| Action Date |
Action |
Description |
DEC Staff |
| 11/2/1983 |
Update or Other Action |
USAF William R. Hanson, P.E. Director, Engrg. & Envmtl. Planning to DEEV (Mr. Hostman) 21 CSG/DEEV RE: Memorandum of Understanding (MOU) between DOD and EPA.
1. The attached guidance has been received from HQ USAF/LEE (atch 1). It is subject to change as time progresses. It is important to note that all actions affected by this agreement will be implemented within the overall guidance of the Installation Restoration Program.
2. All queries or requests for action received from Federal or State agencies concerning releases from former Air Force installations (MOU para 3.2) or other releases for which the Air Force is a responsible party(MOU para 3.3) will be referred to HQ AAC/DEEV for forwarding to HQ USAF/LEEV. HQ USAF will task appropriate commands and/or staff agencies for response action. Any requests received from the State of Alaska or other Federal agencies will be reported by phone to this office, autovon 552-4151. All pertinent information will be provided to assist HQ AAC/DEEV in determining the exact nature of the information requested and required for the reply. The information requested will include any information on pending legislation or other enforcement actions that may have an effect on the situation.
Letter from Gary Alkire Brigadier General USAF Deputy Director, Directorate of Engineering & Services to ALMAJCOM/DE/SG/JA.
1. The attached MOU regarding implementation of the Comprehensive Environmental Response, Compensation, and Liability Act of 1980 is provided for your information. It deals, in general, with DoD and EPA responsibilities and procedures to be followed in identifying, evaluating, and controlling releases of hazardous pollutants from currently active and former DoD facilities and third party facilities at which DoD is a responsible party.
2. This letter provides interim implementation guidance concerning the MOU.
3. All Air Force actions in response to this MOU will be conducted within the framework of the existing Installation Restoration Program.
4. Affected major commands will continue to be responsible for releases from currently active Air Force installations (MOU para 3.1).
5. All queries or requests for action received from Federal or State agencies concerning releases from former Air Force installations (MOU para 3.2) or other releases for which the Air Force is a responsible party (MOU para 3.3) will be referred to HQ USAF/LEEV. HQ USAF will task appropriate commands and/or staff agencies for response action. See site file for additional information. |
Louis Howard |
| 6/26/1987 |
Enforcement Action |
Bill H. Lamoreaux sent a notice of violation (NOV) to Commander USAF 21 Combat Support Group Elmendorf AFB. June 24, 1987 at 11:00 AM ADEC personnel observed large quantities of visible detergents in the storm outfall located next to Cherry Hill. At 1:00 PM the detergents were still there, but somewhat less in quantity (see photographs). However, at a pond near Elder Street (NOW renamed 10th Street) it was noted that oil and solvents were being discharged over a weir. Also there was evidence of solvent emulsions on the water (see photographs). This evidence clearly indicates an industrial discharge into this drainage.
This discharge is not permitted and is in violation of Alaska Statutes A.S. 46.03.100, A.S. 46.03.710, A.S. 46.03.740, Title 18 Alaska Administration code 75.080(3), 18 AAC 72.210, and 18 AAC 70.010(d). ADEC requests that the untreated discharges of industrial waste into the stream be identified and ceased. Furthermore it is requested that the sediments in that stream bed, particularly near Elder Street, be tested for halogenated hydrocarbons. Included in the tests should be; trichloroethylene, 1,1,1-trichloroethane, and methylene chloride. Finally, ADEC requests a report as to what areas were discharging to the stream and the results of the sediment test by September 1, 1987. |
Bill Lamoreaux |
| 8/19/1987 |
Update or Other Action |
Letter sent to Bill Lamoreaux Regional Supervisor regarding AF attempts to comply with June 26, 1987 Notice of Violation. The AF has attempted to identify specific sources of the suspected contamination. To date they have not been successful. AF has taken grab samples at six points on the storm drain system in order to identify the origin. AF is negotiating a contract to have the collected samples analyzed for the contaminants described in your letter. The results of the analysis are expected to be received on September 1, 1987. Signed Richard D. Brown Colonel USAF Commander. |
Bill Lamoreaux |
| 2/17/1988 |
Update or Other Action |
Letter to Bruce Erickson Southcentral Regional Office (SCRO) from USAF. Per 26 June 1987 request from ADEC, six each soil samples were collected along the Cherry Hill ditch in late August 1987. Unfortunately, sample collection errors negated the validity of these test results, necessitating the resampling of all six areas on 12 November 1987.
Based on these results, it does not appear that stream bed sediments are contaminated with halogenated volatile organics. The source of the visible detergents, oils and solvents observed during Mr. Erickson's site visit is still being investigated. Although the most likely source remains the base flight line area, the specific location has yet to be determined. Since the Cherry Hill ditch provides storm drainage for the majority of the EAFB flight line and industrial complexes, quick resolution of this issue is unlikely. Signed Warren Page Colonel USAF Base Civil Engineer. |
Bruce Erickson |
| 8/2/1988 |
Update or Other Action |
Operable Units' source areas that correspond to RCRA SWMUs from the RCRA RFA. SD52 NS-1 Cherry Hill Ditch, located in the southwestern quadrant of the Elmendorf site plan. The ditch drains westerly towards Cook Inlet. At the headwater of this ditch is a 30 inch corrugated pipe
that discharges -200 gal of water/min. from drains under the runway and possible from other shop drains on base. The source of contamination and delineation of the contamination are
unknown. Futher investigation is needed, this will be addressed in the RFI as a facility wide hydrogeologic assessment to determine the source of the surface water and stream sediment
and surface water sampling and analysis. |
Louis Howard |
| 12/8/1989 |
Update or Other Action |
Letter from USAF to Ron Klein. Per our 10/27/1989 meeting, the attached information concerning the Cherry Hill ditch water sample and dye test results are provided. Stream water sampling is accomplished by the Bioenvironmental Engineering office, with results at Attachment 1 (attach. not in file). These samples, taken quarterly, show no trends in contaminant levels and indicate past discharges of industrial wastewater into the storm sewer system have not been of a continuous nature, but were instead transient incidents. This conclusion is supported by stream bed sediment tests which also indicated no contamination. Transient discharges are capable of entering the stream without detection by the existing sampling routine.
Identifying sources of contaminants in the storm sewer will require dye testing of the drains in all industrial facilities on EAFB. Dye tests have been completed for the facilities list in Attachment 2 (again attach. 2 is not in file) with remaining facilities to be tested as resources become available. AF anticipates all testing to be done by July 1990; the results will then be evaluated to identify follow on projects for pretreatment and/or rerouting of wastewater discharges, as necessary. |
Ron Klein |
| 12/15/1989 |
Update or Other Action |
Ron Klein Supervisor-Contaminated Sites Investigations sent letter to Captain Steve Rauner USAF 21st CSG/DEEV. Comments: 11/22/89 letter on ESS Sewage Lagoon did not address the need to obtain a wastewater permit. A permit will be needed for the current sewage lagoon. Contact Mike Lewis for permit requirements. Cherry Hill Ditch: Please provide the District with a copy of the dye test results after the test is completed. In addition, please provide the dye test evaluation after it is completed. ADEC is concerned that the discharges to Cherry Hill Ditch may be in violation of State of Alaska Water Quality standards. Quarterly sampling of Cherry Hill ditch is sufficient. |
Ron Klein |
| 2/20/1990 |
Update or Other Action |
Air Force memorandum for the file. Request for AFOEHL Hazardous Waste Assessment of Elmendorf AFB. 1. The 21 Tactical Fighter Wing Commander, Elmendorf AFB, Alaska has requested a hazardous waste assessment be accomplished by the AFOEHL in an attempt to resolve a number of hazardous waste program discrepancies identified by the Anchorage area office of the Environmental Protection Agency and the Alaska
Department of Environmental Conservation (ADEC). Elmendorf AFB was recently proposed for inclusion on the National Priorities List for comparison with Superfund Sites, resulting in increased attention by ADEC on base environmental programs.
2. The base has received Notices of Violation (NOV) for inadequate training of its accumulation point managers, identification of hazardous waste accumulation points and portions of its programs pertaining to hazardous waste management. To date, a hazardous waste stream characterization of each base location using hazardous materials to determine the amount of hazardous waste generated has not been conducted. Additionally, Elmendorf is in the process of updating its RCRA Part B permit.
3. We envision the assessment to be accomplished in two phases. The initial phase would consist of a traditional waste stream characterization. Information is available from the Elmendorf AFB Bioenvironmental Engineering Section on hazardous material information for each industrial workplace, supply hazardous material turn-in roster (M-15) from base supply and semiannual
industrial wastewater pretreatment monitoring data. The second phase of the study would consist of an on site assessment to identify industrial areas for signs of soils contamination and spillage associated with improper hazardous waste storage and handling. This portion of the evaluation would be conducted in the late spring after the snow has melted.
4. If additional time is available we request:
(a) A dye trace study be conducted at 12 locations on base to assess whether a number of unknown hangar drains discharge to the sanitary sewer or to the storm drain. An NOV was assigned by ADEC to the Cherry Hill drainage ditch alleging signs of contamination (foam and oil sheen) believed to originate from one or a number of these locations.
(b) Recommendations be provided based upon the waste characterization study on methods to minimize the amounts of hazardous wastes being generated. |
Jennifer Roberts |
| 5/1/1990 |
Update or Other Action |
Stage 3 Remedial Investigation (May 1990) for Cherry Hill Ditch (NS-1) Results: Water samples from sample locations NS1-03 and NS1-04 contained chloroform at concentrations of 0.96 and 0.60 ug/L, respectively. The water sample from sample location NS1-04 also contained 1,1,1-
trichloroethane (0.53 ug/L). A sediment sample from sample location NS1-03 contained a total petroleum hydrocarbon concentration of 436 mg/kg. This sediment sample also contained the following polycyclic aromatic hydrocarbons: benzo(a)anthracene (15 mg/kg), benzo(a)pyrene
(16 mg/kg), benzo(b) fluoranthene (13 mg/kg), chrysene (21 mg/kg), fluoranthene (38 mg/kg), phenanthrene (30 mg/kg), and pyrene (27 mg/kg).
The highest lead (850 mg/kg), zinc (450 mg/kg), chromium (120 mg/kg), and copper (190 mg/kg) concentrations were detected in the sediment sample from sample location NS1-03. Water samples from sample locations NS1-02, NS1-03 and NS1-04 at Site NS-1 exhibited a petroleum odor, sheen, and/or foam, thereby exceeding State of Alaska drinking water standards.
Base Wells used for Drinking water:
BLM Building - Base well 50
Bldg. 11-200 (now 9549 Cope Thunder) site D-5 is upgradient of - Base well 42
Bldg. 22-001 (now 3264 Water Supply) site D-17 is 4500 feet from - Base well 2
Bldg. 23-100 (now 4414 EagleGlen Golf Clubhouse) is 3000 feet upgradient of - Base well 52
Bldg. 31-189 (now 10334 Auxillary Power Plant) is 3000 feet upgradient of - Base well 16
Bldg. 5-800 (now 9480 Alaska Command) is 2000 feet upgradient of - Base well 40
Base well 1 is completed at a depth of 16 feet (located between 2nd Street and Davis Hwy just south of the N-S Runway). located a few feet from Ship Creek. The well is 10 feet in diameter and 16 feet deep. The well probably obtains a significant amount of its water from Ship Creek as induced infiltration and the remainder as captured shallow groundwater flow. The
compounds 1,1-dichloroethane, l,,1,-trichloroethane, trichloroethene, and 1,1,2,2,-tetrachloroethane were detected at concentrations of 0.79, 3.4, 1.4, and 1.8 ug/L, respectively, in a sample from BW-1, which draws from the shallow aquifer. This water sample also contained a total petroleum hydrocarbon concentration of 3.0 mg/L. Petroleum hydrocarbons (2.0 mg/L) were also detected in a water sample from BW-52. |
Jennifer Roberts |
| 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 |
| 6/13/1991 |
Update or Other Action |
Jennifer Roberts received a letter regarding the Cherry Hill Stormwater Drainage Ditch. The USAF letter is information requested by ADEC during a June 3, 1991 meeting. Attachment 1 is a copy of the 12/8/89 communication with ADEC concerning the results of our water sampling and preliminary dye testing. Attachment 2 is a copy of the 2/17/88 letter to ADEC concerning the stream bed sampling.
Test results have been misplaced. AF is waiting to reaccomplish testing until ADEC has a chance to review information. Attachment 3 is the latest results of dye testing. This list supersedes the list in Attachment 1. Building D-29 is the 21 Transportation Construction Equipment Maintenance shop, Building 32-141 (Now referred to as the Heavy Equipment Shop Building 8288 Gott Avenue). For ADEC information Hangars 15 and 16 have a project programmed to tie into the sanitary sewer; however the project isn't funded at this time. |
Jennifer Roberts |
| 10/24/1991 |
Update or Other Action |
Letter to Jennifer Roberts by the USAF requesting closure of the June 26, 1987 Notice of Violation (NOV) involving visible detergents in the Cherry Hill Ditch. Sampling presented during an August 1991 meeting indicate no significant pollution and the drainage will be picked up for study in the Comprehensive Environmental Resource Conservation and Liability Act (CERCLA).
The drainage will also be addressed under the requirements for National Pollutant Discharge Elimination System (NPDES) permitting. As agreed during the August meeting, there is no need to address the NOV more than once. Please forward a letter closing the NOV. AF needs documentation for their records and to forward to headquarters showing the NOV to be formally closed.
SD52: (formerly NS-1) Cherry Hill Ditch, located in the southwestern quadrant of the Elmendorf site plan. The ditch drains westerly towards Cook Inlet. At the headwater of this ditch is a 30 inch corrugated pipe that discharges 200 gallons of water per minute from drains under the runway and possibly from other shop drains on the Base. The source of contamination and delineation of the contamination are unknown. Further investigation is needed, this will be addressed in the RCRA Facility Investigation (RFI) as a facility wide hydrogeologic assessment to determine the source of the surface water and stream sediment and surface water sampling and analysis. |
Jennifer Roberts |
| 10/31/1991 |
Update or Other Action |
CH2MHILL found various data gaps from the site investigations done at site. Groundwater depth was estimated, no wells were installed nor were groundwater samples collected from site, large amounts of foam was observed but not sampled and analyzed, TPH and PAHs were detected in sediment at site and these constituents were not detected in other sediment samples, but only 4 other locations were sampled. Additional sediment sampling to determine extent of PAH and TPH contamination. |
Jennifer Roberts |
| 11/12/1991 |
Enforcement Agreement or Order |
Federal Facility Agreement under Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) signed for docket # 1089-07-19-120. The agreement ensures that the environmental impacts associated with past and present activities at the Base are thoroughly investigated and appropriate removal and/or remedial action(s) taken as necessary to protect human health and the environment. Elmendorf Federal Facility Agreement signed.
The general purposes of this Agreement are to: (a) Ensure that the environmental impact associated with past and present activities at the Site are thoroughly investigated and appropriate removal and/or remedial action(s) taken as necessary to protect the public health, welfare, and the environment.(b) Establish a procedural framework and schedule for developing, implementing, and monitoring appropriate response actions at the Site in accordance with CERCLA, the NCP, Superfund guidance and policy, RCRA, RCRA guidance and policy, and applicable state law.
The FFA divided the CERCLA study source areas at Elmendorf AFB into the following seven operable unites (OUs), on the basis of geographic proximity and similar source characteristics or contaminants:
- OU1 Landfills (LF05, LF07, LF13, LF59, OT56)
- OU2 Tank Spill Sites (ST20, ST41, including the ST41 Sludge Disposal Area)
- OU3 Central Containment Area (SD16, SD31, SD52, SS21)
- OU4 Northern Containment Area (SD24, SD25, SD28, SD29, FT23, SSl0)
- OU5 Southern Containment Area (ST37)
- OU6 Surface Disposal Sites (LF02, LF03, LF04, SD15, SD73, WP14)
- OU7 Limited Field Investigation (SS19)
Proposed listing on NPL was 07/14/1989 and Final listing on NPL was on 08/30/1990.
See site file for additional information.
|
Jennifer Roberts |
| 11/12/1991 |
Update or Other Action |
Jennifer Roberts Federal Facility Coordinator sent letter to Joe Williamson and Rich Howard pursuant to Section 9.1 of the Elmendorf Air Force Base Federal Facility Agreement (FFA). ADEC designates Jennifer Roberts as the Project Manager and Ron Klein as the Alternate Project Manager for all activities covered under the FFA. |
Jennifer Roberts |
| 12/30/1991 |
Update or Other Action |
EPA sent letter to AF Rich Howard and Joe Williamson. The notification will serve as an addendum to the previous letter of November 4, 1991 which designates the USEPA project managers pursuant to Section 9.1 of the Elmendorf Air Force Base (EAFB) Federal Facilities Agreement (FFA). Marcia Combes will serve a lead remedial project manager (RPM) for 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 |
| 1/1/1992 |
Site Added to Database |
PAHs in soils and in surface water/sediments, and bis (2-ethylhexyl) phthalate in GW. |
Louis Howard |
| 2/27/1992 |
Enforcement Action Closed |
Kevin K. Kleveno sent letter to Captain Doug Tarbett HQ 3rd Support Group Civil Engineering regarding the request to close the notice of violation for Cherry Hill ditch dated June 26, 1987. It is ADEC's understanding the drainage and associated contamination problems will be addressed by NPDES permit actions and the CERCLA Federal Facility Agreement (FFA).
Cherry Hill ditch has been included in the FFA Operable Unit (OU) 3. OU3 is scheduled for action in 1993 with a final RI/FS in 1995. The action will include water and sediment sampling of Cherry Hill ditch for CERCLA contaminants. The FFA will also address several potential source areas that may contribute contamination to Cherry Hill Ditch. The NPDES permitting action will address storm drain runoff collected from the runway and other base storm drain systems which discharge into Cherry Hill. With the above actions scheduled, ADEC approves the closure on the Cherry Hill ditch notice of violation dated June 26, 1987. |
Kevin Kleweno |
| 7/20/1992 |
Preliminary Assessment Approved |
Memorandum for a meeting held at CH2MHILL/ANC on July 8, 1992 subject: OU4 IRA Planning. Purpose was to discuss the preliminary results of the OU4 Limited Field Investigation (LFI) field work and reach consensus among the project managers on which OU4 source areas would be appropriate for an Interim Remedial Action (IRA). General criteria for an Interim Remedial Action (IRA):
1) contamination verified above action levels (EPA and ADEC guidance levels);
2) point source contamination defined and accessible;
3) IRA implementable;
4) IRA won't interfere with final remedy; and
5) IRA should prevent further release of contaminants.
SD30 Building 21-900: 2 floor drains sampled go to storm sewer which eventually goes into Cherry Hill Ditch. No organic or inorganic contamination detected in LFI beyond "background" concentration ranges. Consensus: No IRA needed for SD30. |
Jennifer Roberts |
| 3/26/1993 |
Update or Other Action |
DOD and ADEC joint Technical Memorandum of understanding signed concerning the Base wide Groundwater (GW) signed by: ADEC Jennifer Roberts RPM and USAF Joseph Williamson Chief Environmental Programs and Restoration. Due to the base wide GW study and the FY92 field work that occurred at Operable Units (OUs) 1, 2, and 5 it appears a large portion of the GW flows into OU5 (attach. 1-contour map).
Based on this fact, Elmendorf (EAFB) will move all upgradient GW into the OU5 Feasibility Study, Proposed Plan and Record of Decision (ROD). This means addressing all GW from upgradient sources (CERCLA (ST20, OUs 3 and 4) and OUs 1 and portions of OU2) and SERA) at OU5 instead of at each individual source area (see attach. 2-Area Map). Sites with free phased product would be looked at to see if there is an available technology to clean them up in a cost effective way. Soil contamination would be addressed at the source areas. NOTE: addressed at the source areas is interpreted by ADEC as removal through excavation or active treatment systems (e.g. high vacuum extraction, bioventing, etc...). |
Jennifer Roberts |
| 5/3/1993 |
Update or Other Action |
Jennifer Roberts sent in a letter to Joe Williamson USAF. ADEC pursuant to the FFA under CERCLA Section 120 between USEPA, ADEC, and the USAF requests an additional twenty days to complete its review for the OU3 management plan. This extension would change the due date of the comments from May 4, 1993 to May 24, 1993. |
Jennifer Roberts |
| 5/7/1993 |
Update or Other Action |
In 1988, Black & Veatch (1990) placed a soil boring, collected soil samples at 15 feet & 20 feet below ground surface, & finished the boring as a monitoring well (IS7-01). A groundwater sample collected from IS7-01 was contaminated with chloroform at 0.32 ug/L & trichloroethene (TCE) at 76 ug/l. The level of TCE is above the drinking water maximum contaminant levels (MCLs). Total petroleum hydrocarbon (TPH) level was 2,000 ug/l. Fuels & solvents are the most likely sources of the contaminants detected.
Because of the position of Monitoring Well IS7-01 relative to the dry well, sumps, & other potential sources, the contamination detected in the groundwater may not be representative of potential contamination from source SD30. Black & Veatch estimated that the direction of groundwater flow was to the south; the well may therefore be located upgradient of SD30 sources.
No Further Action document signed. As a result of the geophysical survey & soil sampling conducted at SD30, the recommended action for the outfall structure source areas investigated at SD30 is No Further Action (NFA). The primary criterion used to place sources into the NFA category as a result of the LFI at SD30 was whether the concentration of contaminants in any sample obtained during the LFI exceeded the risk-based criteria specified by the regulatory agencies. None of the soil samples collected during the LFI at SD30 contained analytes in excess of risk-based criteria. The criteria for NFA were met at each of the source sampling locations; therefore, NFA is justified for these locations.
Source of the groundwater contamination has been identified upgradient of SD30. This upgradient contamination near Source SD30 will be investigated during the OU3 remedial investigation. The decision document was signed in May 7,1993 for SD30 by USAF Oscar V. Bryan Colonel Base Civil Engineer April 27, 1993 & EPA Marcia Combes & ADEC Jennifer Roberts on May 7, 1993.
However, groundwater is still contaminated above cleanup levels & will be monitored while undergoing natural attenuation (at Operable Unit 3). |
Jennifer Roberts |
| 8/20/1993 |
Cleanup Plan Approved |
USAF Action Memorandum letter sent regarding Cherry Hill Ditch (SD52) status. The letter, with ADEC and EPA endorsement, is to serve as a record of decision (ROD) made regarding the status of Cherry Hill Ditch, SD52, during the site reconnaissance/project managers meeting on May 20, 1993. It was agreed that the source area identifier SD52, will be deleted from the program with the understanding that the historical impact to Cherry Hill Ditch resulting from a solvent disposal trench SD16, will continue to be investigated under Operable Unit (OU) 3; and, the impact to Cherry Hill ditch resulting from ongoing airfield operations will be addressed under the environmental compliance program.
The objective behind this revision is to provide clarity during the reporting and decision making phases of the RI/FS being conducted on OU3. From Joseph F. Williamson Chief Environmental Programs and Restoration. Approved and signed by Marcia Combes USEPA and John Halverson for Jennifer Roberts ADEC on August 20, 1993. |
Jennifer Roberts |
| 8/30/1993 |
Meeting or Teleconference Held |
Unit 3 (OU 3) Management Plan to more adequately characterize contamination at possible source areas within the operable unit and to fill existing "data gaps" in the base-wide groundwater monitoring program. The changes summarized below were agreed upon by base personnel (Ms. Lisa Morris), AFCEE representatives, the United States Environmental Protection Agency (Ms. Marcia Combs), and the Alaska Department of Environmental Conservation (Ms. Jennifer Roberts and Mr. John Halverson).
The OU 3 Management Plan proposed that reflection seismic be used at OU 3 to determine the lateral and vertical extent of the Bootlegger Cove Clay Formation. In order to fully characterize the clay interval, reflection as well as refraction techniques were used at sites across the operable unit. Two existing groundwater monitoring wells were scheduled to be abandoned (W-11 and W-
12). Well W-ll was abandoned in July; however, Well W-12 could not be located and therefore was not abandoned.
The locations of hydropunch borings were modified so that groundwater could be investigate on an "operable unit-wide" basis rather than a "source area" basis. The locations of
groundwater monitoring wells were modified based on data acquired from the hydropunch investigation and to provide groundwater level information in areas of the base with limited
groundwater data.
The OU 3 Management Plan stated that 3 base supply wells would be sampled in June (02, 16, and 52). However, well 16 was inaccessible due to the presence of a pump housing and
was not sampled. The OU 3 Management Plan stated that four existing groundwater monitoring wells would be sampled during the first groundwater sampling event in June (W-10, W-13, BH-06, and IS8-01). Wells W-10 and W-13 could not be developed due to inadequate well construction and, therefore, were not sampled. These wells were subsequently abandoned in July.
Source Area SD52-Field screening for PCB contamination was also performed along Cherry Hill Ditch. The remainder of the investigation planned for this source area was performed as outlined in the OU 3 Management Plan. |
Jennifer Roberts |
| 1/11/1994 |
Meeting or Teleconference Held |
Cherry Hill Ditch meeting to discuss PCBs found in Cherry Hill Ditch. PCBs were found in samples up to 39 mg/kg. PCBs appear to be in a small part of the ditch. AF is evaluating response actions (dredging the area of highest concentrations). No public release of information as of 1/11/94, but they planned to do so during an announced 1/26 public meeting. 1/18/94 Environmental Section conference room to discuss possible questions and answers for the public meeting and who should respond to various types of questions. 1/20, 1/24 more of the same in preparation of 1/26/1994 public meeting at Orion School.
NOTE TO FILE: *PCBs belong to a broad family of man-made organic chemicals known as chlorinated hydrocarbons. PCBs were domestically manufactured from 1929 until their manufacture was banned in 1979. Aroclors 1016, 1242, 1254, and 1260 are complex mixtures of polychlorinated biphenyl (PCB) congeners, prepared by the chlorination of biphenyl. For Aroclors 1242, 1254, and 1260, the chlorination reaction was stopped when the weight percent chlorine of the product had reached 42, 54, or 60%, respectively. By contrast, Aroclor 1016 was prepared by the fractional distillation of Aroclor 1242, which excluded the higher boiling (i.e., more highly chlorinated) congeners. Aroclors 1016, 1242, 1254, and 1260 were the most widely used PCBs in the United States, and accounted for 92% of all 1958-1977 production (Monsanto, 1980).
Polychlorinated biphenyls were versatile materials which found use in a variety of applications including plasticizers, printing inks, and heat exchange, dielectric, and hydraulic fluids. The dielectric properties, chemical stability, and noncombustibility of PCB fluids made them a particularly attractive alternative to flammable mineral oils for use in capacitors and indoor transformers. Concerns in the late-1960s regarding the environmental accumulation of highly chlorinated PCB mixtures resulted, in 1971, in a voluntary cessation of the manufacture of Aroclors 1232, 1248, 1260, 1262, and 1268; the introduction of Aroclor 1016; and to a restriction in PCB usage to totally enclosed systems. The Toxic Substances Control Act of 1976 made the manufacture, importation, sale, or use of PCBs illegal after 1978.
|
John Halverson |
| 1/26/1994 |
Meeting or Teleconference Held |
A public workshop was held to discuss the polychlorinated biphenyls found in the sediments in the Cherry Hill Ditch and what removal plans the Air Force has planned. |
John Halverson |
| 2/17/1994 |
Interim Removal Action Approved |
Response from Jennifer Roberts to Keven Kleweno Dimond Anchorage District Office. ADEC has reviewed the preliminary site assessment data, which indicates that the PCB sediment contamination is from historic releases (PCB levels increase with sediment depths) and there are no PCBs in the surface water samples. The PCB levels are of concern for two receptors: children playing in the sediments and those levels also exceed ecological risk exposure levels. Therefore, ADEC and EPA have agreed with the AF that this site needs rapid action to eliminate the risk pathway to both receptors. All parties agreed that by rerouting the water and filling in the currently exposed sediments, the PCB exposure pathway will be eliminated. The AF held a public meeting on 1/26/94 and the public has indicated support to remove the PCB pathway as soon as possible. The agencies reviewed the ARARs that apply and have consistently met any of the applicable regulations that apply. Under the FFA signed by the ADEC commissioner, a regulation, policy or trend must be promulgated to apply.
CERCLA has provisions for resource damage assessments, which does apply to this particular case. ADEC has worked closely with ADEC legal counsel to establish ADEC's position with the AF that ADEC considers Cherry Hill Ditch as a natural resource and that ADEC will take action for a damage assessment. The damage assessment may be monetary or an agreement with the AF to protect another endangered area or promote or replace a natural resource. It is Jennifer's understanding that John Halverson has coordinated this project with all appropriate programs, including the Anchorage Municipality water quality staff, South-central Regional Office staff, and the appropriate Juneau ADEC Program staff. |
Jennifer Roberts |
| 4/21/1994 |
Document, Report, or Work plan Review - other |
Letter sent to Lisa Morris USAF regarding the Cherry Hill Ditch Storm Culvert Design Final Design Submittal (100%) Project FXSD 94-7203 March 28, 1994 and under ADEC Project Number 9421-WW-061-082. If work cannot be done under dry conditions, then silt fencing will be placed at the downstream culvert. Any sediments that are collected will need to be characterized and disposed of properly, with ADEC approval. Sediments from the catch basin and upstream culvert will need to be removed, characterized, and disposed of property, with ADEC approval. ADEC requests submittal of detailed plans for sampling in the area where elevated concentrations of PCBs have been previously been detected. The submitted design states field screening and lab analyses will be conducted, but does not provide any details.
As-built drawings of the project be submitted to our Anchorage District office attn: Keven Kleweno within 90 days after project's startup date under the stamp of a Professional Engineer; EAFB provide the level of maintenance specified by the design engineer; and if dewatering is necessary, EAFB meet the substantive requirements of any wastewater discharge permit (general permit #9440-DB002) that would normally be required. This would entail insuring that any discharge does not cause a violation of the state water quality standards. |
John Halverson |
| 8/1/1994 |
Update or Other Action |
During May through July 1994, the section of Cherry Hill Ditch between Acacia Drive and Cherry Street was reconstructed to regrade the ditch area and install an enclosed storm drainage system. A portion of the sediment in the ditch approximately 10 ft. long and two ft. wide, and thirty inches deep was excavated around the sediment.
A new 36 inch diameter HDPE storm drain 1900 ft. in length was installed parallel to Cherry Hill Ditch. The reconstruction of Cherry Hill Ditch served three purposes: The sediment with the highest PCB-1260 contamination (SD19) has been removed; The remaining soil with low level PCB (3-8 mg/kg) contamination has been covered with backfill material and therefore is part of the subsurface and Human exposure to the contamination has been minimized. The residential scenario is unrealistic, the site is an engineered ditch. To maintain drainage, the site will remain a ditch prohibiting residential construction on the site. Since the residential scenario is not realistic and the risk to construction workers is acceptable, the soil at receptor SD52 is recommended for no further action. |
Louis Howard |
| 8/8/1994 |
Document, Report, or Work plan Review - other |
ADEC letter to USAF RE: OU-3 Draft Remedial Investigation Report; ADEC review comments. The report does not contain a description of work that has been conducted at Cherry Hill Ditch. We understand that at the time the report was being prepared the culvert and ditch work had not been completed, therefore, it was not possible to include it in the draft. However, the ditch has been rebuilt the potential for exposure to contaminated sediments or water in the ditch between Acacia Drive and Cherry Street has been eliminated (other than if someone excavates the site in the future). The final report should include a description of work that has been completed and analytical results from samples collected during the removal action. The risk assessment should also take the ditch work into account.
Several of the figures show contaminant concentrations in both micrograms and milligrams per kilogram of soil. Use of consistent units of measure in figures showing contaminant distribution
would simplify review of the data. The department concurs with EPA comments on the risk assessment.
Pg. E-1 - The first paragraph states the objective of the RI was to define the nature and extent of contamination at the base. It should state, "...within operable unit 3 at the base", since work was focused on OU3 not the entire base.
Pg. E-2 - The summary states four base water supply wells were sampled. However, the remainder of the report indicates only three of the wells were sampled (base wells 2, 40, and 52).
Section 2.1 - The text states OU3 is at an elevation of 150 feet. It should state 150 feet above mean sea level (msl).
Section 2.4.1 - The text in this section does not address heptachlor epoxide, which according to the appendix was present at concentrations which exceeded the MCL.
Section 2.4.3 - This section states figure 2-17 shows soil and groundwater sampling locations prior to 1993. Soil sample locations are not shown other than soil boring IS8-01.
Section 2.4.3 - The first sentence in the second paragraph refers to SD16. The reference should be to SD31.
Section 2.4.3- The text states previous sampling (sample SBDS31A12) showed up to 13 micrograms BTEX per kilogram of soil. Table B-12 in Appendix B shows the sample contained 12.3 milligrams/kg BTEX. Please verify the units of measure.
Section 3.2.2 - The section notes monitoring well W-10 could not be developed due to increasing silt accumulation in the well. It is not clear if W-10 was re-developed and sampled at a later time or if it was properly abandoned.
Section 4.2.3 - The second bullet states concentrations of organic constituents in groundwater at OU3 were compared to concentrations upgradient at OU4. While this is appropriate, compounds should not be eliminated from the COPC based solely on the fact that they are present upgradient in, or downgradient of, another contaminant source area.
Section 4 - Section three notes two surface water samples (SW-1 and SW-2) were collected from a drainage area, however the results are not described in section 4. Discussion of the results should be included.
Section 4.4.1.3 - The text states up to 5.4 micrograms/kg of 4.4'-DDT were present in sediment samples from the ditch. However, the appendix shows up to 55.4 micrograms/kg were present.
Table 4-25 - The units of measure for results of SW8270 analyses are listed as mg/kg, however, the appendix lists the units as micrograms per kg.
Section 5.4 - This section states, "the scenario of contact with contaminated storm water runoff (eg., contaminated storm water in Cherry Hill Ditch) is not considered since it is related to ongoing
operational compliance issues. As noted above, this should be further explained (ie. describe whether water in Cherry Hill Ditch may be impacted by contaminant source areas in OU3).
|
John Halverson |
| 12/6/1994 |
Update or Other Action |
John Halverson corresponded with Keven Kleweno. RI report for OU3 states some surface water from the drainage channel on the southwest portion of SD16 flows into the Cherry Hill Ditch proven by a dye test. Report states that two samples were collected at the point the water flows into the ditch. The results were not included with the report, the report states they were forwarded to persons responsible for Base compliance program for surface water runoff. The information was not forwarded to contaminated sites program or Water Quality program. |
John Halverson |
| 12/13/1994 |
Document, Report, or Work plan Review - other |
John Halverson faxed ADEC comments on the Draft Environmental Update draft December 1994. Reiterated that one day turnaround for comments is not appropriate and ADEC requires more time to provide substantive comments on documents. Document mistakenly implies that PCBs were only identified in one isolated area within the ditch. PCBs were found in numerous locations in the ditch between Acacia Drive and Cherry street. Only the overflow during periods of extreme discharge was to be diverted to the HDPE storm drain.
Discharge during normal flow periods was to be directed through the drain rock placed in the former ditch, in order to allow for filtration and biological degradation of impurities in the water prior to discharge to surface waters. PCBs are very stable and difficult to biodegrade. Natural attenuation of PCBs should not be referenced unless the AF can provide supporting documentation and real-time monitoring that it is occurring. |
John Halverson |
| 3/8/1995 |
Risk Assessment Report Approved |
RI/FS with risk assessment final version received and approved.
Since all of the soil areas of interest are encompassed within either one or two groundwater areas of interest at OU3, the discussion of analytical results, nature and extent of contamination, and potential sources of contamination is divided into two areas:
OU3 East: including soils areas of interest SD16, SS21, east intersource area (including SD31), and the east groundwater area; and
OU3 West: including soils areas of interest SD52 and west intersource area and the west groundwater area.
The carcinogenic evaluation for the worst-case scenario (residential-RME) showed a total risk of 1.3 x 10-4 for source SS21. No other exposure scenarios were associated with a risk in excess of 1.0 x 10-4. The evaluation of the potential for noncarcinogenic effects produced a hazard index of 1.3 at SS21 under the residential RME scenario only. All other scenarios have hazard indices of less than 1.0. Site remediation goals for Superfund sites have generally been in the range of 10-4 to 10-6 risk for carcinogens.
Ecological Assessment: Ecological Quotient (EQ) less than 1.0 indicates that the adverse effect being evaluated is unlikely to occur. EQ greater than 1.0 indicates that an adverse effect is possible. Caveat: due to the health conservative methodology used in the assessment, an EQ of greater than 1.0 DOES NOT indicate an adverse effect WILL occur. No EQs for moose, merlin, or peregrine falcon exceeded 1.0. Meadow vole EQs for several inorganics exceeded 1.0 at one or more source areas. However, the upper threshold limit of the background concentrations for the contaminants also cause the EQ to exceed 1.0. Therefore the EQs are probably overestimating the impacts to meadow voles. Exposures for black-capped chickadees, masked shrews and meadow voles feeding in the vicinity of Cherry Hill Ditch may be significant. However, due to the small areal extent of contamination, significant populations of these indicator species or other animals most likely are not threatened by the contaminants. |
John Halverson |
| 3/8/1995 |
CERCLA RI Report Approved |
Remedial Investigation/Feasibility Study final version received and approved.
As originally defmed. au 3 consisted of a group of three sources: the shop waste disposal site (source SD16), the former polychlorinated biphenyl (PCB) transformer storage area (Source SS21), and Cherry Hill Ditch (source SD52). An aircraft maintenance hangar (source SD31), which was originally defmed as part of OU 4, was added to OU 3 due to its proximity to other source areas within au 3. Source Area SD52 (Cherry Hill Ditch) was removed from the source area list in 1993 and is presently considered a receptor for possible contamination associated with surface runoff.
Soil and sediment analytical results obtained for SD52 and the west intersource area do not indicate a direct correlation with the VOC contamination observed in the west groundwater area of OU3. Furthermore, since the surface water sample results did not indicate the presence of the same VOCs as those detected in the groundwater, it is also not possible to conclude that recharge into the shallow aquifer from Cherry Hill Ditch appears to contribute significantly to groundwater contamination in the area. Therefore, it appears that the presence of VOCs in the groundwater at OU3 West may be related to downgradient migration of contamination originating at source areas upgradient from the OU3 West Groundwater Area.
Groundwater monitoring data will be collected from monitoring wells at OU 3 to ensure that groundwater from OU 3 will not impact the sensitve receptors at OU 5. The Basewide groundwater monitoring plan describes the monitoring locations, sampling frequency, analytical parameters, and reporting format. Since potential future impacts will be monitored, no further action is planned for this site. (Section 7.6.5 Conclusions) |
John Halverson |
| 4/3/1995 |
Update or Other Action |
1995 SERA Phase I Corrective Action Plan: 5557 is within the geographical boundaries of OU-3, in the region defined as the east area, and was included in the remedial investigation (Rl). The only investigation conducted under the OU-3 investigation specifically on S557 was a water sample collected from hydropunch point (HP23), although off-site upgradient soil and groundwater
samples were also analyzed for contamination. Groundwater collected from HP23 was found
to contain low concentrations of halogenated volatile organic compounds (V005), including
chloroform, tetrachloroethylene, 1,1,1-trichloroethane, and perchioroethylene. BTEX constituents were also detected, with benzene present at 8.6 ug/L (2018 Table C is 4.6 ug/L). In general, VOC contamination in groundwater at OU-3 East was found to be widespread and could not be definitively assigned to sources. The RI concluded that contamination impacting SS57 may be associated with pulses of contamination migrating downgradient from OU-4.
Groundwater contamination analysis and local hydrogeologic information at 5557 implicate an upgradient source of the identified groundwater contamination. 5557 is within the geographical boundaries of OU-3 East Area (USAF 1994h). This site was included in the 0U5 model for the entire outwash plain. This model concluded that all sources upgradient from 0U5 (which includes SS57) would remediated via natural attenuation within acceptable risks. It ¡s recommended that further consideration of contamination at SS57 be transferred to OU-3 under the CERCLA program. A risk assessment was conducted as part of the RI for the OU-3 East, which included data from the SERA Phase I Site Assessment. Based on the results of the risk assessment, the East Area (including 5557) was recommended for no further action. |
John Halverson |
| 6/15/1995 |
Site Ranked Using the AHRM |
Initial ranking. Action code added because it wasn't when the site was originally ranked. |
John Halverson |
| 6/20/1995 |
CERCLA Proposed Plan |
Proposed Plan approved. OU 3 includes base housing, maintenance, and operation facilities. OU 3 is located on relatively flat terrain at an approximate elevation of 150 feet above sea level. OU 3 consists of three source areas and two study areas. (See Figure 2.) The source areas include: a shop waste disposal site (SD16), the former polychlorinated biphenyls (PCB) transformer storage area (SS21), Cherry Hill Ditch (SD52), and a dry well at an aircraft maintenance hangar (SD3 1). Site SD52 is not considered a source of contamination but did receive contaminants from SD 16.
The Proposed Plan lists the PCB contaminated soils at Cherry Hill Ditch (SD52) near the vicinity of the West Intersource Area as being excavated and removed/disposed of offsite during a 1994 construction project where an enclosed storm sewer drainage system was installed. Diesel, PCBs, PAHs and Arsenic were detected in the soils, PCBs, pesticides, PAHs were detected in the surface water, and bis (2-ethylhexyl) phthalate and cadmium were detected in the groundwater. |
John Halverson |
| 11/15/1995 |
Update or Other Action |
Basewide Support & GW Monitoring Program, Analytical Results for OUs 3/4 - Round 2 received. The objective of GW monitoring at OUs 3 & 4 is to compare concentrations of contaminants of concern (COCs) to historic concentrations & available background concentrations, at each respective well. Analytical methods utilized for each OU are based jointly on the results of the RI/FS programs conducted at OU 3, OU 4, & OU 5, during which COCs were initially identified.
Changes or trends in concentrations [of CERCLA COCs only] will then be established, & any unsuspected increases in contaminant concentrations can then be identified. When sufficient data are collected, GW sampling results will be evaluated statistically to ensure that the assumptions made in each respective Record of Decision (ROD) is accurate; to validate the groundwater model; & to provide early warning of increased contaminant levels or migration of contaminant plumes towards OU 5 & Ship Creek. All ten wells sampled during this event were completed in the shallow aquifer.
OU3-MW-11 had trichloroethylene at 88.4 ug/L (2018 18 AAC 75 Table C groundwater cleanup level is 2.8 ug/L).
See site file for additional information. |
Louis Howard |
| 12/11/1995 |
Update or Other Action |
John Halverson provided comments on the Draft Final Record of Decision for OU3 to USAF Joe Williamson and Larry Underbakke. ADEC concurs with EPA's comments with additional comments of its own. It is ADEC's understanding that the treatability study will be completed before finalizing the ROD and that if bioremediation turns out to not be a feasible remedial alternative, the ROD will be revised and anther draft final will be submitted. Text states a review will be conducted five years after completion of the remedial action. A five year review is required if waste is left in place. It is not clear if the review is proposed based on the PCBs at SS21, contaminants at other source areas, or both. Alternative 5 is to excavate the soil and treat it on site. Another alternative is to excavate and dispose of at another location on Base if the disposal area is already covered by institutional controls limiting future land use. Also if exposure to and migration of contaminants (PCBs) is limited by the site conditions. If the bioremediation treatability results are negative this may be an acceptable alternative that is not currently included in the ROD. If implementation of the remedial action results in the agreed upon cleanup level for PCBs (5 mg/kg) being met, then a five year review may not be necessary for soil action at SS21. The ROD does not include any reference to PCB impacts to and disposal of the concrete pads at the site.
The ROD refers to institutional controls (ICs) to limit use of groundwater from the shallow aquifer. It does not include any reference to ICs on management of soil that may be excavated from OU3 source areas during future construction projects. Ultimately, no further action decisions will be approved for each source area based on calculated risks in current and estimated future exposure scenarios. However, these decisions do not address identification, characterization, and management of the soil that may be excavated during future development. Real estate records or other appropriate land records should include documentation on where contaminated soil has been identified and remains in the ground. This would help land planners identify potential contaminated areas when proposing development on Base and may help in avoiding future compliance problems or contractor down time. |
John Halverson |
| 3/13/1996 |
Update or Other Action |
Keven K. Kleweno, P.E. ADEC environmental engineer, sent a memorandum to Kent Patrick-Riley on March 13, 1996. As discuss with KPR, KKK remembers sending information to ADEC in Juneau showing that Cherry Hill Creek (also known as Cherry Hill Ditch) was not a water body of the state, but a manmade drainage ditch. After the 3/12/96 discussion, KKK was unable to locate the original email or memorandum he sent to Juneau on the subject.
During summer of 1993, KKK was able to walk the ditch from the snow dump at the edge of the runways to the top of the Bluff. During the walk, KKK could not find any evidence that the ditch was not manmade and the water flowing in the ditch was not from snow dumps or drainage structures that the AF installed when the runways were built in the late 1940s and 1950s.
Information obtained from John Halverson (CSRP) states: Cherry Hill Ditch (formerly source area SD52) is an artificial drainage channel which flows westward from the E-W runway at EAFB towards Knik Arm of the Cook Inlet. 4/15/94 KKK issued a non-objection to the culvert design and ditch modifications for the Cherry Hill Ditch. The modifications were to cover PCB contaminated soils and to improve water quality with in-place treatment using "Best Management Practices (BMPs).
Although KKK has never requested the Department of Fish and Game to set up traps in the Ditch, KKK does not believe that there is a fish population present. KKK will note that there are other aquatic life present such as insects, but they are always found in drainage ditches.
AF is planning to install a sedimentation basin to provide additional treatment. |
Kevin Kleweno |
| 3/15/1996 |
Update or Other Action |
Kent Patrick-Riley Memorandum to Eric Decker regarding Cherry Hill Ditch. The memorandum is written to recommend removal of Cherry Hill Ditch from he proposed 1996 303(b)/305(d) lists. This recommendation is based on a review of the ADEC's files, interviews with ADEC and AF environmental staff, and on site inspections of Cherry Hill Creek.
1) Aerial photos in 1950, 1962, 1972, 1982 clearly show that the entire course of Cherry Hill Creek was artificially constructed, primarily between 1950 and 1962. The photos are identified as Pic Numbers 89720: frames 52, 72, 97, 99, 103VV, 354, 256, and 358. KPR-ADEC, KKK-ADEC, Tim Rumfelt-ADEC, and Larry Opperman EAFB reviewed the photos and concurred that the photos demonstrate it was artificially constructed.
2. Numerous on-site inspections by ADEC and EAFB staff clearly shown that the ditch is of artificial construction for stormwater drainage. Fill is evident on the ditch sidewalls, vegetation is consistent with a constructed ditch, and the landforms and ditch course are consistent with a ditch and not a natural waterbody.
3. Much of the ditch runs through underground piping. Some of this piping has been constructed in the last two years as part of EAFB's remediation effort.
4. No fish has ever been documented to inhabit the ditch and ADEC's site inspections indicate it highly unlikely that fish inhabit it. The ditch has very small amounts of water in it year round. Most of the water in the ditch is less than 6 inches in depth and less than 3-4 feet in width.
5. The ditch is not a water source, but instead it is a stormwater receptor/collection/discharge system. As such, it has received some levels of pollutants, including petroleum and PCBs. Removal and control of these contaminants have been addressed in the ongoing CERCLA work undertaken by EAFB. ADEC contaminated site section staff indicate that this work has satisfied ADEC's concerns.
6. The ditch exits EAFB property at the Port of Anchorage and runs through a culvert for less than a 1/4 mile before out flowing into Cook Inlet. The Port of Anchorage has obtained a stormwater NPDES permit which covers this out flow. |
Kent Patrick-Riley |
| 4/29/1996 |
Update or Other Action |
KPR sent a letter to Donna Walsh of U.S. EPA Water Quality Division (WD-139) Region 10 regarding clarification of the questions raised during a phone conversation on April 23, 1996 regarding Alaska's submission of the 1996 303(d) list of waters. Item 5 of the letter-Cherry Hill Creek: EPA asked for verification that the water quality standards are being met at this creek. As described in the narrative explanation, an intensive cleanup occurred in the area adjacent to the creek through the CERCLA program. Those efforts have been successfully completed, therefore alleviating the potential transfer of petroleum products to the creek, which serves as a stormwater conveyance ditch. Since the CERCLA efforts removed and cleaned up petroleum pollution in the adjacent area, the threat of pollution from this source has been removed. ADEC has determined that removing the potential source of pollution has restored this stormwater conveyance ditch, and water quality standards are being met. |
Kent Patrick-Riley |
| 5/13/1996 |
Update or Other Action |
USAF sent memorandum to Kent Patrick-Riley (KPR) regarding the Cherry Hill Reclassification. They recently received a copy of the 2/20/1996 letter to Peg Mentele of the Government Hill Community Council. This letter covers designation changes for the area which conveys the Base's stormwater to the Port of Anchorage Cherry Hill. USAF maintains that the original ADEC decision to classify the water system as a drainage ditch was appropriate. Therefore, the USAF would like to dispute the reclassification of Cherry Hill to a natural waterbody. In order to address the issue, the AF would like to meet with KPR on Friday March 20, 1996 at 2:00 PM. AF requests ADEC bring those items such as aerial photographs which contributed to KPR's determination. |
Kent Patrick-Riley |
| 9/12/1996 |
Meeting or Teleconference Held |
EPA's Meeting summary of the September 12, 1996 meeting-Decisions reached by Air Force (AF), U.S. Environmental Protection Agency (EPA), and Alaska Dept. Environmental Conservation (ADEC).
1. AF/EPA/ADEC agree that institutional controls (ICs) are necessary to ensure that contaminated shallow groundwater aquifer is not used. There is now a basewide prohibition (AF please cite) on use of the shallow aquifer which appears to be an adequate IC, therefore no additional ICs area required specific to OU3. OU3 ROD will note the need for ICs and the existence of the basewide ICs and groundwater monitoring program, and that since they are in place, no further action is necessary under the OU3 ROD.
In summary, the ROD will say:
a. All sources have been addressed;
b. No current receptors for contaminated groundwater;
c. No potential receptors in OU3 areas;
d. Potential receptors are in OU5 area, which has a remedy in place to deal with them, plus ICs and a monitoring program;
e. Basewide ICs and groundwater monitoring are in place and will continue until MCLs have been achieved.
2. AF/EPA/ADEC will research whether the actions that have taken place at SD52, SD16, etc. allow for unrestricted use. If not, some ICs may be necessary. This includes consideration of whether deep contamination remains at levels which would pose unacceptable risk in the event of future excavation, and if so, whether some ICs should be added to protect in the event of such an occurrence.
3. In addition, ADEC raised the question of ICs on deep soils with high concentrations (didn't show risk because no curren exposure/receptors; concern is for proper handling/disposal in event of future excavation). |
John Halverson |
| 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 |
| 11/15/1996 |
Update or Other Action |
USAF sent Kent Patrick-Riley a memorandum letter regarding the Cherry Hill Storm Water Runoff. Letter thanked KPR for keeping the AF informed on the Government Hill Community Council concerns regarding the storm water runoff through Cherry Hill Ditch. While the AF remains unclear on the motivation behind the council's inquiry, the AF fully supports ADEC's efforts to answer their questions. The AF maintains that the original ADEC decision to classify the water system as a drainage ditch, rather than a natural waterway was appropriate. The drainage from he west end of Elmendorf AFB is piped and channeled through areas that have been graded and filled.
The AF has researched the real estate issues related to this area. Attachment 1 is a map indicating those lands owned by the AF. In addition, the sampling results from the Cherry Hill ditch for the last two years is provided at Attachment 2. These results verify the cleanliness of our storm water effluent. The AF is willing to work with the ADEC and the Council to dispel any ill feelings regarding the AF storm water effluent. The AF welcomes any new information that might clarify the issues around the classification of Cherry Hill. |
Kent Patrick-Riley |
| 1/3/1997 |
Cleanup Level(s) Approved |
Operable Unit 3 ROD Requirements: " Although organic constituents (e.g. , TCE) are present above Maximum Contaminant Levels (MCLs) in the shallow groundwater aquifer beneath OU 3, the concentrations are generally low, there are no current receptors, and institutional controls at the base exist for the shallow aquifer to prevent use. Metals were also identified above MCLs. The Safe Drinking Water Act is not an ARAR for this remedy, since no further action is necessary for groundwater under the OU 3 ROD. However, it is the ARAR for the groundwater action selected in the OU 5 ROD to protect groundwater receptors. If further action to protect groundwater is ever necessary, it will be done pursuant to the OU 5 or OU 6 RODs."
Operable Unit 3 groundwater will be monitored as a part of the Base wide monitoring program and OU5 monitoring. |
Louis Howard |
| 1/3/1997 |
CERCLA ROD Approved |
Record of Decision signed and site SD52 Cherry Hill Ditch closed out. The risks for soil at SD31, SD16, and Cherry Hill Ditch (SD52) are considered acceptable and this resulted in no further action decisions for the soil at SD3 1, SD16, and Cherry Hill Ditch. These sites are
available for unrestricted use. The presence of PCBs in the soil at SS21 results in an unacceptable risk and the need for remedial action.
PCBs were removed from area in 1994, placed in drums and transported off base to a treatment, storage, disposal facility. Ditch was reconstructed and regraded to install an enclosed storm water drainage system.
No current receptors exist for groundwater at the base due to institutional controls. As a
requirement of previously signed RODs for Elmendorf Air Force Base, institutional controls have been established to restrict the use of the shallow aquifer in the outwash plain on the base. These restrictions are enforced through the Base Comprehensive Plan. Projects and other activities are reviewed during the planning stage to ensure compliance with the Base Comprehensive Plan. In addition, construction projects and other activities also undergo an environmental review. This review helps ensure compliance with groundwater use restrictions.
Groundwater will be monitored with ICs in place restricting GW usage - no drinking water wells will be allowed in OU3. |
John Halverson |
| 1/3/1997 |
Institutional Control Record Established |
No current receptors exist for the groundwater at the Base due to the institutional controls (ICs). As a requirement of previously signed RODs for the Base, ICs have been established to restrict the use of the shallow aquifer in the outwash plain on Base. These restrictions are enforced through the Base Comprehensive Plan (BCP).
Projects and other activities are reviewed during the planning stage to ensure compliance with the BCP. In addition, construction projects and other activities also undergo an environmental review. This review helps ensures compliance with groundwater use restrictions.
NOTE TO FILE: § 300.430 Remedial investigation/feasibility study and selection of remedy.(a) General—(1) Introduction. The purpose of the remedy selection process is to implement remedies that eliminate, reduce, or control risks to human health and the environment. Remedial actions are to be implemented as soon as site data and information make it possible to do so. Accordingly, EPA has established the following program goal, expectations, and program management principles to assist in the identification and implementation of appropriate remedial actions.
(iii) Expectations. EPA generally shall consider the following expectations in developing appropriate remedial alternatives:
(D) EPA expects to use institutional controls such as water use and deed restrictions to supplement engineering controls as appropriate for short- and long-term management to prevent or limit exposure to hazardous substances, pollutants, or contaminants. Institutional controls may be used during the conduct of the remedial investigation/feasibility study (RI/FS) and implementation of the remedial action and, where necessary, as a component of the completed remedy. The use of institutional controls shall not substitute for active response measures (e.g., treatment and/or containment of source material, restoration of ground waters to their beneficial uses) as the sole remedy unless such active measures are determined not to be practicable, based on the balancing of trade-offs among alternatives that is conducted during the selection of remedy. |
Louis Howard |
| 1/3/1997 |
Long Term Monitoring Established |
Cadmium, solvents, POL, remain at levels above the MCLs. Operable Unit 3 groundwater will be monitored as a part of the Base wide monitoring program and OU5 monitoring. |
Louis Howard |
| 1/3/1997 |
Conditional Closure Approved |
PCB contaminated soil was removed to below 5 mg/kg.
However, cadmium, solvents, POL, remain at levels above the MCLs. Operable Unit 3 groundwater will be monitored as a part of the Base wide monitoring program and OU5 monitoring. |
Louis Howard |
| 1/17/1997 |
Update or Other Action |
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. |
Ray Burger |
| 2/12/1997 |
Update or Other Action |
KPR sent a letter to Ms. Suzanne Dipietro Government Hill Community Council regarding the listing of Cherry Hill Ditch on Impaired Waterbody List. ADEC received the council's February 10 letter, requesting ADEC examine the listing to include Cherry Hill Ditch (also known as Cherry Hill Brook) on the list of impaired water bodies. As the council's letter noted, ADEC decided not to list it because of our determination that it was solely a stormwater conveyance system.
In examination of historic aerial photographs and visits to the site, it appeared that the ditch system was not natural, but constructed as a ditch, with the primary source being runoff from the Elmendorf Airport. The council's letter indicated that it may have additional information to show a redetermination might be necessary. At the council's convenience, ADEC is available to meet to review the information ADEC used to make its determination. Please note that Julius Rockwell of the Anchorage Waterways Council recently made a similar request. ADEC recommends a joint meeting be held to exchange information. ADEC would also like to set up a meeting between the community council and the landowners adjacent to the Ditch (municipality, Fort Richardson, Elmendorf). |
Kent Patrick-Riley |
| 10/28/1997 |
Update or Other Action |
Government Hill community council sent a fax letter to Kent Patrick-Riley (KPR) addressed to Susan Braley Chief Water Quality Protection ADEC regarding the Proposed 1998 Sect. 303(d) list and Cherry Hill Brook (Creek). They noticed that the Cherry Hill Brook (Creek) is not on the list. Much of it flows through EAFB. It was reclassified as a drainage ditch by ADEC a few years ago because of evidence available to ADEC at the time of reclassification indicated that it was manmade drainage ditch dug by EAFB. Later the council presented additional evidence that showed it was a natural waterway which predated EAFB. Based on that new evidence, ADEC agreed to consider reclassifying Cherry Hill. Although the reclassification is not yet complete, now may be an appropriate time to check the data on it to make sure that the waterway is not contaminated. This may be appropriate because when ADEC representative Kent Patrick-Riley visited the site along with community members and representatives of EAFB, the waterway appeared to be a natural waterway and all of us saw abandoned barrels in the creek bed. |
Kent Patrick-Riley |
| 2/26/1998 |
Update or Other Action |
Kent Patrick-Riley sent letter to Peg Mentele Government Hill community council regarding an ADEC review of information on Cherry Hill Creek/Ditch. Cherry Hill Creek had been on the impaired water bodies list prior to 1996. In spring of 1996, Division of Air and Water Quality removed it from the list of impaired water bodies list.
1) Extensive removal and control of contaminants had occurred since preparation of the list, therefore, pollution of the Creek had been significantly reduced.
2) Information had been obtained by Elmendorf Air Force Base to suggest that the Cherry Hill Ditch was a stormwater ditch and not a "waterbody." It appeared clear that most of its course was a constructed channel, but it was somewhat unclear that the stretch running through the bluff area was constructed and not natural in origin. Two points lead ADEC to make its determination that this stretch was also constructed:
a) interpretation remarks on EPA aerial photographs indicated that the present channel down the bluff was not the historical channel; and
b) a winter site visit and information from the Elmendorf AFB staff indicated that the bluff stretch ran through fill.
Is Cherry Hill Creek/Ditch a natural stream or constructed in origin? ADEC compared information which Peg had presented at the 1996 council meeting to its files. The comparison suggests that the interpretative information from the EPA aerial photos in our files may be incorrect. ADEC believe all of the parties are in agreement that other stretches of Cherry Hill Ditch/Creek are constructed channels and not natural watercourses.
Is Cherry Hill Creek/Ditch considered a "waterbody" or only a stormwater ditch?
ADEC reasons if part of the Cherry Hill Creek is natural in origin and has all the other characteristics of a stream then a stretch of it may be considered to be a "waterbody" and not solely a stormwater ditch. In addition to determine if the bluff segment is a natural stream, there is also the problem of reconciling that the water flow above the bluff is through a constructed ditch and the water flow below the bluff is through a storm sewer. This situation is highly infeasible (impracticable) and must be considered in resolving this question.
Is the water quality in Cherry Hill Creek/Ditch impaired?
For the past several years, EAFB has conducted extensive removal of pollutant sources base wide, including those which would impact Cherry Hill Creek/Ditch. For the past several years, they have also monitored the flows of the Cherry Hill Creek/Ditch. ADEC will review the monitoring data collected, particularly that obtained in the last year, to clarify what is known about the current water quality in the Creek/Ditch. Next step: Peg provided at the 1996 meeting that the bluff stretch of Cherry Hill Creek/Ditch may be a "waterbody" and not a stormwater ditch. In order to resolve this question, ADEC agreed to a follow-up meeting. ADEC tentatively agreed to have it in late April, as that would provide time for gathering further information and also provide an opportunity to visit the site after the snow has melted. ADEC also agreed to invite the current and potential landowners adjacent to the Creek/Ditch. As ADEC is unsure of the ownership boundaries, we will work with the Army and Elmendorf staff to identify the landowners adjacent to the bluff segment and also to coordinate a site visit on their property. Signed Kent Patrick-Riley Watershed Protection. |
Kent Patrick-Riley |
| 10/1/1998 |
CERCLA ROD Periodic Review |
Five Year Review received. This OU consists of three sources and one receptor area. At SD16, waste solvents from Building 31-260 were disposed of in open trenches. At SD31, floor drains from Building 32-060 (Hangar 5) were discharged into dry wells and septic systems. The septic system and dry wells at SD31 were excavated in 1993. SS21 is an area where transformers containing polychlorinated biphenyls (PCBs) were stored. SD52, Cherry Hill Ditch, is a receptor for the stormwater from a major portion of the base. In 1994, low levels of PCBs were capped in the bottom of Cherry Hill Ditch (SD52) and a stormwater diversion project was completed at this receptor area. SD16, SD31, and SD52 were determined to be NFA sources in the OU3 ROD.
PCB contaminated soil was removed to below 5 mg/kg. However, cadmium, solvents, POL, remain at levels above the MCLs. Operable Unit 3 groundwater will be monitored as a part of the Base wide monitoring program and OU5 monitoring. Groundwater will be monitored with ICs in place restricting GW usage - no drinking water wells will be allowed in OU3.
As a requirement of previously signed RODs for EAFB, ICs have been established to restrict the use of the shallow aquifer in the outwash plain. These restrictions are enforced through the Base Comprehensive Plan(BCP). Projects and other activities are reviewed during the planning stage to ensure compliance with the BCP. The GW monitoring of selected wells located within OU3 is included as part of OU5 GW monitoring. In addition, all construction projects and other activities also undergo an environmental review. This review helps ensure compliance with GW use restrictions. For these reasons, it was determined that remedial action is not required for GW at OU3.
|
Jennifer Roberts |
| 9/19/2000 |
Update or Other Action |
KPR received information from David Arehart PDC engineering regarding the Cherry Hill Ditch Erosion Study-Phone Conversation. Mr. Arehart is working for David Bennett EAFB looking at some solutions to the severe erosion occurring in the Cherry Hill Ditch below their storm sewer outfall. First 700' of channel above the Terminal Road is in good shape, following 500' has very aggressive channel bed and stream bank cutting, and the last 100' of channel just below the outfall is in good condition.
This outfall area had rip rap installed some time in the past. Drum cleanup was an outstanding issue along the Ditch. The AF has a contract to remove the drums along the Ditch channel. Gaylor Gulch is the result of the 1964 earthquake. The 1963 aerial photos show vegetated slope, but the photo in 64, after the quake, shows a slide at Gaylor. The concrete rubble adjacent to Gaylor was first visible in the 1965 aerial photo. Just east of Gaylor Gulch another substantial soil block (say almost 100 feet long in the east-west direction and 40 to 50 feet in the north south direction) slid into the Ditch from the south slope. The stream has eroded a tunnel through the bottom of the slide. |
Kent Patrick-Riley |
| 9/20/2000 |
Site Number Identifier Changed |
Changed work plan from X1 to X9 to reflect correct contaminants. |
Former Staff |
| 12/13/2001 |
Document, Report, or Work plan Review - other |
Staff commented on a draft site investigation for area of concern 97 (AOC 97) Cherry Hill Ravine which is associated with Cherry Hill site SD52. After the removal of drums at AOC 97, ADEC has reviewed the data presented in the document and concurs with the no further action decision for AOC 97 pending receipt of concurrence by EPA. However, if in the future, additional contamination is discovered at this site, further investigation and/or remedial actions will be requested of the Air Force by ADEC. ADEC reserves its rights, under 18 AAC 75 Oil and Other Hazardous Substances Pollution Control regulations and AS 46.03 to require additional assessment and/or corrective actions, if information indicates the site conditions pose an unacceptable risk to human health, safety, or welfare, or to the environment. |
Louis Howard |
| 3/21/2005 |
Update or Other Action |
Closure Report signed by Air Force, EPA and ADEC for Area of Concern 97. The purpose of this final Site Closure Report is to document that the selected remedy of no further action at Area of Concern (AOC) 97, also known as Cherry Hill Ravine, at Elmendorf Air Force Base (AFB), Alaska meets the following requirements:
1. Is protective of human health and the environment 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 National Contingency Plan;
2. Meets federal and state requirements that are applicable or relevant and appropriate; and
3; Is cost effective.
The US Environmental Protection Agency (USEP A) and the Alaska Department of Environmental Conservation (ADEC) agree that contaminant levels at AOC 97 have been determined to present no significant threat to human health and the environment; thus, AOC 97 is eligible for closure.
This report was developed in accordance with Department of Defense Environmental Restoration Program protocol and shall be referred to as a Site Closure Report.
The presence of chemicals in sediment and seeps within the Cherry Hill Ravine indicate
that hazardous substances have been released and have impacted sediment and groundwater. However, it is unlikely that the contaminants present pose an unacceptable risk. The only chemicals detected above ADEC soil cleanup levels or background levels in sediment samples include methylene chloride (a common lab contaminant), DRO, total chromium, arsenic, and cadmium.
Only one elevated concentration of DRO [320 mg/kg] was detected in the sediment within drum DR14; however, DRO concentrations were not present above soil cleanup levels in the sediment surrounding the drum. It is likely that the presence of total chromium in sediment is actually representative of background because it is present throughout the ravine at comparable concentrations that do not significantly differ from the background screening level. Arsenic and cadmium were detected above ADEC soil cleanup levels at the same location (on the north flank of the ravine), but the contamination appears to be isolated and limited in extent to this one location.
Only antimony, arsenic and lead were detected in seep samples at concentrations above ADEC MCLs. Activities at Elmendorf AFB may have resulted in surface or subsurface contamination that has migrated to groundwater that discharges to the ravine, or leaking drums buried within the ravine may be the source of these elevated concentrations. However, as indicated in the CSM, the seeps are not considered a significant pathway for receptors and do not pose a significant risk to human health.
Based on these findings, no further action was recommended for AOC 97. The USEPA and the ADEC agreed with the recommendation in letters dated December 27, 2001 and December 31,2001, respectively (USEPA, 2001 and ADEC, 2001). |
Louis Howard |
| 4/1/2005 |
Document, Report, or Work plan Review - other |
The Alaska Department of Environmental Conservation (ADEC) received monitoring remedial process optimization (RPO) report on March 21, 2005. Below are ADEC’s comments on the document.
General Comments
Typically, delineating a plume of contaminated groundwater takes more than one well in the source area. ADEC requests the Air Force redraw boundaries for “plumes” in the following figures where one well is defining a “plume” of contaminated groundwater with a bold line and replace it with a dashed line to show it as being “inferred” or “interpreted” rather than a distinct boundary.
Zone 1
Figures 3.2-1 and 3.3-1 for wells: OU6MW-46 and OU6MW-63
Figure 3.3-3 for well OU6MW-46
Figures 3.5-1 and 3.6-1 for well ST41-10R
Figure 3.9-1 for wells: OU6MW-46 and OU6MW-63
Figure 3.10-1 for well OU6MW-46
Zone 2
Figure 4.1-1 for well 59WL-31
Figure 4.3-1 for well SP7/10-04
Figures 4.3-1 and 4.5-1 for well OU4MW-04
Figure 4.6-1 for well OU4MW-08R
Figure 4.7-1 for IS6-01
Figures 4.9-1 and 4.10-1 for wells: SP7/10-04 and W-4
Zone 3
Figure 5.3-1 for well OU3MW-25
Figure 5.5-1 for wells: 60WL-04 and 64WL-01
Figure 5.6-1 for wells: 64WL-01 and 62WL-05
Figure 5.10-11 for well LF59MW-03
3.2.4 Phase I RPO Conclusions and Recommendations
Verifying that plume expansion is occurring with one monitoring well is nearly impossible to do without additional monitoring wells. The text states that the OU6 ROD mandated 5-year reviews be performed to evaluate the performance of the selected remedy (MNA). However, the recommendation in this section for MNA monitoring states MNA assessments cannot be accurately performed at one-well plumes. Also the text states plume expansion is not occurring and potential downgradient receptors are not being exposed to groundwater contaminants. ADEC requests clarification on how it can be demonstrated with one monitoring well that downgradient receptors are not being exposed to groundwater contaminants and whether or not it can be shown a plume is expanding or shrinking when sampling data is limited to one well.
The comments above apply to: PL81 South Plume (Section 3.3.5), ST41 North Plume (Section 3.5.4), 59WL-31 (Section 4.1.5), Hangar 10 Plume (Section 4.5.4), Hangar 11 Plume (Section 4.6.4), OU4 East Plume (Section 4.7.5), SS43 Plum (Section 4.9.4), W4 Plume (Section 4.10.4), OU3MW-25 Plume (Section 5.3.4), and SP01-2 Plume (Section 5.8.4).
7.0 Phase I RPO Recommendations Summary Page 7-1
ADEC concurs with updating the conceptual site models for inclusion in the 2005 Program Baseline Calculations Report.
7.1 Plume-Specific Recommendations
ADEC concurs with the plume-specific recommendations listed in this section which are not provided in Table 7.1-1.
|
Louis Howard |
| 5/17/2012 |
Update or Other Action |
Staff received the updated Final Environmental Atlas for JBER dated April 2012. |
Louis Howard |
| 6/7/2013 |
Exposure Tracking Model Ranking |
Initial ranking with ETM completed for source area id: 71623 name: auto-generated pm edit Elmendorf OU3 SD52 Cherry Hill |
Louis Howard |
| 4/1/2015 |
CERCLA PA |
FINAL Preliminary Assessment received for multiple U.S. Air Force (Air Force or USAF) and Air National Guard (ANG) Fire Training Areas (FTAs) to determine probable environmental release of perfluorinated compounds (PFCs). Specifically, HGL is completing PA activities consistent with the EPA Guidance for Preparing Preliminary Assessments under CERCLA (USEPA, 1991) to determine potential releases of PFCs at 82 AF & ANG installations from FTAs and other known and suspected PFCs or aqueous film-forming foam (AFFF) usage or storage areas.
Historical accounts also indicate that up to 2 feet of foam have been observed in the ditch south of the west ramp in 1988 (Black & Veatch, Engineers-Architects, 1990), and in 2011, foam was observed in the drainage system of the west ramp, when AFFF testing was conducted in the former AFFF test area. A release from the west ramp through the stormwater drainage system via the Cherry Hill ditch (SD052) is suspected (Bakker, 2014b, personal communication; Appendix C). Quantities of AFFF reaching various portions of the drainage system are unknown. Figure 3.2 highlights the segments of the ditch most likely to be affected by potential AFFF release locations.
Recommendation is to initiate a site inspection. A SI is defined as an investigation to collect and analyze waste and environmental samples to support an evaluation (USEPA, 1992).
Since the draft was not provided to EPA or ADEC prior to the FINAL version being submitted, it was decided that no comments or approval letter would be granted on the preliminary assessment for PFCs on JBER. |
Louis Howard |
| 11/5/2015 |
Meeting or Teleconference Held |
PFC preliminary assessment findings discussion meeting at JBER-E.
5. General findings from the PA were discussed:
a. Definition of the Groups. Ron Porter explained the Group numbers were assigned based on the likelihood that AFFF was released at a location (not a quantitative measurement of the mass released) and are used for Air Force programming.
i. Group 1 included fire training pits where there was routine use of large volumes of AFFF and high probability of groundwater contamination.
ii. Group 2 included test and measurement sites where an unknown or medium volume of AFFF could have been released.
iii. Group 3 included locations where a potential AFFF release was documented, but likely a relatively small amount (and “cats and dogs” locations that did not fit into the other groups).
iv. Group 4 is for locations where there was no known AFFF release.
Discussed secondary releases such as cooling water or wastewater treatment plant sludge. These are currently a lower priority. The focus for the SI is on identifying primary release locations as potential sources for groundwater contamination. The future site investigation/remedial investigation phase will address potential secondary sources.
AFFF use is the starting point for identifying PFC contamination sources. Other potential sources of PFCs (landfills, electroplating) are not part of the SI scope.
Discussed the possibility that the groundwater sampling approach at bases with deep groundwater may not identify PFC contamination that is still migrating through the soil. Todd Blessing asked if wells were planned to be installed in the deeper confined aquifer at JBER (below the Bootlegger Cove formation). Win Westervelt stated that the confined aquifer is artesian (upward groundwater gradient). Cory Hinds stated that no deep wells were currently scoped.
Sandy Halstead asked if there will be vertical profiling during groundwater sampling and Jackie Kramer asked if existing wells would also be sampled. Cory stated that existing wells would be sampled where available and appropriate.
Fred Vreeman asked if drinking water and fire supply water wells had been sampled at each base? Pat Roth stated that Eielson drinking water has been sampled; fire supply wells have not. Don Aide stated that two JBER water supply wells were sampled a couple of years ago. Gary Fink stated there are also 3 backup wells for the hospital, but their water comes from Anchorage Water/Wastewater Utilities.
Todd Blessing asked if surface water sampling was considered? Ron Porter stated that surface water would be considered a secondary source and therefore was not in the current SI scope. If surface water was used as drinking water, then it would be considered a primary source and would be in the scope.
See site file for additional information. |
Louis Howard |
| 12/9/2015 |
Meeting or Teleconference Held |
TPP Mtg #2 held at JBER-E.
The following was agreed:
a. For Eielson and JBER, four versions of the work plan will be needed:
i. Pre-draft for internal (USACE and AFCEC) review only
ii. Draft for internal and external (USACE, AFCEC, ADEC, and EPA) review
iii. Draft-Final for internal and external (USACE, AFCEC, ADEC, and EPA) review, redline format, electronic only
iv. Final
v. Response to comments would be provided for all drafts.
b. For Clear, three versions of the work plan will be needed:
i. Pre-draft for internal (USACE and AFCEC) review only
ii. Draft for internal and external (USACE, AFCEC, ADEC, and EPA) review
iii. Final
iv. Changes between Draft and Final will be resolved via responses to comments.
c. Scope modifications for CH2M contract will be addressed after the Eielson scope is discussed and agreed upon.
The purpose of this meeting was to reach concurrence on the SI scope for Clear and JBER.
Reviewed the revised scoping decisions for monitoring wells and water samples for JBER and Clear.
a. 27 AOCs, 28 wells, and 32 water samples for JBER, including sampling 4 existing wells
b. 5 AOCs, 8 wells, and 9 water samples for Clear, including sampling of backup supply well
c. It was clarified that the sample numbers are primary samples. QC samples will be taken at a frequency per ADEC guidance. For the JBER sampling event, the QC samples will be calculated for JBER as a whole, not JBER-E separate from JBER-R.
d. Discussed the option of using grab groundwater samples via temporary probes instead of installing permanent monitoring wells. Grab samples are often used during the SI with permanent monitoring wells installed during the RI. Louis and Charley both favor monitoring wells for the SI. This is what is currently scoped. If there is a technical recommendation for grab samples, CH2M should submit right away. Win clarified that we do not have a technical reason to recommend grab samples; it is more of an economic reason because collection of grab samples is cheaper than installing permanent monitoring wells and because no future well maintenance and abandonment are required. It was generally agreed that we would continue to propose permanent monitoring wells.
7. Discussed the proposed Incremental Sampling Methodology (ISM) for soil.
a. Agreed that we would proposed methods consistent with ITRC guidance.
b. For JBER, with expected groundwater at 20-45’ bgs, the sample interval or decision unit would be 0-15’ bgs.
i. Several attendees cautioned that depth to water at some locations on JBER-R was deeper than 20-45’.
c. For Clear, with expected depth to water is 60-70’ bgs, the sample interval or decision units are proposed at 0-10’ bgs and 10’ just above the water table.
d. Discussed options for collection of the sample increments including Tera Core and taking wedges from the cores. It was recommended that CH2M review the recent ITRC webinar prior to selecting the preferred method.
JBER revised scope and updated work plan schedule
a. Reviewed the scoping spreadsheet with wells, groundwater samples, and soil samples. No discussion needed.
b. Reviewed a couple figures. Location of AT052 is preferred within the FTA. It was mentioned that there was a concern about dioxins in this area. It was agreed that the sample was needed within the FTA and not further downgradient.
c. Work plan schedule will be updated to accommodate the required number of work plan versions.
9. Clear revised scope and updated work plan schedule
a. Reviewed responses to comments, focusing on the comments that were not accepted.
i. #9: Monte accepted the response. If infiltration rate is found, it will be included.
ii. #10: The approximate range of depth to groundwater was provided in the slides and the Clear spreadsheet. If more accurate data are located, these depths will be adjusted. They should be close.
See site file for additional information. |
Louis Howard |
| 3/14/2016 |
Update or Other Action |
PFC Work Plan received via AMERDEC email.
SI activities are being conducted consistent with the EPA Guidance for Performing Site Inspections Under the Comprehensive Environmental Response, Compensation, and Liability Act of 1980 (CERCLA) (EPA, 1992). SI activities are being initiated at the AFFF release area identified in the PA Report (AFCEC. 2015. Preliminary Assessment Report for Perfluorinated Compounds at Joint Base Elmendorf-Richardson, Alaska. Final.). PFASs are not listed CERCLA hazardous substances (Title 40, Code of Federal Regulations, Part 302, Table 302.4), and there are no soil or groundwater numerical standards promulgated federally or by the Alaska Department of Environmental Conservation (ADEC).
The SIs will be performed to evaluate the presence or absence of contamination, consistent with the Guidance for Performing Site Inspections under CERCLA (EPA, 1992).
See site file for additional information.
|
Louis Howard |
| 5/11/2016 |
Document, Report, or Work plan Review - other |
Staff provided comments on the draft PFC Site Inspections work plan for JBER-E and JBER-R.
Main comments were regarding obtaining prior approval from ADEC and EPA project managers before making changes to the approved QAPP and that the EPA RSSLs are less stringent than the human health soil cleanup levels and migration to ground cleanup levels ADEC will be promulgating this winter (2016). It was noted that WS# 10 is especially vague: "Based on the above, the best available screening criteria for PFOA and PFOS releases are the EPA PHAs for groundwater and RSSLs for soil. Because ADEC has proposed lower concentration limits that are in the public
comment process, the ADEC levels should also be considered."
It states that ADEC levels should also be considered, however in WS # 11, it states the concentrations of PFOA and PFOS in soil and groundwater will be compared to project screening levels based on the most conservative risk based EPA or ADEC values.
For determining presence or absence of PFOS and PFOA using solely risk based screening levels is not acceptable to ADEC. If the migration to groundwater cleanup level is adopted by ADEC and it exceeds for PFOS or PFOA, a release is confirmed and it is deemed to be contaminated by ADEC. 18 AAC 75.990 Definitions.
(23} "contaminated soil" means soil containing a concentration of a hazardous substance that exceeds the applicable cleanup level determined under the site cleanup rules. If AFCEC chooses to proceed with risk based values (as it is apparent upon review of Table 10-2 Steps 2, 4, & 5), then ADEC reserves the right to require further investigation/cleanup under 18 AAC 75 for all areas of concern/source areas where AFC EC determined no addition action was necessary at an area of concern/ source area, but the PFC levels detected exceed migration to groundwater cleanup levels for PFCs.
See site file for additional information. |
Louis Howard |
| 6/20/2016 |
Document, Report, or Work plan Review - other |
It appears that the review comments ADEC has previously provided on the document have been incorporated into this document. ADEC will approve the PFC site inspection work plan for implementation. ADEC’s review and comment on this work plan is to ensure that the work is done in accordance with State of Alaska environmental conservation laws and regulations. While ADEC may comment on other state and federal laws and regulations, our comments on the work plan does not relieve responsible persons from the need to comply with other applicable laws and regulations |
Louis Howard |
| 6/1/2017 |
Update or Other Action |
Draft PFC Site Inspection report received for review and comment. Site inspection (SI) at aqueous film forming foam (AFFF) areas on JBER-E and JBER-R waa received for review and comment. The purpose of the SI was to determine the presence or absence of perfluorooctanoic acid (PFOA) and perfluorooctane sulfonate (PFOS) in the environment. These compounds are a class of synthetic fluorinated chemicals used in industrial and consumer products, including defense-related applications. This class of compounds is also referred to as per- and polyfluorinated alkyl substances (PFAS).
AFFF Area #10 - Cherry Hill Ditch soil samples had PFOS detected above migration to groundwater cleanup levels in CHD-1, CHD-2, CHD-4. Groundwater results had PFOS (CHD-1, CHD-2) and PFOA (CHD-2, CHD-3) detected above the EPA health advisories but below Table C cleanup levels. In surface water: PFOA was detected above EPA health advisory but below the ADEC GW cleanup level. PFOS was detected in surface water above EPA health advisory and ADEC Table C GW cleanup level.
See site file for additional information.
|
Louis Howard |
| 6/15/2017 |
Document, Report, or Work plan Review - other |
Staff reviewed the Draft SI Report for AFFF Areas on JBER-E and JBER-R sites. PFOS and/or PFOA were detected in soil above the MTGW cleanup level. PFOS and/or PFOA were detected in groundwater at concentrations above the EPA Health Advisory levels. It appears there are documented releases of PFOS and/or PFOA at these areas which require additional investigation through a remedial investigation/feasibility study under CERCLA or as required by 18 AAC 75.335 Site Characterization.
See site file for additional information. |
Louis Howard |
| 7/17/2017 |
Document, Report, or Work plan Review - other |
EPA received the Draft Site Inspection Report for Aqueous Film Forming Foam Areas, Joint Base Elmendorf-Richardson, Alaska, May 2017 for review the week of June 2, however Appendix B2 (App B2) laboratory data was not included. EPA received App B2 for review the week of June 20. EPA preliminary comments were sent to the Air Force on July 17, 2017.
EPA Office of Research & Development staff, as well as EPA Region 5 Laboratory chemists, reviewed App B2. EPA has asked the Air Force for clarification regarding what level of report & data review was done by the government prior to submittal of the report to EPA & have not received a clear response. EPA’s initial review has identified a number of data quality issues & that the government data review should be completed & submitted to EPA before we are asked to finalize our comments. The comments submitted reflect only those requiring clarification on the narrative or figures & are not inclusive of review of the laboratory data, & therefore cannot substantiate any conclusions drawn on the presence/absence of PFAS at the 26 AOCs.
EPA review of the laboratory data packages has raised a number of concerns with deviations from workplan approved standard operating procedures, laboratory methods, & data validation. EPA requests the Air Force clarify the level of governmental data review conducted on the JBER Site Inspection laboratory packages, & provide a copy of the Air Force data review to EPA. Additional EPA comments on the laboratory data are pending receipt of the Air Force data review.
The last sentence on page 3-3 states that both well CHD-4 and replacement well CHD-4a were unable to meet stabilization parameters, but does not discuss whether this impacts the data quality of the groundwater sample collected from this area. Please revise Section 3.4 to discuss whether the lack of stabilization at well CHD-4/CHD-4a impacts the data quality of the groundwater results from this well.
According to the first paragraph of Section 3.7.9.2, “The groundwater flow direction could not be confirmed from these wells;” however, three wells were installed at AFFF Area #9 – Current Fire Training Area, which should be sufficient to determine the direction of groundwater flow. Similarly, Section 3.7.10.3 states that the groundwater flow direction could not be confirmed, but four wells were installed at AFFF Area #10 – Cherry Hill Ditch. Please revise the SI Report to determine the direction of groundwater flow at AFFF Area #9 – Current Fire Training Area & AFFF Area #10 – Cherry Hill Ditch using the new wells installed. Alternatively, please revise the SI Report to explain why the direction of groundwater flow could not be determined at these areas.
Section 3.7.11.2 states that the groundwater sample collected at AFFF Area #11 – E3/ Airborne Warning & Control System (AWACS) Crash Location “was analyzed using method WC-LS-0025;” however, the Work Plan specified analysis of PFAS using EPA Method 537. Please revise the SI Report to explain why EPA Method 537 was not used to analyze the groundwater sample collected at AFFF Area #11 – E3/AWACS Crash Location.
See site file for additional information. |
Louis Howard |
| 11/21/2017 |
Update or Other Action |
Per AFCEC email: A memo from the USACE summarizing issues found in their review should be in hand on the 4th of December. |
Louis Howard |
| 2/8/2018 |
CERCLA SI |
SI responses to ADEC's comments are satisfactory and may be incorporated into the final report. with the exception of lack of clarity in the response on which program the PFAS contamination will be investigated under at JBER: RI/FS in accordance with CERCLA as new source areas under the Federal Facility Agreements OR as new sites under State Authority (i.e. 18 AAC 75).
ADEC is requesting specific responses as to which path the investigation will occur (RI/FS per the FFA or Site Characterization per 18 AAC 75..335). Please respond. Additionally, ADEC is reviewing the Data Quality Evaluation Report AND the Technical Memorandum for Data Quality Findings Perfluorinated Compound Site Inspection for Joint Base Elmendorf-Richardson
|
Louis Howard |
| 2/13/2018 |
Document, Report, or Work plan Review - other |
Staff provided comments on the Tech. Memo. for Data Quality Findings PFC Site Inspection of AFFF Areas on JBER. Main comments were: multiple significant quality control issues (including an SOP that was not followed) have been documented that affect the accuracy and precision of the results and thus, a more detailed discussion of the usability of the data is needed. The text states: “Calibrations and quantifications were generally correct, although some results could not be re-created exactly.” Moreover, further down in this paragraph, the argument is made that no changes to the reported results were required.
ADEC requests AFCEC explain the inconsistency between these two assertions. If results could not be recreated or reproduced, then how can ADEC be confident in the reported results?
ADEC requests that analytes reported greater than the concentration range should be qualified as estimated. Detected analytes analyzed past holding time should be qualified as estimated and non-detected analytes analyzed past holding time should be rejected.
See site file for additional information. |
Louis Howard |
| 2/13/2018 |
Document, Report, or Work plan Review - other |
Staff provided comments on the Tech. Memo. for Data Quality Findings for AFFF Areas on JBER.
The text states: “Analyte concentrations were reported greater than the calibration range, either because insufficient sample remained to perform further dilutions or because the holding time was too far out to perform further dilutions.”
ADEC requests that analytes reported greater than the concentration range should be qualified as estimated. Detected analytes analyzed past holding time should be qualified as estimated and non-detected analytes analyzed past holding time should be rejected.
The text states: “The slope and intercept for linear calibrations for 6:2 FTS (320-20909-1, 320-20973-1, 320-21190-1, and 320-22046-1) and PFOA (320-20909-1, 320-20973-1, and 320-22046-1) could not be re-created exactly. Using the laboratory instrument slopes and intercepts, these initial calibrations successfully recalculated all sample and quality control data.”
If you could not recreate the calibration, then how could you determine that the calibrations were successful? Why exactly did the data need to be recalculated? Please discuss this point in more detail since it’s unclear what this bullet point is trying to convey.
See site file for additional information. |
Louis Howard |
| 9/17/2018 |
Document, Report, or Work plan Review - other |
A letter was sent regarding the 2018 ADEC tech memo which establishes drinking water action levels for six PFAS when detected in groundwater or surface water used for drinking at JBER. The tech memo establishes drinking water action levels for six PFAS when detected in groundwater or surface water used for drinking. These compounds, selected in accordance with the U.S. Environmental Protection Agency’s third Unregulated Contaminant Monitoring Rule (UCMR3) under the Safe Drinking Water Act, include: perfluorooctane sulfonate, also known as perfluorooctane sulfonic acid (PFOS), perfluorooctanoic acid, also known as perfluorooctanoate (PFOA), perfluorononanoic acid (PFNA), Perfluorohexanesulfonic acid (PFHxS), Perfluoroheptanoic acid (PFHpA), and perfluorobutane sulfonate (PFBS). Based on review of available information, DEC considers these six UCMR3 compounds to be hazardous substances under state law.
See site file for additional information. |
Louis Howard |
| 9/17/2018 |
Document, Report, or Work plan Review - other |
Staff sent a letter notifying Air Force of Action Levels for PFAS in Water and Guidance on Sampling Groundwater and Drinking Water Technical Memorandum dated August 20, 2018. Action levels for UCMR3 PFAS compounds in groundwater and surface water used as drinking water are as follows: Where one or more of the PFAS compounds, PFOS, PFOA, PFNA, PFHxS, or PFHpA are detected in a water sample analytical result, the sum of the concentrations for all detected compounds will be compared to an action level of 0.07 µg/L. Where PFBS is present in a water sample analytical result, the detected concentration will be compared to an action level of 2.0 µg/L. Please note that all future sampling results for PFAS-impacted groundwater, surface water, and pore water must include results for all six UCMR3 PFAS compounds.
See site file for additional information.
|
Louis Howard |
| 1/15/2019 |
Update or Other Action |
Fifth draft five-year review received which does not directly address sites with AFFF contamination (PFOS/PFOA). Site Interviews: Generally, comments regarding the overall remediation process at JBER-E were positive, with the following comments applicable to JBER-E CERCLA sites as a whole: Reporting of groundwater (GW) monitoring results is often delayed by 1 or 2 years following a sampling event, which could result in missed opportunities to react or change procedures in subsequent monitoring events. Perfluorooctane sulfonate (PFOS)/ perfluorooctanoic acid (PFOA) contamination was recently detected in soil & GW above ADEC cleanup levels & GW contamination above EPA Health Advisory levels. *Note: PFOS/PFOA sampling was conducted at JBER in 2016. These activities are briefly noted in this FYR (Section 6.5.3); however, results were not available at the time of the report, & results will be addressed in the next FYR (March 2024).
In 2014, a Preliminary Assessment (PA) was performed at FT023 and, in 2016, a follow-up site
inspection was conducted into the presence of PFOS/PFOA at JBER locations where aqueous
firefighting foams (AFFFs) were historically used (ADEC, 2018a). Final results from the site
inspection were not available at the time of this FYR and will be addressed in the next FYR (March 2024). |
Louis Howard |
| 2/14/2019 |
Document, Report, or Work plan Review - other |
Staff provided comments on the Five Year-Review. PFAS investigation is needed to delineate the nature & extent of contamination at this source area (CS DB Hazard ID 644) in Operable Unit 3. In 2016, soil sample results detected PFOS at concentrations below the EPA risk based screening level (RBSL) & ADEC human health cleanup level (as found in 18 AAC 75 November 6, 2016), but above the ADEC migration to groundwater (MTGW) cleanup level at locations CHD-1, CHD-2, & CHD-4. [ADEC has promulgated cleanup levels.
PFOA was detected in GW, during a one-time sampling event, at a concentration above the EPA health advisory (HA), but below the ADEC cleanup level at CHD-2 & CHD-3. PFOS was detected in groundwater at concentrations above the EPA HA but below the ADEC cleanup level at CHD-1, CHD-2, & CHD-3. PFOA was detected in surface water at a concentration above the EPA HA but below the ADEC GW cleanup level. PFOS was detected at a concentration above both the EPA HA & the ADEC cleanup level.
AFEC is currently choosing not to conduct any investigation or any groundwater, surface water, seep monitoring for PFAS until 2020 [or more likely 2021], despite the results of the 2018 Site Inspection Report indicating exceedances of State promulgated cleanup levels for PFOA & PFOS (18 AAC 75 as amended through October 27, 2018).
See site file for additional information. |
Louis Howard |
| 7/2/2021 |
Document, Report, or Work plan Review - other |
Reviewed and provided comments on the Draft Phase I Remedial Investigation Management Plan/UFP-QAPP, dated May 2021. The document provides the Work Plan, Field Sampling Plan, and the Quality Assurance Project Plan for the Phase I Remedial Investigation (RI) for PFAS at JBER. |
William Schmaltz |
