing. The Black-Veatch reference to "shop wastes", and the presence of motor parts, caused selection of the debris mound for testing based on possible solvent contamination. Assorted metal debris, including aircraft motor parts, were consolidated into this debris mound during removal of the gravel.
As discussed with your environmental staff, the initial testing revised shortly after submittal to sample only gravel already in the new road. DEC review, followed by their May 4, 1990 letter to Air Force and DOT&PF, prompted this revision.
DEC's notification of our joint responsibility as potentially responsible parties for a hazardous substance discharge, and the improper off-site disposal of Superfund wastes, precluded further use of Davis Pit and gave the final impetus for testing only Boniface Parkway.
The Boniface Parkway sampling plan is statistically derived using thirty three samples over the two mile length of the job. The sample sites fall at random locations that are about evenly split between areas covered by temporary pavement and gravel that did lay open to possible contamination. The sampling depth extends from .7 to six feet below the existing surface.
To the extent that the preponderance of the samples reveal contamination, the samples were taken at multiple depths, and that approximately half the samples came from under pavement, it appears likely that the material was contaminated at its source. You will be kept apprised of further developments and I would appreciate a copy of your test results from the samples taken on the base course stockpile.
Thank you for the time of your staff in dealing with the problems posed by the contamination discovered on Boniface Parkway.
Signed Tommy Gene Heinrich, P.E. Director, Design and Construction. |
Ron Klein |
| 6/28/1990 |
Update or Other Action |
Extension request for Permit #8721 -BA025 from 30 June 1991 to 31 December 1992 citing that
the Air Force is negotiating with the Municipality of Anchorage for disposal of Elmendorf waste at the Anchorage Regional Landfill. The Municipality stated that they could not accept waste from Elmendorf until late 1992. |
Louis Howard |
| 8/9/1990 |
Document, Report, or Work plan Review - other |
Response to extension request for Permit #8721-BA025. ADEC requests additional information.
Also attached to this correspondence is a letter from ADEC to the Air Force that includes the
assumption that landfill sites NS-2, D-5, D-7, and D-13 of the IRP study are in effect part of the State Permit (see page 3 of 7). |
Louis Howard |
| 9/3/1990 |
Update or Other Action |
In 1990, Shannon & Wilson Inc. was contracted by the State of Alaska Dept. of Transportation & Public Facilities to characterize the nature & extent of volatile organic contamination of a gravel stockpile located with the source area LF07 (the landfill area). The gravel from this stockpile was planned for use as the road base for the construction of the Boniface Parkway. Because the source of the gravel was within OU1, the gravel was sampled & revealed volatile organic contamination including the following maximum values:
Petroleum hydrocarbons: 77 ppm,
tricholoroethylene (TCE)* 52 ug/kg (exceeds Table B1 Method Two 2012 MGW 20 ug/kg),
PCBs 0.499 mg/kg, (Table B1 Method Two 2012 1 mg/kg)
Tetrachloroethene (PCE) 100 ug/kg, (exceeds Table B1 Method Two 2012 MGW 24 ug/kg)
benzene at 20 ug/kg (2012 MGW 25 ug/kg)
toluene 70 ug/kg, (2012 MGW 6,500 ug/kg)
ethylbenezene 10 ug/kg, (2012 MGW 6,900 ug/kg) and
total xylenes 60 ug/kg (2012 MGW 63,000 ug/kg)
The Scope of Work for the OU1 RI required that Jacobs update the extent of contamination of the gravel stockpile within the landfill area.
NOTE to FILE:TCE became one of the most widely-used chlorinated solvents for cleaning & degreasing because of its effectiveness, noncorrosivity, & nonflammability. TCE was first prepared in 1864, but was not produced commercially in the US until the 1920s. Earliest applications included use in boot polishes & printing ink dryers. TCE was used in the US food processing industry as an extraction solvent as early as 1927. During the 1930s, TCE's use in the dry-cleaning industry increased, & it began to replace carbon tetrachloride in solvent applications.
During World War II, the production & use of TCE increased significantly due to its use in degreasing. Supplies were controlled by the US government so that military demands could be met. The introduction of neutral stabilizer systems in 1954 helped retain TCE's position as the degreasing solvent of choice. It did, however, have other uses at this time, including dry-cleaning, & extraction of fats & oils. It was also used as a heat exchanging fluid, & in medical applications as an analgesic & anesthetic. DuPont was the largest producer of TCE in the late 1950s.
TCE became the first chlorinated solvent to be subjected to environmental regulation when the LA County Air Pollution Control District enacted Rule 66, which limited air emissions of TCE & other smog precursors. The use of TCE peaked in the US in 1970. Its decline in the following years was primarily due to increased evidence of toxicity & the advent of environmental regulations. The National Cancer Institute released evidence of TCE carcinogenicity in March 1975; in July 1975, General Foods ceased using TCE for decaffeination of coffee. TCE use increased during the 1990s when TCA & other solvents were banned under the 1990 Clean Air Act Amendments. |
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 |
| 10/1/1990 |
Update or Other Action |
Black & Veatch was tasked by the Air Force to conduct an remedial investigation (RI) at landfill (LF) 13 (formerly D-13 Disposal Site), and OT 56 (OT = Other, ordnance, burn areas, buildings a.k.a. NS-2 DRMO (DPDO) Scrap Pile) while starting the RI process at contaminated source areas LF05 (formerly D-5 Sanitary Landfill)and LF07 (formerly D-7 Sanitary Landfill). These investigations included: logging of boreholes, subsurface soil sampling of boreholes, reviewing aerial photographs, performing terrain conductivity and ground-penetrating radar (GPR) surveys and installing six additional monitoring wells. Black & Veatch Remedial Investigation/Feasibility Study Stage 3 Final Report. The Defense Reutilization and Marketing Office (DRMO) scrap pile is designated as site NS-2. Various drums are stored in the vicinity of NS-2 and some surface staining of the soil has resulted. The site is east of Davis Highway and south of Marketing and Distribution. It is north of site D-13 Disposal Site and east of Site D-5 Landfill and north of D-7 Sanitary Landfill.
Groundwater samples were also collected from all monitoring wells at OU1. D-7 had vinyl chloride at 9.5 ug/L (Well GW-1B) and 6.7 (Well GW-2C). Slug tests were conducted in seven wells within OU1. However, water levels in the monitoring wells responded too rapidly to permit analyses of the data by standard slug test methods. Although analyses of the slug test data were not reported by Black & Veatch, the rapid recovery of water levels suggests very HIGH hydraulic conductivity for the tested aquifer materials. A sample from 10 ft. bgs in the borehole for monitoring well D13-02. D13-02 sample results detected trichlorofluoromethane at 420 mg/kg.
D-5 TPH concentrations are at 2,590 mg/kg above the interim State of Alaska soil cleanup level guidelines. NS-2 detected vinyl chloride at 2.2 ug/L and trans-1,2-dichloroethene at 4.7 ug/L.
It was recommended that sites D-5, D-7, D-13, NS-2 be combined due to their proximity and the similarity of the constituents found at these sites. This new site would be assigned a high-priority for remedial alternatives due to the contaminant levels exceeding State of Alaska water quality regulations and the evidence of off-site migration.
Primary pathway to receptors is through contaminated groundwater. A downgradient active well (Base Well 42) is located 5,200 feet to the northwest of the site NS-2 at building 11-200. Well 42 is an artesian well, drilled to a depth of 225 feet. Well samples from NS-2 are from 56 feet or less. Base Well 42 was last tested for volatile organics and metals in 1987. No VOCs were detected in the sample and all metals were detected below State and EPA standards. It appears either contamination from NS-2 has not reached this well or the design of the artesian well has prevented its contamination.
Further investigation at this new combined site should include installing 7 additional wells to determine the extent of contamination. 6 of the new wells should be downgradient of the existing wells (2 of them near the gas station). 1 well near well GW-2B screened in the deeper portion of the aquifer to delineate the extent of vertical contamination. Analysis should be for: VOCs, TPH, extractable priority pollutants, PCBs, pesticides, anions, and metals including lead. |
Louis Howard |
| 10/15/1990 |
Meeting or Teleconference Held |
An IRP progress meeting was held at Elmendorf AFB on 15 Oct 90. The following people were present:
Ken Lauzen EPA, Anchorage Office
Jennifer Roberts ADEC, Anchorage Office
Rick Belan MITRE, HSD/YAQ Brooks AFB Texas
Mark Bryant Harking Lawson Associates, Anchorage
Don Dubois Jacobs Engineering Group, Seattle
Rick Prescott Harding Lawson Associates, Anchorage
H. L. Willman Jacobs Engineering Group, Seattle
H. D. Weaver 21 CSG/DEEV Elmendorf AFB, Alaska
2. The following items were discussed and agreement was reached between all the attendees:
A. Deep wells are to be postponed until spring 91 when we will have more information, from previous testing, to use in deciding where to locate them. Additionally cassing will be requierd to prevent possible cross zone contamination from occuring. A rotary drill rig will be used to drill this well.
B. Clean decontamination rinse water, determined to be clean by
laboratory testing, will be disposed of in the Municipality of Anchorage (MOA) Waste Water Sewage Treatment System if possible. Before any clean decontamination rinse water is disposed of the contractor shall determine what the MOA requires in terms of testing and meet any requirements. If the Anchorage Waste Water Sewage Treatment is unavailable the second choice will be the Eagle River Waste Water Treatment Plant. The Anchorage system might refuse the rinse water because they use a single level treatment process. The Eagle River plant adds a second level of treatment.
C. The sampling location plan was upgraded to include some further sites at the Four Million Gallon Hill (ST41) and the old Power Plant Storage tank site (ST20).
D. A spring with a noticeable odor and a visible sheen has been
discovered north of the Four Million Gallon Hill. It was decided that the surface water needs to be sampled. Our contract called for one surface water sample to be collected from the seep south of the Four Million Gallon Hill, however it was decided to move this sample to the spring. Everyone ageed that the seep has floating petroleum on the surace and a sample to prove this is unnecessary.
E. When petroleum contamination is a possibility we will use stainless steel screens in all monitoring wells. |
Jennifer Roberts |
| 10/30/1990 |
Meeting or Teleconference Held |
Richard L. Howard DERA Program Manager - Memo for the record: SUBJECT: Closeout of 13 IRP sites.
1. During discussions with the DEC and EPA on 30 October 1990, regarding the Elmendorf AFB IRP program, the determination was made that 13 of our previously reported areas are eligible to be closed out at this time. A listing of the sites and a rationale for their closing are as follows.
2. Sites SS--22 and SS-33 will be regulated by provisions of our EPA Part "B" permit. Upon completion of initial base studies, Sites: LF-011, LF-02, LF-06, LF-08, LF-09, OT-1 , LF-12, RW-17,. SS-18, and SS-19 were determined to pose no threat to the environment or human health. This determination was also made by ADEC during its Federal Facilities RCRA Inspection. Also, site SS-59 has been remediated by completion of a removal action.
3. The necessary documentation will be coordinated with EPA and DEC prior to final closeout of any of these sites. |
Jennifer Roberts |
| 10/30/1990 |
Meeting or Teleconference Held |
A meeting was held in our Anchorage office on October 30, 1990. In attendance were: Capt Brad Gerken 11th Air Force, Joe Williamson Elmendorf AFB, Richard Williams Elmendorf AFB, Jennifer Roberts ADEC. The purpose of the meeting was to bring EPA, ADEC and USAF technical staff to a common ground on the history and background of Installation Restoration Program and CERCLA activities to date at Elmendorf AFB. Joe Williamson provided a good overview of the work done by the Air Force to date, work in progress and work scheduled.
A draft " Elmendorf Operable Units" document for potential CERCLA 120 operable units (OU), which was prepared by the Elmendorf on June 7,1990 and transmitted to EPA and ADEC for discussion. The basis for the operable unit proposal is a "worst first" approach, using:
- Previously gathered contractor studies (Black and Veatch),
- Results of a 1988 RCRA investigation by ADEC,
- Public concerns expressed to date, and
- Discussions with EPA and ADEC in the past year
Similarities of types of wastes, physical proximity, potential treatment methods or other site characteristics were all considered in arriving at the groupings. The operable units are also grouped by the fiscal years they are funded or likely to be funded.
Specific comments from Joe W. on the OU's: While a significant amount of data has been collected on a number of sites, no in.terim RODs or expedited RODs are being considered, since no sources have been characterized to the extent that RI/FS documents can be completed yet.
-A treatability study is being considered to address the many petroleum sites, using bioremediation and land treatment and possibly using waste heat from the base steam heating facility to enhance the process.
-Only OU's 1 and 2 are currently funded for RI/FS studies.
-OU's 12, 13 and 14 consist of sites Elmendorf believes will require no further action.
-OU 15 is composed of new sites for which PA/SI's will likely be funded in FY 91. These and any new sites discovered during a CERCLA 120 process will need to be addressed in an IAG.
-One new area has been discovered since the list was prepared, a tar pit, which will be numbered site 61.
-In all, it appears that some 45 to 50 sites could remain under consideration for OUs in an IAG. If the grouping proposed were to be used, a total of 10 to 12 OU's would be involved.
The unlabeled generic schedule was prepared by Elmendorf for discussion and was transmitted to EPA and ADEC on June 7, 1990. It assumes that full characterization of all operable units will be required as mentioned above, and will take 28 to 30 months each. OU's 1 and 2 began in September, 1990.
The Air Force and ADEC summarized the history and their understandings of RCRA activities at Elmendorf to date. There are three sites primarily being addressed right now under RCRA. Site 33 (Bldg 22-009) is currently under a RCRA Part B permit that runs until 1993. Site 22 (DRMO Storage Area) is a new facility. Both are currently being looked at under a single combined RCRA
permit, with tentative public review in the spring of 1991. Site OT11 (Small arms Ammo Disposal) is an active RCRA area (open munitions burning) and will not likely be included under CERCLA 120.
There have been recent meetings between the base and ADEC concerning other sites involving RCRA-type wastes and a number of the sites listed in the OU's for possible CERCLA inclusion are involved. Geoff Kaney of ADEC is preparing language ADEC may propose to use in an IAG that addresses the RCRA/CERCLA interface, and defining how they feel various sites should or should not be included.
It was agreed in our meeting that Jennifer Roberts would get EPA and Elmendorf copies of Geoff's draft, and that, if appropriate, a meeting on November 19 or 20 in Anchorage might be productive to discuss this matter further. It was made clear that there would be no attempt to negotiate positions in regards to IAG language. The agenda would be to share technical information and possibly clarify current positions under RCRA by ADEC and Elmendorf.
In closing comments, it was mentioned that Elmendorf staff have recently received copies of the latest Eielson AFB IAG and need time to be fully conversant with it before any discussions are initiated concerning an Elmendorf agreement. It was also suggested that before EPA initiates an IAG negotiation process by formal letter to the other two parties, that a "strawman" document be prepared by EPA and sent to Elmendorf and ADEC. |
Jennifer Roberts |
| 12/3/1990 |
Update or Other Action |
Memorandum for AF Negotiators of Environmental Cleanup Agreements
Subject: Environmental Cleanup Agreement Philosophy
There are 7 scenarios we have encountered recently which should give you a good idea of how seriously I view the need to enter into agreements whenever practical:
a. We are negotiating with CA & WA to enter into two-party agreements for the cleanup of old hazardous waste sites at non-NPL bases. These agreements are being developed at the request of the states which have CERCLA-type laws on the books. We expect these agreements to be patterned after the model IAGs with which you are already familiar.
CERCLA Sec. 104 & 121 (as delegated to the AF by Executive Order 12580, Sec. 2.d., & DoD delegation letters November 13, 1988 & December 6, 1988) give the AF substantial authority over the cleanup of releases of hazardous substances on facilities under its jurisdiction. However this authority must be exercised consistent with CERCLA Sec. 120, where at Sec. 120(a)(4), "State laws concerning removal & remedial action, including State laws regarding enforcement, shall apply to removal & remedial action at facilities owned or operated by a department, agency, or instrumentality of the United States when such facilities are not included on the National Priorities List."
There is clearly a tension created by these provisions. Rather than debate which one trumps the other, we have decided to accommodate both via two-party agreements. The flavor of these agreements will be to recognize the authorities of both sides, & defuse the contentious issue of who is really in charge of the cleanup at facilities not on the NPL.
b. We are negotiating an IAG with EPA Region VIII & CO at Plant PJKS (an AF installation on the NPL). In this IAG the state (which has been delegated Resource Conservation & Recovery Act (RCRA) corrective action authority) will be granted "RCRA lead" at several of the operable units (OUs) at the facility. However, the EPA will remain a key player at all of the OUs on the installation. A separate dispute resolution process for state-led OUs has been proposed, but it closely tracks the regular dispute resolution process with the exception that if the AF or the EPA cannot agree with the state's final resolution of a dispute, they reserve whatever administrative or judicial rights they may have.
As noted above, the AF has been delegated the authorities found in CERCLA Sec. 104 & 121, but these authorities must be exercised consistent with CERCLA Sec. 120. In CERCLA Sec. 120(i): "Nothing in this section shall affect or impair the obligation of any department, agency, or instrumentality of the United States to comply with any requirement of the Solid Waste Disposal Act (including corrective action requirements)."
There is also a tension between these provisions that must be resolved. There is a strong argument that Sec. 120(i) can be interpreted to mean that the requirements of RCRA, including the corrective action program, are "applicable or relevant & appropriate requirements (ARARs)" which must be accommodated in our cleanup program whether a facility is on the NPL or not. However, it is in the AF's best interest to avoid this argument & resolve this tension via agreements which interweave the parties' respective powers, & leave for another day & the courts the issue of whose power trumps whom.
c. We recently concluded a two-party agreement between Shaw AFB (a non-NPL base) & EPA Region IV for the cleanup of contaminants which had apparently migrated to an off-base drinking water well area. Under the threat of EPA trying to issue a CERCLA Sec. 106 Order or an RCRA Sec. 3004(u)/(v) Order, we entered into an agreement. We did this because it was fruitless to argue whether the State, rather than EPA, had primary jurisdiction over such a non-NPL site, & whether the EPA's actions were appropriate in this case in light of our CERCLA powers. The better course of action was to admit we had a problem & press on with finding a solution. This is exactly what we did by immediately providing a temporary & then a permanent alternate drinking water supply & entering into an agreement with EPA.
d. We have been negotiating an agreement with EPA Region II & NY concerning Plattsburg AFB (an NPL installation). The state has pointed out a disconnect between the RCRA/CERCLA integration language & the funding language. The state's position has been that the integration language can be easily interpreted to mean that the IAG is meant to cover all RCRA corrective actions as well as CERCLA actions, & that the funding language suggests that DERA funds will be used for all of these actions. However, the state points out, the truth is that DoD/USAF funding guidance makes clear that DERA funds will not actually be used for all of these actions.
See site file for additional information. |
Louis Howard |
| 1/15/1991 |
Update or Other Action |
Dept. of Air Force Headquarters Pacific Air Forces Hickam Air Force Base, Hawaii
Subject: Environmental Cleanup Agreement Philosophy - SAF/MIQ Memorandum
TO: 11 AF/CC 13 AF/CC 15 ABW/CC / 343 TFW/CC 5073 ABG/CC 11 TCW/CC HQ DNA/FCL 21 TFW/CCy 633 ABW/CC
1. Interagency Agreements (IAGs) have been typically associated with installations on the National Priority List (NPL). However, in the near future the Air Force will enter into agreements for many installations not on - the NPL. The Air Force is committed to cleaning up and closing out hazardous waste sites. Implementing agreements with regulators can help you avoid time-consuming controversies about who is in charge and move on with the
cleanup effort.
2. In the attached memorandum from SAF/MIQ, Mr Vest provides several scenarios the Air Force has encountered recently which outline the need to enter into agreements. Overall, it appears to be in our best interest to enter into agreements with regulators, regardless of the merits of the legal argument over whether our CERCLA power is predominant. To eliminate costly
delays, we must aviod confrontation and negotiate these agreements from a position of facilitating cleanup. We can then get on with the actual cleanup and make our goal of DOD becoming a leader in environmental protection and enhancement a reality.
3 PACAF POCs are Patrick Dupies, HQ PACAF/DEPV, DSN 449-8077, and Kim Scroggs, DSN 449-8094.
Signed Kenneth E. Eickmann, Brig. Gen. USAF, Chairman, Environmental Protection Committee. |
Louis Howard |
| 5/8/1991 |
Document, Report, or Work plan Review - other |
EPA sent Joe Williamson 21 CES/DEEV a comment letter on the September 1990 SAP OUs 1 and 2. The field sampling plan (FSP) does not appear to contain the supporting rationale for the proposed location and the number of borings, wells, product probes and ground water field sampling probes. No proposed locations were presented for the screening methods. Much of this information is assumed to be available in the earlier reports (e.g., Stage 4 RI/FS Workplan). If so, the relevant maps, tables, figures, and text should be referenced to support the location and number of sampling points.
If the aquifer is less than 10 feet thick, it is appropriate to have well screening that fully penetrates the entire aquifer. When the aquifer becomes thicker, multiple well screens are
necessary to characterize the groundwater flow. Multiple completions at the same location are particularly important in areas of ground water recharge and discharge where flow paths and contaminates will be following flow paths other than horizontal. Significant dilution of the ground water samples will occur if the well screens are too long.
The number of well screens that are necessary both horizontally and vertically is a function of the complexity of the geology and waste disposal history of each unit. The investigation methods have to be consistent with the complexity of the geology and the potential flow paths that contaminants may follow for the waste. It does not appear from reviewing the available data that there is the appropriate number of wells at these units. Further, it does not appear that the appropriate testing has been done to demonstrate that wells are related to each other. Such methods as pump tests and surficial geophysics between wells have not been done to demonstrate that the hydrogeology is understood.
The use of broad arrows to indicate ground water flow directions does not allow for adequate review of the proposed locations of monitoring wells, field sampling points, and product
probes. Supporting information to demonstrate the direction of ground water flow should be included. It is not clear what sampling frequency of the monitoring wells is being proposed. It is necessary to collect ground water samples over a period of time in order to evaluate seasonal
trends in the chemical data and in the ground water flow directions. Since most monitoring wells have been in place since at least the summer of 1989, there has been ample opportunity to
collect at least four to eight quarters of data. Many wells have been in considerably longer. Once it is determined that remedial action will. be necessary, quarterly groundwater sampling is
typically continued to provide additional data for remedial design.
In several places, the presence of floating free product is suspected. Wherever found, this floating layer should be analyzed. The results from analyzing the floating layers should be compared with the analyses of the ground water to determine if changes are occurring as the waste dissolves, volatilizes, and ages within the system.
Page 2-28: There is no proposal to sample and analyze the LNAPL layer, if encountered. It is assumed that no sampling of LNAPLs is being proposed because-there is no question about the
chemical composition of any LNAPL and that all reactions of weathering, chemical interaction, etc. are known from previous studies. If this is the case, then the supporting data should be
at least referenced to support the non-sampling of all LNAPLs.If a LNAPL is detected, it is being proposed that a riser pipe be placed into the wells several feet below the LNAPL/water interface, that the well be purged, and that groundwater be sampled through the riser pipe. It is assumed that part of the intent of using this method is to sample ground water separate from the LNAPL. It is not clear in reading this proposal how smearing of the LNAPL within the aquifer material and filter pack is going to be avoided as the water level is lowered during purging. When the water level recovers, the LNAPL will be coating the aquifer material and the filter pack. This results and may transport contaminants into portions of the aquifer where it has not been before.
More detail is needed regarding: (1) the proposal of using the riser pipe; (2) what controls are to be used to avoid spreading LNAPLs deeper into the aquifer; and (3) the potential for biasing future ground water sampling. It has to be explained what the advantages are of this single wells system over other systems that might be used such as well clusters. Have 2-stage pumps for simultaneous product and ground water sampling been evaluated?
See site file for additional information. |
Jennifer Roberts |
| 8/20/1991 |
Update or Other Action |
Letter from USAF Donald Creighton, Colonel USAF Commander to Svend Brandt-Erichsen Regional Administrator ADEC. As you know, the Air Force, the Environmental Protection Agency-Region 10, and the Alaska Department of Environmental Conservation (ADEC), recently concluded negotiations concerning a Federal Facility Agreement (FFA) for Elmendorf AFB. During these negotiations, the parties mutually agreed that certain of the
identified contamination sites might be more appropriately addressed outside the FFA.
More specifically, the parties agreed that nonhazardous solid waste disposal sites, releases from petroleum underground storage tanks, and other petroleum contamination not subject to RCRA corrective action, should be investigated and, if necessary, remediated in accordance with regulatory authorities not explicitly integrated into the FFA.
The Air Force is anxious to begin work at these sites as soon as possible. To that end, the Air Force believes it would facilitate efforts at these sites if the Air Force and ADEC were to enter into an agreement outlining the process to be followed at these sites, and containing a tentative schedule for completion of the necessary investigatory work. The Air Force is prepared to begin
negotiating this agreement in mid-August at a time and location of mutual convenience. The Air Force additionally proposes to invite the EPA's Project Manager under the FFA to participate in these negotiations to further "cement" the team approach that works so well during the FFA negotiations
.
Please have your representative contact Mr Joe Williamson (907-552-4157) soon concerning a suggested time and location for this meeting. Any legal questions concerning this proposal may be directed to Captain Richard Myers (907-552-3046).
On behalf of Elmendorf AFB, I want to express my appreciation for the technical ability and professionalism your representatives brought to the table during the FFA negotiations. Without their assistance and spirit of cooperation- an agreement would not have been concluded so easily. We look forward to reaching a quick agreement concerning the sites identified in this letter so
that we can get on with the work necessary to clean up Elmendorf AFB. |
Jennifer Roberts |
| 9/30/1991 |
Update or Other Action |
Memorandum for the File.
Closeout of Four Installation Restoration Program (IRP) Sites for Elmendorf AFB AK
TO: HQ PACAF/DEV HICKAM AFB HI 96853-5260
1. Four IRP sites on Elmendorf AFB have been determined to be eligible for no further action (NFA). These sites are the Hazardous Waste Storage Facility (HWSF) (site number SS33), the Explosive Ordinance Disposal (EOD) Range (site number OT11), floor drains in Bldg 22-023 (site number SD58), and an underground waste paint tank (site number ST60).
2. The HWSF and the EOD range are active facilities currently being used. These sites were originally designated as IRP sites because they were used to process and store waste materials or to dispose of munitions. On 15 Aug 91, a Resource Conservation and Recovery Act (RCRA) Part B application was submitted to the Environmental Protection Agency (EPA) to renew our existing permit for the HWSF and to permit the EOD range. Further, IRP investigation is not neccessary because the eventual closure of these sites will be handled under the Part B permit.
2. The floor drains in Bldg 22-023 and the underground waste paint tank are currently undergoing RCRA closure pursuant to our 2 Aug 91 Federal Facility Compliance Agreement. At this time, there is no evidence of contamination to the surrounding area and it appears no IRP investigation is warranted. If, during the closure process, contamination is discovered, then these sites would be added to those requiring study and cleanup.
3. These four sites have been excluded from all Comprehensive Environmental Response, Compensation and Liability Act of 1980 cleanup requirements in the pending Federal Facilities Agreement negotiated between Elmendorf AFB, EPA and the Alaska Department of Environmental Conservation. All parties agreed these sites should qualify as no further action under IRP.
Everett L. Mabry, Colonel, USAF, Base Civil Engineer. |
Jennifer Roberts |
| 10/30/1991 |
Update or Other Action |
Modeling results from the EPA Hydrologic Evaluation of Landfill Performance (HELP) computer model in determining a water balance for the Elmendorf Air Force Base Landfill area received. Results of the water balance are used to estimate the quantity of landfill leachate that may be percolating to local groundwater.
The average annual water balance per acre of landfill area for the years 1986 through 1989 results in an average annual precipitation for this period is 18.91 inches. Based on the input parameters, the HELP model predicts that on an annual basis, approximately 172,000 gallons of leachate per acre percolates through the four-foot fill layer beneath the refuse. This quantity represents 33.5 percent of the average annual precipitation.
For the entire landfill area, totaling approximately 100 acres, the quantity of leachate generated would be about 17.2 million gallons. Thus, it appears likely that about 17.2 million gallons of landfill leachate may be entering the local groundwater each year. |
John Halverson |
| 11/4/1991 |
Update or Other Action |
Pursuant to Section 9.1, paragraph 1, of the Elmendorf Air Force Base (EAFB) Federal Facilities Agreement (FFA), EPA hereby designates Marcia Combes as the Project Manager and Michele Poirier-McNeill as the Alternate Project Manager for the purpose of overseeing the implementation of the agreement. Marcia Combes will serve as the primary point of contact for all communication
and correspondence. Attached please find the corresponding addresses for the Project Manager and Alternate Project Manager.
Section 20, Part G addresses Review and Comment on Draft Documents. For clarification, the thirty day period for review and comment on draft primary documents will begin upon receipt of
the document(s) in EPA's Seattle office. The Project Manager, or Alternate Project Manager will advise USAF and ADEC when the document was received and when the corresponding comments will be
transmitted, which according to the agreement will be on or before the close of the thirty day comment period. |
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.
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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 12, 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 |
| 12/1/1991 |
Site Added to Database |
Petroleum, solvents, metals. |
Louis Howard |
| 12/13/1991 |
Update or Other Action |
EPA sent comment letter on the IRP Stage 4 Sampling and Analysis Plan (SAP) Revision 1 for OUs 1 and 2 dated October 1991. It is EPA's understanding that elements of the SAP will be incorporated into the OU-1 and OU-2 management plans as appropriate. The OU-1 and OU-2 management plans are primary FFA documents due to EPA February 15, 1992 and April 1, 1992, respectively. Upon submission of the draft management plans for OU1 and OU2, this material will be reviewed again for consistency and technical content within the context of the document, and commented on correspondingly.
The document states that the Installation Restoration Program (IRP) is approximately equivalent to U.S. EPA's Superfund Program, and further implies that the IRP will govern the remedial process. This concept may be misleading; compliance with CERCLA is mandatory and there has not been a formal recognition of the functional equivalence of the IRP and CERCLA, as they are separate and distinct programs. A CERCLA Section 120 Federal Facilities Agreement (FFA) has been entered into by the USAF, Alaska Department of Environmental Conservation (ADEC) and elements of CERCLA remedial action at Elmendorf Air Force Base.
The document contains quality assurance project plans (QAPP) prepared by Jacobs Engineering and BC Analytical. Both QAPPs comply with EPA requirements listed in Interim Guidelines and Specifications for Preparing Quality Assurance Project Plans (1980). The document states that the laboratory will provide a data package equivalent to the EPA Contract Laboratory Program
(CLP) data package. However, to produce a CLP-equivalent data package, quality control and data validation criteria need correction or additional clarification. The quality control
criteria deficiencies include precision ranges, accuracy limits, matrix spike/matrix spike duplicate, spike recovery, and method blank acceptance criteria. These deficiencies are presented in greater detail in the specific comments.
Section 1.1.1, page 1, second paragraph Executive Order 12580 delegates to DOD the responsibility for remediating hazardous waste contamination on DOD facilities, not CERCLA Section 120. Section 1.1.1, page 2, fifth paragraph The first sentence refers to Ifthe time needed to complete each step in the IRP..."; suggest replacing "IRP1" with "CERCLA
remedial process" in order to clarify the focus on CERCLA sites, and the corresponding actions.
Section 1.1.2, page 3, second paragraph The document defines the function of the SAP, and states that it "...prescribes the requirements for assuring that the environmental investigation for EAFB is planned and executed in a manner consistent with USAF quality assurance guidelines." CERCLA requires adherence to EPA quality assurance guidelines, thus, USAF quality assurance guidelines must demonstrate functional equivalency.
Section 2.1.5, page 147, second paragraph: A 0.020-inch slot size screen for is proposed for monitoring well construction. Because of problems with sediments in previously installed wells, the screen size should be selected based on sieve analysis. Since well construction will take place after the boreholes are completed, adequate time should be available to obtain these results. If 0.020-inch slot size screen is used, references suggest the use of a 10-20 mesh sand with this size screen.
Section 3.1.10, page 238: The presence of solids in the background groundwater samples
at levels between 100 and 200 g/L indicate that these wells are either improperly constructed, developed, or sampled. It is unlikely that filtered (dissolved) metals analyses represent
actual concentrations of mobile metals in groundwater. An effort should be made to obtain more representative unfiltered samples from those wells.
Figure 3.3-29, page 451: The conceptual site model illustrated in this figure indicates the presence of dense nonaqueous phase liquids (DNAPL). However, data supporting the presence of DNAPLs are not presented in the data summary. The inclusion of DNAPLs as potential contaminants of concern at this source area should be explained.
Section 3.2.1.7.6, page 323: It is unclear what analyses will be performed on the methane
well samples. Sampling the wells for volatile organics in addition to methane to address the subsurface soil-gas migration pathway is recommended. |
Jennifer Roberts |
| 12/30/1991 |
Update or Other Action |
EPA sent letter to AF Rich Howard and Joe Williamson. The notification will serve as an addendum to the previous letter of November 4, 1991 which designates the USEPA project managers pursuant to Section 9.1 of the Elmendorf Air Force Base (EAFB) Federal Facilities Agreement (FFA). Marcia Combes will serve a lead remedial project manager (RPM) for base-wide activities, as well as Operable Units (OUs) 2, 3, 5, 6, 7. Michele Poirier-McNeill will serve as lead RPM for OUs 1 and 4. In addition both RPMs will serve as an alternative RPM on OUs for which they are not the lead. For communication and correspondence purposes, the lead RPM should be the point of contact, and the alternate should be copied. |
Jennifer Roberts |
| 2/5/1992 |
Meeting or Teleconference Held |
Public workshop held at the Government Hill Elementary School to discuss environmental remediation programs ongoing at the Base. |
Jennifer Roberts |
| 2/6/1992 |
Site Characterization Workplan Approved |
Jacobs Engineering Group inc. sent operable unit (OU) 1 management plan contract #F33615-90-D-4009 Delivery Order Number 5 for ADEC comment and review. LF05 (Old number D-5) Located on the southwestern region of the Base, west of ammo storage area "B", east of the Marketing and Redistribution (DRMO), and north of Ship Creek, size sixty-five acres.
LF13 (old site D-13) Disposal Site- at corner East of Davis Highway and South of Market and Redistribution storage. Approximately two acres. Used from 1967 to 1971 for disposal of empty drums, metal piping, drums full of asphalt and small quantities of quicklime from base renovation operations. OT56 (former NS-2) DRMO Scrap pile located east of Davis Highway. Reports that various kinds have been stored in this area some soil staining reported.
LF59 Asphalt Seep: The 1992 exploratory program delineated the outer zones of significant asphalt cement accumulation. |
Jennifer Roberts |
| 2/19/1992 |
Update or Other Action |
EPA MEMORANDUM
SUBJECT:Permits and Permit "Equivalency" Processes for CERCLA On-site Response Actions
FROM: Henry L. Longest II, Director, Office of Emergency and Remedial Response
TO: Director, Waste Management Division, Regions I, IV, V, VII, and VIII; Director, Emergency and Remedial Response Division, Region II; Director, Hazardous Waste Management Division, Regions III, VI, and IX; Director, Hazardous Waste Division Region X
PURPOSE: The purpose of this directive is to clarify the Environmental Protection Agency (EPA) policy with respect to attaining permits for activities at CERCLA sites. CERCLA response actions are exempted by law from the requirement to obtain Federal, State or local permits related to any activities conducted completely "on-site". It is our policy to assure all activities conducted "on site" are protective of human health and the environment. It is not Agency policy to allow surrogate or permit equivalency procedures to impact the progress or cost of CERCLA site remediation in any respect.
BACKGROUND: In implementing remedial actions, EPA has consistently taken the position that the acquisition of permits is not required for on-site remedial actions. However, this does not remove the requirement to meet (or waive) the substantive provisions of permitting regulations that are applicable or relevant and appropriate requirements (ARARs). (For definitions of "substantive" and "administrative," see 55 FR 8756-S7 and the CERCLA Compliance with Other Laws Manual, Part I, pages 1-11-12.) The proposed and final 1982 National Oil and Hazardous Substances Pollution Contingency Plan (NCP) made no mention of the permit issue. However, EPA addressed the issue in a memorandum entitled "CERCLA Compliance with Other Environmental Statutes" which was attached as an appendix to the proposed 1985 NCP (50 FR 5928, February 12, 1985). The memorandum stated: "CERCLA procedural and administrative requirements will be modified to provide safeguards similar to those provided under other laws. Application for and receipt of permits is not required for on-site response actions taken under the Fund-financed or enforcement authorities of CERCLA."
EPA determined in the final rule [1985 NCP section 300.68 (a)(3)] that "Federal, State, and local permits are not required for Fund-financed action or remedial actions taken pursuant to Federal action under section 106 of CERCLA." The 1986 amendments to CERCLA codified section 300.68(a)(3) of the 1985 NCP with a statutory provision, section 121(e) (I). CERCLA section 121(e) (1) provides that no Federal, State, or local permit shall be required for the portion of any removal or remedial action conducted entirely on-site, where such remedial action is selected and carried out in compliance with section 121.
The 1990 NCP [section 300.400(e)(1)] implements this permit exemption for "on-site" actions, defining "on-site" as "the areal extent of contamination and all suitable areas in very close proximity to the contamination necessary for implementation of the response action." The preamble to the NCP (at 55 FR 8689, March 8, 1990) explains that "areal" refers both to the surface areas and the air above the site. EPA policy further defines "on-site" to include the soil and the groundwater plume that are to be remediated. On-site remedial actions may involve limited areas of noncontaminated land; for instance, an on-site treatment plant may need to be located above the plume or simply outside of the waste area itself.
As provided in NCP section 300.400(e)(I), response actions covered by CERCLA section 121(e)(l) include those conducted pursuant to CERCLA sections 104, 106, 120, 121, and 122. Thus response actions conducted by a lead agency, or by a potentially responsible party or other person under an order or consent decree with EPA, are covered under the ambit of CERCLA section 121(e)(1). Response actions by a lead agency include those response actions implemented by EPA, the Coast Guard, or another Federal agency. They also include response actions implemented by a State or political subdivision operating pursuant to a contract or cooperative agreement executed pursuant to CERCLA section 304(d)(1), under which EPA selects (or must approve) the remedy. |
Jennifer Roberts |
| 3/19/1992 |
Update or Other Action |
ADEC sent comments on the Operable Unit 1 (OU1) Management Plan, Elmendorf Air Force Base (EAFB), February 1992. The comment closure date for this primary document is March 19, 1992. ADEC will not review or comment on the Health and Safety Plan. The management plan does not address the future use scenario for the risk assessment. Attachment 1 states that the future use scenario will be determined as the Remedial and risk assessment proceed. ADEC does not agree with this approach. The future land use scenario needs to be developed in the management plan to determine what data and sampling needs must be met.
The Department is concerned that information from the basewide groundwater study will not be available in time to be used in determining data needs for OU1 field work. Information generated by the basewide groundwater study includes on-site and off-site well data which will be a valuable tool in determining possible additional data needs for OUl field work. Applicable information from the basewide groundwater study should be available prior to OU1 field work.
Section 1.6, page 34: This section states that all required regulatory permits will be obtained. Federal, state, or local permits are not required for on-site activities or actions under CERCLA. However, the substantive requirements of the permit must be met.
Appendix A-1, Section 3.1.2, page 37: This section address the hydraulic conductivity of the shallow water table aquifer, this issue is also addressed in Attachment I, page I I and 12, section 3.2.1.2, pages 246 and 253. ADEC is concerned with shallow groundwater aquifer hydraulic conductivity and the uncertainties of previous reports and field work are not adequately addressed in the OU1 management plan. Assuming the conductivity for the shallow aquifer to be .1 cm/sec may be an incorrect assumption due to the wide range of conductivity values related to the soil and aquifer conditions on the base. Site specific flow information should be obtained or the previous pump test data should be analyzed for adequacy and applicability to OU1 aquifer conditions and characteristics.
Appendix A-1, Section 4.1, page 62: This section discusses background concentrations. Upgradient wells GW-1 A and GW-2A show levels of mercury and lead above the maximum contaminant levels (MCL). Both lead and mercury have been detected in several monitoring wells at LF13, LF07, and OT 56. Due to the presence of these metals in elevated levels in the upgr'adient wells it is necessary to determine if these levels are within background levels, from an upgradient source or associated with contamination generated by OU1. It is not clear how the RI sampling will address this issue, please clarify.
Appendix A-2 Section 2.4, page 14: More information should be provided on the applicability of the previous slug test data conducted by (Black & Veatch,l990) and whether the data generated was accurate.
Appendix A-2 Section 2.3 Table 2-1, page 6: In order to fully characterize the extend of the vertical contamination grain size, and soil moisture sampling should be performed on the subsurface samples. This comment applies to OU1 and LF59 areas.
Appendix A-2 Section 2.6, page 17: The location of the twenty methane wells installed around the base should be identified on a map.
Appendix B Table 2-29 and Section 2.5, page 11: The table lists "Alaska Underground Storage Tanks Emergency Regulations (Draft)", these regulations were finalized on August 21, 1991 and should be referred to as " Alaska Underground Storage Tanks".
Appendix B Table 2-4, Page 17: The bullets "ADEC, Guidance for Storage, Remediation and Disposal of Petroleum Contaminated Soils, March 15, 1991", "ADEC, Guidelines for Preparing A Quality Assurance Program Plane for Site Assessment Under 18 AAC 78", and "ADEC
Instructional Guidance for Using the Alaska Cleanup Matrix for Regulated UST's, 18 AAC
78.31 5, Table D, March 20, 1991" are incorrect and should be referred to these as listed in the "Guidance Manual for Underground Storage Tank Regulations, 18 AAC 78, June 18, 1991". The above bullets are listed respectively as Chapter IV, Chapter I, and Chapter Ill. The bullet " ADEC, lnterim Guidance for Soil Cleanup Levels, September 26, 1990" is has been replace with "ADEC lnterim Guidance for Non-Ust Contaminated Soils Cleanup Levels, July 17, 1991". |
Jennifer Roberts |
| 5/1/1992 |
Update or Other Action |
OU1 Management Plan (Final) received. Contaminant source area LF59 is a recently-identified potential landfill or disposal zone located southwest of the zone consisting of LF05, LF07, LF13, and OT56, and northwest of the Davis Highway bridge at Ship Creek. This contaminant source area was identified after joggers on a trail in the area noticed what appeared to be tars or asphaltic liquids at the surface adjacent to the trail. This area has been termed the "Tar Seep", although visual observations do not clearly indicate that the area is a seep rather than a possible area of surface disposal. No previous investigations have been conducted at this contaminant source area.
LF59. Contaminant source area LF59 was not investigated prior to the 1990/1991 studies. However, the initial Records Search (Engineering-Science, 1983) did identify a construction rubble disposal site (D-8) in the general area. Most of site D- 8 was located south of Ship Creek, in a gravel pit area, but a small portion of the site was located north of the creek, possibly near the western edge of LF59. Site D-8 was utilized from 1965 to at least 1983 for the disposal of construction rubble. As of 1983, the site had not been closed. There is no obvious connection between site D-8 and LF59. However, the reported asphaltic material observed at LF59 might be consistent with the disposal of construction rubble in the area. During the 1990/1991 investigations,
LF59 was the subject of two geophysical surveys, an electromagnetic (EM) survey in March and April 1991, and a vertical electrical sounding (VES) survey in May 1991. Only one area of possible subsurface disposal was identified, although there may be localized, widely scattered metallic debris throughout much of the area. The VES survey was conducted to help determine the elevation of the Bootlegger Cove formation in the vicinity of the site. Twenty-one soundings were performed. The Preliminary data show the tap of the Bootlegger Cove Formation ranges from approximately 60 feet to 104 feet below ground surface. Interpretation of the data is continuing. |
Jennifer Roberts |
| 5/1/1992 |
Update or Other Action |
Preliminary Applicable or Relevant & Appropriate Requirments identified by the USAF.
OU1 includes LF05, LF07, OT56, LF13 & LF59. Consistent with the Superfund Amendments & Reauthorization Act (SARA), the remedial action alternatives developed in a Feasibility Study (FS) should address legally applicable or relevant & appropriate requirements (ARARs).
This Preliminary ARARs Evaluation provides a discussion of all ARARs that may be identified throughout the Remedial Investigation (RI) & FS process. As additional contaminants of concern are identified, the chemical-specific ARARs list will be revised. As potential remedial alternatives are identified & evaluated, the list of action-specific ARARs will be reviewed. As any new information becomes available, it will be reviewed & incorporated into the ARARs list as appropriate..
Once all contaminants of concern are determined as a result of the RI & the list of final remedial alternatives are identified during the FS, the U.S. EPA & the ADEC will confer & evaluate the most current list of ARARs for OU1. Upon concurrence between the agencies, the list of ARARs will be finalized, & the final remedial alternatives selected during the FS must comply with ARARs or a waiver of ARARs must be justified. Field work for the RI is scheduled to be completed by Fall 1992, & the FS is scheduled to be completed by December 1993, according to the Federal Facility Agreement.
Potential chemical-specific ARARs include Safe Drinking Water Act MCLs, MCL Goals (MCLGs), Proposed MCLs (PMCLs), Ambient Water Quality Criteria (AWQC), AK UST Regulations, & RCRA TCLP levels for hazardous waste.
Potential action-specific ARARs include
AK Air Quality Control Regulations 18 AAC 50
Establishes classification of air pollution sources
AK Environmental Conservation Law AS 46.03
Contains provisions dealing with hazardous waste disposal
AK Underground Storage Tank Act AS 46.03
Provides for regulation of underground storage tanks.
AK Underground Storage Tanks Regulations 18 AAC 78
Provides guidance for cleanup of UST sites & associated soil.
AK Solid Waste Management Regulations 18 AAC 60
Provides requirements for solid waste management at industrial or commercial facilities & public places.
AK Hazardous Waste Management Regulations 18 AAC 62
Adoption of federal requirements with additional criteria & standards.
AK Hazardous Waste Management Facilities Siting Regulations 18 AAC 63
Provides administrative procedures & requirements for new hazardous waste management facilities.
AK Oil & Hazardous Substance Releases Law AS 46.08
Provides funds for state cleanup of oil discharges.
AK Administrative Procedures & Permit Regulations 18 AAC 15
Establishes permit & written approval procedures for air contaminant emissions, surface oiling, public pesticide projects, & disposal of wastewater into or upon the waters or land of the state.
AK Wastewater Disposal Regulations 18 AAC 72 Provides for permits for disposal of nondomestic wastewater into or onto the land, surface water, or groundwater
AK Oil & Hazardous Substances Pollution Control Regulations 18 AAC 75 Establishes permit requirements for discharge of oil, asphalt, bitumen, or a residuary product of petroleum onto the lands of the state
AK Water Quality Standards 18 AAC 70 Sets standards for operations that cause or contribute to degradation of a water body.
AK Oil Pollution Control Law AS 46.04 Provides for cleanup of oil discharges & also for the preparation of oil discharge prevention & contingency plans.
Migratory Bird Treaty Act of 1972 If migratory birds are present, provides protection of almost all species of native birds in the U.S. from unregulated activities. Unregulated activities can include poisoning at hazardous waste site
Fish & Wildlife Conservation Act of 1980 Requires the submittal of conservation plans outlining provisions to conserve non-game fish & wildlife. Approved conservation plans are enforced by state agencies
Federal Land Policy & Management Act Establishes requirements concerning utilization of public lands, particularly rights-of-way regulation, land use planning & land acquisition, & appropriation of waters on public lands.
Fish & Wildlife Improvement Act Provides for development, protection, rearing, & stocking of all species of wildlife, wildlife resources, & their habitat.
Endangered Species Act Provides for protection & conservation of various species of fish, wildlife, & plants
Wilderness Act Requires that federally-owned wilderness areas be administered in a manner that will leave the area unimpaired as wilderness & preserve its wilderness character.
See site file for additional information. |
Louis Howard |
| 9/11/1992 |
Document, Report, or Work plan Review - other |
Issuance of Permit #9221 -BA001 issued to Elmendorf AFB to replace Permit #8721 -BA025 |
Louis Howard |
| 10/30/1992 |
Update or Other Action |
It appears that Ship Creek is a gaining stream directly due south of the landfill LF59. The creek is thought to recharge the shallow aquifer upstream of the Davis Highway (now called Vandenburg Avenue) bridge and gain water from the aquifer down stream of the bridge. These relationships are generally confirmed by the stream flow data. On average, it would be expected that the stream loses 33 cubic ft./sec between the Fort Richardson diversion dam (located about 8 miles upstream of the mouth) and the Landfill Bridge (4.9 miles upstream of the mouth of the stream), and then gains 32 cubic ft./sec between the Landfill Bridge and the Elmendorf Power Plant (2 1/2 miles upstream of the mouth of the stream).
The gain in stream flow below the Landfill Bridge is of particular interest because shallow groundwater flow patterns suggest that at least part of the gain may be derived from shallow groundwater flow beneath OU1, OU2, and OU5 at Elmendorf AFB. To the extent that groundwater flowing beneath those might receive contaminants from those OUs, contaminated groundwater could discharge to Ship Creek and adversely affect the water quality of the creek. The increase in low flow of Ship Creek between the Landfill Bridge and the Power Plant could have three principal components: 1) Lateral groundwater inflow from the north side of Ship Creek. This inflow could contain contaminants generated at OU1 or OU5. 2) Lateral groundwater inflow from the south side of Ship Creek. This inflow would not be affected by contaminants generated at Elmendorf AFB. 3) Underflow representing water flowing essentially downstream within streambed deposits but with little or no surface expression.
Weeks (1970) concluded that of the 22 cubic feet per sec increase flow between the Landfill Bridge gage and Post Road, approximately 11 cubic feet per sec could be attributed to surface runoff from the drainage area below the Landfill Bridge gage. The remaining 11 cubic feet per sec in stream flow gain is the result of INFLOW of groundwater from the aquifer recharge area UPSTREAM of the Landfill Bridge gage. Jacobs conducted two seepage run investigations in October 1991 and September 1992. For comparison, Weeks conducted six seepage run investigations from September 1968 and March 1969. All of Weeks data was from the Landfill Bridge gage and a measuring point at Post Road, which is about 1 mile downstream of the Elmendorf Power Plant Gage. The Jacobs study suggested the component of groundwater flow at LF59 flows to Ship Creek. The remaining OU1 wells suggest that the flow is essentially parallel to the stream. There is no apparent component of flow from the stream to the aquifer. Thus the Weeks (1970) data which observed a decrease in stream flow UPSTREAM of the Davis Highway Bridge may reflect mostly a loss to UNDERFLOW in the downstream direction rather than a lateral recharge to the shallow groundwater aquifer beneath the landfill area. |
Jennifer Roberts |
| 10/31/1992 |
Update or Other Action |
Aquifer testing was performed in wells at OU1 during October 1992. Slug tests were performed to determine aquifer properties essential to contaminant transport modeling efforts. A pumping test was also performed at OU2 (Base Well 42) to evaluate the potential for contaminant migration to occur across the bootlegger cover formation and into the confined aquifer. However, due to the extremely rapid responses observed in some wells, a pneumatic testing device was used to create a larger initial displacement of water column within selected wells. This larger displacement allowed the data logger to record a more representative aquifer response around that well.
A total of 37 slug tests were performed at 18 out of 20 monitoring wells at OU1. LF05-MW07, LF05-MW13, and LF05-MW07 were heavily contaminated and no slug tests were done. Of the 37 tests, 9 slug tests produced errant data resulting from either improper test procedures or lack of significant displacement by which to monitor recovery. Of the 37 tests, 15 pneumatic aquifer tests were performed and of the 15 two tests exhibited data to which the data logger had not been initially programmed correctly.
For the pumping test, Base well 42 was used and three observation wells were used: St20-MW12, ST20-PZ01, ST20-PZ02. The hydraulic conductivity inferred from the test data ranged from 280 to 400 feet per day. The mean was 340 feet per day. The estimated storativity ranged from 0.004 to 0.08. Hydraulic conductivity values are substantially lower at LF59 than at LF05. LF59 range from 4.2 to 60.4 ft. per day and at LF05 it ranges from 27.4 to 463.2 ft. per day. Groundwater flows generally west and across the LF05 area, roughly parallel to Ship Creek, and then southwesterly toward Ship Creek at LF59. Average water-level gradients are about 0.0037 foot per foot across LF05 area and about 0.0064 at LF59. Geometric mean hydraulic conductivity for LF05 is 175 ft. per day, and LF59 is 18 ft. per day. Average specific discharge across LF05 is 0.65 foot per day and LF59 is 0.12 foot per day. |
Jennifer Roberts |
| 11/20/1992 |
Meeting or Teleconference Held |
Technical Review Committee meeting held to discuss overview of the regulatory process and status update on environmental cleanup activities on base. |
Jennifer Roberts |
| 12/11/1992 |
Update or Other Action |
Environmental Restoration Program, LF59, Operable Unit 1, Site Characterization Summary,
Informational Technical Information Report, December 1992 received. The characterization included drilling 25 exploratory soil borings and installing six groundwater monitoring wells and two piezometers. Fifty-five soil samples were collected for selected analyses including VOCs and metals. The study indicated that the tar/asphalt detected could have been buried in place at the time of the closure of the asphalt plant. The study verified three potential source areas: the Tar Seep Area, a potential landfill disposal area located around the north entrance to the jogging trail, and a potential disposal area along the western extent of LF59. |
Jennifer Roberts |
| 3/1/1993 |
Update or Other Action |
WMPLUME Modeling results received. In order to aid in the interpretation of contaminant transport through the shallow groundwater aquifer at OU1, a model of the system has been developed. The model is intended to help describe contaminant transport in the groundwater system, to provide estimates of contaminant concentrations at potential points of receptor contact, and to provide a tool for subsequent analyses of remedial alternatives that might involve groundwater extraction or control.
The model of the OU1 groundwater system is based on an analytic model of two dimensional contaminant transport from a continuous point source in a uniform groundwater flow regime. The specific program used was WMPLUME, written by M.S. Beljin of the International Ground Water Modeling Center (Beljin, 1985). WMPLUME includes advective transport, hydrodynamic dispersion, retardation of solutes due to sorption/desorption phenomena, and decay of solutes due to biological or chemical reactions. The program can apply superposition of multiple sources to
simulate areal contaminant sources or the effects of source cleanup. The model output consists of simulated solute concentrations at nodes of a grid within the groundwater
flow regime downgradient of the simulated contaminant source.
The input parameters needed for the model include the specific discharge (sometimes called Darcy velocity), effective porosity, aquifer thickness, longitudinal and lateral dispersivities, retardation factor, decay constant (related to the contaminant half-life),
point source strength, and elapsed time of source activity. The OU1 model, as originally developed and calibrated, applies only to the area downgradient of the landfill cell located immediately northeast of contaminant source area LF07.
During the calibration process, the effective porosity, aquifer thickness, retardation coefficient, and decay factor were not varied. Initially, the specific discharge was held constant, but a reasonable fit to the field data could not be obtained until the
specific discharge was increased to 0.75 ft/day. The principal parameters varied during the calibration were dispersivity, source strength, source duration, and, as noted above, specific discharge. The simulated concentrations of 1,1-DCA were most sensitive to specific discharge and dispersivity values, once the source duration had been reduced to 5 years from 10 years.
Reasonable simulations were obtained for all of the chemicals considered except acetone. Acetone was observed at 250 ug/L at well LF05-MW11, near the landfill cell, and at 120 ug/L at well LF05-MW03, about 900 feet further downgradient. Acetone was not detected at any other wells downgradient of the landfill cell. The rapid decrease in acetone concentration both longitudinally and transversely away from the assumed source at the landfill cell suggested that phenomena other than advection, retardation, and dispersion were influencing the attenuation of acetone concentrations. Consequently, a series of calibration runs were made in which contaminant decay was also considered.
Both the source strength and decay constant were varied until the model simulation matched the observed data fairly well. However, since acetone was only detected at two wells, and one of those wells is closer to the source than the minimum distance required for the error to be less than 3 percent, the calibration to acetone is not considered very reliable. The exercise does indicate that, given sufficient data for model calibration, decay phenomena can also be incorporated into the model. |
Jennifer Roberts |
| 3/5/1993 |
Update or Other Action |
USAF Joe Williamson sent Jennifer Roberts (ADEC) letter regarding the Data Quality Problems study. Elmendorf has concluded its study of the data quality problems that were identified in the Weston SW8010 and SW8020 processes for analysis of some samples from Elmendorf Operable Units (OUs) 1 and 2. After the laboratory procedures were more closely evaluated during a conference call on 16 Feb 93 with EPA, PRC, AFCEE, MITRE and the Air Force, it was determined that the errors noted in the lab procedures were limited to a small amount of the total data developed.
Additionally, method 8240 procedures had been performed on most of the'samples for OUs 1 and 2 and provide a backup check for those samples. Attached is a letter from Jacobs Engineering which details their analysis of this situation and the procedures they used to generate valid risk information at OU1. OU2 sampling and risk assessment procedures will be addressed in a future letter.
2. Based on the results of the discussions and analyses of the data packages, the Air Force proposes the following:
a. because methods SW8010/8020 and SW8240 have provided enough information on contaminants in groundwater, surface water, soils and sediment to evaluate the risk at OU1, no further sampling will need to be done there to complete the Remedial Investigation and Feasibility Study. Groundwater monitoring will likely be a major component of the Remedial Action at the area and this will supply additional data for continued source evaluation.
b. Method by method and sample location by sample location procedures will continue to be used to ensure that all source areas are assessed for appropriate risk factors based on the contaminants of potential concern at each area.
c. The entire OU1 area has been limited to nonresidential uses in the past and will be zoned only for that use in the future. This should reduce the risk factor and the level of cleanup required for the entire area in the future. Jacobs has advised Elmendorf that they also have SW8240 data for samples from OU2.
Elmendorf will also be developing a method for the use of this data to support decisions for work on OU2. This information should be available for your review by 10 Mar 93. |
Jennifer Roberts |
| 3/26/1993 |
Update or Other Action |
DOD and ADEC joint Technical Memorandum of Understanding (MOU) signed concerning the Base wide Groundwater (GW) and associated groundwater contamination signed by: ADEC Jennifer Roberts RPM and USAF Joseph Williamson Chief Environmental Programs & Restoration. Due to the base wide GW study and the FY92 field work that occurred at Operable Units (OUs) 1, 2, and 5 it appears a large portion of the GW flows into OU5 (attach. 1-contour map).
Based on this fact, Elmendorf (EAFB) will move all upgradient GW into the OU5 Feasibility Study, Proposed Plan and Record of Decision (ROD). This means addressing all GW from upgradient sources (CERCLA (ST20, OUs 3 and 4) and OUs 1 and portions of OU2) and SERA) at OU5 instead of at each individual source area (see attach. 2-Area Map). Sites with free phased product would be looked at to see if there is an available technology to clean them up in a cost effective way. 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. 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...). |
Jennifer Roberts |
| 6/28/1993 |
Update or Other Action |
EPA sent a letter regarding Project manager changes pursuant to paragraph 9.1 of the FFA. Christopher Cora will replace Michele Poirier-McNeill as Project manager for Operable Unit 1 and serve as alternate project manager for OU2, OU3, OU4, OU5, OU6 and OU7 which is served by Marcia Combes. |
Jennifer Roberts |
| 7/2/1993 |
Document, Report, or Work plan Review - other |
The Alaska Department of Environmental Conservation ("the Department") has completed its review of the OU1 draft Remedial Investigation (RI) Report. The document does not adequately explain and address the issues related to data validation protocols. The document should explain any deviations or modifications to the data validation protocols that are listed in the Management Plan. These deviations should also be addressed when analytical methods, 8010 and 8020, are used for risk assessment evaluations.
The Department is concerned with the high levels of manganese found in the groundwater. It is the Department's opinion that the RI does not adequately address the possible
origin of the manganese. The manganese occurs in a limited area at very high levels beyond established background and exceeds acceptable human health risk levels. Jacob's must evaluate the possibility of landfill leachate products creating changes in naturally occurring soil and groundwater chemistry to allow manganese to become mobilized.
The ecological risk assessment is an area of special concern for the Department due to the potential impacts to Ship Creek. As stated in a June 1993 scoping meeting, DEC and U.S. Fish and Wildlife Service are currently organizing a Biological Technical Assessment Group (BTAG) to bring all concerned natural resource trustees, regulatory agencies and local government together to evaluate the impacts to Ship Creek. The Department will submit our initial comments at this time but reserves the right to submit additional comments based on the cumulative input of the Ship Creek BTAG.
The Department has multiple concerns about methodologies and assumptions used in the
ecological risk assessment which will be listed in greater detail in the specific comment area. The ecological risk assessment utilizes many "screening" type methodologies which, though conservative, are not definitive but act as indicators. The ecological risk assessment evaluates each contaminant of concern separately and does not address the combined cumulative effects.
Exposure models for the landfill area indicates that several ecological receptors are at risk. These risk results are then discounted by claiming that the models utilized overly conservative exposure assumptions. These conclusions need to be supported with additional information and analysis. The hazard quotient does not delineate from hazard quotients derived from no-effects levels and those from acute-effects levels. This creates confusion when evaluating assessment endpoint in context to the measurement endpoint.
Monitoring well data indicated that there was difficulty in developing the wells to the acceptable levels of turbidity. Of the 20 wells developed only 2 wells produced water with mephelometric (NTU) levels less that 5 units. Multiple wells produced groundwater with NTU values over 100. High levels of turbidity may mask or reduce the actual concentrations of
volatile organic compounds (i.e. trichloroethene-TCE). Investigations in the outwash plain indicate the shallow aquifer has extremely high hydraulic conductivity values. Due to this fact it may be prudent to alter the purging volumes to only 1 or 2 casing volumes, since the water in the boreholes rapidly recharges and is unlikely to be stagnant. Also, more accurate results may be obtained if a slower method of purging and sampling is used. A submersible bladder pump with a low flow rate (less than one half gallon per minute) could replace the use of a bailer for purging and sampling.
See Site file for additional information.
|
Jennifer Roberts |
| 8/3/1993 |
Update or Other Action |
USAF Memo for the Record Subject: Backfilling IRA trenches with POL Contaminated Soil by Richard Howard Remedial Project Manager. 1. Today I spoke with Jennifer Roberts, DEC, and Marcia Combes, EPA, about levels of contamination that would be allowed in soil to be replaced in excavations at IRA site. They both agreed that any material that exhibited HNU readings up to 50 PPM could be replaced in the excavations, while material with higher readings would have to be stored on protective liners pending disposition as determined by a joint agreement between the RPMs. |
Jennifer Roberts |
| 8/11/1993 |
Update or Other Action |
USAF sent a letter regarding schedule extensions for Operable Units (OUs) 1 and 2. Pursuant to part XX of the Elmendorf Federal Facility Agreement (FFA), the Air Force is scheduling a 13 day extension for all future Secondary and Primary documents for OU1 and a 20 day extension for all future Secondary and Primary documents for OU2. The Alaska Department of Environmental Conservation (ADEC) requested a 10 day extension for comments on the draft Remedial Investigation and Baseline Risk Assessment for OU1, but the comments were not received by the Air Force until 13 days after the scheduled comment date. ADEC has also indicated a need to extend the review time for the draft Remedial Investigation and Baseline Risk Assessment for OU2 by up to 20 days.
The Air Force will therefore require schedule extensions for both of these OUs to allow adequate time to evaluate and respond to the ADEC comments and to develop subsequent documents. |
Jennifer Roberts |
| 8/12/1993 |
Update or Other Action |
USAF Memo for the Record Subject: Handling of IRA Construction Derived Waste by Richard Howard. 1. Today I contacted Jennifer Roberts, ADEC, and told her that Elmendorf had decided to utilize the POL-contaminated soil area at the landfill for storage of any construction-derived waste that exceeded an HNU reading of 50 PPM. This material would then be put into the biopile for the next treatment sequence. She said that this was acceptable, particularly since there is no evidence of any non-POL contaminants at the work site. Marcia Combes of EPA was also contacted and agreed with this arrangement. |
Jennifer Roberts |
| 8/16/1993 |
Update or Other Action |
Letter from Joseph Williamson (3 SG/CEVR) to Jennifer Roberts (ADEC) RE: Identification of State Proposed Applicable or Relevant and Appropriate Requirements (ARARs). 1. The Installation Restoration Program (IRP) at Elmendorf AFB is now reaching the point where decisions will have to be made at source areas, so it is necessary to identify all related State remedial requirements.
a. Section 121(d) of the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA), as amended by Superfund Amendments and Reauthorization Act, requires selected remedial actions to attain a degree of cleanup of hazardous substances, pollutants, and contaminants released into the environment and of control of further release at a
minimum which assures protection of human health and the environment. Such remedial actions shall be relevant and appropriate under the circumstances presented by the release or threatened release of such substance, pollutant, or contaminant. Section 121(d) further requires attainment of Federal ARARs and of State ARARs in State environmental or facility siting laws when the State requirements are promulgated, more stringent than Federal laws, and identified by the State in a timely manner.
b. According to Environmental Protection Agency Publication 9347-3-15, Compendium of CERCLA ARARs Fact Sheets and directives, as the support agency, the State is responsible for:
(1) Receiving and reviewing information about proposed Federal ARARs and to-be-considered's, as early as site characterization;
(2) Coordinating State input on ARARs from all State agencies;
(3) Identifying State ARARs during the remedial investigation/feasibility (RI/FS) study;
(4) Justifying proposed State ARARs; and
(5) Reviewing ARARs identified in the proposed plan and record of decision.
States are always responsible for identifying State ARARs and communicating them to the Federal-lead agency in a timely manner.
c. A critical point for identifying ARARs is during the scoping of the RI/FS. We have reached this point on the majority of operable units (OUs). To avoid an issue of "timeliness" and prevent a delay in the scoping process, we request the State identify its ARARs with justification for OUs 1 through 6. As lead agency, the Air Force is not legally required to consider potential State ARARs that are not identified in a "timely" manner.
d. To demonstrate that the State requirement is an ARAR, you are required by the National Contingency Plan to provide citations to the statute or regulation number. In addition, you
should provide the requirement's effective date and description of scope, where appropriate. Furthermore, you should provide evidence that the requirement is more stringent than the Federal
requirement. Finally, you should also describe in writing the relationship between the State requirement and the site or action, to show that the State requirement is applicable or
relevant and appropriate to that particular site or action.
2. Please provide the requested ARARs data so the information can be used to complete the required evaluations of the source areas in the previously-mentioned OUs.
-------------------------------------------
NOTE to the Database-EAFB FFA states: "Identification and Determination of Potential ARARs" 20.10 For those primary or secondary documents that consist of or include ARAR determinations, prior to the issuance of a draft document the Project Managers SHALL meet to identify and propose, to the best of their ability, all potential ARARs pertinent to the report being addressed. Draft ARAR determinations SHALL be prepared in accordance with Section 121(d)(2) of CERCLA, 42 U.S.C. S 9621(d)(2), the NCP, and pertinent written guidance issued by U.S. EPA and ADEC, that is not inconsistent with CERCLA and the NCP.
Also see: 20.11 In identifying potential ARARs, the Parties recognize that actual ARARs can be identified only on a source-specific basis and that ARARs depend on the specific hazardous substances, pollutants, and contaminants at a source, the particular actions proposed as a remedy, and the characteristics of a source. The Parties recognize that ARAR identification is necessarily an iterative process and that potential ARARs MUST be re-examined throughout the RI/FS process until a ROD is issued. |
Jennifer Roberts |
| 8/18/1993 |
Update or Other Action |
USAF Memo for the Record: Use of OU1 Gravel Pile for on-base projects. 1. Chris Cora,(EPA-Region X), stated that the VOC levels detected in the pile (.005-.008 mg/kg) were so low that there would be no problem associated with using the material on base. He asked why we were putting so much effort into getting EPA concurrance on this when the Region X office had already more or less stated there was no need to look any closer at the matter.
2. Chris said, if we wished, he would reply if we wrote a letter to him stating our intent and the way we would be utilizing the material. I said we would send a letter explaining these items. Signed Richard Howard Remedial Project Manager. |
Jennifer Roberts |
| 8/20/1993 |
Meeting or Teleconference Held |
August 20, 1993 meeting documented in memo from Rich Howard, Elmendorf AFB, Alaska regarding concurrence from regulators on OU1 gravel use.
1. During the regular Remedial Project Manager meeting today, the subject of base use of the OU1 gravel pile was discussed and all regulators, (Chris Cora - EPA, Seattle, Marcia Combes - EPA, Anchorage and Jennifer Roberts - DEC), agreed that the use of the gravel by the base for asphalt and basecourse applications was acceptable as a means of utilizing this resource that has been demonstrated to be non-harmful to the environment.
2. Letters were sent to the agencies stating the work intentions by the base for the material. |
Jennifer Roberts |
| 8/20/1993 |
Update or Other Action |
August 20, 1993 Memo from Chief, Environmental Programs and Restoration, Elmendorf AFB to ADEC, State of Alaska regarding use of OU 1 gravel pile for Elmendorf AFB construction projects.
1. Road and runway rehabilitation efforts at Elmendorf AFB require the use of a substantial amount of base-course gravel. The base proposes to utilize previously processed gravel now
located at Operable Unit 1. This gravel had been crushed and stockpiled by the Alaska Department of Transportation (DOT) in 1989. After testing of the gravel in 1990 revealed trace amounts 7 of volatile organic compounds (VOCs), the Alaska DOT decided not to utilize the material for scheduled construction work on Anchorage street projects.
2. Another sampling round from the gravel pile was analyzed for VOCs in the fall of 1992 and it revealed two traces of only one compound, (1,1,2,2,tetrachloroethane) at levels of .005 and .008
Parts Per Million (PPM). These levels are substantially below the Environmental Protection Agency Risk-based concentration of 3 PPM. Therefore, it appears that use of the gravel for on-base projects would pose no human health or ecological risk.
3. Elmendorf plans to use the gravel both in asphalt and as base material beneath asphalt paving at 8 separate locations on the base. This process will effectively encapsulate the gravel so that even the trace VOCs present would be completely immobile. This process would avail the base of the use of this material and pose no risks to the environment. Similar additional work will be done in the future with the remaining gravel until the supply
is exhausted. |
Jennifer Roberts |
| 9/2/1993 |
Update or Other Action |
Note from Rich Howard, Elmendorf AFB, Alaska, regarding notification of concurrence from USEPA and ADEC to utilize the Boniface gravel pile for base projects. On 20 Aug 93, 3 SPTG/CEVR received concurrance from EPA and DEC to utilize the "Boniface" gravel pile for base projects. Letters were sent to both agencies describing the work and the locations where the gravel will be utilized. No additional comments have been received from higher agency staff, so it appears at this time that approval for the gravel use will not be over-ruled. The gravel is now a resource to be used by the base as needed. |
Jennifer Roberts |
| 9/30/1993 |
Update or Other Action |
Contaminant source area LF05 covered roughly 17 acres and operated as a sanitary landfill from 1951 to 1973. Trench and fill procedures were used to dispose of general refuse, scrap metal, spent chemicals and other scrap materials. The trenches were generally excavated 14 to 16 feet below ground surface (bgs). Geophysical surveys suggest that the entire area was used as a landfill at various times.
Source area LF07, a 35-acre sanitary landfill, was operated from 1965 to 1982 for the disposal of base-generated refuse, scrap metal, construction rubble, drums of asphalt, empty pesticide containers, and small amounts of shop wastes. A portion of the landfill also received wastes containing asbestos until 1992. Two pits, each 30 to 40 feet deep, were operated using area fill methods.
Source area LF13, was a 20-acre gravel pit that was used as a disposal area for empty drums, metal piping, drums of asphalt, and small quantities of quicklime from 1967 to 1971. The site overlaps part of what had been previously identified as the southwestern portion of contaminant source LF05.
The Defense Reutilization and Marketing Office area, source area OT56, was used to store various materials, such as scrap metal and drums. However, it is not known how long the 2.5-acre area was in use.
In summary the area consisting of contaminant sources LF05, LF07, LF13, and OT56 encompasses an area of roughly 60 acres in the southeastern part of the base. The area has been used for past landfilling operations, waste disposal into old gravel pits, gravel production operations, and drum storage. Most of the area has been closed, covered, and revegetated, although miscellaneous debris, primarily construction rubble, is present at the surface in some areas. Various portions of the area were used for waste disposal operations between 1951 and 1993. |
Jennifer Roberts |
| 10/22/1993 |
Update or Other Action |
Dept. of Army Cold Regions Research and Engineering Laboratory, Corps of Engineers, CECRL-RC Memorandum for Sharon C. Stone, Remedial Project Manager, 3 SPTG/CEVR Subj: Peer Review for Operable Units 1 and 2 Elmendorf AFB.
CRREL review of OU 1 found no conspicuous concerns, This review was limited since no remedial investigation reports were available for reference. Even with all the limited data, CRREL
feels confident the U.S. Air Force is proceeding in a manner consistent with all applicable federal and state requirements.
Solid Waste Alternatives: In reviewing the State's newly proposed solid waste regulations, it appears this debris area could be classified as an inert disposal site, 18 AAC 60.435. If this interpretation is correct, the Air Force may not have to excavate and dispose of the material. Another excavation concern is testing. Is testing required? If so, how would it be accomplished for inorganics and PAHs since there are no readily available real-time screening mechanisms for these substances? |
Jennifer Roberts |
| 10/22/1993 |
Update or Other Action |
USAF 3 SG/CEVR (Joseph F. Williamson GS-12 Chief, Environmental Programs and Restoration) Letter to SOA DEC Jennifer Roberts SCRO subject: Identification of State Proposed Applicable or Relevant and Appropriate Requirements (ARARs).
1. The draft Remedial Investigation/Feasibility Study (RI/FS) report for Operable Unit 1 (OU1) on Elmendorf AFB was delivered to your office on 8 October 1993. The study for this OU is now
at the point where it is necessary for you to identify all related State remedial requirements. States are responsible for identifying State ARARs and communicating them to the Federal lead agency in a timely manner. Elmendorf had previously reminded you of this in our letter to you dated 16 August 1993.
2. To avoid an issue of "timeliness" and to prevent a delay in finalization of the RI/FS report, it is requested that the State identify its ARARs with justification for OU1. As lead agency, the Air Force is not legally required to consider potential State ARARs that are not identified in a "timely" manner.
3. To demonstrate that the State requirement is an ARAR, you are required by the National Contingency Plan to provide citations to the statute or regulation number. In addition, you
should provide the requirement's effective date and description of scope, where appropriate. Furthermore, you should provide evidence that the requirement is more stringent than the Federal
requirement.
Finally, you should also describe in writing the relationship between the State requirement and the site or action, to show that the State requirement is applicable or relevant and appropriate to that particular site or action.
4. Please provide the requested ARARs data so the information can be used to complete the required evaluations of the source areas for OU1. This information is required within 30 days of
the date you receive this letter. If you have any questions, please contact Richard L. Howard at 552-7507. |
Jennifer Roberts |
| 10/25/1993 |
Update or Other Action |
Modeling results from the OU1 Groundwater Leachate Model. In general, the process involves determining the soil contaminants at a given area, the distribution and retardation coefficients for each contaminant, the infiltration rate i, the dimensions L*L of the contaminated soil compartment, the specific discharge q and saturated thickness b, and the concentration Co of the contaminant in groundwater upgradient of the soil compartment.
Results indicate that the subsurface soil concentrations of ethylene dibromide (EDB) and methylene chloride could produce groundwater concentrations in excess of MCLs. Methylene chloride is a common laboratory contaminant, and was detected in samples from seven of the 14 boreholes for which data were collected above the water table. In only three boreholes was the average soil concentration high enough to result in predicted groundwater concentrations in excess of the MCL. Methylene chloride was also detected in samples from most of the other boreholes, but was qualified as being present in the associated lab blanks and thus was not incorporated into this analysis. EDB was detected in only one borehole.
Several other contaminants are present at soil concentrations that could result in groundwater concentrations in excess of PRGs. These include acetone, aldrin, MEK, 1,1-dichloroethene, 4-methylphenol, and 1,1,2,2-tetrachloroethane. With the exception of acetone, which like methylene chloride is a common lab contaminant and was frequently detected in lab blanks, these contaminants were detected in only one or two boreholes each. Acetone was detected in samples from six boreholes, but at a level sufficiently high to result in a predicted groundwater concentration in excess of the PRG in only one borehole.
LF59-The results of the analysis indicate that the subsurface soil concentrations of ethylene dibromide, methylene chloride, and 1,1,2-trichloroethane could produce groundwater concentrations in excess of MCLs. Methylene chloride is a common laboratory contaminant, and was detected in samples from six of the 10 boreholes for which data were collected above the water table. It was also detected in samples from most of the other boreholes, but was qualified as being present in the associated lab blanks and thus was not incorporated into this analysis. EDB and 1,1,2-trichloroethane were detected in only one borehole each.
Methylene chloride, and 1,1,2-trichloroethane, several other contaminants are present at soil concentrations that could result in groundwater concentrations in excess of PRGs. These include acetone, aldrin, MEK, chloromethane, 1,1,2,2-tetrachloroethane, and arsenic. With the exception of acetone, which like methylene chloride is a common lab contaminant and was frequently detected in lab blanks, the other organic contaminants were detected in only one borehole each. Arsenic was detected in all ten boreholes, and at levels sufficiently high to result in predicted groundwater concentrations in excess of the PRG in nine of the boreholes. |
John Halverson |
| 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 willconduct and finance the response action or assure that another party does soand 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 |
| 11/4/1993 |
Document, Report, or Work plan Review - other |
The Department has completed its review of the draft Remedial Investigation/Feasibility Study .
(RIIFS) for Operable Unit 1 (OU 1). Due to the concerns raised by Elmendorf pertaining to timely identitication of ARARs, the Department has paid additional attention to the ARARs proposed (Section 13.0) in this document. The comments related to state regulations should address your concerns regarding ARARs. Manganese-Throughout the document, manganese in groundwater is discounted as a risk. Recent ancl ongoing studies indicate that high levels of manganese may be a risk (see EPA comments). There is preliminary information that indicates manganese is released from its natural state in soil/aquifer media due to a chemical reaction caused by a change from the naturally occurring state clue to the presence of contaminants. The Department is not satisfied with how manganese was addressed in this document ancl suggests that a meeting be held between EPA, DEC and Elmendorf to address this issue.
Ship Creek Eco1oe;ical Impacts-The revised approach to the data gaps for the Ship Creek ecological study is satisfactory. The recommendation of additional study to resolve the data gaps is in line with the Department's comments on the RIIRA. The report did not elaborate on the scope of future studies for Ship Creek ani the associated Oxbow Lake. It may be possible to address some of these issues during the OU 6 ecological study. While the OU 6 ecological study will focus on the South side of Ship Creek, there does appear to be a large number of similar data needs between OU 6 ecological study and the OU 1 ecological data needs. The Department also recommends that the new formed Ship Creek Biological Technical Assistance Group be included in scoping the data needs for the additional information needed at OU 1.
Groundwater-The Department has noted previously that the state considers all groundwater a drinking water resource, regardless of depth. In several sections, the rational for acceptable risk was that the shallow aquifer was not in use as a drinking water source. There is no state regulation that precludes the shallow aquifer being used as drinking water. Therefore, the rational that the shallow aquifer is not used as drinking water is not an acceptable risk screening criteria.
Section 13.0. Potential Applicable or Relevant and Appropriate Reauirements (ARARs)-The section identifies the refined ARARs that would apply to OU 1. The Department proposes that 18 AAC 75.319 through 18 AAC 75.337 be applied to OU 1. The Department frequently uses the solid waste regulations (18 AAC 60) in conjunction with the Oil and Hazardous Substances Pollution
Control (18 AAC 75) regulations. The use of these regulations together is protective but allows flexibility in determining remedial actions, long term monitoring and site closure. The Department proposes that 18 AAC 70.010 (a) and (b) be considered to any potential discharges to Ship Creek and its associated water sources. Inclusion of the above regulations will address the ARARs that the Department considers applicable to OU 1. |
Jennifer Roberts |
| 12/7/1993 |
Update or Other Action |
USAFJoseph Williamson letter to Jennifer Roberts ADEC RE: Draft Final Remedial Investigation/Feasibility Study (RI/FS) for Operable Unit (OU) 1. 1. Attached is a copy of the Draft Final RI/FS for OU1. Please review and provide comments to this office by 22 Dec 93. Also attached are the Air Force responses to Alaska Department of Environmental Conservation (ADEC) comments on the draft RI/FS. The Air Force has addressed all of your comments in the preparation of the draft final of the RI/FS, except for the inclusion of proposed Alaska State Applicable or Relevant and Appropriate Requirements (ARARs).
2. In the ADEC comments dated 4 Nov 93, it was requested that Alaska Statutes 18 AAC 75.319 through 18 AAC 75.337 and 18 AAC 70.010 (a) and (b) be included as potential ARARs. It is the
Air Force's interpretation of the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) that requirements that meet the requisite ARAR criteria will be
included as potential ARARs if they are legally applicable or relevant and appropriate. In order to make that determination, we need you to provide the following information:
a. Identify all the cleanup sites at which proposed requirements have been applied and how they have been applied, specifically addressing the consistency issue, so we can determine if the proposed requirements meet the criteria. For a requirement to qualify as a potential ARAR it must be promulgated. A state requirement is promulgated if it is: (1) legally enforceable; and (2) of general applicability. See CERCLA Section 121(d)(2)(iii)(I) and 40 CFR 300.400(g)(4).
Although inconsistent application is a potential basis to waive an ARAR (CERCLA 121(d)(4)(E)), it is also a prerequisite for a requirement to qualify as an ARAR. The requirement must apply
to a broader universe than CERCLA/Superfund sites.
b. Provide an in-depth explanation of why each of these requirements is applicable or relevant and appropriate to OU1 in accordance with the definitions found at 40 CFR 300.5.
c. Quantify/qualify the standard in 18 AAC 70.010 (a) and (b). Is the cleanup standard to background levels, to the aquifer's original condition, to zero, or to not degrade the
ground water any further than its present condition?
On its face, the language appears to say that even if the ground water contamination is below published water quality criteria, it can not be degraded further. Also, please explain how the standard is determined for each site.
3. When we receive the required information, we may be able to include these proposed ARARs in the final RI/FS. Please provide the information as soon as possible to prevent a possible delay
in the preparation of the Proposed Plan and Record of Decision for OU1. If you have any questions, please call Richard Howard at 552-7507. |
Jennifer Roberts |
| 12/16/1993 |
Document, Report, or Work plan Review - other |
EPA sent Richard Howard (EPR 3 SC/CEVR) Elmendorf AFB a letter RE: Approval of OU 1 Draft Final FI/FS. EPA has completed the review of the Draft Final OU-1 Remedial Investigation/Feasibility Study Report (RIIFS) for Elmendorf Air Force Base. The agency does not find any significant issues which warrant delaying the finalization of the RI/FS. However, during my review of the document it became clear that certain issues could benefit from more discussion, to better convey the conclusions from the characterization of OU-1 and the need for potential remedial action alternatives. The document will also require an editorial review to correct areas of typographical or transcription errors. EPA will not be submitting specific comments on editorial changes.
EPA feels the following suggestions will improve the document and assist the Airforce in preparing future decision documents for OU-1. The Airforce, however, is not obligated to respond or incorporate these comments, pursuant to the FFA.
1. The data does not demonstrate the existence of defined, or consistent groundwater contamination plumes at OU-1. The depiction in chapter 5.0 of Manganese and BTEX plumes may imply that there is a clear and defined area of contamination which exists at the Site. The plumes may be an artifact of the computer program filling in data gaps. This possibility should be discussed and incorporated in chapter 5.0 and the in the risk management discussion.
2. The definition of baseline risk assessment presented in chapter 11 is not accurate. The purpose of the baseline risk assessment in the CERCLA process is to characterize the actual and potential risks posed to human health and the environment by a site. The definition presented on page 11-1 is appropriate for how project managers conduct a risk management evaluation, but not the purpose of the Baseline Risk Assessment.
3. The FS presents five remedial action alternatives for groundwater. EPA-does not recognize any practical difference between Alternative 11, No Action with long-term monitoring and Alternative III, Natural Attenuation with long-term monitoring. The coupling of Institutional Controls with Alternative III is equivalent to a Limited Action alternative, and may be appropriate, but not in conjunction with Natural Attenuation, as presented in the FS.
In certain site specific circumstances EPA recognizes the applicability of Natural Attenuation for remediation of groundwater. Those circumstances would require that the groundwater contamination be clearly definedi that an estimate of source volume be provided; and that a reliable estimate of the time required to achieve the remedial action objectives and/or cleanup levels be identified. These circumstances do not exist at OU-1.
In summary, EPA recognizes that the Airforce has satisfied the scope of investigations at OU-1. There rema.in areas, such as potential impacts to Ship Creek and the detections of manganese at OU-1 which still require investigations, .but these issues were not anticipated when the RI began and are common outcomes of large environmental investigations. The data in the RI/FS supports a number of conclusions:
1) That there are no current exposure pathways that pose an unacceptable risk to human health and the environment;
2) That there is not a clear source of contamination;
3) That the contaminants detected in groundwater are sporadic, cannot be linked to a distinct source, and, when detected, marginally exceed potential ARARs or risk-based levels; and
4) That there is no apparent aggressive remedial action measures that can be effectively and practically applied to the sporadic contamination problem in the groundwater. |
Jennifer Roberts |
| 12/22/1993 |
Document, Report, or Work plan Review - other |
ADEC sent review letter to Richard Howard HQ 3rd Support Group, Civil Engineering RE: OU1 Draft Final RI/FS. The department has completed the review of the Draft Final Operable Unit 1 (OUI)
Remedial Investigation/Feasibility Study Report (RI/FS), Elmendorf Air Force Base. The department has no significant technical issues pertaining to the RI/FS that would effect finalization of the document. A separate letter from the Alaska Department of Law was sent on December 20, 1993 addressing application of state regulations to OU1. However, on the technical side, there are several areas in the document that would-benefit from additional discussions. These areas pertain to the conclusions developed from the OU1 site characterization as they relate to the potential remedial action alternatives for compliance with CERCLA and the FFA.
The following areas would benefit from additional discussion in the RI/FS. While the department supports the inclusion of these discussions and clarifications in the final RI/FS, pursuant to the FFA, the Air Force is not obligated to respond or incorporate these comments in the final RI/FS. As we have discussed in meetings, the sampling data does not indicate the presences of clearly defined contamination groundwater plumes and conclusive contamination source areas at OUI. Sample data indicates the presence of sporadic groundwater contaminates (BTEX, VOA, manganese), but not well defined plumes. EPA has indicated that the plumes may be the result of the computer programs filling in data gaps. Inclusion of this information and an associated explanation in Section 5.0 and the risk management discussions in the FS would more accurately portray the site conditions pertaining to groundwater contamination.
There are five remedial action alternatives presented for groundwater. The department does not acknowledge any significant difference between Alternative II (No Action with long-term monitoring) and Alternative III (Natural Attenuation with long term monitoring). The use of two virtually identical alternatives makes the FS redundant, confusing and obscures the decision process.
Natural attenuation may be an applicable remedial strategy for other sites, however, application natural attenuation to OU1 is not practicable for the following reasons.
1) Application of natural attenuation to groundwater contamination is based on a clearly defined plume, OU1 lacks a clearly defined plume;
2) Application of natural attenuation needs to be tied into a specific definitive source area to calculate source contaminant volume, OU1 lacks definitive source areas;
3) Effectiveness of natural attenuation is based on definitive cleanup levels to be achieved within specific time limits, due to the sporadic and inconsistent nature of contamination at OU1, neither of these parameters can be applied or calculated.
The department agrees that the data in the RI/FS supports the following conclusions:
1. There are no current exposure pathways that pose an unacceptable risk to human health;
2. There are no clearly defined sources of contamination;
3. The contaminants detected in groundwater are sporadic and cannot be linked to specific source areas, and when detected, marginally exceed potential ARARS or risk-based levels.
The department acknowledges that with the finalization of OU1 RI/FS the Air Force will have addressed most of the investigative issues at OUI. It is the department's understanding that the remaining areas of concern will be addressed in the following manner:
1) Potential impacts to Ship Creek will be addressed by OU6,
2) Detection of manganese will be addressed in the proposed plan, and
3) Solid waste compliance issues, such as the tar seep at LF59 and other OU1 debris, will be addressed under the guidance of DEC solid waste compliance program. |
Jennifer Roberts |
| 1/4/1994 |
Update or Other Action |
OU1 consists of five contaminant source areas located in the southeastern part of the Base, near the intersection of Davis Highway & Second Avenue. These five areas are: LF05, LF07, LF13, OT56 & LF59. Four of the source areas (LF05, LF07, LF13, & OT56) are contiguous & are located northeast of the intersection of Davis highway & Second Avenue. Three of the source areas, LF05, LF07, LF13, include former subsurface landfilling operations.
Contaminant source area LF59 was not investigated before the 1990-1991 studies. However, the initial records search (ES, 1983) did identify a construction rubble disposal location (0-8) in the general area. Most of D-8 was located south of Ship Creek in a gravel pit area, but a small portion of the area was located north of the creek, possibly near the western edge of LF59. 0-8 was used from 1965 to at least 1983 to dispose of construction rubble, & construction rubble was noticed during soil boring operations in the summer of 1992. As of 1983, the location had not been closed (ES, 1983). There is no obvious connection between location 0-8 & source area LF59. However, the reported asphaltic material observed at LF59 might be construction rubble.
LF59 is located southwest of the intersection of Davis highway & Second Avenue, & was also subject to smaller-scale landfilling operations. In addition, residual tar-like material is present in surface & subsurface soils. The tar is believed to be related to past asphalt production in the vicinity of LF59.
Based on soil boring activities conducted during the summer of 1992, three potential source areas have been identified in LF59:
1) The Tar Seep Area. During the summer of 1992, the tar seep area was characterized by an exploratory drilling program (Jacobs, 1992) designed to delineate both the lateral & vertical extent of the tar. The data are discussed in Section 3.9. Based on the vertical & lateral estimates, a calculation of the estimated volume of the tar-contaminated area was made. The tar surface exposure area is estimated to cover more than 2,100 square yards, & the volume of tar-contaminated soil is estimated at 1 ,900 to 2,500 cubic yards.
2) Potential Landfill Disposal Area. This area is located around the north entrance to the jogging trail. This area was bored (LF59-BH08) because it had been delineated as an EM anomaly by HLA & interpreted as a potential disposal area. Boring LF59-BH08 encountered sanitary landfill debris to the bottom of the borehole at 17 feet bgs. The anomaly as delineated by HLA encompasses an area of approximately 3,900 square yards. It is assumed that this area is correct & the landfill cell is 17 feet deep, the volume of landfill material is approximately 22,300 cubic yards.
3) Potential Disposal Area. This area Is Identified by the EM survey located along the western extent of LF59. This area, encompassing approximately 5,900 square yards, was also identified as a potential landfill disposal area by HLA based on the EM survey. Two boreholes drilled directly into the anomaly encountered no landfill debris. Surface debris, Including broken concrete blocks, & surface disturbance were observed by Jacobs personnel during drilling operations just inside the tree line.
|
Louis Howard |
| 1/5/1994 |
Update or Other Action |
Model of the potential effects of groundwater discharge on Ship Creek water quality received. In order to provide estimates of potential contaminant concentrations in Ship Creek water, a model has been developed to simulate the transport of contaminants from individual monitoring wells to Ship Creek. The model is based on the assumption that each monitoring well can be taken to be an instantaneous point source of contaminants at the concentrations detected in fall 1992. The model incorporates retardation of contaminant transport due to sorption/desorption effects, hydrodynamic dispersion, and biochemical degradation of organic contaminants.
Two-dimensional mass transport from a point source in an aquifer with uniform groundwater flow has been described by Hunt (1978) and Wilson and Miller (1978). Accounting for retardation, dispersion, and degradation, the concentration distribution C(x,y,t) produced by instantaneous injection of mass per unit length m' at the origin of the x,y-plane at time t = zero is (Wilson and Miller, 1978).
The model was applied for two transport scenarios, transport with dispersion only and transport with dispersion and degradation. In addition, two scenarios of mixing with Ship Creek flow were considered, mixing with low flow and mixing with mean annual flow. The resulting estimates of contaminant concentrations in Ship Creek are then compared with minimum standards and criteria for three classes of potential exposure: acute exposure to aquatic organisms, chronic exposure to aquatic organisms, and human health criteria. Estimated contaminant concentrations under low flow conditions are most reasonably compared to the acute and chronic aquatic life criteria, since such criteria generally assume exposure times measured in hours and days, respectively.
Estimated contaminant concentrations under mean flow conditions are most reasonably compared to the human health criteria, since such criteria are based on ingestion of water or organisms and water, which would occur over longer periods of time during which streamflow characteristics will be best represented by mean annual flow rather than low flow.
In no case does the estimated contaminant concentration in Ship Creek exceed the minimum criterion for aquatic life, and in general the estimated concentration in Ship Creek is several orders of magnitude less than the associated criterion. When degradation of organic contaminants is taken into account (Table 4), estimated contaminant concentrations often approach several tens of orders of magnitude less than the associated criteria. In only three cases does the estimated contaminant concentration in Ship Creek for mean flow conditions exceed the minimum criterion for human health. These are arsenic transported from wells LF05-GW2A, LF05-W6, and LF05-GW2C. As noted below, arsenic is believed to be naturally-occurring in local groundwater. In general the estimated concentrations in Ship Creek for mean flow conditions are several orders of magnitude less than the associated criterion.
The estimated concentration of arsenic under low flow conditions exceeds the minimum human health criterion for most of the assumed source wells. However, the minimum standard is for human ingestion of water and aquatic organisms on a routine basis. Since Ship Creek is not now a drinking water supply source, and is unlikely to ever be one, long-term human ingestion of water and fish from the stream is extremely unlikely.
Furthermore, under long-term conditions, it is more appropriate to apply the estimated concentration in Ship Creek under mean flow conditions rather than low flow conditions. Finally, the presence of arsenic in groundwater at OU1 appears to be the result of natural background distribution of this element in the local soils and groundwater, and not the result of any sources of contamination at OU1.
Other contaminants that may exceed minimum standards for human ingestion under low flow conditions include aluminum from five wells and manganese from well LF05-MW04. Again, concentrations under low flow conditions do not represent concentrations that might be ingested on a long-term basis and thus are not appropriately compared with human health criteria. Manganese, like arsenic, is believed to be naturally-occurring in local groundwater (Section 5.4 of the RI/FS). The aluminum criterion is a secondary, rather than primary, drinking water standard. |
Jennifer Roberts |
| 2/4/1994 |
Risk Assessment Report Approved |
As part of the January 1994 Remedial Investigation/Feasibility Study the risk assessment was approved and went final on Feb. 4, 1994. LF59: No site-related non-carcinogenic hazards were identified in the LF05, LF07, LF13 LF59 and OT56 source areas assuming residential exposure conditions. There are 3 chemicals of potential concern (COPC) detected in groundwater (GW) are associated with carcinogenic risk exceeding 1 x 10-6 assuming either residential reasonable maximum exposure (RME) or average exposure conditions. These COPCs are arsenic, 1,2-dibromoethane and 1,1,2,2-tetrachloroethane. Arsenic is present at naturally occurring levels.
The only contaminants identified for GW at OU1 that were associated with risks exceeding this 1 x 10-6 excess cancer rate were 1,2-dibromoethane (EDB) and vinyl chloride (VC). All risks associated with EDB fall in the range of 1x10-6 to 1x10-4 with the exception of 1 well located within the landfill area. This well LF05-W5 exceeded the range by 10%. VC is associated with a risk of 2.2 x 10-5 at a single well LF05-MW10. For chronic exposure to non-carcinogens, only manganese, a heavy metal, exceeded the hazard index of 1.0 for both the residential and the commercial/industrial land use exposure scenarios. Manganese is present at naturally occurring levels.
The terrestrial risk assessment identified a potential environmental risk due to the presence of several heavy metals within the soils. These metals include cadmium, mercury, lead, and barium. Cadmium was found at only 1 surface soil sample location and appears to be an isolated "hot-spot". Mercury was detected in concentrations up to 0.26 mg/kg at 3 surface soil sample locations east of the Davis Hwy. and 2 locations west of the highway at OU1. Lead was detected in concentrations exceeding 25 mg/kg at only 2 locations east of the Davis highway and none to the west. Lead is believed to be an indication of isolated "hotspots". Barium was found in concentrations exceeding 150 mg/kg at 3 locations one east of the Davis highway and 2 to the west. Localized small mammal and passerine bird populations at OU1 may be at risk from ingestion of heavy metals. However, the exposure to heavy metals is expected to be limited.
Only one surface sample collected near the oxbow lake located just north of Ship Creek at LF59 indicated the presence of Total Petroleum Hydrocarbons at 1,600 ug/L. The ecological quotient for this sample was considerably greater than 1.0 indicating potential risk. Between 1984 and 1992, TPH was not detected in Ship Creek samples. It does not appear that TPH is being introduced to Ship Creek in detectable quantities due to groundwater discharge from the shallow aquifer.
Based on review comments from EPA and ADEC for the OU1 Ecological Risk Assessment, the screening level ecological risk assessment for Ship Creek needs additional data to further evaluate the degree of aquatic risks present at OU1. These additional studies will fill data gaps in the current ecological risk assessment so that an informed risk management decision regarding the degree of aquatic risk at the site may be provided. As a result, no risk management discussion will be presented for the surface water bodies of OU1 at this time.
As is the case with surface water, the ability to fully characterize the nature and extent of sediment contamination, based on the current data, is limited. The evaluation of ecological risk is therefore considered only a screening of potential toxicity. As discussed above, additional studies of Ship Creek are recommended by EPA and ADEC to further evaluate the degree of aquatic risk at OU1. These studies will include more detailed characterization of the potential toxic effects of the TFH concentrations in the sediments along Ship Creek. As a result, no risk management discussions will be presented at this time for the sediment medium at OU1.
The regulatory agencies have determined that insufficient data exist to support a risk management decision regarding the degree of aquatic ecological risk posed by the surface water and sediment contamination observed at OU1. EPA and ADEC recommended that decision regarding the degree of potential aquatic risk in Ship Creek be deferred until additional studies can be performed at the site. Therefore, the scope of the OU1 FS does not include an evaluation of potential remedial alternatives applicable to either the surface water or sediment medium. Subsequent decision documents (e.g., Proposed Plan, Record of Decision) will provide the rationale for an interim remedy for these media. |
Jennifer Roberts |
| 2/4/1994 |
CERCLA RI Report Approved |
January 1994 OU 1 RI/FS Final report received. Source areas LF05 (17 acres), LF07 (35 acres), LF13 (20 acres), OT56 (2.5 acres), LF59 (2.5 acres). A records search conducted in 1991 indicated that an asphalt batch plant may have been located in the LF59 area during some of the period between 1950 and 1965. This is consistent with the large, and apparently continually growing, areas of tar seeping to the surface in the area.
There is also an area of apparent past trench & fill activities in the central western portion which may be expected to be associated with a variety of contaminants. The tar surface exposure area is estimated to cover more than 2,100 sq yds, & the volume of tar contaminated soil is conservatively estimated to be between 1,900 to 2,500 cyds.
GW flows generally west and across the LF05 area, roughly parallel to Ship Creek, & then southwesterly toward Ship Creek at LF59. The average water-level gradients are about 0.0037 foot per foot across the LF05 area, & about 0.0064 at LF59. The geometric mean hydraulic conductivity for LF05 is 175 feet per day, & for LF59 is 18 feet per day. Consequently, the average specific discharge across LF05 is 0.65 foot per day, & at LF59 is 0.12 foot per day.
Only one surface water sample, collected near the oxbow lake located just north of Ship Creek at LF59, indicated the presence of TPH (1,600 ug/L). NOTE TO FILE SW Quality Standards for TAH = 10 ug/L and TAqH = 15 ug/L.
OU1 Risk Mgt Evaluation: "Soil. The HHRA specifically evaluated the potential human health and environmental risks posed by surface soil alone. No risk assessment was performed for subsurface soils because of the nature and level of observed levels of the contaminants found at OU1. However, the potential for subsurface soils to serve as a potential source of GW contamination (e.g., leaching of contaminants through the landfill cells to the water table) is discussed in this FS."
NOTE TO FILE: the assumptions in the RI for OU1 subsuface regarding risk evaluation from contaminants is no longer relevant due to changes in regulation and maximum allowable concentrations for petroleum contaminants per 18 AAC 75.
OU1 rapid screening results: organic contaminants found to exceed applicable standards at LF59 are:
LF59-EXP-BH-01-R 3-5' bgs (taken from LF59-EXB-F2-3D-R) Total extractable petroleum hydrocarbons-gasoline at 28,000 mg/kg, (MAC 2012 1,400 mg/kg) AND totla xylenes 870,000 mg/kg (MGW 63 mg/kg and DIRECT CONTACT 20,300 mg/kg), Lube oil 17,000 mg/kg (10,000 mg/kg RRO ingestion 2012)
LF59-BH01-0 lube oil (RRO) was detected at 16,000 mg/kg,(10,000 mg/kg RRO ingestion 2012)
LF59-BH02 6' bgs diesel range organics 35,000 mg/kg
LF59-BH02-06 (AWT sample collected Above the Water Table) Lube oil: 16,000 mg/kg (10,000 mg/kg RRO Ingestion) and 1,2-dibromomethane 52 ug/kg,(Table B1 Method Two MGW 0.16 ug/kg),
LF05-BH04-35 35' bgs TPH-Diesel at 4,500 mg/kg, (250 mg/kg DRO MGW)
LF59-BH01-4 TPH-Diesel at 1,800 mg/kg and (250 mg/kg DRO MGW)
LF59-BH-5-0 TPH-Diesel at 1,100 mg/kg, (250 mg/kg DRO MGW),
LF59-MW05-9.5 (AWT): 1,1,2-trichloroethane 2.2 mg/kg (Table B1 Method Two MGW 0.18 mg/kg), MIBK 10 mg/kg (MGW 8.1 mg/kg)
Lead in soil at LF05 and LF59 was addressed with the Biokinetic Uptake Model (BKU) so lead exposure could be modeled on a site specific basis. This approach was taken instead of EPA Region X Supplemental RAG for Superfund (August 1991b) does not provide a RBC for lead. Using lead levels detected above background, BKU modeling determined that 0.3 percent of the resident children are estimated to have blood lead levels above the level of concern (10 ug/dL). A result of 5% or more would have indicated that a health hazard from lead exposure exists. Therefore, lead will be eliminated from further consideration in Nature and Extent of Contamination in this RI/FS.
LF59:
LF59-MW02 – GW had 1,1,2,2-tetrachloroethane at 12 ug/L (2012 Table C 4.3 ug/L) & TCE at 6.3 ug/L (Table C 5 ug/L).
LF59-MW03 had 1,1,1 DCA at 6/6.2 ug/L & 1,1,2,2 PCA at 9/5.8 ug/L.
LF59-GW-2C-C had EDB at 0.15 ug/L (Table C 0.05 ug/L)
LF05-GW-2C had benzene at 10 ug/L (Table C 5 ug/L) Detection of Arochlor 1260 was only evident during the fall 1991 sampling & the BEHP & vinyl chloride detects were only present during the fall 1992 sampling event.
At downgradient locations within LF59: methylene chloride, 1,1 DCA, TCE, 1,1,2,2 PCA, 1,1,1 TCA, 1,2 dibromoethane, ethylbenzene, xylene, & dalapon were present at levels that exceed upgradient levels. The contaminants that were detected in excess of upgradient levels & exceed MCls include TCE and 1,1 ,2,2 PCA. |
Jennifer Roberts |
| 2/28/1994 |
Update or Other Action |
EPA sent comment letter on the Draft Proposed Plan for OU-1. The Environmental Protection Agency (EPA) has reviewed the Draft Proposed Plan for OU-1, submitted on January 27, 1994.
This document was submitted pursuant to § 20.7 of the Federal Facility Agreement for Elmendorf Air Force Base, as a secondary document. The Proposed Plan is a secondary document and
finalization therefore is not required until the corresponding draft final primary document is issued. However, there is no corresponding primary document in regards to the proposed plan.
Therefore, EPA's only recourse, pursuant to the FFA and E.O. 12580 would be not to concur on the preferred alternative. EPA does not intend to pursue that course of action, at this time, because the three respective Project Managers have been rewriting the proposed plan to meet each agencies needs. This process is proceeding well and currently the amended draft proposed plan is being reviewed by EPA.
However, pursuant to notification requirements of the FFA, EPA is notifying the Air Force that the original deliverable was unacceptable for numerous reasons, one of which is that it did not reflect comments submitted on the draft final remedial investigation/feasibility study report.
EPA anticipates submitting final comments on the draft proposed plan no later than March 18, 1994, as agreed upon during our January 12, 1994 meeting. |
Jennifer Roberts |
| 4/4/1994 |
CERCLA Proposed Plan |
Public comment period for OU1 Proposed Plan 4/4/94 to 5/3/94. The proposed plan states that the contaminants in the surface and subsurface soils at OU1 do not exceed EPA risk criteria based on the residential land use scenario and would not cause any unacceptable adverse health effects for humans. Main contaminants of concern in the shallow groundwater are metals and volatile organic compounds. Certain non-hazardous materials (such as solid wastes) are being addressed under separate Base cleanup programs outside of CERCLA. Such materials include the tar seeps at LF07, LF13, and LF59.
Tar is not contributing to the groundwater contamination at the source area. The tar is considered a solid waste and will be addressed under Alaska solid waste regulations (18 AAC 60). Other non-hazardous materials exist, such as scrap metal found along the ground surface at OU1 and the closure requirements for the OU1 landfills themselves fall under 18 AAC 60.
The preferred alternative selected for groundwater is long term monitoring, institutional controls and monitored natural attenuation. There is no current human exposure in the shallow groundwater. The groundwater monitoring program will provide an early warning of any increase in concentrations or movement of manganese. Existing land use controls will ensure no current exposure to shallow groundwater. Institutional controls and required property transfer provisions of CERCLA will ensure that there will be no exposure to shallow groundwater in the future. Elevated levels of manganese appear to be isolated within a limited area and are not anticipated to migrate.
The compounds in the groundwater that exceed federal acceptable risk ranges are: 1,2-dibromoethane, arsenic, manganese and polychlorinated biphenyl (PCB). Risks associated with arsenic are slightly above background concentrations for the base, and therefore do not appear to be site related. Only manganese was found to be consistent and widespread throughout the site.
The elements of the preferred alternative for OU1 are:
* institutional controls;
* monitoring groundwater for five years, or until the groundwater poses an acceptable health risk;
* five-year review to assess the protectiveness of the remedial action; and
* periodic evaluation of monitoring results to determine if there is need for further remedial action. |
Jennifer Roberts |
| 4/21/1994 |
Meeting or Teleconference Held |
7:00 PM Public meeting held to discuss the remedial action alternatives and to take comments on the Proposed Plan for Final Remedial Action at Operable Unit 1. Federal Building Room 137, 222 West 7th Avenue, Anchorage, Alaska. |
Louis Howard |
| 5/9/1994 |
Update or Other Action |
Letter from USEPA Randall Smith Director of Hazardous Waste Division RE: Emergency Permit Elmendorf Air Force Base AK8570028649. The permit is an emergency permit to treat hazardous waste munitions at EAFB's Open burning/open detonation (OB/OD) units. Munitions are highly reactive and if not treated, pose an imminent and substantial endangerment to human health and the environment. Due to this situation, EPA, in conjunction with the Alaska Dept. of Environmental Conservation, hereby issue Elmendorf AFB an emergency permit for a duration of 90 days to treat these highly reactive materials. Permit will be in effect on May 10, 1994 and expire on August 7, 1994.
In addition to allowing for the treatment of these highly reactive munitions, the permit requires sampling of the existing ground water wells, submittal of a plan for installation of two additional ground water monitoring wells, submittal of a plan to perform soil characterization, submittal of a plan to perform an environmental assessment and submittal of a closure plan to address closure upon termination of the emergency permit. |
Louis Howard |
| 5/31/1994 |
Update or Other Action |
AF (P. Coullahan Lt. Colonel) sent a letter to Janice Adair re: Notice of Violation closure-information memorandum. Additional information was included with letter needed to close NOV #4a which was issued to the Air Force on January 14, 1994. It included a discussion of the problem and the solution, and attachment 2 provides the analytical test results for soil samples and a location map.
Originally, the violation was for failure to make a hazardous waste determination on residue from the open detonation craters. Results showed detectable levels of metals were attributable to typical background soil concentrations. Risk assessment will be conducted as part of the Elmendorf Emergency Open Burning/Open Detonation (OB/OD) permit. Location of OB/OD operations on the Base is in the northern portion off of Loop Road east of Lake Beebe. |
Janice Adair |
| 7/25/1994 |
Update or Other Action |
EPA sent comments on the Draft Record of Decision (ROD) for OU-1 to Lisa Morris 3 SPTG/CEVR. The ROD was well written and EPA concurs with the selected remedy. However, the ROD will require revisions to satisfy the requirements of the NCP. The enclosed comments address these revisions. 2.1; Discuss the following characteristics in the ROD: Wetlands, floodplains, rarelendangered species, and historical preservation. This is necessary to ensure that the NCP process is functionally equivalent to the NEPA process.
2.1, OT56 discussion; discuss whether OT56 is still in use and what it's RCRA status is.
2.1 p. 14, 2nd P.; The last two sentences are confusing. A suggested solution would be: "Surface water from Ship Creek has been used extensively at EAFB for a number of years. Much of the surface water collected is used for industrial .....
p.20, last P. When stating that the "RI did not identify a source of Manganese, provide information on whether the RI looked for a source of Manganese. Language could be inserted which
shows that "increased levels of manganese were not detected until the last round of GW monitoringI1 This should lead into our premise that the manganese is naturally occurring from background soil concentrations and is being mobilized by the reduced groundwater chemistry locally influenced by disposal cells, septic systems, or even a natural event.
A paragraph should be added on the uncertainty of the problem, and a figure (figure 3) which shows the disposal cells and other llsourceslaln d the elevated manganese. It would also be appropriate to discuss the latest results of groundwater monitoring which the Air Forces has done. (If it has been done).
2.7 p.24 & 25; Since capping and containment are presumptive remedies for landfills in the CERCLA process there should be a rationale for why capping and containment would not work. For instance: ill defined disposal cells, valuable habitat would be lost, State program for solid waste (probably not a preferred rationale) no risk or significant source of leachate, cost, etc. There should also be a similar discussion on why disposal, removal, and reclamation were not pursued.
2.8.1, 2nd.P.; EPA considers the Safe Drinking Water Act as an MCL for OU1. EPA will provide additional information for this position during our project manager discussion of comments. At this time EPA does not see this ARAR as requiring a waiver or altering the selected remedy, but text alteration may be required. |
Jennifer Roberts |
| 9/27/1994 |
Update or Other Action |
Air Force letter to EPA. Language submitted in your letter of September 9, 1994 will be incorporated into Section 2.10.2 Page 40 of the ROD. The Air Force concurs with comments submitted by the Environmental Protection Agency and is in the process of revising the Draft Final ROD accordingly. |
Jennifer Roberts |
| 9/29/1994 |
Cleanup Level(s) Approved |
Record of Decision (ROD) identified elevated levels of volatile organic compounds (VOCs) and manganese are occurring in the shallow groundwater beneath the site, if not addressed by implementing the response action selected in the ROD, it may present an imminent and substantial endangerment to public health, welfare or the environment.
Contaminants and cleanup level in groundwater: 1,2-Dibromoethane (0.05 ug/L), Manganese (9,100 ug/L), trichloroethylene-TCE (5.0 ug/L) and vinyl chloride (2.0 ug/L). |
Jennifer Roberts |
| 9/29/1994 |
CERCLA ROD Approved |
ROD signed on 9/29/94 for five general waste disposal areas LF05, LF07, LF13, LF59 and OT56 located near the Davis Highway. Elevated levels of manganese are occurring in the shallow groundwater beneath the site, if not addressed by implementing the response action selected in the ROD, it may present an imminent and substantial endangerment to public health, welfare or the environment. Major components of the selected remedy are:
1) monitoring groundwater for five years or until groundwater no longer poses an unacceptable health risk;
2) five year review to assess the protectiveness of the remedial action;
3) periodic evaluation of monitoring results to determine if there is a need for further remedial action;
4) maintaining institutional controls specifically aimed at restricting access to the shallow aquifer.
Because the remedy will result in the continued presence of hazardous substances on the site above health-based levels, a review will be conducted within five years of commencement of the remedial action, to ensure that the remedy continues to provide adequate protection of human health and the environment.
Soils do not require any action under CERCLA. therefore the ROD memorialized a no further remedial action required for soils only under CERCLA. However, the soils will be addressed under the state's solid waste program (18 AAC 60) to deal with the tar seeps at LF07,LF13 and LF59.
The OU1 groundwater contaminants of concern (COCs) identified in the RI/FS and addressed in the selected remedy are EDB, manganese, trichloroethene (TCE) and vinyl chloride. The cleanup goals for EDB, TCE, and vinyl chloride are based on Maximum Contaminant Levels (MCLs). A background concentration of 9,100 micrograms/liter (ìg/L) was established as the manganese cleanup goal, because there is no primary MCL established.
Alaska Oil Pollution Regulation (18 AAC 75). Under the Alaska Oil Pollution Regulations, responsible parties are required to cleanup Oil of Hazardous Substance releases. Due to the sporadic, infrequent nature of groundwater contaminant sample results and the lack of source areas, it is the general opinion that the groundwater contaminant trend is decreasing in
concentration through time. Under 18 AAC 75.327, the ADEC has the authority to determine alternative cleanup standards for groundwater. In accordance with this requirement, the purpose of the monitoring is to verify that groundwater contaminantion is decreasing and will meet acceptable human health risk levels and Safe Drinking Water standards within an acceptable time
limit, which is expected to be five years from initiation of the monitoring program. |
Jennifer Roberts |
| 9/29/1994 |
Long Term Monitoring Established |
The main contaminant of concern (COC) is manganese (Mn), however, there are other contaminants that exceed federal acceptable risk criteria: 1,2-dibromoethane, trichlorethylene (TCE), vinyl chloride, arsenic, and PCBs. Arsenic is slightly elevated above Elmendorf Air Force Base (EAFB) background levels for groundwater (GW) at the facility. Subsurface and surface soil contamination does not exceed federal risk criteria. Groundwater monitoring program will provide early warning of any increase in concentrations or movement of manganese. Existing land use controls will ensure no current exposure to shallow GW.
Institutional controls (ICs) and required property transfer provisions of CERCLA will ensure that there will be no exposure to shallow GW in the future.
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 alter-natives:
(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.
Elevated levels of Mn appear to be isolated within a limited area and are not anticipated to migrate. The source of the Mn is uncertain. There is no current (as of 9/29/94) exposure to Mn in the shallow groundwater.
Major components of the selected remedy: ICs, monitoring GW for five years, or until the GW poses an acceptable health risk, five year review to assess the protectiveness of the remedial action and periodic evaluation of monitoring results to determine if there is need for further remedial action. Remedial action goals will have been met when GW concentrations have been met for 1,2-dibromoethane (0.05 ug/l), Mn (down to background levels of 9,100.0 ug/l), trichloroethylene (5.0 ug/l) and vinyl chloride (2.0 ug/l). |
Louis Howard |
| 9/29/1994 |
Conditional Closure Approved |
No further remedial action required for the surface and subsurface soils only. Groundwater will require long term monitoring until cleanup levels specified in the Record of Decision (ROD) are achieved. Action was established when the ROD was signed for Operable Unit (OU)1. |
Louis Howard |
| 10/7/1994 |
Update or Other Action |
Air Force sent a memorandum letter to EPA RE: Remedial Design/Remedial Action (RD/RA) Statement of Work (SOW) for OU-1. Per our conversation late last month (September 1994), the RD/RA SOW for OU1 is not necessary due to the limited scop of action being taken. A SOW for Long Term Monitoring at OU1 will be submitted for your review and coordination at a later date. |
Jennifer Roberts |
| 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 (TCE) 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 after 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. |
Jennifer Roberts |
| 2/25/1995 |
Meeting or Teleconference Held |
Restoration Advisory Board Meeting held and advertised beforehand in the Anchorage Daily News 2/12/95 and Sourdough Sentinel on 2/17/95. |
Louis Howard |
| 5/17/1995 |
Cleanup Plan Approved |
Remedial Action Plan Approved for Operable Unit 1. Major components of plan include monitoring groundwater until groundwater no longer poses an unacceptable risk, maintaining institutional controls restricting access to shallow groundwater until the groundwater contamination attenuates to levels that will no longer pose any unacceptable human health or environmental risks, securing of existing water supply and groundwater monitoring wells. |
Louis Howard |
| 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 |
| 12/1/1995 |
Update or Other Action |
Environmental Cleanup Plan Phase I Final received for removal of asphalt & asphalt-contaminated soils from Landfill 59 (LF59) & removal of 70 drums of roofing tar from Spur Road at EAFB.
Contaminant source area LF59 was not investigated before the 1990/1991 RI studies. In June 1991, a literature search was conducted for information regarding LF59. In particular, a land-use assessment of the area was completed based on aerial photographs taken in 1946, 1950, 1965, 1973 & 1990.
In the 1946 aerial photo, Second Avenue appeared to be located approximately 150 yards south of its present location. No disturbance of the vegetation was 3 apparent in the area of the present site. An apparent borrow pit operation was evident near the south end of the North-South Runway, approximately one-half mile west of the site.
The area between Second Avenue & Ship Creek had undergone extensive change by 1950. Second Avenue had been moved north to its present location.
The 1950 aerial photo showed the borrow pit operations expanded eastward, with a large building located just north of the present site location. This building could possibly have been an asphalt batch plant. By 1965, the borrow operations had been terminated & most of the area leveled. The large building observed in the 1950 photograph had been removed.
The 1973 aerial photo showed revegetation occurring throughout the borrow pit area, but cover was still sparse. A path had been established which passed through the site. By 1990, LF59 was thickly revegetated. The path running through the site had become a parking area on its south end, & overgrown on its north end. The aerial photo interpretation appears consistent with the LF59 surficial geologic map, which shows extensive artificial fill at the site. The fill probably coincides with the borrow pit & building construction shown in the photographs.
During the summer of 1992, the site was investigated by an exploratory drilling program designed to delineate both the lateral & vertical extent of the tar. A total of 25 exploratory soil borings were drilled. Based on the vertical & lateral estimates, a calculation of the estimated volume of the tar-contaminated area was made. The tar surface exposure area is estimated to cover more than 2,100 sq yds, & the volume of tar contaminated soil is conservatively estimated to be between 1,900 to 2,500 cubic yds.
Primary contaminant sources identified during RI scoping, & verified during the RI, include tar seeps & surface & subsurface land debris. Secondary contaminant sources are surface & subsurface soil, which may have received contaminants via surface runoff/erosion, percolation/infiltration of precipitation, & entrainment of waste material.
The primary release mechanism in the LF59 source area was interpreted to be percolation/infiltration of contaminants into subsurface soil &, eventually, into GW. These sources included the tar seep & landfill areas. Contaminated GW may then migrate into Ship Creek, thereby, contaminating sediment & surface water. It is also possible that runoff/erosion may transport contaminants at the ground surface into Ship Creek or into the Small Oxbow Lake.
It has been emphasized, however, that the types of contaminants present in the asphaltic material are relatively insoluble in water. Therefore, migration of contaminants from tar sources into GW, & subsequent migration into Ship Creek or other surface water, was not expected. The results of the RI indicated that the types of contaminants common in asphalt are not present in subsurface soil, surface water, sediment, or GW in this area.
The project will be implemented in two phases. Project activities of Phase I will take place at LF59 & at Spur Road. Initial activities will focus on defining the extent of asphalt surface contamination at LF59. The asphalt tar weeps will be excavated down to the source. It is anticipated that a large mother lode will be found as the source of surface weeps. Once the mother lode is identified, a trench will be dug near the surface. Then, the temperature of the asphalt deposits will be increased using heating rods or similar methods. The viscosity of the tar will drop to the desired level & asphalt will start to flow into the lined trench, which will be built simultaneously during the heating process.
At this stage, if the asphalt is collected in the trench, OHM will attempt to pump it into base-supplied containers. Drums of asphalt stored at Spur Road have already been verified to be non-recyclable & will be collected & disposed of. This activity will conclude Phase I of the project.
Phase II will consist of:
* Characterization & either recycling or disposition of asphalt
* Sampling & analysis of the excavation integrated with investigation of the remaining portion of LF59
* Potential further excavation
* Backfill & compaction
* Site restoration. |
Jennifer Roberts |
| 7/12/1996 |
Update or Other Action |
USAF MEMORANDUM Subject: ROD OU1 Specific Institutional Controls submitted on June 12, 1996. The ROD for OU1 listed the maintenance and implementation of specific institutional controls. We want to verify with ADEC our plans to change the usage of a facility near OU1. We believe this change is allowed because the operation of this facility is outside the affected area described in the ROD. A response by July 31, 1996 would be appreciated.
Efforts are underway to install a Maxigrinder at the AAFES gas station on the Davis Hwy. across from the former landfill. The gas station is scheduled for closure this month. This location is considered ideal for this solid waste shredder. Since the risk of exposure to manganese at the AAFES station is zero, our plan is to locate and operate the Maxigrinder from there.
Reference OU1 ROD, Page 29, Section 2.6.1 paragraph three: "Contaminants of concern (COCs) were identified using the screening method suggested in the supplemental guidance for Superfund Risk Assessments in EPA Region X (EPA 1991). This method, called the "risk-based screening approach", compares the highest concentration of each chemical detected at a site to a risk-based screening concentration. According to the National Contingency Plan a risk range of 1E-04 to 1E-06 is acceptable. At OU1 the COCs detected did not occur at concentrations above EPA acceptable risk ranges in soil nor in surface waters. The only COCs identified were in the shallow groundwater at OU1. COCs detected were arsenic, ethylene dibromide (EDB), polychlorinated biphenol (PCB), lead and manganese.
The depth to groundwater under the AAFES station is 30 feet. The chance of any contact with the groundwater is zero.
Reference OU1 ROD, Page 31, last paragraph: "Of the contaminants detected above the acceptable risk ranges, only manganese was observed consistently and widespread throughout shallow groundwater at OU1."
Reference Basewide Support and Groundwater Monitoring Program, Annual Report of Groundwater Sampling Activities, Final dated March 1996, Section 5 Conclusions and Recommendations, fourth bullet down. "Manganese concentrations at OU1 appear to have substantially decreased. Decreases of several orders of magnitude were noted. No significant increases were detected (See table 5-1). |
Ray Burger |
| 8/1/1996 |
Update or Other Action |
The U.S. Environmental Protection Agency (EPA) Region 10 Superfund program has reviewed your memorandum regarding Operable Unit 1 (OU1) Institutional Controls and the proposed change in
usage of the AAFES gas station on Davis Highway. EPAconcurs with your assessment that. positioning and operation of a Maxigrinder at the AAFES gas station location should not cause environmental harm, and should in fact pose less chance of an impact to ground water
than the operation of the gas station which is being closed.
However, consideration of this question has brought to light the fact that certain of the "Specific Institutional controls" described in the OU1 Record of Decision (ROD) have not been completed. Specifically, the site map showing the areas currently and potentially impacted by groundwater contaminants has not been developed, and it is not clear whether the zoning of the affected area for undeveloped outdoor/recreational use only has been done.
Without the site map, at this time EPA cannot concur with certainty that the facility is "outside the affected area described in the ROD" as your memorandum requested. However, as we discussed at our meeting on June 12, 1996, EPA does concur that this change of use is appropriate and permissible under the OU1 ROD, with the understanding the USAF, EPA and the Alaska Department of Environmental Conservation will work together in the near future to
ensure the ROD requirements are completed. |
Jennifer Roberts |
| 10/17/1996 |
Update or Other Action |
Air Force memo: Restricted Use of the Shallow Aquifer on EAFB signed by William R. Hanson P.E. GM-14 Chief Environmental Flight dated October 17, 1996 Memorandum for 3 SPTG/CEC/CEO from 3 SPTG/CEV
1) Due to the contamination and commitments to EPA/DEC the use of the shallow aquifer for any purpose on is not allowed. Attached Facilities Board minutes-03/29/1994 0930 Item 9 has Mr. William Hanson, briefing the Board on the policy to not use the shallow aquifer due to contamination. The Board approved this policy. Minutes approved by Thomas R. Case Brigadier General USAF Commander. The IRP has RODs for OUs 3 and 6 which require, the aquifer remain unused.
2) Personnel in the review process within CES must be aware of these policies and review them on a recurring basis. It is imperative this restriction be recognized and observed during engineer reviews and operations. |
Louis Howard |
| 1/17/1997 |
Update or Other Action |
ADEC (R. Burger) sent Joe Williamson (3 SPTG/CEVR) a letter RE: Remedial Project Manager changer under the Federal Facility Agreement (FFA). This letter is written to officially notify the Air Force of our change in Project Managers for Elmendorf Air Force Base. Louis Howard is replacing me as our lead project manager. He will now be handling all operable units as well as basewide activities under the FFA. Please direct future project correspondence to Louis. He can be reached at the same mailing address, phone # 269-7552, or via facsimile at 269-7649. I will continue to work with him during a transition period to help facilitate a smooth project transfer. signed Ray Burger. cc:Tim Brincefield EPA Region X. |
Ray Burger |
| 2/10/1997 |
Document, Report, or Work plan Review - other |
Review of the draft Basewide Suport and Groundwater Monitoring Program Draft Annual Report of GW Sampling Activities at Elmendorf AFB January 1997. 3.0 Data Evaluation Procedures
3.5.6 Validate Predictions Made in the Groundwater Modeling Report page 3-14: This section states if the results from the 1994 groundwater model does not correlate with current trends, the model may be recalibrated and ran to update predictionts to year T30. The groundwater data from: Operable Unit (OU) 5 and the State-Elmendorf En~vironmental Restoration Agreement (SERA) Phase I and III sites that had contaminant of concern (COC) with increasing trends which conflicted with the predictions made by the 1994 model. The trichloroethylene (TCE) trend prediction made in the OU 5 Record of Decision (ROD) and the 1994 Model for wells located next to Ship Creek was not consistent with the analytical data collected.
The data showed an increase of TCE in five out of seven locations. SERA. Phase I had six wells out of eight with increasing trends for benzene and increasing TCE concentrations in wells where the maximum contaminant level (MCL) was exceeded. SERA Phase III sites, in comparison to the baseline, show increasing trends outnumbering decreasing trends for both benzene and TCE. It is assumed that the 1997 model is to be recalibrated and run to update new predictions since the 1994 model did not predict the trends observed at OU 5, SERA Phase I and II sites.
OU 1 4.1.5 Conclusions page 4-20: The text states that an evaluation of the analytical data determined that nitrate could be eliminated from the OU 1 analytical suite if the data was not used to fulfill Landfill Closure requirements. It should be noted that after dissolved oxygen has been depleted at the microbiological level, nitrate may be used as an electron acceptor for anaerobic biodegradation.
In this process of denitrification, nitrate is reduced to nitrite (NO,). By eliminating analysis for nitrate, it would eliminate the chance to observe any changes in nitrate concentrations across a contaminant plume that provides another indication of bioactivity. DEC recommends continued monitoring for nitrates at OU 1 in support of further characterization of natural attenuation. DEC also recommends continued monitoring for the organic and inorganic compounds identified that continue to exceed MCLs or baseline concentrations to establish trends.
Recommendations page 5-6: DEC concurs with the recommendation listed in this section with the exception of eliminating nitrate and sulfate data from OU 1 and OU 6 groundwater monitoring constituents. See comments above for section 4.1.5 regarding eliminating nitrate analysis. After dissolved oxygen and nitrate have been depleted at the microbiological level, sulfate may be used as an electron acceptor for anaerobic biodegradation. Sulfate concentrations could be used as another indicator of anaerobic degradation of fuel compounds. |
Louis Howard |
| 4/1/1997 |
Update or Other Action |
The Air Force performed removal & recovery of asphalt cement & asphalt containing soil from Landfill 59 (LF59), during 1995 & 1996 documented in Technical Report -Study/Services Final, Project Activities at Landfill LF59 dated April 1997. The report documents the field activities performed in 1995 & 1996. GW was not encountered in 1995 or 1996.
The project was performed in two phases:
Phase I work efforts occurred in 1995. Project activities included the following:
- Removal/Disposal Actions-Seventy (70) drums of hardened, unusable roofing tar were removed from a wooded area on Spur Road & disposed of as a nonhazardous solid waste at a local municipal landfill.
-Recovery Actions-Work effort focused on delineation of the asphalt cement source, preliminary characterization of the waste streams expected from the site, & evaluation of recovery methods. Passive & heat-enhanced techniques were tested to determine practicable approaches for recovering the asphalt cement.
Phase II work efforts occurred in 1996. Project activities included the following:
-Removal Actions-Asphalt cement, asphalt-containing soil & asphalt-containing debris was recovered using removal techniques tested in Phase I. Buried drums of unknown origin were encountered in two sections of the main asphalt cement removal excavation, requiring a modification of the project scope to accommodate the changed site conditions.
-Reclamation/Disposal of Waste Streams-Asphalt cement recovered from LF59 was segregated & turned over to base personnel for reuse. Asphalt-containing soil was reclaimed as fill material for a former municipal landfill located at EAFB. Asphalt containing debris was disposed of as a municipal solid waste. Hazardous & nonhazardous waste streams were characterized, packaged & transported off site for recycle, reclamation, treatment, or disposal.
-Project closure-AFCEE initiated restoration of the site, including revegetation, & return of the site to conditions suitable for recreational use by base personnel.
In summary, the project achieved the following:
* The primary objective of the project, delineating & carrying out, to the extent practicable, the recovery & removal of asphalt cement, asphalt-containing soil, & asphalt-containing debris, was satisfactorily performed.
* The secondary objective, performance of approved recycle or disposal activities on behalf of EAFB for waste streams from LF59 & the Spur Road site, was achieved by the following actions:
- Recovery of 5,000 gallons of asphalt cement (AC-5, 90% by weight) from LF59 for reuse by EAFB
- Reclamation of approximately 8,275 cubic yards (12,413 tons) of asphalt containing soil from LF59 as fill material for a former municipal landfill at EAFB
- Off-site treatment of 120 cubic yards (188 tons) of asphalt-containing, waste oil contaminated soil from LF59 by low temperature thermal desorption
- Off-site disposal of approximately 7 cubic yards (8.2 tons) of soil, asphalt cement, gravel & debris with low-level trichloroethylene contamination as a nonhazardous waste associated with reported spills from buried drums recovered from two sections of LF59
- Off-site disposal of 4,053 gallons (15,338 liters) of hazardous waste liquids recovered from buried drums discovered in two sections of LF59
- Off-site nonhazardous waste treatment of 495 gallons (1,874 liters) of decontamination water & reclamation of 140 gallons (530 liters) of unused diesel fuel
- Disposal of nonhazardous RCRA Subtitle D solid wastes, including seventy 55-gallon drums (13 tons) of roofing tar from the Spur Road site, 60 cyds of asphalt-containing debris from LF59, & 42 cyds of municipal solid wastes from LF59
* Restoration activities were initiated in 1996; final actions were delayed by weather, & are to be completed in 1997.
On August 23, 1996, two grab samples (W01, W02) of rainwater that accumulated in the asphalt collection sump at Excavation Area No. 1 were collected. These samples were analyzed for TPH by EPA Method 418.1 & for aromatic hydrocarbons by EPA Method 602 to evaluate conformance with stormwater discharge requirements. The accumulated rainwater was transferred into polytanks & stored until characterization was completed.
The liquids from both Drum Areas 1 & 2 contained one or more analytes (benzene, trichloroethylene (TCE), or metals) at levels exceeding the TCLP maximum concentrations for classification as a hazardous waste. In addition, certain drum contents would be classified as a hazardous waste based on the characteristic of ignitability. The contaminated soils did not exceed maximum TCLP for specific chemicals, but Sample 3 exceeded the limit for ignitability. The rainwater samples did not contain TPH or benzene, toluene, ethyl benzene, & xylenes (BTEX) above detection limits. |
Jennifer Roberts |
| 9/9/1997 |
Update or Other Action |
EPA sent correspondence to ADEC and USAF re: June 20, 1997 OU1 ICs letter from Colonel Honnet. The U.S. Environmental Protection Agency (EPA) appreciates your letter of June 20 1997, regarding Clarifications to the Elmendorf Air Force Base Operable Unit 1 (OU1) Record of Decision. As you requested, EPA has reviewed your letter. EPA agrees that the OU1 ROD is somewhat unclear and out of date in its discussion of institutional controls and shares your goal of clarifying the land use controls which are needed and putting them into place to ensure continued protection of public health and environment.
EPA is generally in agreement with the proposed approach to land use controls at Elmendorf. It is consistent with the approach developed by the Project Team (including EPA, Alaska Department of Environmental Conservation, and E1mendorf Environmental Management Office Project Managers) to ensure protection public health and the environment, complete all components of the selected remedy for OU1, and allow for appropriate productive use(s) of the areas in question. However, certain details of the institutional controls approach and the rationale for it which were not discussed in your letter need to be documented, particularly if all parties continue to concur that no Explanation of Significant Differences is necessary. Those details are documented in Enclosure l, and EPA will concur with the proposed institutional controls approach assuming the USAF (and ADEC) concurs with Enclosure 1.
With your concurrence, minor modifications to the Base Planning maps and notification of the appropriate personnel, the selected remedy for OU1 would be in place, Operationa1 and Functional, and assuming State concurrence, would meet the EPA definition of "Remedial Action Complete" for this OU. We look forward to reaching concurrence.
Once all six OUs at Elmendorf achieve Remedial Action Completion in 1998 or 1999, Elmendorf AFB will be eligible for inclusion on the President's Construction Completion list, which is an Air Force Measure of Merit. Note that even after "Construction Completion", at Elmendorf some cleanup operations and maintenance, institutional controls, monitoring and five-year reviews must continue until cleanup goals are achieved.
EPA concurs that the proposed "Clarifications to Operable Unit (OU1) Record of Decision (ROD)" in the letter from USAF Elmendorf dated June 27, 1997, are acceptable and the proposed approach meets the OU1 ROD requirements for institutional controls with the following understandings:
The proposal to substitute the “Restricted Use" designation and description administered by the Elmendorf Planning and Environmental Management Offices through the Base General Plan for the requirement for zoning controls in the OU1 ROD (which called for “zoning the affected area for undeveloped outdoor recreational use only''), is acceptable because the general and specific restrictions described in your letter, the Base General Plan, and the Drilling Permit/Work Order process will, ensure that there is no unacceptable exposure to or spread of contaminants, yet will allow appropriate productive uses of the area.
a. EPA understands that the General Plan addresses all Elmendorf AFB land use planning and facility siting. In addition, smaller excavations or other activities on Base potentially likely to impact the protectiveness of the remedy require Drilling Permits and/or Work Orders, both of which are reviewed by both the base Planning and Environmental Management Offices.
b. The OU1 boundary (including the entire former landfill bisected by the western edge of the boundary) is acceptable as the definition of the "actually and potentially affected area.” based on current site data which indicates that contaminants of concern are not migrating beyond the OU1 boundary. The affected area will be evaluated and if necessary adjusted as part of five-year reviews" or sooner if site conditions, groundwater monitoring results or modeling predictions changes significantly;
c. To ensure the effectiveness of these controls, the legends of all relevant maps in the Base General Plan and the Environmental Management Action Plan shall be revised as soon as possible (initially by pen and ink, if revised maps will not be issued within six months of the date of this letter) to include language explaining:
1) what "Restricted Use" means/requires, and, 2) that due to contamination; use of the sha11ow aquifer is prohibited on Elmendorf AFB. The Air Force will provide EPA and ADEC the opportunity to review and comment on proposed revisions of the maps identifying restricted use areas and related land use planning/control documents before they are implemented, and will annually notify EPA and ADEC of any updates to such documents so that EPA and ADEC may review them to ensure that the proper controls are being maintained.
See site file for additional information. |
Louis Howard |
| 11/18/1997 |
Meeting or Teleconference Held |
Restoration advisory board meeting held and announced beforehand in the Alaska Star 10/30/97 and 11/6/97, 11/13/97 and the Sourdough Sentinel 11/7/97 and the Daily News 11/17/97. |
Louis Howard |
| 12/9/1997 |
Institutional Control Record Established |
Institutional controls implementation plan completed for the Base. Groundwater monitoring program will provide early warning of any increase in concentrations or movement of manganese. Existing land use controls will ensure no current exposure to shallow GW. Institutional controls (ICs) and required property transfer provisions of CERCLA will ensure that there will be no exposure to shallow GW in the future. Elevated levels of Mn appear to be isolated within a limited area and are not anticipated to migrate.
The source of the Mn is uncertain. There is no current (as of 9/29/94) exposure to Mn in the shallow groundwater. Major components of the selected remedy: ICs, monitoring GW for five years, or until the GW poses an acceptable health risk, five year review to assess the protectiveness of the remedial action and periodic evaluation of monitoring results to determine if there is need for further remedial action. Remedial action goals will have been met and institutional controls removed when concentrations have been met in groundwater for 1,2-dibromoethane (0.05 ug/l), Mn (down to background levels of 9,100.0 ug/l), trichloroethylene (5.0 ug/l) and vinyl chloride (2.0 ug/l). |
Louis Howard |
| 2/10/1998 |
Document, Report, or Work plan Review - other |
EPA Comments on Groundwater Model: 1.1 Pg 1-1 Why were there only selected receptors sites selected to see if Ship Creek and unnamed beaver would be impacted form GW contamination on base. It seems logical that all receptor sites along the bluff would be tested. Because there is no way to determine if a groundwater seep is contaminated unless it is tested. How was the degree of contamination decay determined? Report mentions the model was modified to incorporate contaminant decay. Many physical, chemical and biological factors can significantly affect the rate of contaminant decay.
Pg. 1-7 It appears the assumption made stating that due to limited data on soil and soil gas concentrations in the vadose zone, concentrations in the source areas were set equal to the groundwater concentrations under the source area. That assumes the leaching of the contaminant has reached equilibrium with the groundwater. I don’t believe that is a correct assumption. Last paragraph. Report states a sensitively analysis was performed to see if data manipulation could be done to make the model results better correspond to what was actually being found. A slight improvement was found when the time step was reduced from 1.0-50 days to 0.1- 5.0 days. That is a reduction of a factor of ten yet, it only made a slight improvement.
I would think that to allow such a reduction EAFB would have show the reduction had a more significant impact, otherwise it should be left alone. Time restraints didn’t allow me enough time to research the 1996 report to see how EAFB rationalizes the reduction of the benzene half-life from 370 days to 100 days. What I’m wondering could other factors e.g., groundwater flow rate, non-homogeneity of soils or, amount of organic carbon in the soil, have effected to the model in the same way (made the predicted results match the actual results).
Pg1-13. It seems that EAFB has determined that a source area only contributes to groundwater contamination for a period of 5 years. How did they come to that conclusion? It is well documented that old release scan still contribute to groundwater contamination. The LUST program has reviewed files where gas stations that have been out of business for 10-15 years have high levels of benzene contamination in soils and groundwater. Factors contributing to the length of time a source remains active are, but not limited to, the amount of surface water infiltration, amount of organic material in the soil, and the maximum concentration of contaminants in the soil. To say that the contamination in the soil is only contributing to the groundwater contamination levels for a period of 5 years is unjustifiable especially if free product or near free product levels exist in the soils. First paragraph. “ New contamination sources within the 1996 update were not assumed to be active. This assumption was based on the fact that the sources hadn’t been fully characterized”. It sounds like they are saying, if a contaminant source hasn’t been thoroughly characterized it is assumed to be non-existent.
1.3 Recent Spills and New Source Additions. Why weren’t SERA IV & V sites added? Release Investigation for these SERA projects were started in 1996 and continued this last year? Release Investigations indicated high levels of petroleum contamination exist from just beneath the former location of the UST to the ground water table or just the first six inches of soil above the groundwater table. Some sites were very close to the bluff.
2.2 The assumption that 54 mg/l of benzene in the groundwater is the maximum achievable level at the spill #3 site of 54 mg/l is incorrect. 54 mg/l appears to be based on the assumption that benzene makes up 3% of JP-8, and the maximum solubility of benzene is 1780 mg/l, therefore, 1780 mg/l x .03 = 54. That statement also assumes all the other components of JP-8 have the same ability to dissolve into water and are competing equally with benzene for space within the water molecule, which isn’t true. Many components of JP-8 have very low solubility rates, therefore, benzene will have a higher solubility rate than the 54 mg/l, The amount of dissolved benzene could be somewhere between 54 and 1780 mg/l. |
Louis Howard |
| 2/11/1998 |
Document, Report, or Work plan Review - other |
EPA continued comments on the groundwater model: 3.1 Paragraph 2 contains a statement that spills 1 & 2 will only be active sources for five years. As of March of 1998, the Air Force is still collecting free product from all their active monitoring/product recovery wells at the South Apron site (spill #2). They have yet to do a release investigation to show how big the free product plume is for spill #2.
Paragraph 4 states that benzene with attenuate to levels below MCLs within five years for all three spills mentioned in the report. That is a pretty bold statement considering the Air Force has stated they may only be able too recover up to 20% of the estimated 84,000 gallons release below ground.
3.2 Paragraph 3 states “little down gradient migration of the plume is predicted to take place, as was the first scenario. Downgradient migration is expected to be counteracted by the rapid (?) degradation of benzene in the groundwater, which is responsible for the significant predicted decrease in dissolved benzene concentrations at the spill site.” [Spill 3]. I don’t know how they can justify this statement because, 1) They don’t even know of big the plume is, never mind saying it will do little(?) down gradient migration. 2) The maximum level of benzene in the groundwater may not have occurred yet. The water table is anticipated to move up into fuel saturated soils, dissolving more benzene that is trapped in the residual phase.
It is interesting to note that in paragraph 5, the Air Force states that the size and geometry of the (benzene) plume is expected to stabilize and stay fairly consistent between years 10 – 15, yet earlier it was mentioned they expect benzene levels to be below MCL with in 5 years |
Louis Howard |
| 4/27/1998 |
Document, Report, or Work plan Review - other |
EPA comments on Draft Environmental Monitoring Plan and Groundwater Modeling Report. EPA has completed its review of the advance portions of the draft 1998 Environmental Monitoring Plan (EMP) and the Groundwater Modeling Report. This letter addresses the advance draft EMP; EPA’s comments on the Modeling Report are contained in the enclosed draft letter from EPA Hydrogeologist Curt Black.
In general we are supportive of the recommended monitoring plan, however we will need more time to review the chemical data for a number of wells across the site before making final comments. Based on our review to date, there are a number of wells which appear to be appropriate for monitoring down gradient of various units which are not in the program. In most cases, other wells, further down gradient or tangential to the presumed flow direction are included in the program, and EPA is in the process of reviewing past analytical results. Based on our review, we may yet recommend returning some of the previously excluded wells to the sampling program (Examples include LF-05-W6,no wells down gradient of OU-4-ss10,OU6-MW-12 and OU6-MW-05 (due to apparent increase in COCs near WP14).
Our QA/QC expert, Bruce Woods, evaluated the proposed methods and indicator parameters. Based on his review, he concluded that the proposals generally look like appropriate citations for methods, with the exception of the 3 digit SM numbers which he believed had been replaced a number of years back with another system (if so, we should update the EMP).
The use of 50ug/l as an aggregate detection limit appears supported by the Washington state use of a similar number. If Alaska doesn't have a specific number, and if the Base is willing to work with 50, EPA believes the proposed aggregate detection limit is workable (combination of protective and attainable).
EPA believes the analyses we saw called out were appropriate for laboratory run analytes. The only question might be on encompassing the range of biodegradation products of trichlorethylene (TCE) and tetrachlorethene (PCE) degradation. These would be more important to add in the future after we demonstrate that conditions are present which are capable of supporting the biodegradation of these compounds. Those environmental indicators will be provided this year with the geochemistry they have proposed to monitor. Therefore, we think we can wait on the degradation products themselves and if necessary look to include them next year. |
Louis Howard |
| 5/1/1998 |
Update or Other Action |
Based on discussions in May 1998 between the Alaska Department of Environmental Conservation (ADEC), U.S. Air Force (USAF), and U.S. Environmental Protection Agency (USEPA), the analytical list was changed from EPA Method 8015M to include EPA Methods 602 for benzene, toluene, ethylbenzene, xylene (BTEX) and 8310 for PAH. Both methods have detection limits below 10
ug/L and allow for analysis of fuel hydrocarbon components. The lower detection limits have allowed for improved monitoring of contaminant concentrations that may exit the system in the effluent water.
No elevated contaminant concentrations were reported exiting the Wetland Remediation System (WRS) during the 1997-1998 Operations & Maintenance period. Analytical methods for Nitrate-Nitrite and Total Phosphorus were also updated. The methods are now Method E353.2 for Nitrate-Nitrite and E365.3 for Total Phosphorus. The new analytical methods do not quantify the identified contaminants of concern (COCs) specified in the OU 5 record of decision (ROD) (USAF 1995a), but are appropriate for determining contaminant levels and monitoring the effectiveness of the wetland system.
Since the new analytical methods do not quantify all of the specified COCs, clean-up levels from
the Alaska Water Quality Standards, 18 AAC 70.020, are utilized for comparison purposes. The Alaska Water Quality Standards for petroleum hydrocarbons, oils and grease contamination concerns for growth, and propagation of aquatic and wildlife specify 10 (ug/L maximum concentration for Total Aromatic Hydrocarbons (TAH) and 15 gg/L maximum concentration for Total Aqueous Hydrocarbons (TAqH). TAH and TAqH concentrations were determined from the BTEX (E602) and PAH (8310) analytical results. TAH concentrations were determined by summing the concentrations of all detected BTEX. TAqH concentrations were determined by summing the concentrations of all detected PAHs and BTEX compounds. These clean-up levels are required for the Wetland Cell effluent.
(*NOTE to file: As a result of the basewide groundwater study and the FY92 field work that occurred at operable units (OUs) 1, 2, and 5 it appears that a large portion of the GW flows into OU5. March 26, 1993 5.40 ELM 021740-021740) |
Louis Howard |
| 5/27/1998 |
Document, Report, or Work plan Review - other |
EPA comments on draft Environmental Monitoring Plan dated April 1998. Page 2-3, Section 2.3.1.1 – EPA understands the specification for methane analysis has been superseded by recent correspondence. EPA agrees with limiting the collection of methane data to wells which have proven problematic in the monitoring program, that is, wells for which the geochemical indicator data are not all supporting the same interpretation as to geochemical environment.
Figure 2-1 – The specification/question is asked, “Have any analytes exceeded primary MCLs or cleanup levels during the previous 2 sampling events?” EPA reviewers again raised the concern 2 events in biannual sampling is only 1 year and that 1 year is too short a period over which to base the decision to permanently remove a well from the monitoring program. RCRA uses a period of 30 years for post-closure monitoring. Such a lengthy period is not necessary or desirable here, but EPA reviewers recommend revising the decision guide and continuing to sample for a longer period before removing wells from the monitoring program. Additionally, at our last meeting the project team discussed the periodic revisiting of wells (possibly at a 5 year frequency) to ensure not erroneously deleting a well in which constituents of concern still exceed action levels or which might show evidence of changed conditions on-site. EPA would like to discuss these issues with USAF and ADEC before the 1998 EMP is finalized.
Page 3-3, Contaminants of Concern, paragraph 2 – EPA reviewers questioned the advantage to the facility of elimination of specific COCs before all the COCs of a particular method (i.e., SW8260) have been “eliminated.” EPA suggests that if it costs the same to run a volatile scan regardless of the reported values which are required (as has been our experience) the full results should be reported until the method is no longer needed for the program area(s) in question.
Page 3-5, First sentence: EPA suggests replacing the phrase, “. . .and degrade more slowly under aerobic or anaerobic conditions. . .” with, “. . .and compounds such as trichloroethylene (TCE) may show no appreciable degradation under aerobic conditions.” which more accurately represents our understanding of how TCE, the chlorinated compound of particular interest at this site, behaves under aerobic conditions. Section 3.1.4, Intrinsic Remediation: For greater accuracy, EPA recommends inserting the word, “petroleum” before the word “hydrocarbons”, and inserting the word “may” before the words “initiates” and “provide”. Also was the word “exogenous” or “anthropogenic” intended instead of “extraneous”?
Page 3-6, bulleted list: This list doesn’t match the parameters listed in Appendix A, the FSP. The addition of dissolved oxygen is suggested. From the FSP is appears it was your intention to collect DO. Last paragraph: EPA is concerned that the approach presented may be flawed by the assumption of the “single flow path” which may affect how conservative the estimate will be. At a minimum there should also be some discussion of the potential impacts of multiple flow paths and the safeguards built into the Basewide GWMP would highlight potential problems in a timely manner. With respect to the proposed 3 evaluations, EPA believes the first evaluation should be changed to either read “1) that the destructive components of natural attenuation is are occurring within a program area;” or “1) the rate at which natural attenuation is occurring within a program area”. This comment is based on EPA’s understanding natural attenuation is always occurring, but what is not clear and what needs to be known is at what rate, by what mechanisms (e.g., dilution, destructive processes...), and whether the situation is and is expected to remain protective.
Page 3-7, Section 3.1.6: EPA reviewers were confused by this section. Are these recommendations for future 5-year review evaluations? EPA is not aware of plans to do the work described in this section during the current 5 year review cycle. This is the section where EPA would have expected discussion of our earlier recommendation to consider adding wells eliminated from annual sampling back into the program at 5-year intervals. EPA would appreciate some explanation of what is intended here and an opportunity to discuss it with you and ADEC prior to finalization of this EMP. |
Louis Howard |
| 7/14/1998 |
Document, Report, or Work plan Review - other |
EPA letter to USAF Joe Williamson/Claude Mayer RE: Draft OU 1 Remedial Action Report. The following are comments that EPA recommends be addressed to
make the final OU1 RA Report clearer and more complete.
1.2 Project Background, first paragraph after source area descriptions: Reviewers were unclear as to the disposition of LF05, LF07, LF13, and OT56 after reading this Report.
Recommend revising the first sentence in the paragraph following the source area descriptions, which reads "The OU1 investigation supported the determination that certain solid wastes identified within the OU do not warrant further action under CERCLA.", by adding the following to the end of the sentence: "(including LF05, LF07, LF13, and OT86)". If this is not accurate and/or acceptable, we should discuss this fmther before the final Report is completed.
2.3 Performance Standards (Cleanup Goals): All entries under "Target Date to Meet Cleanup Goals" are marked with a footnote that says "Section 2.1 covers time frames selected in the OU1 ROD for cleanup", however reviewers did not find the expected information on estimated timeframes there (all I can find is the bullet which says "monitoring groundwater for five years, or until groundwater no longer poses an unacceptable health risk"). In other RA Reports the Air Force has provided both the initial ROD timeframe estimates for Contaminants of Concern to reach target levels and updated projections based on current information.
EPA review of the ROD did not reveal such specific time estimates, however some revision of the RA Report text still appears indicated.. One option would be to change the footnote to read something like "No estimated time frame for achieving goals was established in the ROD, which called for monitoring and institutional controls until groundwater contamination is below levels that pose any unacceptable human health or ecological risks, but current estimates based on monitoring and modeling indicate groundwater throughout OU1 is expected to achieve
cleanup goals by the year 2004" |
Louis Howard |
| 7/14/1998 |
Document, Report, or Work plan Review - other |
EPA comments on the OU1 draft remedial action report. In general the report is consistent with the previous Elmendorf Air Force Base RA Reports and with the EPA RA Report and Site Completion Guidances. The following are comments that EPA recommends be addressed to make the final OU1 RA Report clearer and more complete.
1. 1.2 Project Background, first paragraph after source area descriptions: Reviewers were unclear as to the disposition of LF05, LF07, LF13, and OT56 after reading this Report.
Recommend revising the first sentence in the paragraph following the source area descriptions, which reads "The OU1 investigation supported the determination that certain solid wastes identified within the OU do not warrant further action under CERCLA.", by adding the following to the end of the sentence: "(including LF05, LF07, LF13, and OT86)". If this is not accurate and/or acceptable, we should discuss this further before the final Report is completed.
2. 1.2 Project Background, next to last paragraph: recommend revising "Lead" sentence by replacing "they were" with "lead was". Last paragraph: "Proposed Plan" should be capitalized.
4. 1.3 Chronology: Recommend spelling out acronyms on this chart.
5. 2.3 Performance Standards (Cleanup Goals): All entries under "Target Date to Meet Cleanup Goals" are marked with a footnote that says "Section 2.1 covers time frames selected in the OU1 ROD for cleanup", however reviewers did not find the expected information on estimated timeframes there (all I can find is the bullet which says "monitoring groundwater for five years, or until groundwater no longer poses an unacceptable health risk"). In other RA Reports the Air Force has provided both the initial ROD timeframe estimates for Contaminants of Concern to reach target levels and updated projections based on current information. EPA review of the ROD did not reveal such specific time estimates, however some revision of the RA Report text still appears indicated.
One option would be to change the footnote to read something like "No estimated time frame for achieving goals was established in the ROD, which called for monitoring and institutional controls until groundwater contamination is below levels that pose any unacceptable human health or ecological risks, but current estimates based on monitoring and modeling indicate groundwater throughout OU1 is expected to achieve cleanup goals by the year 2004" (consistent with the text in Section 3.3).
6. 3.0 RAs Performed: Recommend revising sentence to read as follows to better address all components of the selected remedy: "...included establishment and maintenance of institutional controls and a groundwater monitoring program, as described below:".
7. 3.1 and.3.2: Recommend marking the "Lessons Learned" sub-titles with bold type so they stand out for the reader to find.
8. 3.1 Institutional controls, second bullet: Recommend inserting the word "institutional" before the word "controls" in the first sentence. Third bullet: In the fourth sentence, the phrases "construction of" and "would be allowed to be built" are redundant. One of the two should be deleted.
10. 3.2 Groundwater Monitoring, first paragraph: Recommend inserting "by USAF, ADEC and EPA" after "evaluated".
11. 3.3 Current Status, second paragraph: At the end of the third sentence, after "downgradient receptors", recommend adding "such as Ship Creek" or "including Ship Creek", as that is the area typically of most concern. |
Louis Howard |
| 8/5/1998 |
Update or Other Action |
Remedial action report signed by ADEC (Jennifer Roberts) states remedy of monitored natural attenuation is operational and functional according to EPA, AF and ADEC staff during five year review. From the 1991/1992 RI: Of the seven potential COCs, only manganese was observed consistently and widespread throughout groundwater at the site. The highest values detected were 26,000 ug/L in GW-2A collected in August 1988.
Trichloroethylene (TCE) was detected in groundwater collected from one well, LF05-GW-2B, at a concentration of 8.2 ugL, which exceeds the MCL of 5 ugL. Vinyl chloride was detected in only one well with a concentration of 3.3 ug/L. Since vinyl chloride is a known human carcinogen and sampling in 1988 indicated vinyl chloride detections at other locations within OU1 it was included in the sampling program. EDB was detected several times in the fall 1992 sampling event, however it was only once detected above the MCL of 0.05 ug/L.
Arsenic was detected in four monitoring wells at levels only slightly above background conditions. PCBs were detected once at 14.0 ug/L in one well. Two subsequent sampling events in the same well failed to confirm the presence of PCBs. Lead exceeded EPA's drinking water benchmark level of 15 ugL in 1991 fall sampling event in one well. EDB is an additive to leaded gasoline. TCE and vinyl chloride are solvents most likely present due to past disposal activities. Arsenic and manganese are naturally-occurring substances found in soils throughout the Base. No source for the PCBs or lead was found in OU1.
Groundwater monitoring is being conducted semi-annually as part of the basewide groundwater monitoring program. Two of the OU1 COCs, EDB and vinyl chloride, were below detection limits and cleanup goals during the 1996 and 1997 sampling events.
Groundwater monitoring results indicate OU1 COCs, manganese and TCE, are migrating down gradient; however, the levels decrease with distance and are not expected to impact down gradient receptors such as Ship Creek. The results are consistent with natural attenuation. As there are no active drinking water wells within or down gradient from OU1, there is no evidence of current threat to human health and the environment at this time and none is anticipated. Additional efforts are being made to understand the source and significance of manganese in OU1 and throughout the Base. This evaluation could conceivably lead to modification of the cleanup
goals in the future.
Long-term operation (LTO) and maintenance of the remedy will continue until groundwater cleanup goals are achieved. Current estimates (based on groundwater monitoring and modeling results) indicate groundwater throughout OU 1 is expected to achieve cleani[ goals within the next six years (year 2004). (NOTE: Three wells downgradient from LF07 and LF13 (OU1-LF21, LF05GW-2B, OU1LF-19) are above the RAOs for TCE (Wells LF05GW-2B & OU1LF-19 have been above the MCL for TCE since 2006, 2007, 2008) PLUS 4 groundwater grab sample downgradient locations in 2006 were above the TCE MCL.) |
Louis Howard |
| 8/12/1998 |
Update or Other Action |
Letter to AF regarding Response to Comments on draft work plan SERA Phase II Sites ST36/66, ST74, and ST61 Investigation dated July 1998. ADEC disagrees with contractor's response to comments concerning analytical methods discussed in Items 1(i) and 1(m). UST and CS regulations require cleanup levels for GRO/DRO be based on analyticals using AK methods not 8015M/8100M.
The only exception to the analytical methods are found in 18 AAC 78.090: "If site assessment sampling began before November 3, 1995, and if test results satisfy the water quality criteria and cleanup levels referred to in (i) of this section, the owner or operator may continue to use the analytical methods used before that date to complete the site assessment. If a site assessment is begun on or after November 3, 1995, the owner or operator shall use the analytical methods set out in Table G of 18 AAC 78.800(b)."
ADEC requests the AF cease use of alternative lab methods (8015M/8100M) for DRO and GRO analyses by the end of the calendar year for soil and groundwater analysis or long-term monitoring which do not include AK 101 or 102. The alternative methods will no longer be acceptable when the new 18 AAC 78 and 18 AAC 75 regulations become final. It is anticipated that the UST and CS regulations will become finalized by the end of this calendar year. Please make changes to any future contracting or scopes of work to ensure that by March 1, 1999 all analyses for gasoline range organics and diesel range organics utilize AK methods for both soil and groundwater. |
Louis Howard |
| 10/27/1998 |
Update or Other Action |
7/98-9/98 Quarterly progress report received for Base. Groundwater monitoring is ongoing as the 9/94 ROD states will occur for 5 years. Implementation of the institutional controls has occurred. Manganese levels in the groundwater continue to be above the acceptable risk ranges. |
Louis Howard |
| 11/3/1998 |
CERCLA ROD Periodic Review |
Five-Year Remedy Review conducted by U.S. USAF to ensure that the remedial actions selected in the Record of Decision (ROD) for the operable unit (OU) remains protective of public health, the environment and are functioning as designed. The start of construction of the OU2 Interim Remedial Action (IRA) on August 5, 1993 triggered this five year review CERCLA requirement. Response actions at the OU are ongoing, all remedial actions are operational and functional as documented in the OUs remedial action report. All required institutional controls have been established and incorporated into the Base General Plan and the management action plan.
The United States Air Force (USAF) has conducted this review pursuant to the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA), 42 USC 9621(c), the National Contingency Plan (NCP) - 40 CFR 300.400(f)(4)(ii), Executive Order 12580 (January 23, 1987), and Section 19.1 of the Federal Facility Agreement (FFA) for Elmendorf dated September 1991. This document is consistent with these EPA guidance documents: OSWER Directive 9355.7-02 (May 23, 1991) as supplemented by OSWER Directives 9355.7-02A (July 26, 1994) and 9355.7-03A (December 21, 1995). Consistent with the FFA, the project managers for the EPA and the State of Alaska Department of Environmental Conservation (ADEC) have participated in this review. This review is limited to only those sites being remediated under CERCLA authority (i.e. not SERA or or LUST sites).
1991 EAFB FFA actually states: "19.1 If a remedial action is selected that results in any hazardous substances, pollutants, or contaminants remaining at the Site, the Parties shall review such remedial action no less often than each five (5) years after the initiation of such remedial action to assure that human health and the environment are being protected by the remedial action being implemented. The U.S. EPA Project Manager and the ADEC Project Manager shall advise the USAF Project Manager of their findings in this regard. If any Party determines that additional action is required, the Agreement may be amended pursuant to Part XXXIII. If the Parties are unable to agree on the need tc amend this Agreement, dispute resolution under Part XXI shall be available to any Party."
Site conditions and land use are consistent with the OU 1 ROD requirements and remain protective, based on evaluation of current monitoring data and trends and the most recent joint inspection by the USAF, EPA, and ADEC project managers on April 9, 1998.
To accomplish the remedial objectives of the final ROD, a Land Use Controls plan was developed and implemented between 1994 and 1998. All aspects of the Land Use Controls plan have been completed as follows:
• The OU1 boundary (including the entire former landfill on the western edge of the boundary) has been determined to be the appropriate definition of the “actually and potentially affected area” based on current site data, which indicates that COCs are not migrating beyond the OU1 boundary.
• The legends of all relevant maps in the Base General Plan (BGP) (USAF, 1997a) and the Environmental Restoration Program’s Management Action Plan (MAP) (USAF, 1998b) have been revised to show the contaminated area and potentially affected areas, in order to ensure the effectiveness of the Land Use Controls.
• The affected area has been designated as a restricted use area of the Base to prevent exposure to the contaminated shallow aquifer. Construction of manned facilities and excavation affecting the integrity and function of the landfill caps, or impacting the shallow groundwater, are strictly prohibited. The area is designated for recreational use and construction of unmanned facilities.
• Access to and/or use of the shallow groundwater aquifer in the affected area was prohibited by order of the Base Commander dated March 29, 1994, and the prohibition continues to be enforced.
• Key Air Force personnel have been notified of the areas on Base restricted by Land Use Controls, the purpose of the controls, and their responsibilities during review of proposed facilities, construction, drilling permits, and work orders.
Future Five-Year reviews are necessary because contamination remains above levels that allow for unrestricted use and/or unlimited exposure at the operable units. The next five-year review will be completed by August 2003. The Alaska Department of Environmental Conservation concurs with the Five-Year Review for Elmendorf Air Force Base (signed by Jennifer Roberts DoD Oversight Section Manager). |
Jennifer Roberts |
| 1/12/1999 |
Update or Other Action |
10/98-12/98 Quarterly progress report received for the Base. Five-Year remedy review signed by EPA, ADEC stating the remedy is operational, functional and remains effective at protecting human health and the environment. Round 2 of monitoring well base-wide program and of 13 wells in OU1 only LF59-MW-03 exceeded trichloroethylene (TCE) MCL of 5 ug/L. Manganese continues to be above the MCL in 8 wells. |
Louis Howard |
| 4/13/1999 |
Update or Other Action |
01/99-03/99 quarterly report received. As a result of the five-year remedy review, groundwater base-wide monitoring program was expanded to collect parameters to evaluate manganese levels throughout the Base. Manganese continues to be above MCLs. |
Louis Howard |
| 7/8/1999 |
Update or Other Action |
04/99-06/99 Quarterly progress report received. Groundwater monitoring continues and manganese continues to be above MCLs. |
Louis Howard |
| 10/5/1999 |
Update or Other Action |
07/99-09/99 quarterly progress report received. Of 14 wells sampled, one well had 11 ug/L of trichloroethylene (TCE) detected in groundwater. Manganese continues to be above MCLs. |
Louis Howard |
| 10/11/1999 |
Update or Other Action |
OU1 Round 1 September 1999 monitoring results received. Results appear non-eventful for all contaminants of concern with the exception of well ID LF59-MW-03 sample ID E99-OU1-LF59-MW-03-01 for 1,1,2,2-1,1,2,2-Tetrachloroethane detected at 21 ug/L. Table C groundwater cleanup level is 4 ug/L. |
Louis Howard |
| 11/20/1999 |
Update or Other Action |
OU1 Round 2 monitoring well results received. Trichloroethylene (TCE) at well LF59-MW-03. TCE decreased from 11 ug/L to 8.4 UG/L which is still above 5 ug/L. Manganese secondary MCL is exceeded at 7 well locations. |
Louis Howard |
| 12/28/1999 |
Site Number Identifier Changed |
Changed work plan from X1 to X9 to reflect metals and solvents. |
Louis Howard |
| 1/10/2000 |
Update or Other Action |
10/99-12/99 Trichloroethylene (TCE) detected in groundwater. Manganese continues to be above remediation goal of 9,100 ug/L at seven well locations. Target year to meet cleanup levels is 2004. |
Louis Howard |
| 3/30/2000 |
Update or Other Action |
Staff reviewed and accepted the Draft Community Relations Plan for the Base. |
Louis Howard |
| 4/10/2000 |
Update or Other Action |
1 January to 31 March 2000 quarterly report received. Trichlorethylene remains above maximum contaminant level (MCL) of 5 ug/l at 8.2 ug/l and manganese is at 33,000 ug/l which is above the remediation goal of 9,100 ug/l. Still anticipate meeting cleanup goal by 2004. |
Louis Howard |
| 6/1/2000 |
Update or Other Action |
Basewide Environmental Monitoring Plan received. The purpose of the Basewide Environmental Monitoring Program (EMP) is to provide information on surface water and groundwater quality, groundwater flow characteristics, and monitoring well integrity at specified locations throughout Elmendorf AFB. The data assessment portion of the program includes data collection via groundwater and surface water sampling, and groundwater level measurements.
Groundwater samples will be collected from 14 wells in Round 1 and 13 wells in Round 2 as part of the OU 1 Groundwater Sampling Program. The groundwater samples at OU 1 will be analyzed for anions (nitrate, chloride, fluoride, sulfate, and phosphate), trace metals, volatile organics, pesticides, polychlorinated biphenyls (PCBs), and chlorinated herbicides. These methods include, but are not limited to, constituents that have either exceeded maximum contaminant levels (MCLs) during the RI/FS or were identified as COCs in the ROD. The remedial action goals for OU 1 include reduction of these contaminant levels to below MCLs or background concentrations.
The purpose of long-term monitoring at OU 1 is to compare concentrations of constituents in the samples collected to historic OU 1 concentrations, and to available background information, such that changes or trends in concentrations can be established, and any unsuspected increases in contaminant concentrations can be identified. As sufficient data become available, groundwater sampling results will be evaluated statistically to ensure that the assumptions made in the OU 1 ROD are accurate; to validate predictions made in the 1998 Groundwater Model; and to provide early warning of increased contaminant levels or migration of contaminant plumes.
In addition, Round 1 sampling at OU 1 is comprised of wells and methods required for annual sampling to meet landfill closure monitoring requirements. These requirements are specified in 18 AAC 60.410.
The OU 1 EMP was modified in 2000 to follow the same methodology of 1999. To improve long-term groundwater monitoring, in accordance with specified Elmendorf AFB landfill closure requirements, a Landfill Groundwater Monitoring Network was established for the site in 1998. Historically, some of the wells in this network list were either not included in the EMP for OU 1 or they were sampled as a part of another program area. Beginning in 1999, an additional well was added to the OU 1 sampling program to comply with the Final Landfill Closure Plan. In addition, the following methods were added to the Landfill Groundwater Monitoring Network wells for round 1 sampling only: total dissolved solids (TDS), gasoline range organics (GRO), diesel range organics (DRO), odor & sheen screen, total organic carbon (TOC), methylene blue active substances (MBAS), biological oxygen demand (BOD), chemical oxygen demand (COD), and total Kjeldahl nitrogen (TKN).
MTBE will be added to the list of compounds analyzed in the Method SW8260B volatile organics analysis. This change is made as a result of a request by ADEC to monitor for this compound at all wells in the Basewide Sampling Program for one year. |
Louis Howard |
| 9/12/2000 |
Update or Other Action |
Round 1 groundwater monitoring well results received. Methyl tert-butyl ether (MTBE) was added to the analyte list and was not detected in any wells. Manganese continues to exceed the secondary MCL of 0.05 mg/L at seven well locations. Manganese increased to above the MCL at well LF590MW-03. Trichloroethene continued to exceed the MCL at well LF59-MW-03. |
Louis Howard |
| 10/2/2000 |
Update or Other Action |
Quarterly progress report received for the 3rd quarter 1, July 2000-30 September 2000. Round 2 groundwater samples collected in August 2000. Processed work clearance requests for geophysical work on the Alaska Railroad Corporation realignment Project in August 2000. Manganese continues to be exceeded in seven wells and one well has Trichloroethylene (TCE) above the MCL. |
Louis Howard |
| 11/20/2000 |
Update or Other Action |
Base-wide Monitoring OU1 Round 2 report received. Trichloroethene (a.k.a. trichloroethylene): LF05-GW-1C not analyzed in round 2 but round 1 and 1999 rounds below MCL of 5 ug/L. LF59-MW-03 round 1 detected at 9 ug/L and round 2 increased to 10 ug/L. 1999 round 1 was at 11 ug/L and round 2 at 8 ug/L. W-6 was not analyzed in round 2 but was below 5 ug/L in round 1 and for both rounds in 1999. Manganese: LF05-GW-1C was not analyzed in round 2 but previous sampling ranged from 5.0 to 4.0 mg/L (MCL is 0.05 mg/L). LF05-MW-04 was the highest detected level of manganese at 14.0 mg/L. W-6 was not analyzed for manganese but levels in previous sampling was detected at 2.1 to 2.3 mg/L. |
Louis Howard |
| 12/15/2000 |
Document, Report, or Work plan Review - other |
Staff commented on the draft environmental baseline survey conducted by the Alaska Railroad Corporation for proposed rights-of-way which will pass through Landfill LF59. Comments emphasized that the cover material at LF59 must be reestablished where disturbed by the project. Institutional controls on the Base must be adhered to and observed for the project. The ARRC must acknowledge that the Base is listed on the National Priorities List and the Federal Facility Agreement addresses transfer of the property on Elmendorf AFB. Contaminated material must be properly screened in accordance with the UST procedures manual. |
Louis Howard |
| 1/12/2001 |
Update or Other Action |
Quarterly progress report received for October 2000 to December 2000. Round 2 groundwater results for Base-Wide Environmental Monitoring Program. Of ten wells sampled, Trichloroethylene (TCE) exceeded the MCL at well LF59-MW-03 at 10 micrograms per liter. Manganese was measured above the secondary MCL at five well locations. Reviewed and commented on draft Environmental Baseline Survey for the Alaska Railroad project. Next planned activities: continue long-term monitoring for base-wide groundwater, draft 2000 annual report of ground water sampling activities. |
Louis Howard |
| 1/30/2001 |
Update or Other Action |
Staff commented on the revised draft of the restoration and remediation plan for the realignment project. This is the first time ADEC has seen or commented on the plan for the project. Notice of the FFA and its applicability to the new right-of-way property must be included in the document and any right-of-way grant/temporary use permit. Excavated materials decision matrix which would have provided a stepwise guidance and contact information was missing from the document. Field screening must follow the UST Procedures manual for petroleum contaminants expected to be found at the site.
Segregation and stockpiling of contaminated soil must be less than two years unless the ARRC submits a stockpiling plan to ADEC for review and comment. ARRC must dispose of any hazardous wastes within a certain time frame (90 or 180 days after generation) or it may incur penalties for not disposing of the wastes in a timely manner. RCRA metals analyses: 6010B, 7080A, 7130, 7420, 7520 and 7910 are for high contaminant level screening only. These specific methods can be used for closure only if site specific method detection limits (MDL) criteria are met.
Analytical methods 6020, 7031A, 7060, 7061, 7081A. 7190, 7191, 7421, 7521 and 7911 are acceptable for closure. ADEC requests the ARRC, when possible, collect field screening samples directly from the excavation of the WRFL or from the excavation equipment's bucket. If field screening is conducted only from the equipment's bucket, then a minimum of one field screening sample must be collected from each 10 cubic yards of excavated soil. Because of the unusual size and shape of the ballast material, ADEC recommends that the ARRC take composite samples from four discrete locations in the WRFL spray area or excavation. |
Louis Howard |
| 2/1/2001 |
Update or Other Action |
Staff specified that the FFA review time of 30 days for draft documents would be applicable to documents generated for review on the Alaska railroad realignment project.
The Appendix F lacks specificity on methods that will be used in the field to manage potential solid and hazardous wastes that may be encountered during the construction of the line change. The matrix still does not provide the necessary detailed information on methods that will be utilized to characterize and manage solid and hazardous wastes that may be encountered during this project. ADEC requests the ARRC review the Remedial Investigation/Feasibility Study Management Plans for Operable Unit 1 Elmendorf AFB (May 1992) and Operable Unit A Fort Richardson (E&E 1995) to better understand what type of effort is expected for this project. Normally a sampling and analysis plan is developed and will describe the specific field investigations proposed at each source area, the type, number, frequency, and rationale for samples collected, sampling/environmental measurement procedures and equipment needs, sample handling procedures, and analytical requirements.
For information on data quality objectives, ADEC requests the ARRC review the following for developing DQOs and incorporation into their Restoration and Remediation Plan: U.S. EPA Guidance for the Data Quality Objectives Process EPA/600/R-96/055 August 2000, U.S. EPA Guidance for the Data Quality Objectives for Hazardous Waste Sites (G-4HW) EPA/600/R-00/007 January 2000; and State of Alaska Underground Storage Tank Procedures Manual December 1999. |
Louis Howard |
| 2/13/2001 |
Update or Other Action |
Staff reviewed and commented on a draft Base-Wide Annual Groundwater Monitoring report. Main comments were to clarify regulatory requirements for sampling frequency under 18 AAC 75.345(h) and whether or not four consecutive sampling events below action levels is reason enough to drop the well from the monitoring program. There are there instances on Base where the criteria was met during four sampling events and after the fifth sampling event the results were above action levels. Staff recommended methyl tert-butyl ether (MTBE) be dropped from the sampling program (with the exception of one well) since it has not been detected in two consecutive sampling events above 7 ug/L. Where it was detected in well 703-WL-02 at 7 ug/L, ADEC has recommended continued monitoring for MTBE. |
Louis Howard |
| 2/26/2001 |
Update or Other Action |
Staff commented on the redline Final Restoration and Remediation Plan Anchorage to Eagle River Line Change.
Overall the document is a major improvement over the original draft document. ADEC has no further comments on the “redline” Final Restoration and Remediation Plan and approves it as submitted. It is ADEC’s understanding that the Restoration and Remediation Plan is a general scoping document for the contractor to review to get a general idea on the project’s scope.
The site-specific Project Management Plan (PMP), which will be developed at a later date, must include all of the items mentioned in section 4.1 Introduction: Sampling Analysis Plan, Quality Assurance Project Plan, Investigation Derived Waste Plan, Stormwater Pollution Prevention Plan, Spill Prevention Control and Counter Measures Plan.
The contractor must incorporate adequate review times for the above documents by the agencies prior to fieldwork commencing. ADEC requires that all draft documents shall be subject to a thirty (30) day period for review and comment. ADEC may extend the thirty (30) day comment period for an additional twenty (20) days by written notice prior to the end of the thirty (30) day period. Then the contractor has thirty (30) days to incorporate comments made by ADEC. After that time period a draft final version of the document will be resubmitted for review and comment. ADEC will have fifteen (15) days to review and comment on the draft final version of the document. If changes are not necessary, then the draft final version of the document will become the final version. |
Louis Howard |
| 3/28/2001 |
Update or Other Action |
Staff commented on the ARRC draft Environmental Management Plan. Use of maximum contaminant levels for BTEX are more appropriate under section 3.1.2 Groundwater than for surface water. For surface water cleanup criteria use Alaska's water quality criteria TAH and TAqH. ADEC requests that the reference to the 1991 guidance for NON-UST contaminated soil cleanup be replaced with 18 AAC 78.090 Site Characterization and Assessment which is used for both UST and NON-UST investigations. |
Louis Howard |
| 4/17/2001 |
Update or Other Action |
Overall, ADEC concurs with Elmendorf’s approach to reduce its groundwater monitoring costs while still providing protection to human health, safety, or welfare and the environment. With regards to decreasing the monitoring frequency in Operable Unit (OU) 1 to an annual basis, ADEC concurs. With regards to OU 6, ADEC recommends not discontinuing groundwater monitoring at well 703-WL-02 and to continue to monitor for methyl tert-butyl ether (MTBE). |
Louis Howard |
| 4/30/2001 |
Site Characterization Workplan Approved |
Final Environmental Project Management Plan received for the Track Realigment Project - Military Segment. Ongoing military environmental programs have documented locations where contamination is anticipated along the existing & proposed ROWs. Environmental subcontractors will be present during excavation in these areas to facilitate the identification of potential contaminants. The environmental subcontractor will be "ADEC-qualified" in accordance with the definition provided in ADEC 18 AAC 75. "ADEC qualified" person is defined in Section 4. The areas where this individual will be present include Operable Unit (OU)-1, locations of existing monitoring wells, Roosevelt Road Transmitter Site (RRTS), Ammo Storage Area A (Ammo A), & locations of wayside rail & flange lubricators (WRFLs).
The proposed ROW travels through portions of Landfill 59 (LF59), a 2.5-half acre landfill & a tar seep located in the southwestern region of OUL The tar seep was located adjacent to & north of the proposed ROW. LF59 received general refuse & construction debris from 1965 until 1983. LF59 is currently closed & capped. Numerous groundwater monitoring wells associated with restoration efforts exist in the vicinity of OU1. Groundwater flow beneath OU1 is generally to the southwest towards Ship Creek.
It is likely, given the routing of the proposed ROW, that portions of the above landfill will be encountered during construction. Impacted soil may also be encountered, depending upon the depth & extents of cut & fill operations associated with construction. Institutional controls established for OU1 will be maintained to the maximum extent practicable during the construction of the ARRC realignment.
Groundwater monitoring wells installed during various environmental investigations are present within the existing & proposed ROW. The realignment of the rail line will not affect the viability of wells within the existing ROW. Two groundwater monitoring wells (LF59-MW-01 & LF59-MW-06) are present within the proposed ROW. Monitoring well LF59-MW-01 is located such that the proposed ROW will pass directly over it. LF59-MW-06 is located such that it will be adjacent to the track within the proposed ROW. Several years of monitoring data have been obtained from each of these wells. This data is essential for regulatory compliance & for use in demonstrating achievement of established cleanup goals for site closure.
ARRC will have an "ADEC-qualified" person (ESO) present during excavation of OU'1. The soil evaluation program detailed in Section 4.2 will be followed at this site. If necessary, the construction contractor will separate contaminated soil into PCMSA under the direction of the ESO. A summary of existing environmental information for OU-I is presented in Section 2.1.1. Prior to excavation for the proposed ROW, additional sample(s) of the ash-like material within the OU1 LF-59 landfill area which had a benzene concentration of 0.187 ppm (see Section 2.1.8.2) will be collected & analyzed in accordance with the sampling protocol in Section 4.2.
Based on the results of the geotechnical borings in this area, it does not appear that significant contamination or debris will be encountered. However, the potential to encounter hazardous materials cannot be ruled out, the results of all geotechnical borings, groundwater elevation data, & the results of groundwater sampling will be made available to the construction contractor & the ESOs. Table 4-1 shows possible materials that may be encountered at OU-1 & general handling guidelines to be followed. Disposal of munitions & ordnance has not been documented at OU-1; they are included in Table 4-1 for completeness only.
The integrity of the landfill cap will be maintained according to ADEC 18 AAC 60. LF59 is considered a class 3 landfill requiring a 2-foot unspecified soil cap. In areas where the cap is disturbed, the area will be back excavated & 2 feet of clean fill replaced & sloped to ensure proper drainage from the new cap. |
Louis Howard |
| 5/2/2001 |
Update or Other Action |
Staff commented on and approved the base-wide environmental monitoring plan for the facility. |
Louis Howard |
| 7/11/2001 |
Update or Other Action |
After a site inspection of the ARRC realignment area, it appears that the asphalt is once again seeping out of the hillside. A previous meeting with EPA, ARRC on June 11, 2001 was held and it was agreed that the ARRC will address any and all seeps of asphalt coming out of the ground in its right of way. Also it was agreed that the asphalt contaminated soils uncovered in the railroad bed area during cut and fill (if not free flowing or pure asphalt seepage) would be reused as fill material in the railroad bed. The asphalt contaminated material would be certified by the ARRC as acceptable for its purpose as fill material for the railway bed and not to be located any closer than 12 feet from existing ground surface. |
Louis Howard |
| 11/19/2001 |
Update or Other Action |
Staff reviewed and approved the draft final management action plan for FY01. |
Louis Howard |
| 2/21/2002 |
Document, Report, or Work plan Review - other |
Staff reviewed the draft base-wide annual groundwater report and provided comments on it.
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).
Benzene and Trichloroethylene (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 |
| 11/18/2002 |
Update or Other Action |
Staff reviewed and commented on the base-wide institutional controls (ICs) management plan for the Base. 1.2.2 Environmental Restoration Program Page 1-2: The text states that no ICs are associated with the State Elmendorf Environmental Restoration Agreement (SERA) program. The Department requests the Air Force clarify how it will implement and manage ICs at sites not in the CERCLA program, such as those sites in the environmental restoration and compliance programs, where ICs would normally be required. For example, sites requiring ICs would include those sites where long-term groundwater or surface water monitoring is being conducted, or sites where monitored natural attenuation (MNA) is being considered/have been established, or where alternative cleanup levels are being considered or have been established.
The Department is in receipt of a compliance program document which identifies several compliance sites where MNA was identified as a remedy. In order for MNA to be accepted by the Department for any site, it will require that ICs be in place and enforceable on the impacted soils and/or groundwater until cleanup levels have been achieved.
Additionally, preliminary data results for the ST401 investigation were obtained during a project manager meeting held on November 12, 2002. The data shows that groundwater results from two monitoring wells located upgradient of two groundwater seeps are contaminated with diesel range organics (DRO) above cleanup levels. Specifically, wells 401-WL-03 and 401-WL-04 had 38.6 mg/L and 13.2 mg/L DRO detected in the groundwater. Residual range organics (RRO) results could not be conclusively ruled out for well 401-WL-03 since the detection limit was above the Table C cleanup level. In view of this new data, the Department will require continued monitoring in the OU5 area for DRO and RRO in addition to the other petroleum constituents that are being monitored.
If monitoring for petroleum fuel range constituents will not be conducted under CERCLA as a part of the base-wide program, then the Department will require groundwater monitoring be conducted under environmental restoration/compliance programs as required by 18 AAC 75 Contaminated Sites regulations (see 18 AAC 75.335 Site Characterization, 18 AAC 75.345(g-j)) and 18 AAC 78 Underground Storage Tank regulations (see 18 AAC 78.235 Release Investigation and 18 AAC 78.615 Groundwater and Surface Water Sample Number and Location). |
Louis Howard |
| 1/14/2003 |
Meeting or Teleconference Held |
Meeting minutes from January 14, 2003 meeting with Joe Williamson (USAF), Gary Fink (USAF), James Klasen (USAF), Kevin Oates (EPA), Louis Howard (ADEC), Cory Hinds (URS), Paul Dworian (URS), Kristin Paul (URS)
Discuss ADEC’s request to add the analyses of Diesel Range Organics (DRO) and Gasoline Range Organics (GRO) to several Operable Units at Elmendorf.
1. URS summarized recent (year 2000) ADEC risk assessment guidance that shows that DRO and GRO themselves can cause noncarcinogenic human health risks. This information was not known during preparation of the risk assessments and RODs for Elmendorf Operable Units. Therefore, addition of DRO/GRO to the sampling scheme for Elmendorf was recommended.
2. The Air Force agreed to add DRO/GRO, but cannot add funding to cover the additional analysis until 2004.
3. The following was decided on implementation:
A. This decision will be documented in the 5-Year Review. The addition of DRO/GRO to the program should be introduced in the 5-Year Review under mention of new issues affecting protectiveness.
B. The Air Force will NOT add DRO/GRO as a CERCLA ARAR, but will compare DRO/GRO results to ADEC cleanup levels in the annual reports and will discuss in subsequent 5-Year Reviews. The benefit of this is that if CERCLA COCs meet ARARs, the Air Force can achieve a partial delisting.
C. The Air Force will add DRO and GRO to the suite of analyses at monitoring wells associated with fuel plumes starting in 2004.
D. The Air Force will not pursue a decision document with ADEC on DRO/GRO until more data is gathered on the extent of the problem.
E. Until a decision document is signed with ADEC, GRO and DRO concentrations will be compared to ADEC regulations in 18 AAC 75 (Table C, Groundwater Cleanup Levels; 1,500 µg/L for DRO, 1,300 µg/L GRO).
F. Sampling frequency for DRO/GRO will follow the latest Decision Guide for Sampling Frequency (see 2002 Basewide Annual Report). “Immediately upgradient” means within a 2-year warning line, similar to that generated for OU5.
G. ADEC GRO/DRO criteria apply to groundwater, not to seeps which daylight as surface water. Criteria in 18 AAC 70 (TAH, TaqH) apply to surface water. |
Louis Howard |
| 1/31/2003 |
Update or Other Action |
2002 Annual Report Basewide Environmental Monitoring Program Draft January 2003 received. Note to file under:
ARARs
This data-reporting category addresses groundwater constituents for each individual program area
specifically identified as COCs. The original list of cleanup levels for each program area is listed in Table 2-1. These chemical-specific cleanup levels were identified either in decision documents prepared for these sites (FFA program areas) or as contaminants which were found to significantly exceed cleanup levels where groundwater COCs were not specifically identified in previous investigations (SERA and Taxiway “N” program areas). Source documents that listed cleanup levels are referenced in Section 4.
Within the context of the Basewide Program, the list of COCs for each program area can change
as data are continuously evaluated and the quality of data improves with new methods. For instance, as natural attenuation occurs, select constituents will reach cleanup levels and additional monitoring for that constituent will not be required unless mandated by a regulatory agreement. Specifically, if a COC is below cleanup levels for two consecutive sampling rounds, sampling for that COC can be discontinued.
Similarly, if cleanup levels for all COCs in a given analytical method are met across an entire program area, analysis using that method in that program area will no longer be required. An exception to the above guideline is made for OU 5. Because OU 5 serves as the downgradient receptor for most of the other program areas, COCs will not be eliminated from OU 5 unless the COC in question has been similarly eliminated first from all upgradient program areas. |
Louis Howard |
| 2/6/2003 |
Document, Report, or Work plan Review - other |
Staff reviewed and commented on the annual report for base-wide environmental monitoring dated January 2003.
General comments - The document states in several areas that cleanup levels may not be met as predicted by the groundwater model used by the Air Force. The Department requests clarification on whether a memo to the file or an explanation of significant difference will be created for each operable unit that groundwater will not meet the predicted cleanup goal deadline or where it is stated in the document “…it is unlikely that this (cleanup) goal will be met.” (e.g. OU 6 page 3-47).
A single monitoring well with contamination above cleanup levels does not necessarily delineate the extent of a plume in the groundwater as presented in this document (e.g. SP1-02, OU5MW-02, LF59-MW-03, OU3MW-25, 62-WL-05, 64WL-01). Typically, if the direction of groundwater flow is known, at least three monitoring wells must be installed and sampled, one upgradient and two downgradient of the potential contamination source. If the direction of groundwater flow is unknown, it is recommended that the number of wells installed be sufficient to characterize the groundwater flow using horizontal and vertical control measures; at least three monitoring wells must be installed and sampled.
The Department recommends the Air Force either install enough wells for the adequate plume delineation for these point source plumes or state that these plumes are merely inferred and do not reflect the extent of contamination present in the groundwater. Alternatively, the single well plumes presented on Plate 4 could be reflected by dashed lines rather than clearly delineated plume shading.
3.1.4 OU 1 Conclusions and Recommendations Page 3-5: The text states it is recommended to continue sampling for manganese at OU 1 until 2004 and at that time, if manganese levels remain below cleanup levels, remove it from the sampling scheme. The Department concurs with this recommendation and others found in this section.
3.2.3 OU 2 Conclusions and Recommendations Pages 3-10 and 3-11
In general, the Department concurs with the recommendations made in this section. The text states that revising and/or recalibration of the ST41 model will be done to generate estimates for natural attenuation that match groundwater concentrations at the site. The Department concurs, however, has the following recommendations for the Air Force to consider in its selection of a new model, if that what the Air Force is considering in its recalibration efforts for ST41.
1.The model should provide conservative predictions. With the uncertainty in model parameters and unknowns in subsurface (for example, a few fractures are always present in a porous medium) conservative prediction is critical.
2.The model should be technically sound and legally defensible.
3.The model is within the public domain and not considered a proprietary modeling program.
4.Model information and reviews are published in reputable technical journals.
5.The model has received adequate peer review.
See site file for additional information. |
Louis Howard |
| 5/27/2003 |
Update or Other Action |
Staff reviewed and commented on the draft environmental monitoring plan for base wide groundwater sampling. Staff requested the Air Force include DP98 monitoring wells in the monitoring program as soon as possible. Contaminants of concern would include those identified in the DP98 Remedial Investigation/Feasibility Study (RI/FS) for groundwater such as: benzene, ethylbenzene, diesel range organics, gasoline range organics, vinyl chloride and other chlorinated solvents. |
Louis Howard |
| 7/17/2003 |
Document, Report, or Work plan Review - other |
Staff reviewed and commented on the second draft five-year review for Elmendorf's Operable Unit (OU) OUs 1, 2, 4, 5, 6. Section 121 of CERCLA, as amended by the Superfund Amendments and Reauthorization Act of 1986 (SARA), requires that remedial actions which result in any hazardous substances, pollutants, or contaminants remaining at the site be subject to a five-year review. The National Oil and Hazardous Substances Pollution Contingency Plan (NCP) further provides that remedial actions which result in any hazardous substances, pollutants, or contaminants remaining at the site above levels that allow for unlimited use and unrestricted exposure be reviewed every five years to ensure protection of human health and the environment.
"Elmendorf 1991 Federal Facility Agreement XIX: 19.1-If a remedial action is selected that
results in any hazardous substances, pollutants, or contaminants remaining at the Site, the Parties shall review such remedial action no less often than each five (5) years after the
initiation of such remedial action to assure that human health and the environment are being protected by the remedial action being implemented. The U.S. EPA Project Manager and the ADEC
Project Manager shall advise the USAF Project Manager of their findings in this regard."
The requirement applies to all remedial actions selected under CERCLA §121. Therefore, sites with CERCLA remedial actions may be subject to a five-year review. Consistent with Executive Order (EO) 12580, other Federal agencies are responsible for ensuring that the reviews are conducted at sites where five-year reviews are required or appropriate.
The text makes several recommendations and follow-up actions for various operable units. The Department suggests the Air Force formalize these recommendations or follow-up actions in either a separate technical memorandum or separate formal document, as appropriate, to EPA and ADEC for concurrence or non-concurrence to be placed in the administrative record.
General comment: OU (matrix and units) listings are not consistent with the rest of the document. Operable unit 4 is listed as OU 4 instead of “OU4” as is Operable Unit 5 and 6 which are listed as OU 5 and OU 6 instead of OU5 and OU6. Please correct this to be more consistent within the document. The Department requests clarification on the origin of the OU 4 soils cleanup level for 4, 4-DDT at 34 mg/kg. In 18 AAC 75.341 Table B-1 states that DDT has a cleanup level for ingestion in the Under 40-inch zone of 24 mg/kg. Additionally, for OU 5, Di-n-butyl phthalate and Diethyl phthalate have 2,700 ug/L and 23,000 ug/L listed as groundwater cleanup levels in the table.
In 18 AAC 75.345 Table C, the groundwater cleanup levels listed for Di-n-butyl phthalate is 3.65 mg/L or 3,650 ug/L and for Diethyl phthalate it is listed as 29.0 mg/L or 29,000 ug/L. Please correct Table B-1 to reflect the correct cleanup levels or provide justification as to leaving the cleanup levels unchanged.
General comments: The Department requests changing the column heading for Current Applicable Standard (Table B.1.) to include Table C or drop Table B.1 reference and leave it as Current Applicable Standard. Otherwise, the reader will infer that Table B.1 (Soil Cleanup Levels) applies to groundwater cleanup levels, which is incorrect. Also, see comment above regarding OU labeling within Table B-2 to match rest of the document (e.g. OU1 vs. OU 1). See comments above regarding cleanup levels for: 4, 4-DDT, Di-n-butyl phthalate, Diethyl phthalate.
General comment: Also see comment regarding Operable Unit labeling within the table to match rest of the document (e.g. OU1 vs. OU 1). The Department requests that the origin of the cleanup levels for the three OU 4 contaminants of concern be clarified. The Table B1 soil cleanup inhalation values for: 1,1,2-Tricholorethane is 460 mg/kg not 457 mg/kg, benzene is 9 mg/kg not 8.64 mg/kg, and for methylene chloride it is 180 mg/kg not 457 mg/kg. Please correct text in Table B-3. |
Louis Howard |
| 10/31/2003 |
Update or Other Action |
2003 Annual Activities Addendum received which provides evaluations of various Basewide Groundwater Monitoring Program (the "Program") components and details field activities to be performed this year. Plume-specific monitoring, well sampling, well installation, and well abandonment activities are described in the 2003 Addendum.
Groundwater resources beneath Elmendorf AFB are tainted with a variety of contaminants at several locations. In an effort to more efficiently direct remedial efforts, individual groundwater plumes have been evaluated and ranked. Recommendations for each plume have been provided based on these rankings.
An ongoing part of the Program is a reevaluation of these rankings in the yearly Addendums. As such, Elmendorf AFB groundwater plumes will be re-ranked in the annual Addendums based on current analytical results and plume recommendations will be modified as required.
The Elmendorf AFB plumes have been ranked and prioritized based on the following four categories:
* Migration characteristics (is the plume considered to have reached equilibrium, i.e., is it stable or unstable?);
* Location (is the plume in an interior location or near an Elmendorf AFB boundary?);
* Presence of free product (is free product present in recoverable quantities?); and
* Are COCs going to be beneath cleanup standards within ROD-specified timelines (is natural attenuation occurring at a rate such that ROD-specified cleanup dates will be met?).
Plume rankings will be adjusted in annual addenda, as their characteristics change. Plume recommendations will subsequently be reformulated to reflect these changes. Within the context of this Program, the list of monitored COCs for each plume can change as data are continuously evaluated and the quality of data improves with new methods. For instance, as natural attenuation occurs, select constituents will reach cleanup levels and additional monitoring for that constituent will not be required unless mandated by a regulatory agreement. Specifically, if a COC is below cleanup levels for two consecutive sampling rounds, sampling for that COC can be discontinued. However, it will still remain on the original list of COCs. Similarly, if cleanup levels for all COCs in a given analytical method are met across an entire plume, analysis using that method in that plume area will no longer be required. As such, while no COCs are ever "dropped" from the Program, routine monitoring for COCs can change.
An exception to the above guidelines concerning the removal of COCs is made for OU 5. Because OU 5 serves as the downgradient receptor for most of the other program areas, routine monitoring for COCs will not be discontinued at OU 5 unless monitoring for that COC has been has been similarly discontinued first from all upgradient plumes.
It is recommended that future wells intended to monitor gasoline range organics (GRO) and/or diesel range organics (DRO) for the Program be completed such that their screen interval straddles the mean water table. This may take some extrapolation from the onsite geologist if water levels are higher or lower than normal at the time of installation, but a comparison of historical groundwater elevations in vicinity wells will aid this process. When fuels dissolve, they will behave in the same manner as local groundwater. In the non-aqueous phase, benzene, toluene, ethylbenzene and xylenes (BTEX), GRO and DRO will float. Light non-aqueous phase liquids (LNAPL) such as these will be detected as floating product in wells screened in this manner.
Non-aqueous phase chlorinated solvents such as Program COCs trichloroethene (TCE), tetrachloroethene (PCE) and 1,1,2,2-PCA are all heavier than water and will sink. To check deeper locations for chlorinated solvents, a deep well will be installed in the Fairchild (OU5MW-38) TCE plume in an effort to define vertical profile of this plume (Section 5.2). This well will proceed down to the underlying Bootlegger's Cove clay formation where a grab sample will be collected from the clay at the bottom of these borings. Additionally, an undeveloped groundwater sample will be collected from OU5MW-38 after completion.
Screen location recommendations for wells monitoring chlorinated solvent plumes will be dependent upon the findings gathered from this well. If dense non-aqueous phase liquid (DNAPL) is found during this fieldwork, it will be recommended that subsequent wells be placed near the Bootlegger's Cove formation. They will be screened below the water table and located near the bottom of the aquifer. If no DNAPL is found, the recommendations for screen locations in chlorinated solvent plumes will mirror those for wells targeting fuel constituents. Although these heavier chlorinated solvents will not be found as LNAPL, the low concentrations of dissolved phase contaminants will not require deep wells.
See site file for additional information. |
Louis Howard |
| 1/27/2004 |
CERCLA ROD Periodic Review |
Five-Year Remedy Review conducted by USAF to ensure that the remedial actions selected in the Record of Decision (ROD) for the operable unit (OU) remains protective of public health, the environment and are functioning as designed. Consistent with the FFA, the project managers for the EPA and the State of Alaska Department of Environmental Conservation (ADEC) have participated in this review. This review is limited to only those sites being remediated under CERCLA authority. 1991 EAFB FFA actually states: "19.1 If a remedial action is selected that results in any hazardous substances, pollutants, or contaminants remaining at the Site, the Parties shall review such remedial action no less often than each five (5) years after the initiation of such remedial action to assure that human health and the environment are being protected by the remedial action being implemented. The U.S. EPA Project Manager and the ADEC Project Manager shall advise the USAF Project Manager of their findings in this regard. If any Party determines that additional action is required, the Agreement may be amended pursuant to Part XXXIII. If the Parties are unable to agree on the need to amend this Agreement, dispute resolution under Part XXI shall be available to any Party."
OU1 ROD states that land use controls will continue until groundwater cleanup goals are reached. Currently at OU1 groundwater cleanup goals have been reached at LF05, LF07, LF13, OT56 and the land use controls at these sites within OU1 will expire once a closure document for these sites are signed (by EPA, ADEC and AF). After LF05, LF07, LF13, OT56 closure document is signed, then land use controls will be in effect for LF59 only. In OU1, cleanup levels have been met at sites LF05, LF07, LF13 and OT56. Wells at these sites should be removed from the Base wide Groundwater Monitoring Program and the sites are recommended for closure. However, TCE and manganese are the only remaining COCs at OU1 at LF59 (LF59-MW-03).
A comparison of historical and current state or federal criteria found newly promulgated standards for 1,1,2,2-tetrachloroethane and PCBs in groundwater. PCB was detected in one well during the preparation of the ROD and subsequent sampling events failed to confirm the presence of PCBs; therefore the data was not validated and the remedy is considered to remain protective for this COC. For 1,1,2,2-tetrachloroethane, the current maximum detected level of 18 ug/L in well LF59-MW-03 is higher than the new standard of 4 ug/L; however, the calculated risk of 5 x 10 -5 is within EPA's risk management decision range. Protectiveness of the remedy for this compound is further assured because toxicity data and exposure assumptions have not changed for it, results are regularly received as part of the VOC analytical suite for COCs at this site, the remedy appears to be effectively remediating similar compounds (like Trichloroethylene (TCE), 1,1,2,2-tetrachloroethane is a chlorinated solvent and follows a similar natural attenuation process.). Toxicity information has changed for trichloroethylene (TCE) and vinyl chloride. Based on updated information in the scientific literature, there is a more stringent cancer slope factor for vinyl chloride and a provisional cancer slope factor for TCE that has been calculated by EPA. Despite this, the standards specified in the ROD are still within EPA's risk management range for these compounds.
Progress since the last 5YR Review-No areas of non-compliance were identified during the first review in 1998. At that time, all remedies were protective of human health and the environment and LUCs adequately prevented potential exposure to contaminants present in soil and shallow aquifer. No recommendations for follow-up actions were made during the 1998 review. The USAF agreed, during a meeting with EPA and ADEC on January 14, 2003, because both DRO and GRO have been shown to be associated with non-carcinogenic human health risks since the signing of the RODs, funding will be included to add DRO and GRO to the sampling scheme of the Base wide Groundwater Monitoring Program. This will apply at wells associated with fuel plumes. It was also agreed that until a decision document is signed with ADEC, concentrations will be compared to the current cleanup levels of 1,500 ug/L and 1,300 ug/L for DRO and GRO respectively (18 AAC 75) in annual reports and subsequent five-year reviews. The USAF will not be required to add DRO and GRO as a CERCLA ARAR. |
John Halverson |
| 7/2/2004 |
Update or Other Action |
Final version of the Site Closure Report for Operable Unit (OU) 1 source areas. The purpose of this final Site Closure Report is to document that all remedial actions and objectives specified in the Record of Decision (ROD) for sites LF05, LF07, LF13, and OT56 within Operable Unit 1 (OU1) at Elmendorf Air Force Base (AFB), Alaska have been met in accordance with the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) of 1980, as amended by the Superfund Amendments and Reauthorization Act (SARA) of 1986 and the US Environmental Protection Agency’s (USEPA’s) Office of Solid Waste and Emergency Response (OSWER) Directive 9355.3-01.
These remedial actions consist of: 1) long term groundwater monitoring; 2) performance of five-year reviews to assess the protectiveness of the remedial action; 3) periodic evaluation of analytical results; and 4) maintenance of Land Use Controls (originally referred in the ROD as institutional controls) restricting access to shallow groundwater. The USEPA and the Alaska Department of Environmental Conservation (ADEC) agree that the actions in place are protective of human health and the environment, and that these four sites (LF05, LF07, LF13, and OT56) within OU1 are eligible for closure.
Groundwater monitoring for OU1 began on May 22, 1995. Two of the COCs, EDB and vinyl chloride, were below detection limits and cleanup goals during the 1996 and 1997 sampling events and were subsequently dropped as COCs at that time. Concentrations of TCE in these wells have never exceeded the MCL (NOTE: This is not true. In wells downgradient from LF07 and LF13 (OU1-LF21, LF05GW-2B, OU1LF-19) have sample results that are above the RAOs for TCE (Wells LF05GW-2B & OU1LF-19 have results from 2006, 2007, 2008 and there were 4 groundwater grab sample locations in 2006 that are above the 5 ug/L TCE MCL) and , and manganese concentrations have been below the Applicable or Relevant and Appropriate Requirement (ARAR) for this metal for the past two consecutive sampling events. With the decline in manganese concentrations below the ARAR and the fact that none of other COCs exceed their respective MCLs, Sites LF05, LF07, LF13, and OT56 have achieved their cleanup objectives as defined by the ROD.
All of the completion requirements for Sites LF05, LF07, LF13, and OT56 have been met as specified in CERCLA and OSWER Directive 9355.3-01. Specifically: All required Land Use Controls have been established in the BGP and the MAP and have been administered by the Air Force; Site conditions and land use are consistent with the OU1 ROD requirements and remain protective, based on the results of the Second Five-Year Review Report; and All cleanup goals have been achieved (no longer true see above).
Based on the existing conditions, which do not pose a significant threat to human health and the environment, Sites LF05, LF07, LF13, and OT56 are deemed ready for closure. As such, they will no longer be subject to further Five-Year Reviews or OU 1 ROD specific Land Use Controls. |
Louis Howard |
| 2/3/2005 |
Meeting or Teleconference Held |
Elmendorf FFA XIII. REPORTING 13.1 USAF shall submit to the other Parties quarterly written progress reports. The reports will include, but not be limited to, the following information:
(a) A detailed summary of all of the remedial, removal, and investigation activities during the previous quarter, including any analytical results, any community relations activities, and any community contacts or inquiries related to the hazardous substance contamination at the Site; (b) An outline of the planned activities for the upcoming quarter;(c) A detailed statement of the manner and the extent to which the timetables and deadlines are being met;(d) The status of efforts to obtain rights-of-entry necessary for monitoring and well installation off base; and(e) The status of any other activities proposed or underway that may affect any phase of the activities described in the Attachments.
13.2 The quarterly written progress reports shall be submitted on the tenth (10th) day of each calendar quarter following the effective date of this Agreement.
Meeting minutes from RPM meeting February 3, 2005, ADEC and EPA agreed to decrease the frequency of quarterly reports to semi-annual or twice a year. h. 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 |
| 3/21/2005 |
Update or Other Action |
2004 Phase I RPO Annual Report (Draft Final) Groundwater Performance Optimization Monitoring Program received. The long-term monitoring plan for the LF59MW-03 Plume should focus on monitoring TCE concentrations to see if the trend direction changes from increasing to decreasing. To optimize performance monitoring at this plume, it is recommended that the following evaluations be performed on the LF59MW-03 Plume:
COC monitoring: COC monitoring for this plume is currently performed at one in-source well and one downgradient well. Monitoring network optimization and sampling frequencies should continue to be determined by using the decision guides presented in Appendix H.
Contaminant mass calculations: Contaminant mass calculations cannot be determined at this plume with any high degree of accuracy because LF59MW-03 is a two well plume. It is recommended that contaminant mass calculations not be performed at the LF59MW-03 Plume.
MNA monitoring: MNA monitoring at the LF59MW-03 Plume should be discontinued because it is not mandated by the OU 1 ROD.
Cleanup date predictions: Although this plume did not meet the early cleanup date of 1999, the OU 1 ROD allows remedial activities to proceed at this plume until a late cleanup date of 2024. It is recommended that SourceDK Tier 1 be used to predict a LF59MW-03 Plume cleanup date for comparison. Milestones should be manually developed when this date is known.
Remedy protectiveness summary: Land use controls and COC monitoring is the selected remedy at the OU5MW-02 Plume. This remedy should be considered protective of human health and the environment. Although a predicted cleanup date does not exist, COC concentrations are decreasing, plume expansion is not occurring, and potential downgradient receptors are not being exposed to groundwater contaminants.
It is recommended that the COC monitoring network be reevaluated with existing decision guides and a new cleanup date be calculated during the summer of 2005. This exercise should be performed and the findings should be submitted as a stand-alone report before the 2005 Annual Report is prepared. The results of the reevaluation would not be generated in time to guide field activities during 2005, but would be available to influence recommendations in the 2005 Annual Report.
|
Louis Howard |
| 4/1/2005 |
Document, Report, or Work plan Review - other |
The Alaska Department of Environmental Conservation (ADEC) received the document on March 21, 2005. Below are ADEC’s comments on the document.
General Comments-Typically, delineating a plume of contaminated groundwater takes more than one well in the source area. ADEC requests the Air Force redraw boundaries for “plumes” in the following figures where one well is defining a “plume” of contaminated groundwater with a bold line and replace it with a dashed line to show it as being “inferred” or “interpreted” rather than a distinct boundary.
Zone 1
Figures 3.2-1 and 3.3-1 for wells: OU6MW-46 and OU6MW-63
Figure 3.3-3 for well OU6MW-46
Figures 3.5-1 and 3.6-1 for well ST41-10R
Figure 3.9-1 for wells: OU6MW-46 and OU6MW-63
Figure 3.10-1 for well OU6MW-46
Zone 2
Figure 4.1-1 for well 59WL-31
Figure 4.3-1 for well SP7/10-04
Figures 4.3-1 and 4.5-1 for well OU4MW-04
Figure 4.6-1 for well OU4MW-08R
Figure 4.7-1 for IS6-01
Figures 4.9-1 and 4.10-1 for wells: SP7/10-04 and W-4
Zone 3
Figure 5.3-1 for well OU3MW-25
Figure 5.5-1 for wells: 60WL-04 and 64WL-01
Figure 5.6-1 for wells: 64WL-01 and 62WL-05
Figure 5.10-11 for well LF59MW-03
3.2.4 Phase I RPO Conclusions and Recommendations-Verifying that plume expansion is occurring with one monitoring well is nearly impossible to do without additional monitoring wells. The text states that the OU6 ROD mandated 5-year reviews be performed to evaluate the performance of the selected remedy (MNA). However, the recommendation in this section for MNA monitoring states MNA assessments cannot be accurately performed at one-well plumes. Also the text states plume expansion is not occurring and potential downgradient receptors are not being exposed to groundwater contaminants. ADEC requests clarification on how it can be demonstrated with one monitoring well that downgradient receptors are not being exposed to groundwater contaminants and whether or not it can be shown a plume is expanding or shrinking when sampling data is limited to one well.
The comments above apply to: PL81 South Plume (Section 3.3.5), ST41 North Plume (Section 3.5.4), 59WL-31 (Section 4.1.5), Hangar 10 Plume (Section 4.5.4), Hangar 11 Plume (Section 4.6.4), OU4 East Plume (Section 4.7.5), SS43 Plum (Section 4.9.4), W4 Plume (Section 4.10.4), OU3MW-25 Plume (Section 5.3.4), and SP01-2 Plume (Section 5.8.4).
7.0 Phase I RPO Recommendations Summary Page 7-1
ADEC concurs with updating the conceptual site models for inclusion in the 2005 Program Baseline Calculations Report.
7.1 Plume-Specific Recommendations
ADEC concurs with the plume-specific recommendations listed in this section which are not provided in Table 7.1-1. |
Louis Howard |
| 11/1/2005 |
Update or Other Action |
As a result of the 2005 BRAC, Fort Richardson and Elmendorf AFB were realigned and created JBER as of October 1, 2010. “BRAC" is an acronym which stands for base realignment and closure. It is the process DoD has previously used to reorganize its installation infrastructure to more efficiently and effectively support its forces, increase operational readiness and facilitate new ways of doing business. DoD anticipates that BRAC 2005 will build upon processes used in previous BRAC efforts.
The Base Realignment and Closure (BRAC) Commission in 2005 recommended the transfer of installation support functions of Ft Richardson to Elmendorf AFB establishing Joint Base
Elmendorf-Richardson. The recommendation became law in November 2005.
Realignment
Includes any action that both reduces and relocates functions and civilian personnel positions, but does not include a reduction in force resulting from workload adjustments, reduced personnel or funding levels, or skill imbalances.
Fort Richardson and Elmendorf Air Force Base were realigned to form Joint Base Elmendorf-Richardson (JBER) which became fully operational on 1 October 2010. Joint Base Elmendorf-Richardson met the milestone of Full Operational Capability, Friday, as mandated by the 2005 Base Realignment and Closure law.
FOC means JBER has merged installation management functions and assets to become the sole provider of support, services and a home to more than 40,000 Airmen, Soldiers, family members, retirees and civilians.
Joint Base Elmendorf-Richardson will be commanded by an Air Force colonel with an Army colonel as a deputy. As for the commanders of the Service specific missions (e.g. 3rd Wing and U.S. Army
Alaska, as well as other supported units), the current commanders will remain in charge of their units until they are replaced by follow-on mission unit commanders.
|
Louis Howard |
| 6/25/2007 |
Update or Other Action |
Received from the solid waste program a report for the: Characterization to Determine Nature and Extent of Groundwater Contamination OU 1 Landfill under Contract No. F41689-01-D-0013 / Delivery Order 5180. The contaminants of concern for this characterization were those found to statistically exceed the
protection standard in any well during assessment monitoring at the landfill. Those constituents include one metal (arsenic) and three volatile organic compounds (VOCs) (TCE, PCE, and vinyl
chloride).
All of the fieldwork planned to be performed in the work plan was performed during October of 2006, which included the following:
• Installed one new groundwater monitoring well;
• Collected groundwater samples from the new well, from the six downgradient monitoring wells currently in the assessment monitoring program, and from three additional existing groundwater monitoring wells located downgradient of those wells; and
• Collected groundwater grab samples at eight locations using a Geoprobe® Screen Point Sampler.
Arsenic concentrations ranged from undetected to 20 ìg/L in the eleven monitoring wells sampled (18 AAC 75 groundwater cleanup level is 50 ug/L).
TCE concentrations ranged from undetected to 27 ìg/L in the samples collected. Samples collected from wells LF05GW-2B, OU1LF-19, and grab sample locations SP-07, SP-09, SP-10,
SP-14, SP-15, SP-17, and SP-26 had concentrations exceeding the groundwater protection standard of 5 ìg/L.
PCE concentrations ranged from undetected to 17 ìg/L in the samples collected. Grab samples collected at SP-07, SP-09, SP-10, and one of the samples collected at SP-26 had concentrations
exceeding the protection standard of 5 ìg/L.
Vinyl chloride concentrations ranged from undetected to 2.5 ìg/L in the samples collected. Only three samples, collected from wells LF05GW-2B, SP-02, and the SP-02 field duplicate (FD), had
concentrations detected above the RL of 1 ìg/L. Only the field sample and field duplicate sample collected at SP-02 had concentrations exceeding the protection standard of 2 ìg/L. Vinyl
chloride results were not reported for the samples analyzed with the portable GC because detection limits were higher than the groundwater protection standard for vinyl chloride and the
purge and trap method is not considered a good method for analyzing the highly volatile constituent.
There is evidence to suggest that arsenic concentrations found in the groundwater downgradient of the Elmendorf AFB OU 1 landfill may be due to the reduction and increased solubility of the
naturally-occurring arsenic in the saturated zone soil.
At the northern plume, groundwater containing TCE and PCE with concentrations above protection standards does not appear to be originating at the landfill; there were samples collected between the landfill and the contaminated area that did not have concentrations of TCE or PCE above their protection standards. This suggests that the landfill may not be the source of
the contamination. Another explanation is that in the past a slug of contamination was released from the landfill, and the head of the contamination has moved downgradient over time. Some
residual TCE is found in well OU5MW-10, located upgradient of this plume, but no PCE is present in the well or other upgradient grab sample locations. Vinyl chloride was however detected in LF05MW-10 in 1992, and some residual remains, suggesting that any TCE or PCE upgradient of the well was naturally attenuating (reducing) to vinyl chloride by the time it reaches the well.
Overall, two groundwater plumes containing TCE above groundwater protection standards have been identified and their extent is well defined by this characterization. Questions
still remain, however, as to the exact origin of the contamination. The extent of the southern plume appears to be lengthened because the TCE concentration doubles after leaving the landfill
boundary. This suggests that the TCE contamination migrating from the landfill is merging with other TCE contaminated groundwater.
Overall, one groundwater plume containing vinyl chloride above groundwater protection standards was identified and its extent is well defined by this characterization. The contamination is likely present due to the reduction of TCE or PCE originating at the landfill. |
Louis Howard |
| 7/20/2007 |
Update or Other Action |
ADEC received the Management Action Plan (MAP) which describes the integrated, coordinated approach of conducting the
environmental restoration program (ERP) activities required at Elmendorf Air Force Base. A general overview of the installation and restoration sites is provided to assist in communicating with state and federal regulators and the public to develop a comprehensive and meaningful plan useful to all.
This MAP summarizes the status of the Elmendorf Air Force Base ERP and identifies specific program issues to promote effective investigation and cleanup strategies. The focus of the MAP is to get cleanup remedies in place (RIP) and to attain response complete (RC) as early as possible. Meeting RIP/RC schedules will ensure a corresponding reduction in risk. Consequently, the MAP presents a comprehensive strategy for funding and implementing response actions necessary to protect human health and the environment.
Formal updates to this MAP use data from the Air Force Restoration Information Management System (AFRIMS). The data in this MAP is taken from the AFRIMS database as of Thursday, July 19, 2007 Information and estimates provided on costs, schedules, relative risk, and remedial activities, do not necessarily represent those that have been, or will be approved, by the Air Force, state or federal regulatory agencies. The cost estimates are made based on best available information at this time, and may dramatically vary over time.
Currently, there are 85 source areas in the Elmendorf AFB ERP. These source areas include former landfills, petroleum storage tanks, waste disposal areas, fire training areas, fuel spills, a radioactive waste site, and old asphalt disposal areas. These source areas have been divided into three major divisions: CERCLA sources, state program sources, and other program sources. Thirty-eight of the 85 source areas are designated as
CERCLA sources. These sources have been grouped into several operable units (OUs) and remedial activities are being conducted under the FFA.
Forty -two source areas have been designated as petroleum, oil, and lubricant (POL)-contaminated sources and remedial activities are being performed under the State of Alaska cleanup regulations. These source areas have been grouped into solid waste (SW) sites, POL spills, and underground storage tanks (USTs). The POL spill and UST sources have been further grouped into Phase I, II, and III. The remaining five source areas are SW sites that were initially included in the ERP but were later determined to be Resource Conservation and Recovery Act (RCRA) sources. In regards to the ERP, these five SW source areas have been closed and transferred to the Environmental Quality Program. |
Louis Howard |
| 10/15/2008 |
Update or Other Action |
5 YR Review
The Compliance program commissioned a characterization study to determine the nature and extent of the groundwater contamination; this study was performed in 2006 (USAF 2007f). The study identified two chlorinated solvent plumes, including a TCE plume that appears to originate at or near LF07 and may be the source of TCE contamination at LF59. Compliance program monitoring showed that TCE concentrations continued to be elevated, though decreasing, at well LF05GW-2B in 2007 and 2008.
While the cause of the increased TCE concentrations downgradient of the landfill area is unknown, it is suspected that the evapotranspiration landfill covers may be causing changes to the hydraulics of the area. The full impact of the covers may not be realized until the plants reach maturity, which is predicted to occur approximately seven years after cap construction/planting (about 2013 for LF07). Monitoring at LF05GW-2B should continue, and the data should be used to evaluate potential impacts to the remedy effectiveness at LF59.
The remedy at OU1 is expected to be protective of human health and the environment upon attainment of groundwater cleanup levels, through natural attenuation, at one remaining site (LF59). In the interim, exposure pathways that could result in unacceptable riks are being controlled.
Two wells at OU1 were monitored under the CERCLA program during 2003 through 2007. Only one well, LF59-MW-03, contained TCE concentrations above the ROD-established cleanup level. Trend analysis indicates that the cleanup level at well LF59MW-03 will be reached by 2018, which is similar to the ROD-estimated cleanup date of 2024.
During the period from 2003 through 2007, 1,1,2,2-tetrachloroethane, a COPC in OU1 groundwater, was detected at concentrations up to 12 µg/L at sample location LF59MW-03 in 2005, and has been detected in this well since 1992. Since it is not a COC, there is no OU1 cleanup level for 1,1,2,2-tetrachloroethane. The 2003 Five-Year Review (USAF, 2003j) concluded that 1,1,2,2-tetrachloroethane concentrations at OU1 do not impact the effectiveness of the remedy. By 2007, the 1,1,2,2-tetrachloroethane concentration had decreased to 5 µg/L, probably due to natural attenuation processes.
Recommendations for changes in the OU1 monitoring program include:
• Incorporate data from upgradient wells LF05GW-2B and OU1LF-19 into evaluation of
contaminant trends for LF59.During the period from 2003 through 2007, 1,1,2,2-tetrachloroethane, a COPC in OU1 groundwater, was detected at concentrations up to 12 µg/L at sample location LF59MW-03 in 2005, and has been detected in this well since 1992.
Since it is not a COC, there is no OU1 cleanup level for 1,1,2,2-tetrachloroethane. The 2003 Five-Year Review (USAF, 2003j) concluded that 1,1,2,2-tetrachloroethane concentrations at OU1 do not impact the effectiveness of the remedy. By 2007, the 1,1,2,2-tetrachloroethane concentration had decreased to 5 µg/L, probably due to natural attenuation processes.
Recommendations for changes in the OU1 monitoring program include:
• Incorporate data from upgradient wells LF05GW-2B and OU1LF-19 into evaluation of contaminant trends for LF59.
Site Inspection
OU1 (LF59). All active monitoring wells were located and were in good condition. There was no evidence of unauthorized wells or site disturbance. Evapotranspiration covers have been installed on the other OU1 landfills (no longer part of the CERCLA program) between 2005 and 2007. Mr. Gary Fink, the USAF project manager for the OU1 landfills, estimates that plants on the evapotranspiration covers will be fully mature (i.e., evapotranspire potential recharge later at full capacity) after about seven years of growth.
Issues
Upgradient Plume: The TCE plume at LF59 appears to be originating, at least in part, from the upgradient OU1 landfills. There are insufficient data to determine the impact to long-term
groundwater quality and the estimated cleanup date at LF59.
Recommendations/Follow-up Actions
Upgradient Plume: Incorporate data from upgradient wells LF05GW-2B and OU1LF-19 into
evaluation of natural attenuation and analysis of contaminant trends, and update the conceptual
site model for the TCE plume at LF59.
The remedy at OU1 is expected to be protective of human health and the environment upon
attainment of groundwater cleanup levels at one remaining site (LF59). In the interim, exposure
pathways that could result in unacceptable risks are being controlled. |
Louis Howard |
| 2/27/2009 |
Update or Other Action |
ADEC (J. Roberts)sent a letter on the Final Five-Year Review Report to Air Force (D. Baumler). ADEC appreciates the opportunity to review the third Five Year Review report for the Elmendorf Air Force Base Superfund site, in Anchorage Alaska. ADEC reviewed this report for technical adequacy, accuracy, and consistency with EPA guidance and the Elmendorf Federal Facility Agreement. In general, ADEC agrees with the protectiveness determinations in this review for those source areas which a remedial action has been initiated with the exception of Operable Unit 1 (OU-1).
Operable Unit 1
ADEC agrees with the Air Force’s recommendation for further action at the OU-1 landfill area for the TCE groundwater contamination. However, after meeting with ADEC Solid Waste Program staff regarding ongoing groundwater monitoring and corrective measures to be taken at LF05, LF07 and LF13 and the five-year review for the Base, it appears there are some significant issues which need to be addressed.
ADEC disagrees with the Air Force regarding the installation of a landfill gas extraction and treatment system by its Compliance Program to address or prevent the migration of chlorinated solvents in groundwater downgradient from the OU-1 landfill cells. There is no technical reason that supports that the extraction of gas from landfill cells will address chlorinated solvents in groundwater at LF59, LF07 or LF13.
It appears the 2004 CERCLA Site Closure Document which was signed by the three agencies needs to be withdrawn. Data from CERCLA and Compliance Programs groundwater monitoring wells and Compliance Program groundwater grab samples shows there have been ongoing exceedances of the MCL in groundwater downgradient of LF07 and LF13 for several years. ADEC believes the CERCLA process is the necessary means to address this issue as soon as possible, either through the SS-022 Remedial Investigation or as a potential new source. Sites LF07 and LF13 are not meeting cleanup goals as specified in the 1994 OU1 ROD and the subsequent 2004 CERCLA Site Closure Document.
Pursuant to Paragraph 20.25 Page 42 and Part XXXIII of the 1991 Federal Facility Agreement (FFA), based on the Zone 3 2009 report and the supplemental information provided by the draft OU-1 Compliance Program Corrective Measures Study Report (2008), ADEC believes additional action is required. ADEC requests the three signatories to the FFA meet to discuss the relevance and appropriateness for additional action needed to address the sites (source areas) LF07 and LF13 under CERCLA instead of solely under the Air Force Compliance Program and State Solid Waste Program.
Signature page modification which shall be adopted with cover letter above or ADEC will not sign the five year review: The State of Alaska Department of Environmental Conservation's concurrence with the findings of this five year review, with the exception of Operable Unit 1 as noted in the State's February 27, 2009 cover letter, is based on the information presented in the accompanying Five-Year Review, Third Five-Year Review for Elmendorf Air Force Base. Signed Jennifer Roberts, Federal Facilities Program Manager ADEC Contaminated Sites on February 27, 2009. |
Jennifer Roberts |
| 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 |
| 3/20/2009 |
Meeting or Teleconference Held |
Meeting with EPA, Air Force and ADEC to discuss Five-Year Review, OU1 and Solid Waste Program corrective measures. After the Air Force briefed the attendees on what corrective measures it plans to take for the landfill cells (includes but not limited to LF07, LF05, LF13, OT56) for methane gas and chlorinated solvents in the groundwater as well as LF59 investigation under CERCLA, the State agreed it would sign the five year review. Assurances and promises were made by the Air Force to incorporate findings from the Solid Waste program corrective measures and long-term groundwater monitoring results with the CERCLA project managers to ensure that the measures are protective of human health and the environment. |
Louis Howard |
| 4/3/2009 |
Document, Report, or Work plan Review - other |
ADEC Jennifer Roberts signed the signature sheet for the US Air Force's Elmendorf 5-Year Review. Text: This signature sheet documents the State of Alaska Department of Environmental Conservation’s (ADEC’s) acceptance of the Third Five-Year Review Report for Elmendorf Air Force Base. As presented in the report, ADEC looks forward to working with Elmendorf and EPA to address chlorinated solvent groundwater plumes associated with the Operable Unit 1 Landfill. |
Jennifer Roberts |
| 4/13/2009 |
Update or Other Action |
Staff received for review: 2009 Zone 2 and Zone 3 Management Areas Work Plan. This work plan outlines the 2009 scope of work for four sites in the Zone 3 Management Area: ST37, ST48, ST68, and LF59. Site ST37 includes several discrete plumes including the Fairchild Avenue Plume, Kenney Avenue Plume, Slammer Avenue Plumes, OU3MW-25 Plume, OU5MW-02 Plume, and SP1-02 Plume. In addition to these plumes, Site ST37 includes groundwater seeps and surface water locations near the southern boundary of the base, the Beaver Pond, the Operable Unit (OU) 5 engineered
wetland remediation system (WRS), and the early warning and sentry well networks.
Zone 3 also includes operation, maintenance, and monitoring (OM&M) of the Restoration Staging Facility, which is also commonly referred to as the “Contractor’s Yard”.
The 1994 Record of Decision (ROD) for OU 1 specifies the selected remedy for LF59 as long-term groundwater monitoring until cleanup levels are met combined with land use controls (LUCs).
The approximately 1-acre site is located near the intersection of 1st Street and Arctic Warrior Drive in the southeast portion of Zone 3. The LF59 landfill contains refuse and construction debris and may have housed an asphalt batch plant.
Well LF59MW-02 will be used instead of LF59-06R to monitor conditions downgradient of LF59MW-03 Plume as this well is closer to the plume. Two wells for LF59 (OU1) will be used to monitor the plume/location LF59-03 on an annual basis. Contaminants of concern in the ROD/DD are TCE, 1,2-Dibromoethane, vinyl chloride and manganese. Currently as of 2008, only TCE is above cleanup levels in groundwater.
Estimated end date for LF59MW-03 (from 2007 RPO Report) is 2018. |
Louis Howard |
| 4/30/2009 |
Document, Report, or Work plan Review - other |
Staff provided comments on the Draft 2008 Zones 2 and 3 Management Areas Work Plan, March 2009
for Elmendorf Air Force Base, Alaska.
SOP #13 Groundwater Sampling
Passive Diffusion Bag Sampling Attachment 1-31
ADEC concurs with the tasks and approach outlined in this section. There are some limitations regarding passive diffusion bag (PDB) sampling. Passive samplers do not provide direct or real-time data. PDB samplers cannot be used for all contaminants; metals and other inorganic compounds will not diffuse through the membrane. The general target is non-polar VOCs with a molecule size of less than 10 angstroms. Biofouling can make PDBs less effective. PDB sampling in monitoring wells relies on the presence of an uninhibited horizontal water flow.
Other factors, such as vertical flow, biofilms, or iron fouling may negatively affect the quality of PDB sampling data. Well stratification can be an issue even in wells with small screened intervals. If PDB samplers are used to identify the highest potential concentration in a well, numerous linked samplers may be needed to decide on the optimal placement of the final sampler.
SOP # 14 Subsurface Soil Sampling Attachment 1-34
ADEC requests the Air Force clarify text in the second paragraph regarding VOC/GRO samples collected concurrently will not be emptied into a stainless steel bowl for homogenization prior to filling the sample jars. |
Louis Howard |
| 10/15/2009 |
Meeting or Teleconference Held |
A meeting of the remedial project managers (RPMs) convened at 0900 on 15 October 2009 in the CEAN Conference Room, Building 5312, at Elmendorf Air Force Base (EAFB), Alaska. Attendees included: Mr. Jacques Gusmano (Environmental Protection Agency [EPA]), Mr. Louis Howard (Alaska Department of Environmental Conservation [ADEC]), Mr. Don Aide (CEANR), Ms. Donna Baumler (CEANR), Mr. Gary Fink (CEAN), Ms. Melissa Markell (CEANR), and Ms. Renee Wright (3 WG/PA).
Program Update. The following items were discussed:
a. Joint Base Elmendorf-Richardson (JBER) (Mr. Fink).
(1) General Atkins of the 11th Air Force has determined that joint basing will happen; this became official on 9 Oct 09 when the Memorandum of Agreement (MOA) was signed. JBER is everyone’s top priority, but our environmental responsibilities will not be neglected.
(2) MOA Annex G was distributed (Attachment 1). This annex addresses environmental responsibilities, with Restoration responsibilities detailed in the last paragraph on the second page.
(3) The JBER implementation plan for Restoration was distributed (Attachment 2). Mr. Fink pointed out Initial Operational Capability (IOC) and Final Operational Capability (FOC) dates. One date that did not appear on the plan was June 2010; this is when the new 673rd Air Base Wing command stand-up will occur.
(4) A memorandum is expected to be sent to the agencies soon regarding transfer of the Fort Richardson Federal Facilities Agreement (FFA) to the joint base. The joint base position is that the Ft. Richardson FFA does not need to be reopened because the only changes required are administrative, such as changing the name of the FFA manager. Currently, EPA’s position on who will be the EPA RPM(s) for the joint base is unknown.
(5) Mr. Gusmano explained that there are new CERCLA sites in Alaska, so EPA is scoring and evaluating site priorities, responsible parties, etc. New RPMs may be hired, and different RPMs may be assigned to existing projects. Nothing will be certain for JBER until the EPA evaluates what lands are included in, and excluded from, JBER.
(6) Mr. Gusmano explained that because JBER will have two FFAs and two NPL sites at a single installation, we need to be aware that if waste is removed from an NPL installation, it must go to a permitted Treatment, Storage, and Disposal (TSD) facility. In other words, we can’t consolidate soil from the two different bases. EPA is working to get a waiver for this technicality so efficiencies can be realized on the joint base. Mr. Gusmano added that since the waste would not cross or use a commercial thoroughfare, this may not even be a problem.
(7) Mr. Gusmano asked who is the JBER counterpart for the EPA and ADEC attorneys. Is it Jim Klasen? Mr. Fink wasn’t sure who the official attorney would be after joint basing, but Mr. Klasen is currently the attorney for environmental issues.
Presentation by Mr. Donald Aide.
(1) Mr. Aide distributed an RPM Meeting Presentation paper addressing the status of three projects.
The field work has been completed for the LF59 Field Investigation and Conceptual Site Model Update.
Almost all field work has been completed for the pipeline and bioventing decommissioning project; no contaminated soil has been found associated with the pipeline decommissioning work, but more contaminated soil than anticipated was found during hotspot removal at SD15. Soil excavation at SD15 is on hold until all other field work on this contract is complete to ensure that contract limits for soil excavation are not exceeded.
The MMRP CSE Phase II report is expected in December 2009. Three MRSs are expected to go to the Removal Action phase.
(2) Mr. Gusmano asked if CEANR was involved in reviewing the Environmental Impact Statement (EIS) for Eagle River Flats. Mr. Fink responded that we got two days to review an 800-page document, and this review task was taken over by the conservation staff. A discussion ensued about the planned future use of phosphorous at this still-active range site.
(3) Mr. Fink pointed out that the OT92 pipeline decommissioning project would meet the Air Force’s RIP goal. |
Louis Howard |
| 11/10/2009 |
Update or Other Action |
Draft MEMORANDUM TO THE SITE FILE Elmendorf Air Force Base Operable Units (OUs) 1,2,4, and 5 received. The minor revisions to the OU 1,2,4 and 5 RODs clarify how LUCs will be implemented and managed for activities within these operable units. In addition, this minor revision will correct inconsistencies to chemical specific ARAR in the Operable Unit 4 ROD. In 2003, the USAF published guidance for active installations entitled Air Force Policy on Performance-Based Records of Decision (RODs) for Land Use Control (LUC) Implementation (SAF/IE Memo, 7 Oct 03) requiring documentation of LUCs in administrative documents such as the ROD. LUCs are part ofthe selected remedies in the RODs for OUs 1,2,4, 5, and 6 and Site DP98. This Memorandum to the Site File uses the 2003 guidance to clarify how the USAF intends to implement the LUCs at OUs 1,2,4 and 5. The ROD for Site DP98 is compliant with USAF Policy. The ROD for OU 6 was updated to be compliant with the policy in an Explanation of Significant Difference dated 15 June 2007. The cleanup for OU3 is complete and no LUCs are in place as part of the remedy.
Land Use Control Performance Objective: Restrict land use and designate area for recreational use. Enforce base policy prohibiting installation of groundwater wells into the shallow aquifer.
Secure existing water supply and groundwater monitoring wells.
The Air Force is responsible for implementing, monitoring, maintaining, reporting on and
enforcing the identified controls. If the Air Force determines that it cannot meet specific LUC requirements, it is understood that the remedy may be reconsidered, and that additional measures may be required to ensure the protection of human health and the environment.
Some of the cleanup levels presented in the OU4 ROD Table 5-2 (Chemical specific ARARs for groundwater and soils) are inconsistent with their referenced standards. These are likely typographical errors. Specifically, the clean up levels for 1,2-dichloroethane, tetrachloroethene, and TCE at the FT23 are presented as 6 ug/L, but the source ofthe cleanup level is the drinking water maximum contaminant level (MCL), which was, and is, 5 ug/L for all of these chemicals (and also listed as 5 ug/L in Table 4-1 ofthe ROD). Also, the SD25 soil cleanup level values for GRO and DRO appear to be reversed. This Memorandum to the Site File establishes corrections to these inconsistencies.
Proposed Minor Change
OU1 - Implement LUCs, which include: Restrict land use and areas designated for recreational use. Enforce base policy prohibiting installation of groundwater wells into the shallow aquifer. Securing of existing water supply and groundwater monitoring wells.
OU2 - Maintain land use controls that restrict access to groundwater and groundwater development at the site: The specific institutional controls to be implemented and/or maintained at OU2 are as follows: Designate the affected area for outdoor/recreational use and
unmanned indu~trial use, excluding the development of commercial aquaculture; Continued enforcement of base policy prohibiting installation of groundwater wells (other than for monitoring purposes) into the shallow aquifer underlying OU2; and Prohibiting unauthorized access to existing water supply and groundwater monitoring wells.
OU4 - Institutional controls on land use and water use restrictions will restrict access to the contaminated groundwater throughout OU 4 until cleanup levels have been achieved. OU4 is designated "Airfield Use Area" for aircraft operations and maintenance, to include active and
inactive runways, taxiways, and parking aprons for aircraft.
Soil: Institutional controls on land use (also called LUCs) will continue to restrict
access to the contaminated shallow soils throughout OU 4 until cleanup levels have been achieved.
OU5 - Institutional controls (also called LUCs) that prohibit use of the upper aquifer will
ensure that people will not be exposed to contaminated groundwater until cleanup goals are achieved. |
Louis Howard |
| 12/1/2009 |
Update or Other Action |
Semi-Annual Progress Report received. SUMMARY OF WORK PERFORMED DURING LAST SIX MONTHS-Developed Work Plan for LF59 Field Investigation and Conceptual Site Model (CSM) Update (Jun 09), Received and distributed Final 2008 Annual Monitoring Report (Aug 09), Conducted annual groundwater monitoring (Sep 09)and Field activities for LF59 Field Investigation and CSM Update were completed (Nov 09)
PLANNED ACTIVITIES FOR NEXT SIX MONTHS-Finalize minor site letter for clarification of land use controls (LUCs) at OUs 1, 2, 4, and 5 (Jan 10), Distribute Draft 2009 Annual Monitoring Report (Feb 10), Distribute Draft Field Report and CSM Update (Mar 10), and Develop work plan for annual groundwater monitoring (Apr 10). |
Louis Howard |
| 2/16/2010 |
Update or Other Action |
Staff received the draft 2009 Zone 3 Management Area Annual Report Environmental Restoration Program. The depth to groundwater and total well depth were measured at wells LF59MW-02 and LF59MW-03 on 23 June 2009. The groundwater flow direction at Site LF59 is generally to the southwest consistent with base-wide historical data. However, the orientation of the contaminant plume, as defined during previous investigations, suggests a more west-southwest flow direction. The discrepancy between the direction of plume migration and the interpreted groundwater flow direction could be the result of preferential flow paths in the subsurface and/or a local flow direction that may deviate slightly from the regional direction. A LUC inspection conducted on 23 June 2009 identified no LUC issues at Site LF59.
Observations and recommendations for Site LF59: The 2007 RPO evaluation identified Site LF59 as a Yellow priority site because there are uncertainties associated with the predicted time to reach the cleanup levels given the information obtained through the compliance program (Solid Waste). Based on the 2009 groundwater analytical data at wells LF59MW-02 and LF59MW-03, TCE concentrations are still above the cleanup level of 5 ug/L. The non-detect result at well LF59MW-03 in 2008 appears to be an anomaly, and the TCE concentration detected in this well in 2009 (6.8 ug/L) is effectively equal to the 2007 concentration (6.6 ug/L). In addition, questions remain regarding TCE concentrations and potential upgradient source areas. Therefore, Site LF59 remains a Yellow priority at this time. As discussed in the 2007 RPO evaluation, the relationship between Site LF59 and source areas upgradient of this area should be evaluated. As part of this evaluation, the extents of the LF59 Plume should be revised based on data collected in 2010. |
Louis Howard |
| 2/22/2010 |
CERCLA ROD Periodic Review |
Final Memorandum to.the Site File for OUs 1,2,4, and 5 received. The purpose of this Memorandum to the Site File is to present non-significant or minor changes to the Record of Decision (ROD) signed for OUs 1,2,4, and 5. The minor changes to the OUs involve clarifying how the US Air Force (USAF) intends to implement the Land Use Control (LUC) at sites LF59 (in OUI), ST41 (in OU2), FT23, SD24, SD25, SD26, SD27, SD28, SD29 (in OU4) and ST37 (in OU5).
OU 1 is composed of five general waste disposal areas (LF05, LF07, LF13, LF59, and OT56) located next to Vandenberg Avenue. Three of the source areas LF05, LF13 and LF07 were disposal areas for various materials, such as general refuse, scrap metal, used chemicals, construction rubble, empty drums, metal piping, drums of asphalt and small quantities of quicklime. Source area LF59. consisted of two one-half acre landfills and a tar seep in the southwestern portion of OUI. The landfills received general refuse and construction debris and the tar seep is renmant of a former asphalt batch plant. Source area OT56 was a storage area for scrap metal and drums and is no longer in use. The majority of the landfills were closed in the early 1980s, although a portion of the LF07 landfill received wastes containing asbestos unti11992. In 1996, source area LF59 was excavated and over 10,000 gallons of asphalt were recovered and recycled.
Land Use Control Performance Objective: Restrict land use and designate area for recreational use. Enforce base policy prohibiting installation of groundwater wells into the shallow aquifer.
Secure existing water supply and groundwater monitoring wells. LUCs at OU 1,2,4 and 5 shall be maintained until the concentrations of hazardous substances in the groundwater andlor soil are at such levels to allow for unrestricted use and exposure.
The Air Force will provide notice to USEPA and ADEC at least six (6) months prior to
any transfer or sale of any part of OU 1, 2, 4 and 5 affected by LUCs so that USEPA and
ADEC can be involved in discussions to ensure that appropriate provisions are included
in the transfer terms or conveyance documents to maintain effective LUCs. If it is not
possible for the facility to notify USEP A and ADEC at least six months prior to any
transfer or sale, then the facility will notify USEP A and ADEC as soon as possible but no
later than 60 days prior to the transfer or sale of any property subject to LUCs. In
addition to the land transfer notice and discussion provisions above, the Air Force further
agrees to provide USEPA and ADEC with similar notice, within the same time frames, as
to federal-to-federal transfer of property. The Air Force shall provide a copy of executed
deed or transfer assembly to USEPA and ADEC.
Summary Comparison of Original and Proposed Minor Changes: These changes to the RODs do not significantly change or fundamentally affect the remedy selected in the RODs; therefore, no public comment is required.
Proposed Minor Change: Implement LUCs, which include: Restrict land use and areas designated for recreational use. Enforce base policy prohibiting installation of groundwater wells into the shallow aquifer. Securing of existing water supply and groundwater monitoring wells. LUCs will be managed and implemented in accordance with Section 4.1 of this memorandum to the site file. The LUC boundaries are depicted in Figure 4.1 of this memorandum to the site file.
Rationale for Change: Air Force Policy (SAF/IE Memo 7 Oct 03) requires RODs to contain details on implementation of LUCs. Section 4.1 of this document describes how LUCs will be managed, including the duration of the LUCs. |
Louis Howard |
| 2/26/2010 |
Document, Report, or Work plan Review - other |
The Alaska Department of Environmental Conservation (ADEC) Contaminated Sites Program has received the above document [Draft Zone 3 Management Area Annual Report, February 2010
Elmendorf Air Force Base, Alaska] for review and comment on February 16, 2010. The cover letter requested comments by March 12, 2010. Below are ADEC’s comments regarding the annual report which covers various groundwater plumes and the following source areas (but is not limited to): LF59 (CS DB Hazard ID 642), ST37 (CS DB Hazard ID 631), ST48 (CS DB Hazard ID 1237) and ST68 (CS DB Hazard ID 2746).
2.4 Summary and Recommendations Page 22
The text states: “As discussed in the 2007 RPO evaluation, the relationship between Site LF59 and source areas upgradient of this area should be evaluated (USAF, 2008a). As part of this evaluation, the extents of the LF59 Plume should be revised based on data collected in 2010.” ADEC concurs.
ADEC review and comment on this draft report and appendices 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 document does not relieve the Air Force from the need to comply with other applicable laws and regulations.
|
Louis Howard |
| 3/12/2010 |
Document, Report, or Work plan Review - other |
The following are EPA comments on the subject Report:
In General, the Report does a good job correlating sampling strategy and well maintenance with the findings of the 2007 RPO Report.
Some items less clear, are the last well survey, or screen depths and lengths. Also the use of PDP samplers needs to be consistent and there may be an issue here. All the aforementioned issues effect sample integrity and consistency and determine proper depth of a sample in the
water column.
A brief intro to each section outlining the above well info would help greatly.
It is also hoped that some of the issues raised in the last RPO Report will have been addressed by the next RPO Report; or at least an improved plan implemented so better data can be collected to improve the monitoring program.
2.4 Summary and Recommendations Page 22
EPA agrees with this finding. |
Louis Howard |
| 4/5/2010 |
Exposure Tracking Model Ranking |
Initial ranking with ETM completed for source area id: 71621 name: OU1 LF05, 07, 13, 59&OT56 |
Louis Howard |
| 6/21/2010 |
Document, Report, or Work plan Review - other |
Staff reviewed and commented on the Draft Field Investigation and CSM Update Work Plan (April 2009).
7.2 Recommendations Page 7-1
ADEC does not concur with no further action for LF59 until such time that the corrective action measures associated with the TCE plume are proven successful under the landfill compliance program. If the corrective action measures are not successful, then ADEC expects the 2004 CERCLA Site Closure of LF07 (and if necessary, sites LF13, OT56 and LF05) to be rescinded and further response actions meets the requirements of the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA), as amended by the Superfund Amendments and Reauthorization Act of 1986 (SARA), and to the maximum extent practicable, the National Oil and Hazardous Substances Pollution Contingency Plan (NCP).
|
Louis Howard |
| 11/17/2010 |
Meeting or Teleconference Held |
A 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.
JBER Meeting and Federal Facility Agreement (FFA) Concerns - Mr. Gary Fink, Mr. Nick Muszynski, Mr. Robert Shirley, and Mr. Rafael Vazquez attended a quarterly partnering meeting with EPA Region X on 16 Nov 10. One of EPA's concerns with illER, which runs off of two separate FFAs, was how to ensure FF NCERCLA cleanup schedules were enforced. We agreed to prepare a schedule for all primary documents for newly discovered CERCLA sites, including NIKE Site Summit. A Gantt chart should be prepared; however, the schedule provided to EPA could be a simple list of the primary documents and date due to EPA. There was some discussion about how EPA uses OUs to track in their database whether there is only one site within the OU; however, in some cases, the installations use site IDs once the program has matured. No further discussion or decision was made whether we should switch back to using OUs even if only a single site would be within an OU. Another item of discussion was whether the MMR Program will eventually roll up into the FF A. No one had an answer and the subject was tabled until the next RPM meeting.
The question came up about whether EPA planned to keep 2 RPMs managing illER. Currently, Mr. Bill Adams (EPA RPM) manages the JBER Richardson FFA and Mr. Jacques Gusmano (EPA RPM) manages the JBER-Elmendorf FFA. It appears as though EPA will continue managing JBER' s separate FF As with separate EPA RPMs. Some discussion came up about whether the FFA would have to be opened and JBER be run under one FF A. At this time, it appears that neither FFA will be opened; however, it is possible that this subject will come up again in the future.
Action Items: 1) Prepare spreadsheet identifying schedules for document reviews on a quarterly basis. This spreadsheet will include all JBER ERP, MMRP and CR documents, not just primary FFA documents. 2) Document NIKE Site Summit schedule in a Gantt chart and provide a list of the primary documents and dates the documents are due to EPA. 3) EPA and AF to provide follow up on MMRP/FFAs.
Restoration Advisory Boards (RABs) - The first illER RAB, also known as a Community
Environmental Board (CEB), will be conducted this evening (17 Nov 10) at 1900 on the third
floor of the Howard Johnson Hotel. We are currently recruiting community members for the
CEB. Recruitments will include installation residents and members of the Government Hill and
North East communities. We also need to determine whether the former Fort Richardson RAB
needs to be formally adjourned. All parties agreed that it would be appropriate to write a memo
documenting adjournment of the former Fort Richardson RAB and management of membership.
Action Item: Prepare adjournment memo for the fonner Fort Richardson RAB and place in the
administrative record.
Closing Discussions. The next RPM meeting will be scheduled for the Mar-Apr timefrarne.
Many of the same topics discussed in this meeting will be topics of the next meeting, which will
be scheduled for March or April 2011. |
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.
Soil - Restrict land use and designate area for recreational use only.
Groundwater - Enforce base policy prohibiting installation of groundwater wells into the
shallow aquifer. Secure existing water supply and groundwater monitoring wells.
Evaluation - A land use control inspection was performed and land use controls are in place and continue to be effective at LF59.
The Air Force ensures compliance with LUCs by conducting periodic monitoring and completing site inspections. Separate controls are in place and enforced by the Air Force to prevent inappropriate soil and groundwater exposure at these sites. The Air Force currently requires all proj ects resulting in soil disturbance of greater than four inches below ground surface
to follow 3r Wing Instruction 32-1007, Safeguarding Utilities from Damage, dated 17 Aug 07
and 3rd Wing Instruction 32-7003, Land Use control Management, dated 16 Feb 07. Both instructions require the proponent to obtain an approved Base Civil Engineer Work Clearance
Request (3 WG Form 3) prior to conducting work on the Base. |
Louis Howard |
| 2/10/2011 |
Update or Other Action |
Staff received the Draft Zone 3 Mgt. Area Annual Report. Water samples were collected from wells LF59MW-02 and LF59MW-03 on 01 June 2010. Groundwater samples from both wells were submitted to a fixed-based laboratory for analysis of VOCs. TCE concentrations measured in samples from LF59MW-02 (6.3 yg/L) and LF59MW-03 (8.1 ug/L) were above the groundwater cleanup level of 5 ug/L.
Biogeochemical indicator parameters measured 8 in the field indicate a weakly anaerobic
(reducing) environment at wells LF59MW-02 and LF59MW-03, which is a slight change from the aerobic (oxidizing) environment observed 10 at both wells in 2009. Although TCE degrades more readily under anaerobic conditions than under aerobic conditions, the change to weakly reducing conditions in both locations is not considered significant in terms of expected contaminant degradation processes. The attainment of cleanup goals at this site will occur due to other natural attenuation mechanisms incl14 uding dispersion, adsorption, and dilution.
The 2007 RPO evaluation identified Site LF59 as a Yellow priority site because there are
uncertainties associated with the predicted time to reach the cleanup levels given the information obtained through the compliance program. Based on the 2010 groundwater analytical data for wells LF59MW-02 and LF59MW-03, TCE concentrations in both wells have not changed significantly since 2009 and are still above the cleanup level of 5 ug/L. Two successive years of TCE results at LF59WM-03 have now been similar to the concentration measured in 2007, suggesting that the below detection result measured in 2008 is an anomaly and not indicative of decreasing TCE concentrations at Site LF59. In addition, questions remain regarding TCE concentrations at potential upgradient source areas. Therefore, Site LF59 remains a Yellow priority at this time.
In accordance with a recommendation from the 2007 RPO evaluation (USAF, 2008a), an investigation into the extent and source of contamination for the LF59 Plume was performed in 2009. The results of this study should be used to guide future investigations at Site LF59. |
Louis Howard |
| 2/24/2011 |
Document, Report, or Work plan Review - other |
Staff reviewed and approved the recommendations in the draft annual report for this source area in Operable Unit 1. |
Louis Howard |
| 5/19/2011 |
Update or Other Action |
Wing Instruction 32-7003 dated May 19, 2011 Land Use Control Management. OPR: 673 CES/CEANR Certified by: 673 CEG/CC (Col Russell R. Hula). This instruction implements AFPD 32-70, Environmental Quality, & is used in conjunction with AFIs 32-7020, The ERP, 32-7066, Environmental Baseline Surveys in Real Estate Transactions, & 673ABWI 32-1007, Safeguarding Utilities From Damage.
It prescribes the processes & responsibilities for the management of & compliance with land use controls on Joint Base Elmendorf-Richardson (JBER) & applies to all military & civilian organizations that occupy facilities, or conduct business, on the installation. This publication does not apply to the USAF Reserve or Air NG units & members. The current land use control areas can be found on the Environmental Restoration map located on the GeoBase webpage.
General:
1.1. Land use controls (LUC), such as limitations on access, water use, excavations, & property transfers, will supplement engineering controls as appropriate for short-term & long-term mgt to prevent or limit human & environmental exposure to hazardous substances, pollutants, or contaminants. Examples include limitations on the depth & location of excavations, prohibition of or restrictions on well drilling & use of GW, mgt. of excavated soils, & prohibition of certain land uses. LUCs, often used interchangeably with (ICs), are administrative, procedural, engineering, & regulatory measures to control human access to & use of property.
1.2. LUCs were established at JBER to prevent exposure to contaminated soil & water, based on agreements between the military services & the EPA & the ADEC. LUCs are used to reduce the potential for exposure to hazardous substances or to enhance the protectiveness of a soil &/or water cleanup remedy. They include restrictions on the use of portions of the shallow aquifer south of the Elmendorf Moraine, limitations on the types of buildings allowed in certain areas – primarily occupancy limitations, & land use designations for certain areas as recreational use only. The LUCs have been implemented at several sites & operable units (OU) as part of the ERP. LUCs were established for DP98 & OUs 1, 2, 4, 5, & 6 on former Elmendorf AFB property in their respective records of decision (ROD), as a component of the selected cleanup remedy.
LUCs were also established for restoration & compliance sites formerly part of Fort Richardson in their respective RODs or Decision Documents. LUCs must be in place as long as a property is not available for UU or UE & may include temporary or permanent restrictions or requirements. When all cleanup goals have been achieved for a given site, temporary controls, such as GW use restrictions, may be removed.
2. Responsibilities:
2.1. JBER personnel, tenants, or contractors whose projects or activities require excavation in areas where site-specific LUCs are in effect will comply with all LUCs, 673ABWI 32-1007, & applicable AF instructions. Base contractors & tenant organizations will have LUC compliance requirements incorporated into their contracts & interagency agreements, as will be necessary. Failure to comply with LUCs will be grounds for penalty, in accordance with provisions specified in applicable contract documents. At project completion, the JBER organization or contractor will sign a certification of LUC compliance & return the compliance statement to 673 CES/CEANR.
2.2. The 673d Civil Engineer Squadron (673 CES):
2.2.1. Asset Management Flight (673 CES/CEA):
2.2.1.1. Natural Resources Management (673 CES/CEAN):
2.2.1.1.1. Environmental Restoration (673 CES/CEANR):
2.2.1.1.1.1. Will provide GW & site-specific LUC requirements throughout the installation & identify any known soil contaminated sites & monitoring wells for the area of the proposed project.
2.2.1.1.1.2. Will conduct annual site visits to ensure compliance with LUCs during project implementation.
2.2.1.1.1.3. Will conduct 5-year reviews, at 5-year intervals, or as required by any subsequent RODs.
2.2.1.1.1.4. Will prepare annual LUC compliance reports & submit reports to ADEC & USEPA by 1 February each year.
2.2.1.1.1.5. Will disseminate LUC information to personnel involved in LUC mgt, including real property & 673 CES/CEPT for inclusion into GeoBase.
2.2.1.1.1.6. Will operate an active educational program that includes disseminating updated fact sheets & LUC information, providing notices through the installation intranet & the Arctic Warrior newspaper, & by briefing LUC mgt at project kick-off meetings; Environmental, Safety & Occupational Health Council meetings, & CEB meetings.
2.2.1.1.1.7. Will coordinate any changes in the base general plan (BGP), or real estate transactions, with USEPA & ADEC.
2.2.1.1.1.8. Will maintain copies of signed certificates of compliance, indicating requestor’s adherence to LUCs during project execution.
See site file for additional information. |
Louis Howard |
| 7/15/2011 |
Update or Other Action |
Draft Work Plan Environmental Remedial Action-Operations & LTM & Maintenance received.
The purpose of this project is to perform RA-O & LTM activities for several JBER Programs. These programs include sites distributed across both JBER-Elmendorf & JBER-Richardson. This Work Plan addresses remedial activities in JBER-Elmendorf Zone 1, Zone 2, & Zone 3 Mgt 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).
Two sites are monitored under the Zone 3 Mgt Area: Sites LF59 & ST37. Site LF59 is estimated to be a single plume that is located at the eastern edge of the Zone 3 Mgt Area. The LF59 plume extends from near the intersection of Arctic Warrior Drive & Vandenburg Avenue towards monitoring well LF59MW-02. Site ST37 includes several discrete plumes including the Fairchild Avenue Plume, Kenney Avenue Plume, Slammer Avenue Plumes, OU3MW-25 Plume, OU5MW-02 Plume, & SP1-02 Plume. In addition to these plumes, Site ST37 includes GW seep & surface water locations near the southern boundary of the base, the Beaver Pond, the OU5 engineered Wetland Remediation System, & the early warning & sentry well networks. The scope of work for Zone 3 also includes the O&M of the Contractor’s Yard.
The OU1 ROD specifies the selected remedy for LF59 as long-term GW monitoring until cleanup levels are met combined with LUCs. Impacted media at the Zone 3 sites includes GW at both sites & surface water at Site ST37, where GW emerges as surface water at seeps that eventually flow into Ship Creek. COCs specified for Site LF59 in the OU1 ROD include TCE, 1,2-dibromoethane, vinyl chloride, & manganese (USAF, 1994). As of 2008, TCE was the only COC that exceeded its applicable cleanup level at Site LF59.
The COCs originally specified for GW at Site ST37 included benzene, TCE, total fuel hydrocarbons-gasoline range (TFH-gas), & total fuel hydrocarbons-diesel range (TFH-diesel; USAF, 1995c). The COCs specified in the OU5 ROD for surface water & seeps at Site ST37 originally included TFH-gas & grade 4 jet propulsion fuel (JP-4). Due to a lack of cleanup standards for TFH-gas or TFH-diesel, AF identified total aromatic hydrocarbons (TAH) & total aqueous hydrocarbons (TAqH) as the appropriate standards for TFH-gasoline & TFH-diesel, respectively, in GW & surface water. THF-gas & JP-4 were replaced in 1998 with TAH & TAqH, as defined in ADEC Water Quality Standards (Title 18 Alaska Administrative Code Chapter 70 [18 AAC 70]).
This modification was officially acknowledged in a 2005 Memorandum to the Site File. Based on recent monitoring data, COCs that remain above cleanup levels in Site ST37 seeps, surface water, & GW are TCE, benzene, TAH, & TAqH. The objectives of the RA-O activities within the Zone 3 Mgt Area are to monitor the rate of natural attenuation within plumes, provide early warning of potential off-site contaminant migration, ensure that contamination does not impact Ship Creek, treat contaminated GW using the Wetland Remediation System, maintain operable components of the Wetland Remediation System if necessary, & manage all wastes according to state & federal regulations.
Additional Zone 3 Mgt Area project objectives in 2011 include:
• Sampling of early warning & sentry wells twice per year;
• Quarterly or annual sampling of GW seeps;
• Quarterly or annual sampling of surface water;
• Monitoring levels of COCs at the early warning & sentry wells & surface water sampling locations with sufficient precision & accuracy to compare the levels with cleanup goals;
• Operating, maintaining, & monitoring the performance of the Wetland Remediation
System to ensure that 1) Ship Creek is not impacted by hazardous levels of contaminants, & 2) contamination does not impact the areas adjacent to active Wetland Remediation
System components that are on ARRC property;
• Determining the effectiveness & protectiveness of the site remedies (e.g., MNA, seep collection systems, Wetland Remediation System), making recommendations to improve the remedies as appropriate, & implementing modifications to remedial systems as appropriate;
• Operating & managing of the Contractor’s Yard, including handling, treatment, & disposal of wastes generated during 2011 field activities, startup of the wastewater treatment system, contractor training, & winterization of the facility; & Managing waste at the Contractor’s Yard so that wastewater is properly treated before discharge to the storm water drain & all waste is disposed according to state & federal regulations. |
Louis Howard |
| 7/15/2011 |
Update or Other Action |
Quality Program Plan for Evaluating Ship Creek Hydrology near Site LF59 & Optimizing Early Warning/Sentry Wells. This work plan describes tasks that will be performed in 2011 & 2012 to 1) evaluate Ship Creek hydrology near Site LF59, & 2) optimize the long-term monitoring program for early warning/sentry wells at Joint Base Elmendorf-Richardson (JBER), Alaska.
Site LF59 occupies approximately 15 acres & is located in the south central portion of JBER.
The site is within the lower Ship Creek drainage & is comprised of wooded & open areas, a
paved biking & jogging trail, the Alaska Railroad Corporation (ARRC) right-of-way, & an
access road. GW within the shallow, unconfined aquifer system flows to the west
southwest & discharges to Ship Creek.
Site LF59 is one of five source areas (LF05, LF07, LF13, LF59 & OT56) that were originally
investigated & managed under the Comprehensive Environmental Response, Compensation,
& Liability Act (CERCLA) as Operable Unit (OU) 1. Site LF59 is located south of Arctic
Warrior Drive & west of Vandenberg Avenue. The other OU1 sites are located east of
Vandenberg Avenue. In 2004, Site LF05, LF07, LF13, & OT56 were removed from the CERCLA program.
The former OU1 landfill sites (i.e., Sites LF05, LF07, & LF13), commonly referred to as the OU1 landfill complex, continue to be managed as part of a landfill closure permit under the jurisdiction of Alaska solid waste regulations (USAF, 2008a). Site LF59 remains part of OU1.
The remedial action objective (RAO), stated as a “goal” in the OU1 Record of Decision (ROD;
USAF, 1994b), is to prevent ingestion or direct contact with GW containing contaminants having concentrations exceeding United States Environmental Protection Agency (USEPA) maximum contaminant levels. The OU1 ROD identified manganese, 1,2- dibromoethane (ethylene dibromide [EDB]), trichloroethene (TCE), & vinyl chloride (VC) as contaminants of concern (COCs) in GW at Site LF59. TCE in GW is currently the only COC that remains above an applicable cleanup level.
Data collected in 2007 (USAF, 2007) & 2009 (USAF, 2010a) suggest that the source of TCE in
GW near Site LF59 is Site LF07. Evidence supporting this conclusion includes 1) the
absence of TCE contamination in soil samples from Site LF59, 2) observation of a west36
southwesterly GW flow direction under Site LF59, & 3) elevated TCE concentrations
in monitoring wells & discrete water samples collected north of Site LF59.
To achieve the project goal of addressing the data gap at Site LF59, the following activities will be performed:
-Establish surface water monitoring locations in Ox Bow Lake, which is located between
Site LF59 & Ship Creek, with sufficient precision & accuracy to replicate these sample locations during future monitoring events (if needed);
-Measure concentrations of COCs in surface water, seep, & monitoring well locations with sufficient precision & accuracy to evaluate the concentrations with respect to applicable cleanup goals; &
- Use monitoring results to evaluate if changes to the CSM or monitoring program for Site
LF59 are appropriate.
Fieldwork to support the evaluation of Ship Creek hydrology near Ox Bow Lake & Site LF59 will consist of the following activities:
- Perform a pre-mobilization site walk to assess site conditions & access to proposed sampling locations;
- Establish 1) a seep monitoring location near the sediment sampling location LF59- 09SEEP-SE, & 2) up to three surface water locations in Ox Bow Lake;
-Measure the depth to water in monitoring wells & the elevation of surface water at Ox Bow Lake to determine if Ox Bow Lake is gaining or losing water; &
-Collect water samples from two existing monitoring wells (LF59-MW-02 & LF59-MW- 06R), one seep monitoring location (near the sediment sampling location LF59-09SEEP12SE), & up to three surface water locations in Ox Bow Lake for analysis of VOCs by USEPA Method 8260B & manganese by USEPA Method 6010B at a fixed-base laboratory.
Data collected at the Ship Creek hydrology evaluation near Site LF59 will be used to
1) determine whether VOCs in GW near Site LF59 are impacting surface water at Ox Bow Lake, &
2) identify whether the CSM &/or long-term monitoring program for Site LF59 requires revision. This report will update the CSM (if needed) & provide recommendations for future monitoring objectives if any are identified. |
Louis Howard |
| 8/3/2011 |
Document, Report, or Work plan Review - other |
Staff reviewed and commented on the Draft Work Plan Environmental Remedial Action – Operations and Long-Term Monitoring and Maintenance July 2011.
8.2.2: Water quality parameters are considered stable when three successive readings, collected 3-5 minutes apart, are within:
• ± 3% for temperature (minimum of ± 0.2 oC),
• ± 0.1 for pH,
• ± 3% for conductivity,
• ± 10 mv for redox potential,
• ± 10% for dissolved oxygen (DO), and
• ± 10% for turbidity.
A minimum of three (minimum of four if using temperature as an indicator) of these parameters should be monitored and recorded (ADEC May 2010 Draft Field Sampling Guidance A. General Guidelines Page 29).
ADEC will require that a fourth field parameter be used in addition to the three proposed in the document (pH, specific conductivity and temperature) to determine when a well is considered stable or stabilized. This comment is applicable for sampling activities of any monitoring well on JBER. The variance allowed for considering temperature and conductivity “stable” is a three percent (3%) variance not ten percent (10%) as stated in the document.
The text states: “Trip blanks will be kept with samples and analyzed whenever volatile organic samples are required.” ADEC will require one trip blank per analysis and cooler for all water samples being analyzed for GRO, BTEX or VOCs. The allowable tolerance for trip blanks will be less than the practical quantitation limit (ADEC May 2010 Draft Field Sampling Guidance Table 3).
2-8 2.1.5: The following applies to existing monitoring wells on JBER: At sites with long-term detection monitoring, survey the location of each well, the elevation of the land surface, and the top of each well casing. A registered professional surveyor or registered civil engineer engaged in the practice of surveying must conduct this work.
Sites undergoing contaminant assessment monitoring with a large number of monitoring wells should have the wells surveyed as described above. Re-survey monitoring wells every five years, or more frequently, if freeze-thaw processes compromise the well (Pages 7 and 8 from ADEC’s Monitoring Well Design and Construction for Investigation of Contaminated Sites, February 2009)
2-9 2.2.1: See comment #10 regarding the number of water quality parameters and their use for determining whether a well is stabilized or not.
2-10 2.2.2: The text states: “In the event that floating product is detected in the well, a disposable polyethylene bailer will be used to first remove the product from the top of the water column. The bailer will be lowered to just above static water level and purging cycles performed until no visible product remains at the groundwater interface. After the field crew has determined that no product remains in the casing, actual sampling procedures will commence.”
The statements in this section are in conflict with the statements from Section 2.2.1 Well Purging on Page 2-9: “Samples will not be collected from wells with measurable product because the samples would contain light nonaqueous phase liquids (LNAPL) that is not representative of dissolved phase concentrations.” Please clarify whether or not wells containing measurable free product will be sampled.
2-15 Table 2-1: EPA 8011 or EPA 504.1 should be used when evaluating ethylene dibromide (EDB). EDB soil samples should be field preserved in hexane. EPA 8260 will quantify EDB in ground water; however, the detection limits do not meet the Table C cleanup level of 0.00005 mg/L.
|
Louis Howard |
| 8/4/2011 |
Document, Report, or Work plan Review - other |
Staff reviewed and commented on the Draft Quality Program Plan For Evaluating Ship Creek Hydrology Near Site LF59 and Optimizing Early Warning/Sentry Wells July 2011 on JBER.
28 QAPP WS #15a: The Project Reporting Limit of 1.0 ug/L, the MDLs (1/2 the RL), and the Method RL 1.0 ug/L and Achievable Laboratory Limits MDLs 0.25 ug/L and RL of 1 ug/L will not meet the Table C EDB cleanup level of 0.05 ug/L. EPA 8011 or EPA 504.1 should be used when evaluating ethylene dibromide (EDB). EPA 8260 will quantify EDB in ground water; however, the detection limits do not meet theTable C cleanup level of 0.00005 mg/L
49 QAPP WS # 28A: Field duplicate - Minimum of one per every ten (10) field samples for each matrix sampled, for
each target analyte (minimum of one).
|
Louis Howard |
| 11/17/2011 |
Update or Other Action |
Evaluation of Ship Creek Hydrology Near Site LF59 received. This report describes tasks that were performed to evaluate Ship Creek hydrology near Site LF59, Joint Base Elmendorf-Richardson (JBER), Alaska.
Surface water and seep monitoring locations were established in Ox Bow Lake with sufficient precision and accuracy to replicate these sample locations during future monitoring events (if needed);
Concentrations of COCs in surface water, seep, and well locations were measured with sufficient precision and accuracy to evaluate the concentrations with respect to applicable cleanup goals; and
Monitoring results were used to evaluate if changes to the CSM or monitoring program for Site LF59 are appropriate.
The primary document used to guide the work conducted to meet the project objectives was the Quality Program Plan for Evaluating Ship Creek Hydrology near Site LF59 and Optimizing Early Warning/Sentry Wells.
Groundwater contours shown on the potentiometric map are similar to earlier findings (USAF, 2010) and indicate a general southwesterly groundwater flow direction. As groundwater approaches Ox Bow Lake, the hydraulic gradient steepens with a slight groundwater flow direction shift to the south. The estimated gradient between well LF59MW-06R and surface water monitoring point LF59SW-01 was approximately 0.016 foot per foot (ft/ft), while the gradient between piezometer LF59-PZ02 and well LF59MW-06R was approximately 0.006 ft/ft. The combined observation of an increased hydraulic gradient, a groundwater flow direction shift, and a flowing seep on the north side of Ox Bow Lake suggests that groundwater at Site LF59 was discharging to Ox Bow Lake in September 2011.
Surface water, seep, and groundwater samples were collected for analysis of VOCs, EDB, and total manganese. VC concentrations (not shown) were below the method detection limit of 0.2 µg/L at locations sampled in September 2011. Appendix A presents all concentrations measured in samples collected during the September 2011 monitoring event described in this report. The concentrations of COCs in samples from wells LF59MW-02 and LF59MW-06R collected in September 2011 were similar to earlier findings (USAF, 2010).
The TCE concentration at well LF59MW-02 was the only COC concentration measured above an applicable cleanup level. TCE concentrations measured at well LF59MW-06R and the three surface water sampling points were above the method detection limit, but below both the project reporting limit of 1 µg/L and applicable cleanup level of 5 µg/L. The similarity in concentrations of TCE and manganese between surface water samples and the nearest well (LF59MW-06R) provides additional evidence that groundwater from Site LF59 was discharging to Ox Bow Lake in September 2011.
SUMMARY AND CONCLUSIONS
Surface water elevations, depth to groundwater, and water samples were collected at multiple locations during September 2011 in support of an evaluation of Ship Creek hydrology near Site LF59. The surface water elevation data and depth to groundwater measurements were used to develop a potentiometric surface map in the area of interest. These data show that 1) the groundwater flow direction is generally southwesterly, and 2) the hydraulic gradient steepens as groundwater approaches an abandoned surface water feature, known as Ox Bow Lake, which is north of Ship Creek. These data, along with the observed presence of a flowing seep on the north side of Ox Bow Lake, suggest that groundwater was discharging to surface water during the September 2011 sampling event described in this report.
Concentrations of VOCs and total manganese were measured in water samples collected from six locations, including three surface water locations at Ox Bow Lake, one seep location, and two monitoring wells. TCE at well LF59MW-02 was the only COC concentration measured above an applicable cleanup level. TCE concentrations measured at well LF59MW-06R and the three surface water sampling points were above the method detection limit, but below both the project reporting limit of 1 µg/L and applicable cleanup level of 5 µg/L. The similarity in concentrations of TCE and manganese between surface water samples and the nearest well (LF59MW-06R) provides additional evidence that groundwater from Site LF59 was discharging to Ox Bow Lake in September 2011.
The presence of COCs related to Site LF59 and the potentiometric surface map developed based on groundwater and surface water elevations measured during this project suggests that groundwater flowing through Site LF59 was discharging to Ox Bow Lake. For the September 2011 sampling event, concentrations of COCs in seep and surface water samples from Ox Bow Lake were below applicable cleanup levels specified in the OU1 ROD. |
Louis Howard |
| 11/29/2011 |
Document, Report, or Work plan Review - other |
Staff reviewed and commented on the Draft Evaluation of Ship Creek Hydrology.
3.0 Hydrology Evaluation and Analytical Results
It appears that groundwater from LF59 is closely connected to surface water (i.e. Ox Bow Lake) and therefore the Alaska Water Quality Standards (18 AAC 70 amended as of May 26, 2011) and the Alaska Water Quality Criteria Manual for Toxic and Other Deleterious Organic and Inorganic Substances (as amended through December 12, 2008) are applicable cleanup standards.
18 AAC 75.345 (f) states:
Groundwater that is closely connected hydrologically to nearby surface water may not cause a violation of the water quality standards in 18 AAC 70 for surface water or sediment.
The department will, in consultation with local, state, and federal officials and the public, establish points of compliance with this subsection, taking into account the following factors:
(1) groundwater travel time and distance from sources of hazardous substances to surface water;
(2) the contribution of the groundwater to the chemical and physical quantity and quality of the surface water;
(3) organisms living in or dependent upon the groundwater to surface water ecosystems;
(4) climatic, tidal, or seasonal variations;
(5) feasibility of attaining applicable water quality standards to support the designated uses of the surface water;
(6) presence of sediment contamination;
(7) if conducted for the site, the conclusions of a site-specific risk assessment conducted under the Risk Assessment Procedures Manual, adopted by reference in 18 AAC 75.340.
ADEC requests the remedial project managers discuss the need for monitoring surface water downgradient of LF59. At a minimum, there needs to be regular monitoring of LF59SW-01 and LF59SW-02 and perhaps LF59SW-03. Recommend surface water monitoring be added to the Basewide monitoring program for Zone 3. An interesting observation for monitoring well LF59MW03: it has always had TCE above the 5 ug/L cleanup level for groundwater since 1992 (Figure 2.1 LF59MW-03 Plume Monitoring Results 2010 Zone 3 Management Area Annual Report, Page 2-2). Additionally, the Zone 3 Annual Report states: “Biogeochemical indicator parameters measured in the field indicate a weakly anaerobic (reducing) environment at wells LF59MW-02 and LF59MW-03, which is a slight change from the aerobic (oxidizing) environment observed at both wells in 2009. Although TCE degrades more readily under anaerobic conditions than under aerobic conditions, the change to weakly reducing conditions in both locations is not considered significant in terms of expected contaminant degradation processes.”
ADEC requests clarification on why LF59MW-03 is not included in the boundary outline on Figures 3.1 and 3.2 as part of the “restoration site” since it is part of the trichloroethylene plume for LF59 source area in Operable Unit 1. 18 AAC 75.990 (115) “site” means an area that is contaminated, including areas contaminated by the migration of hazardous substances from a source area, regardless of property ownership. 1991 Federal Facility Agreement states: “Site shall meant the areal extent of contamination and shall include sources of contamination subject to this Agreement at Elmendorf…”
4.0 Summary and Conclusions
ADEC concurs with the conclusions in this section regarding data shows that groundwater is discharging to surface water (e.g. Ox Bow Lake).
|
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.
OU1:
LF59
Soil - Restrict land use and designate area for recreational use only.
Groundwater - Enforce base policy prohibiting installation of groundwater wells into the
shallow aquifer. Secure existing water supply and groundwater monitoring wells.
Evaluation - LUCs are in place and continue to be effective at LF59. A land use control inspection was accomplished in Oct 2011. The inspection forms will be presented in Appendix B of the 2011 Zones 1, 2, and 3 Mgt. Area Annual Report.
2. The Air Force ensures compliance with LUCs by conducting periodic monitoring and completing site inspections. Separate controls are in place and enforced by the Air Force to prevent inappropriate soil and groundwater exposure at these sites. The Air Force currently requires all projects resulting in soil disturbance of greater than four inches below ground surface to follow 3 Wing Instruction 32-1007, Safeguarding Utilities from Damage, dated 20 Aug 10 and 673d Wing Instruction 32-7003, Land Use control Management, dated 19 May 2011. Both instructions require the proponent to obtain an approved Base Civil Engineer Work Clearance Request (3 WG Form 3) prior to conducting work on the Base. |
Louis Howard |
| 4/10/2012 |
Update or Other Action |
Draft 2011 Zones 1, 2, 3 Annual Report received. Two sites are monitored under the Zone 3 Management Area: Sites LF59 & ST37. GW is monitored at seven plumes within these two sites.
LF59 consists of two 0.5-half acre landfills & a tar seep near the intersection of Arctic Warrior Drive & Vandenberg Avenue. This landfill received general refuse & construction debris from 1965 to 1983 & may have housed an asphalt batch plant in the 1950s & 1960s. The OU1 ROD specifies the selected remedy for LF59 as long-term GW monitoring until cleanup levels are met combined with LUCs. The OU1 ROD identified manganese, 1,2-dibromoethane, TCE, & VC as COCs in GW at Site LF59. TCE is the remaining COC at LF59. The OU1 ROD-estimated cleanup date for this plume is 2024.
GW samples from both wells were submitted to a fixed-based lab for analysis of VOCs. TCE concentrations measured in samples from LF59MW-02 (6.4 J µg/L) & LF59MW-03 (9.3 J µg/L) were above the GW cleanup level of 5 µg/L.
The following text summarizes observations & recommendations for Site LF59:
• The 2007 RPO evaluation identified Site LF59 as a Yellow priority site because there are uncertainties associated with the predicted time to reach the cleanup levels given the information obtained through the compliance program. Based on the 2011 GW analytical data for wells LF59MW-02 & LF59MW-03, TCE in both wells have not changed significantly since 2010 & are still above the cleanup level of 5 µg/L.
• Three successive years of TCE results at LF59WM-03 have now been similar to the concentration measured in 2007, suggesting that the below detection result measured in 2008 is an anomaly & not indicative of decreasing TCE at Site LF59. In addition, questions remain regarding TCE at potential upgradient source areas. Therefore, Site LF59 remains a Yellow priority at this time.
• In accordance with a recommendation from the 2007 RPO Evaluation Report, an investigation into the extent & source of contamination for the LF59 plume was performed in 2009. The results of this study should be used to guide future investigations at Site LF59.
Water samples were collected from wells LF59MW-02 & LF59MW-03 on 26 & 27 August 2011, respectively. Biogeochemical indicator parameters measured in the field indicate an aerobic (oxidizing) environment at wells LF59MW-02 & LF59MW-03, which is a slight change from the weakly anaerobic (reducing) environment at both wells in 2010; however, it is similar to the environment observed at both wells in 2009. Although TCE degrades more readily under anaerobic conditions than under aerobic conditions, the change to oxidizing conditions in both locations is not considered significant in terms of expected contaminant degradation processes. The attainment of cleanup goals at this site will occur due to other natural attenuation mechanisms including dispersion, adsorption, & dilution.
NOTE TO FILE: 2008 5 YR Review issues-The trichloroethene (TCE) plume at OU 1 LF59 appears to be originating, at least in part, from the upgradient OU1 landfills. There are insufficient data to determine the impact to long-term GW quality & the estimated cleanup date at LF59.
5 YR Review recommendations: At LF59, incorporate data from upgradient wells LF05GW-2B & OU1LF-19 into evaluation of natural attenuation & analysis of contaminant trends, & update the conceptual site model for the TCE plume at LF59.
Under the Compliance program, former sites LF05, LF07, & LF13 were capped with evapotranspiration (ET) covers in 2005 through 2007 to comply with AK Solid Waste regulations. These caps were designed to prevent storm water infiltration into the landfills, limiting leachate migration to GW. During the Compliance program’s routine GW monitoring at well LF05GW-2B in 2006, elevated levels of TCE were observed (see Attachment C, Figure C-1).
Consequently, the Compliance program commissioned a characterization study to determine the nature & extent of the GW contamination; this study was performed in 2006. The study identified two chlorinated solvent plumes, including a TCE plume that appears to originate at or near LF07 & may be the source of TCE contamination at LF59. Compliance program monitoring showed that TCE continued to be elevated, though decreasing, at well LF05GW-2B in 2007 & 2008.
While the cause of the increased TCE downgradient of the landfill area is unknown, it is suspected that the ET landfill covers may be causing changes to the hydraulics of the area. The full impact of the covers may not be realized until the plants reach maturity, which is predicted to occur approximately seven years after cap construction/planting (about 2013 for LF07). Monitoring at LF05GW-2B should continue, & the data should be used to evaluate potential impacts to the remedy effectiveness at LF59. |
Louis Howard |
| 4/10/2012 |
Update or Other Action |
Draft 2011 Zones 1, 2, and 3 report received. Two sites are monitored under the Zone 3 Management Area: Sites LF59 and ST37. Groundwater is monitored at seven plumes within these two sites. In addition, groundwater, seep, and surface water are monitored at locations near the southern boundary of JBER Elmendorf, the Beaver Pond, the OU5 Engineered Wetland Remediation System, and the early warning and sentry well networks. Zone 3 also includes the operations and maintenance (O&M) of the Contractor’s Yard.
LF59 consists of two 0.5-half acre landfills and a tar seep near the intersection of Arctic Warrior Drive and Vandenberg Avenue. This landfill received general refuse and construction debris from 1965 to 1983 and may have housed an asphalt batch plant in the 1950s and 1960s. The
OU1 ROD (USAF, 1994e) specifies the selected remedy for LF59 as long-term groundwater monitoring until cleanup levels are met combined with LUCs. Trichloroethene (TCE) is the remaining COC at LF59.
The depth to groundwater and total well depth were measured at wells LF59MW-02 and LF59MW-03 on 26 August 2011 and 27 August 2011, respectively, as presented in Table 4.2. The groundwater flow direction at Site LF59 is generally to the southwest (Figure 4.1), consistent with base-wide historical data. However, the orientation of the contaminant plume, as defined during previous investigations, suggests a more west-southwest flow direction.
The discrepancy between the direction of plume migration and the interpreted groundwater flow direction could be the result of preferential flow paths in the subsurface and/or a local flow direction that may deviate slightly from the regional direction illustrated on Figure 4.1. Water samples were collected from wells LF59MW-02 and LF59MW-03 on 26 and 27 August 2011, respectively.
TCE concentrations measured in samples from LF59MW-02 (6.4 J µg/L) and LF59MW-03 (9.3 J µg/L) were above the groundwater cleanup level of 5 µg/L. A LUC inspection conducted on 13 October 2011 identified no LUC issues at Site LF59.
The 2007 RPO evaluation identified Site LF59 as a Yellow priority site because there are
uncertainties associated with the predicted time to reach the cleanup levels given the information obtained through the compliance program (USAF, 2007c and 2008d). Based on the 2011 groundwater analytical data for wells LF59MW-02 and LF59MW-03, TCE concentrations in both wells have not changed significantly since 2010 and are still above the cleanup level of 5 µg/L.
5234
· Three successive years of TCE results at LF59WM-03 have now been similar to the concentration measured in 2007, suggesting that the below detection result measured in 2008 is an anomaly and not indicative of decreasing TCE concentrations at Site LF59 (Figure 4.2). In addition, questions remain regarding TCE concentrations at potential upgradient source areas. Therefore, Site LF59 remains a Yellow priority at this time.
· In accordance with a recommendation from the 2007 RPO Evaluation Report (USAF, 2008h), an investigation into the extent and source of contamination for the LF59 plume was performed in 2009. The results of this study should be used to guide future investigations at Site LF59. |
Louis Howard |
| 11/14/2012 |
Update or Other Action |
NOVEMBER 2012 USEPA Assessing protectiveness at sites for VI Supplement to the "Comprehensive Five-Year Review Guidance" OSWER Directive 9200.2-84.
Key Concepts for Incorporating Vapor Intrusion into the Five-Year Review
As discussed in the Comprehensive Five-Year Review Guidance, data for a review may be collected through document reviews, interviews, a site inspection, & supplemental sampling. If decision documents have identified the vapor intrusion pathway as a risk to human health at a site, the data collected should help assess whether the portion of the remedy that was designed to address the vapor intrusion pathway is operating as intended & is still ensuring protectiveness of human health.
It is possible that the vapor intrusion pathway was not considered at the time site-related decision documents were issued or that new site information (discovered since the decision documents were issued) suggests that vapor intrusion is now a potential pathway of concern at a site. At sites where a complete vapor intrusion pathway is suspected, the five-year review site team may consider whether there is adequate, appropriate data to evaluate the pathway prior to commencing the five-year review.
If no or inadequate data are available, the five-year review document can make recommendations for gathering appropriate data relevant to potential vapor intrusion. Where there is adequate, appropriate data to evaluate the vapor intrusion pathway prior to commencing the five-year review, the Region may be able to minimize the need to defer a protectiveness determination if vapor intrusion is determined to be an issue.
Site Characteristics & Data.
Vapor migration from the source to indoor air may be influenced by a number of factors, including hydrogeology, anthropogenic conditions, outdoor air contaminants, preferential pathways (e.g., utility lines), characteristics of individual buildings that may affect the degree vapors enter from the subsurface (e.g., building foundation & ventilation conditions), &/or seasonal & meteorological influences. By considering these factors early, EPA can minimize the likelihood of deferring a protectiveness determination due to insufficient information to evaluate whether vapor intrusion is an issue.
The Region typically should review the site characteristics & other available information as part of the preliminary technical assessment to determine whether adequate data exist to identify an actual or potential vapor intrusion pathway. For those sites where a vapor intrusion pathway may represent a risk to human health, the Region should assess whether that portion of the remedy originally selected & designed to address the vapor intrusion pathway is operating as intended, & if so, assess whether the vapor intrusion remedy is still protective of human health, also taking into account sensitive populations (such as the very young, the elderly, pregnant women, & the immunocompromised). Particular attention should be given to identifying data in the potential or actual vapor intrusion receptor area, for example, presence of shallow wells present, or whether soils on or near the vapor intrusion properties of interest have been characterized.
Assessing the Protectiveness of the Vapor Intrusion Remedy
The site characteristics & data collected during the literature review, interviews, site inspection, & supplemental sampling generally should be evaluated to assess the protectiveness of the selected response action. The three technical assessment questions (Questions A, B & C) described in the Comprehensive Five-Year Review Guidance & Frequently Asked Questions About Vapor Intrusion provide a recommended framework for organizing & evaluating the data & information to help ensure all relevant issues can be considered when determining the protectiveness of the overall site remedy during the five-year review. Both existing & potential vapor intrusion exposure pathways generally should be assessed during the document review; the possible existence of a vapor intrusion pathway may not have been considered prior to the five-year review.
When answering the three recommended technical assessment questions, the Region should be able to evaluate whether an actual or potential vapor intrusion exposure at the site affects the ability of the overall site remedy to ensure protectiveness of human health & the environment. Answering the three questions generally should allow the Region to reach appropriate conclusions for the five-year review report by identifying relevant issues, making follow-up recommendations, & assessing the protectiveness of the overall site remedy. |
Louis Howard |
| 3/18/2013 |
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 I, 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.
Soil- Restrict land use and designate area for recreational use only.
Groundwater - Enforce base policy prohibiting installation of groundwater wells into the
shallow aquifer. Secure existing water supply and groundwater monitoring wells.
Evaluation -Inspection conducted on 29 Aug 12 and LUCs are in place and continue to be effective at LF59. |
Louis Howard |
| 5/30/2013 |
Update or Other Action |
Draft Annual Field Activities report received for review & comment.
This report summarizes the 2012 annual long-term management activities, including remedial action-operation (RA-O) & Record of Decision (ROD) requirements conducted at Joint Base Elmendorf-Richardson (JBER) Comprehensive Environmental Response, Compensation, & Liability Act (CERCLA) sites. The United States Air Force (USAF) has mandated a reduction of long-term environmental liabilities & life-cycle costs through accelerated cleanup of contaminated sites.
As such, the Performance Based Remediation (PBR) initiative has been developed to protect human health & the environment in a cost effective manner while at the same time reducing life-cycle costs. In April 2012, Weston Solutions, Inc. (WESTON) was awarded a PBR contract from the Air Force Civil Engineer Center (AFCEC) (Contract Number FA8903-09-D-8589, Task Order No. 0016) that includes remediation & related activities at several JBER contaminated sites. The contract includes performing RA-O & ROD requirements at those sites. The WESTON Team performing the activities summarized in this report consists of WESTON & CH2M Hill Constructors, Inc. (CH2M HILL). WESTON executed project work on sites located within JBER-Elmendorf (JBER-E) while CH2M HILL executed project work on sites located within JBER-Richardson (JBER-R).
During 2012, groundwater monitoring wells LF59MW-02 and LF59MW-03 were sampled for VOCs. Analytical laboratory results exceeded the OU1 ROD cleanup criterion in groundwater wells LF59MW-02 and LF59MW-03 for TCE (6.8 µg/L and 8.8 µg/L, respectively). All other analytical laboratory sample results were below OU1 ROD cleanup criteria. Table 7-1 presents a summary of the results. Historic results are presented on Figure 7-1. A LUC inspection performed at LF059 on 29 August 2012 did not identify any issues.
Site Summary
Based on the 2012 data, TCE concentrations in both wells have not changed significantly since sampling began in 2009 for LF59MW-02 and 1992 for well LF59MW-03. Analytical results for TCE are still above the cleanup criteria of 5 µg/L. Four successive years of TCE results at LF9WM-03 have now been similar to the concentration measured in 2007, suggesting that the below detection result measured in 2008 is an anomaly and not indicative of decreasing TCE concentrations at Site LF059. No changes to the annual monitoring are being proposed for this site.
|
Louis Howard |
| 6/28/2013 |
Document, Report, or Work plan Review - other |
Staff provided comments on draft annual field activities CERCLA report.
Comment#1
ADEC is requesting that 1,4-dioxane be sampled for in groundwater where trichloroethylene (TCE) or 1,1,1- trichloroethane (TCA) contamination exists or was previously above cleanup levels at any site (CERCLA or State restoration or compliance). Please incorporate these comments into any basewide sampling plans (current/future).
1,4-Dioxane readily leaches to groundwater, is not expected to adsorb significantly to soil particles, and is difficult to biodegrade. Due to these properties, a 1,4-Dioxane plume typically proceeds ahead of the chlorinated solvent plume, and will tend to impact an aquifer system to a much larger extent.
Suggested laboratory methods: SW-846 Method 5030C, SW-846 Method 5021, SW-846 Method 8261A, SW-846 Method 5031, SW-846 8270C SIM, LVI and isotope dilution (1.0 µg/L or 2.0 µg/kg reporting limits). Dioxane can be detected using EPA 8260; however, its high water solubility causes relatively high reporting limits.
Routine organic extraction procedures like those traditionally used for EPA 8270 analyses produce low recoveries (approximately 50% or less). Whatever laboratory method is proposed for 1,4-Dioxane by JBER, the laboratory method must be able to detect at or below the ADEC promulgated groundwater cleanup level in Table C and migration to groundwater cleanup level in soil.
Be aware that with ADEC’s regulatory revisions in 2014, the level for 1,4-Dioxane (as well as many other compounds) will go down substantially from its current promulgated levels for soil and groundwater. These changes in regulations will be available for public comment sometime this year.
Finally, the EPA May 2013 Regional Screening Levels for tapwater lists a lower screening level of 0.67 ug/L which equates to a 1x10-6 total risk as well as a noncarcinogenic screening level of 47 µg/L which equates to a HI of 0.1.
7.4 LF059 Site Summary
See comment #1 regarding 1,4-dioxane analysis in groundwater. This comment applies to JBER-E and JBER-E sites with current or past TCE or TCA contamination.
See Site file for additional information.
|
Louis Howard |
| 11/4/2013 |
CERCLA ROD Periodic Review |
Fourth Five-Year Review (draft) received for review & comment.
All remedial actions are operational & functional at OU1. Cleanup levels were met for 1,2-dibromoethane in 1996, vinyl chloride in 1997, & manganese in 2001. Groundwater cleanup levels for all COCs were met at LF05, LF07, LF13 & OT56, leading to the removal of these sites from CERCLA in 2004. Monitoring is ongoing at LF59, where only TCE remains above the cleanup level.
Although Mann-Kendall trend analysis at the source area indicates no trend in TCE concentrations, plume boundaries appear stable. An upgradient source of TCE & 1,1,2,2-PCA is affecting LF59 groundwater. A cleanup date for TCE cannot be predicated at this time.
The groundwater at the site should be proposed for No Further Action. The groundwater at LF59 affected by the upgradient source should be managed under the Compliance program, which is currently managing the plume migrating into LF59.
New groundwater cleanup levels &/or MCLs (not addressed in the ROD or previous Five-Year Reviews) for arsenic, beryllium, fluoride, methyethylketone, & nickel were identified. However, only fluoride & nickel exceeded the newly promulgated cleanup levels at the time of the ROD. Of the contaminants that exceeded their newly established cleanup levels, only fluoride had the potential to result in a hazard/risk level greater than the EPA risk management decision range; however, in both cases, the existing remedy is protective.
One concentration of fluoride at 5,200 µg/L was detected at the time of the ROD, which exceeds the current cleanup level of 4,000 µg/L. Because only one concentration of fluoride exceeded the hazard/risk level at the time of the ROD, it was not considered a COPC for OU1. For this reason, & because fluoride is naturally occurring, the protectiveness of the remedy is not called into question by the newly promulgated cleanup level.
The maximum concentration of nickel (310 µg/L) reported at the time of the ROD exceeds the current cleanup level of 100 µg/L. However, the hazard/risk level calculated for nickel is the EPA risk management decision range; therefore, the protectiveness of the remedy is not called into question by the newly promulgated cleanup level.
Although the surface water standards were discussed in the 2008 Five-Year Review (USAF, 2008a), the discussion focused only on the TAH. The data collected at the time of the RI/FS does not have sufficiently low detection limits to evaluate TAqH at the level specified in the surface water quality standards.
Changes to OU1 COC chemical specific toxicity information that occurred since the 2008 Five-Year Review affect one of the OU1 COCs, TCE. The ROD-established groundwater RAO for TCE was assessed for protectiveness by applying the updated chemical-specific toxicity information & calculating the hazard quotient & cancer risk at the RAO concentration. The ADEC Risk Assessment Procedures Manual (ADEC, 2000) was followed for the assessment.
The assessment found that the groundwater RAO for TCE continues to be protective of human health under a residential exposure assumption.
Future Five-Year Reviews for OUs 1, 2, 4, 5 & 6 & Site DP98 are necessary because contamination remains above levels that allow for UU/UE in these areas. The next Five-Year Review is due on or before January 27, 2019. |
Louis Howard |
| 12/20/2013 |
Document, Report, or Work plan Review - other |
Staff provided comments on the draft 4th 5 Year Review report.
S-2, S-3, S-4, S-5 & S-6 Issues & Recommendations Identified in the Five-Year Review: OU1
Remedy Performance Recommendation - ADEC requests the text be changed to determine the source & extent of TCE & other COPCs (e.g. 1,1,2,2-Tetrachloroethane) contamination in GW, determine whether it can be incorporated into the current remedy or whether an alternative remedy is necessary.
4-2 4.1 OU 1 - ADEC requests the report state whether or not there are occupied buildings at LF59 within 100 feet of GW exceedances of vapor intrusion criteria for volatile compounds (e.g. TCE). "…an inhabited building [is] generally be considered “near” subsurface contaminants if it is located within approximately 100 ft laterally or vertically of known or interpolated soil gas or GW contaminants…
If the source of contamination is GW, we recommend migration of the contaminant plume be considered when evaluating the potential for future risks.” (EPA 2002 Draft Guidance for Evaluating the Vapor Intrusion to Indoor Air Pathway from GW & Soils).
ADEC requests that a comparison of current GW concentrations to GW vapor intrusion (VI) criteria (target levels) to help demonstrate that the current conditions are protective of this vapor intrusion exposure pathway if there are buildings at LF59.
For those locations where there is a completed pathway for TCE vapor intrusion, then EPA Region 10 guidance (OEA Recommendations Regarding Trichloroethylene Toxicity in Human Health Risk Assessments, December 13, 2012) is applicable for assessing vapor intrusion based on TCE toxicity using non-cancer, not-to-be-exceeded average 21-day exposure scenarios when women of reproductive age may be present to prevent fetal cardiac malformations.
4-4 4.1.1 OU 1 Remedy Implementation & Status - The text states: “Natural attenuation parameters measured in the field indicate that geochemical conditions at LF59MW-02 & LF59MW-03 fluctuate between weakly reducing & weakly oxidizing; significant reductive dechlorination is unlikely to occur under these conditions.”
Changes in the geochemical setting as indicated by geochemical parameters (particularly the redox parameters such as redox potential, dissolved oxygen, nitrate/nitrite, manganese (II), iron (II), sulfate, & methane) may suggest there are changes in biotic or abiotic processes affecting the rate & extent of natural attenuation, so monitoring of these parameters is key for performance monitoring of MNA.
ADEC requests the 5-Year Report be revised to include discussion of specific geochemical parameters being monitored at OU1 LF59.
ADEC requests the Air Force direct the reader in the document where they can review the most recent assessment of the performance of the natural attenuation remedy for OU1 LF59 GW (e.g. June 2011 Zones 1, 2, & 3 Annual Report).
3rd Paragraph
The text states: “TCE is the only GW COC that remains above the cleanup level.”
This is correct however, there is a likelihood that 1,4-dioxane is present at OU1 as a result of the TCE contamination which also present in GW & therefore must be, at a minimum, monitored for in GW at OU1.
Prior to the next (Fifth 5 Year Review) ADEC requests JBER conduct GW sampling (& soil if applicable) for 1,4-dioxane. 1,4-dioxane sampling in GW wells where TCE or TCA contamination exists or was previously existed above cleanup levels at any site (CERCLA or State restoration/2-Party or JBER Compliance program).
See Site file for additional information.
|
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 1
The EPA concurs that the remedy for OU 1 is currently short-term protective of human health and the environment through implementation of Land Use Controls. Short term protectiveness is appropriate for this remedy where residential use of the site is not permitted and access to groundwater and subsurface debris is restricted through land use controls.
For OU1 to be protective in the long term, EPA agrees additional investigation is required to evaluate source areas for the chlorinated solvent plume observed in monitoring wells OU1LF-19 and LF05GW-2B. This OU contains a number of landfills, many which have previously been closed under CERCLA and transferred to monitoring under the State of Alaska Solid Waste compliance program.
Compliance monitoring data for groundwater wells OU1LF-19 and LF05GW-2B contains concentrations of trichloroethene (TCE) above federal drinking water standards. The source of this contamination and the plume boundary have yet to be defined. EPA agrees with the recommendation to pursue further investigation into the source and extent of groundwater contamination impacting these wells. |
Louis Howard |
| 3/20/2014 |
CERCLA ROD Periodic Review |
ADEC appreciates the opportunity to review the fourth Five Year Review report for the Elmendorf Air Force Base (now JBER-E) Superfund site, in Anchorage Alaska. ADEC reviewed this report for technical adequacy, accuracy, and consistency with EPA guidance and the Elmendorf Air Force Base Federal Facility Agreement. 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. ADEC has reviewed the report which includes: Operable Units (OU) 1, 2, 4, 5, 6 and DP98, associated with Elmendorf Air Force Base on Joint Base Elmendorf-Richardson, Alaska. In general, ADEC agrees with the protectiveness determinations in this report.
General Comments
ADEC has commented on the matter of sampling for Perfluorinated compounds (PFCs) in this Five-Year Review at various fire-training areas/pits where Aqueous Film Forming Foam (AFFF) fire-fighting agents containing PFCs were used to extinguish fires. The Air Force’s response to ADEC’s comments was the following: “USAF guidance (Interim Guidance on Perfluorinated Compounds, 17 Sep 2012) will be followed to address potential release of perfluorinated compounds (PFCs). A centrally-funded project to conduct initial sampling has been authorized and programmed.” ADEC expects JBER to sample all of its former fire training areas/pits for PFCs [e.g. perfluorooctane sulfonate (PFOS), and perfluorooctoanoic acid (PFOA)] prior to the Fifth Five-Year Review to determine whether or not these compounds are contaminants of concern and require remedial action to protect human health, welfare, safety or the environment.
ADEC concurs that the remedy for OU1 is currently protective of human health and the environment in the short term through implementation of Land-Use Controls (LUCs) and long-term groundwater monitoring. However, for the remedy to be protective in the long-term, additional investigation, through the process established in the Elmendorf Air Force Base Federal Facility Agreement, is required to evaluate upgradient source areas for the chlorinated solvent plume observed in monitoring wells OU1LF-19 and LF05GW-2B. Further response action, through the process established in the Elmendorf Air Force Base Federal Facility Agreement may be necessary to address this chlorinated solvent plume. Compliance monitoring data under ADEC’s Solid Waste Program for groundwater wells OU1LF-19 and LF05GW-2B contain concentrations of trichloroethlene (TCE) above the federal drinking water standard and concentrations of 1,1,2,2-Tetrachloroethane above Table C groundwater cleanup level. The source of this contamination and the plume boundary have yet to be defined. |
John Halverson |
| 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 TCE concentrations are still above the OU1 ROD cleanup criteria of 5 µg/L in monitoring
wells LF59MW-02 and LF59MW-03. Mann-Kendall trend tests show that there is not a statistically significant increasing or decreasing trend at the 95% level of significance in the well. Mann-Kendall trend test analysis records are provided in Attachment 1. There are not enough data points to establish a trend for well LF59MW-02. |
Louis Howard |
| 6/4/2014 |
Document, Report, or Work plan Review - other |
Staff provided comments on the draft CERCLA GW report.
See comments regarding 1,4-Dioxane at sites with TCE groundwater contamination, IC's adequacy being noted as N/A, and dig permits issued within the last 12 months. ADEC concurs with the recommendations for LF004. |
Louis Howard |
| 11/5/2014 |
Document, Report, or Work plan Review - other |
EPA provided comments on the draft CERCLA report.
Comment: At what point will the site description for LF059 be modified to include the undefined upgradient plume that is migrating into LF59 at OU1-LF19 and LF05GW-2B? The Northern Plume is now a site under the FFA as of summer 2014.
Comment: Figure 7-2 is a good example of how outlier or non-dectects could be handled under the Mann-Kendall analysis. What's the trend if this point is dropped? What criteria would be used to determine if a sample result is an outlier and omitted from the analysis?
|
Louis Howard |
| 7/23/2015 |
Update or Other Action |
Draft Annual Field Activities Report received for review and comment.
SITE SUMMARY AND RECOMMENDATIONS
The TCE concentrations were just below the OU1 ROD cleanup levels of 5 µg/L in the primary
samples for monitoring wells LF59MW-02 and LF59MW-03 and exceeded the cleanup levels in the field duplicate.
7.4.1 Five-Year Review
Areas in OU 1 that remain above cleanup goals are required to have CERCLA five-year reviews
conducted until such time as the cleanup goals are achieved. The purpose of the five-year review
is to evaluate the implementation and performance of the remedial actions. There were no
recommendations for LF059 documented during the first five-year review period in 1998, or for
the second five-year review in 2003. The third five-year review report recommended incorporating data from upgradient wells LF05GW-2B and OU1LF-19 into the evaluation of natural attenuation and analysis of contaminant trends, and updating the conceptual site model for the TCE plume (USAF, 2008c).
The fourth five-year review report recommended pursuing a “Response Complete” status for LF059, delineation of the upgradient plume affecting LF059 that may originate from closed site LF007, pursue reopening LF007 under CERCLA and the management of the groundwater plume that is affecting part of LF059 as part of the upgradient source. The review also recommended a sampling event be conducted to identify if concentrations of 1,4-dioxane exist and whether or not there is an unacceptable risk at the site.
Recommendations
LF059 is identified as a Green priority. The TCE Contamination at the LF059 site appears to be coming from an upgradient source. A new CERCLA site has been opened (CG704) to investigate the potential upgradient source. A limited field investigation is planned for2015 or 2016. Pursuit of a “Response Complete” for LF059 is recommended. It is recommended that all groundwater sampling be discontinued at all monitoring wells at this site, including the LF59-09SEEP-SE sampling. |
Louis Howard |
| 8/10/2015 |
Document, Report, or Work plan Review - other |
Staff provided comments on the Annual CERCLA Report. Staff commented on the need to monitor groundwater for 1,4-Dioxane which is associated with TCE contamination. |
Louis Howard |
| 4/20/2016 |
Document, Report, or Work plan Review - other |
Draft Interim Remedial Action Completion Report received. This Interim-Remedial Action Completion Report (I-RACR) documents that all remedial actions (RAs) have been taken, RA objectives (RAOs) have been achieved, & human health & the environment are protected at Site LF059. No soil remedy was provided, as it was determined that soil remediation was not needed at OU 1.
The major components of the GW remedy outlined in the ROD include: ICs; Monitoring GW for 5 years or until the GW poses an acceptable health risk; Five-year review to assess the protectiveness of the RA; & Periodic evaluation of monitoring results to determine whether further remedial action is needed.
ICs – also known as land use controls (LUCs) – were established to prevent access to soil & contaminated shallow GW at OU 1. LUCs are part of the selected remedy in the ROD. As stated in the LUC Mgt. Plan, OU 1 (including LF059) is designated as a “Restricted Use Area” for recreational use only. Construction of manned facilities is prohibited at the site. Excavation that would compromise the landfill caps or impact the shallow GW is also prohibited.
The 4th five-year review report recommended pursuing a “Response Complete” status for LF059; delineating the upgradient TCE plume affecting LF059 that may originate from the closed site LF007; & pursuing reopening LF007 under CERCLA & managing the GW plume affecting part of LF059 as part of the upgradient source. The review also recommended that a sampling event be conducted to identify whether concentrations of 1,4-dioxane exist & whether or not there is an unacceptable risk at the site. In response to the five-year review, the USAF opened a new site (CG704) associated with the unknown upgradient source for the LF059 plume & will initiate a Limited Field Investigation for the new site in 2016.
The implemented remedy for GW achieves the degree of cleanup or protection specified in the ROD for all pathways of exposure for contaminants originating at LF059. The previous investigations support the interpretation that TCE is associated with an unknown upgradient source. Interpretation of the offsite TCE source is based on a combination of GW flow direction, distribution of TCE in 3 monitoring wells & the lack of onsite TCE sources. Because the remaining contamination is associated with the unknown upgradient source, this effectively satisfies the attainment of RAOs for LF059. It is recommended that GW monitoring be terminated at CERCLA Site LF059 & transferred to the new CG704 site. A letter of agreement is hereby requested from EPA & ADEC.
The termination of GW monitoring, coupled with the attainment of the ROD RAOs by virtue of transfer of the TCE contamination to CG704 will make the LF059 site eligible for an Air Force “Response Complete” status
See site file for additional information. |
Louis Howard |
| 4/27/2016 |
Document, Report, or Work plan Review - other |
Staff reviewed the Draft IRA Completion Report.
Based on the information provided, ADEC agrees that the trichloroethylene groundwater contamination is from an off-site source and any further action and groundwater monitoring be terminated at LF059 and transferred to the new CG704 site. Pending resolution of any EPA comments, please finalize the document. Note: ADEC does not support the use of groundwater statistics as detailed in the EPA 2014 Groundwater Restoration Completion Guidance to determine that a groundwater restoration remedial action is complete. Remedial action complete or “cleanup complete” determinations for closure will be based on the maximum detected concentrations in groundwater, as required by 18 AAC 75.380(c)(2), at each monitoring well. |
Louis Howard |
| 5/19/2016 |
Document, Report, or Work plan Review - other |
EPA provides comments on the IRAC Report.
1.1 The purpose of the iRACR is to document RAO complete at only a portion of the COCs in the OU1 ROD, and to transfer monitoring of the VOC-based COCs to site CG704. It is incorrect to state that RAOs in the OU1 ROD have been met without some additional explanation.
1.4.2 The last paragraph discusses COCs at LF059. To be clear, add Soil to the sentence “ Soil contaminants of concern at LF059 were determined to be benzo(a)anthracene, benzo(k)fluoranthene, bis(2-ethylhexyl)phthalate, 2-methylnapathalene, arsenics, barium and copper.
The next sentence states groundwater was the only medium that posed a human health risk but then does not describe the COCs in groundwater. The OU1 ROD spends quite a bit of time discussing elevated manganese, and lists 1,2-dibromoethane, TCE and VC as COCs in groundwater. These should be listed here with a brief discussion.
1.5 The risks were calculated for soils and groundwater, not surface water. “The OU 1 COCs were detected at concentrations below the acceptable risk ranges cited in the ROD (1 x 10-4 to 1 x 10-6) for soil and surface groundwater.”
Include a short discussion on why arsenic, polychlorinated biphenyls (PCBs), and lead in groundwater exceeded risk levels but were not included as groundwater COCs.
7.0 The first sentence must be supported with attainment statistics for the other groundwater COCs ‘originating’ from the site. No data was presented for manganese or EDB.
The summary should clarify exactly which COCs are transferring to CG704 for continued monitoring. (TCE and VC? EDB, TCE, and VC?)
|
Louis Howard |
| 1/13/2017 |
Update or Other Action |
ADEC received a groundwater monitoring report for several JBER sites. The report summarizes the 2015 annual long-term management (LTM) activities, including remedial action-operation (RA-O) and Record of Decision (ROD) requirements conducted at Joint Base Elmendorf-Richardson (JBER) Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) sites.
Site LF059 is identified as a Green priority. The TCE contamination at the LF059 site appears to
be coming from an upgradient source. A new CERCLA site has been opened (CG704) to investigate the potential upgradient source. Pursuit of a RC for LF059 is recommended. An IRACR is in the process of being prepared, and should be submitted in 2016. It is recommended to transfer monitoring wells at this site (LF59MW-02 and LF59MW-03) to the new site and become program wells as appropriate.
See site file for additional information. |
Louis Howard |
| 2/9/2018 |
Document, Report, or Work plan Review - other |
Draft annual RA-O Monitoring report for CERCLA sites reviewed and commented on. Staff concurred with the recommendations to transfer monitoring wells at this site (LF59MW-02 and LF59MW-03) to CG704 and become program wells as appropriate. ADEC also concurs with the recommendation that LUC inspections continue until the site reaches SC. |
Louis Howard |
| 1/15/2019 |
Update or Other Action |
Draft 5 Year Review received for comment which include Operable Unit 1 source area LF059.
Remedial action objectives have been met, monitoring for remaining TCE contamination in groundwater at LF059 has been transferred to the upgradient source CG704, and the site is eligible for “Response Complete” status.
No issues affecting remedy protectiveness were identified during this FYR. Recommendations
identified during this FYR that do not affect the protectiveness of the remedy at LF059 include:
LUCs should remain in place since risks and hazard exceed acceptable thresholds for 1,1,2,2-PCA and TCE (in groundwater). The next sampling event at CG704 should include an assessment of current 1,1,2,2-PCA concentrations.
See site file for additional information. |
Louis Howard |
| 5/28/2021 |
Document, Report, or Work plan Review - other |
DEC Approved of Final LTM and LUC Inspection Work Plan for select CERCLA sites dated May 2021. |
William Schmaltz |
| 8/9/2021 |
Document, Report, or Work plan Review - other |
DEC staff reviewed and provided comments on Draft 2020 Land Use Control report for Select CERCLA sites dated June 2021. Report summarized LUC inspections performed in December 2020. Most sites were covered in snow and a full inspection could not be performed until spring 2021. DEC requested that the spring 2021 inspections are included in the 2020 report or as a separate cover because they are a continuation of the 2020 inspections and separate of the 2021 inspections. |
William Schmaltz |
| 4/20/2023 |
Document, Report, or Work plan Review - other |
DEC reviewed and provided comments for the 2021 Annual Remedial Action-Operations and Long-Term Management Report for Select CERCLA Sites, Draft, dated December 2023. The report describes the site inspections, maintenance activities, and groundwater monitoring, at multiple sites located on Joint Base Elmendorf- Richardson (JBER), Anchorage, Alaska. Site inspections and sampling were recommended to continue for all applicable sites to ensure that conditions remain protective of human health and the environment. |
Ginna Quesada |
| 1/29/2024 |
Document, Report, or Work plan Review - other |
DEC reviewed the 2022 Annual Remedial Action-Operations and Long-Term Management Report for Select CERCLA Sites, Draft, dated October 2023. The report describes the site inspections, maintenance activities, and groundwater monitoring, at multiple sites located on Joint Base Elmendorf- Richardson (JBER), Anchorage, Alaska. Site inspections and sampling were recommended to continue for all applicable sites to ensure that conditions remain protective of human health and the environment. |
Ginna Quesada |
| 7/2/2024 |
Document, Report, or Work plan Review - other |
DEC approved the 2022 Annual Remedial Action-Operations and Long-Term Management Report for Select CERCLA Sites, Final, dated June 2024. The report describes the site inspections, maintenance activities, and groundwater monitoring, at multiple sites located on Joint Base Elmendorf- Richardson (JBER), Anchorage, Alaska. Site inspections and sampling were recommended to continue for all applicable sites to ensure that conditions remain protective of human health and the environment. |
Ginna Quesada |
| 11/12/2024 |
Document, Report, or Work plan Review - other |
DEC approved the 2023 Annual Remedial Action-Operations and Long-Term Management Report for Select CERCLA Sites, Final, dated October 2024. The report describes the site inspections, maintenance activities, and groundwater monitoring, at multiple sites located on Joint Base Elmendorf- Richardson (JBER), Anchorage, Alaska. Site inspections and sampling were recommended to continue for all applicable sites to ensure that conditions remain protective of human health and the environment. |
Ginna Quesada |
