Action Date |
Action |
Description |
DEC Staff |
9/3/1979 |
Update or Other Action |
Sparrevohn Long Range Radar Site (LRRS), located about 200 miles west of Anchorage, Alaska, has been used continuously by the U.S. Air Force (USAF) since 1951. The installation occupies 1,180 acres on the top and south slope of a northeast-southwest trending ridge, informally referred to as Sparrevohn Mountain. Sparrevohn LRRS has consisted of several discrete facility locations connected by road and served by a landing strip.
The ridge-top sites include radar facilities located at Upper Camp, a White Alice Communication System (WACS) facility (OT04)and an older radio relay facility located at the Opportunity Site. Housing, fuel storage, water supply, and the landing strip were located at Lower Camp, on the lower south facing flank of the ridge. Most of the structures associated with these facilities have been demolished as a result of decommissioning activities conducted in the late 1980s. The radome is the only remaining structure at Upper Camp; several warehouse buildings remain at Lower Camp. The White Alice Communication System (WACS) facility occupied the ridge top southeast of Upper Camp and was used between 1957 and 1979. |
John Halverson |
6/15/1983 |
Update or Other Action |
Land Use and Economy of Lime Village by Priscilla Russell Kari - Technical Paper Number 80, Alaska Department of Fish and Game, Division of Subsistence (dated June 1983) - found paper in library by ADEC during risk assessment process. |
Former Staff |
9/30/1985 |
Update or Other Action |
Phase I - Records Search AAC Southern Region for six Air Force Stations including Sparrevohn AFS by Engineering Science. Sparrevohn AFS is a 1,180-acre installation located on the slopes of Sparrevohn Mountain, approximately 120 miles west of Anchorage. The installation consists of a Lower Camp which includes support facllltles and an Upper Camp which houses the radar equipment. Sparrevohn AFS became operational in 1951. Sparrevohn AFS was found to have sufficient potential to create environmental contamination with eight sites. White Alice Site was ranked seventh and operation period was from 1958 to 1978. A HARM Score of 57 was generated with follow-on action warranted.
Site Description: Suspsected disposal of oil containing PCBs. The following key items were noted relative to the subject sites: Three sites are located in close proximity at the Upper Camp. Two sites are similarly located at the Lower Camp. All the sites are located on what probably corresponds to the recharge zone for the respective shallow aquifers underlying the facilities. Aquifer characteristics are uncertain. Permafrost conditions are unknown.
The original installation water supply gallery was replaced due to the POL contamination. The existing gallery is at severe risk to contamination. Numerous POL seeps have been observed on the south slopes of Sparrevohn Mountain near the Lower Camp. For these reasons, it is recommended that an intensive environmental study be conducted at the Upper Camp for the sites identified there. Similarly, an intensive environmental study should be conducted at the Lower Camp for the sites identified there.
Recommended Monitoring Program for Phase II at Sparrevohn AFS: White Alice Site- Perform a basic study: drill 5 ft. deep borings across site on a 5 by 5 ft. square grid. Sample at 1-2 ft. and 4-5 ft. depth intervals. Additional borings may be required to determine the extent of contamination. Recommended list of analytical parameters for Phase II IRP: List "C" Soil-Oil & Grease (EPA 413.2), Volatile organics (EPA 8010/8020), Lead (EPA 239.1), and PCBs (EPA 608). |
Louis Howard |
4/9/1992 |
Update or Other Action |
EPA Memorandum April 9, 1992 Reply to the ATTN of ES-098. Subject Toxicity of Fuels. From Carol Sweeney Toxicologist Health and Environmental Assessment Section. To Wayne Pierre Federal Facilities Superfuend Branch (HW-124). A response has been provided to the frequently-asked question of whether a reference dose or other toxicity information can be provided for fuel mixtures so that these mixtures can be addressed quantitatively in Superfund risk assessments. The memo from ECAO Cincinnati is attached (last attachment). They have developed reference doses for gasoline, JP-5/kerosene, and JP-4, and a cancer potency factor for gasoline. The memo emphasizes that these are provisional numbers and that considerable uncertainty is involved in this quantitative assessment, because of data limitations, and because inhalation studies were used to calculate oral reference doses.
I typed up a summary table showing the numbers (first attachment) and calculated some risk-based concentrations (second attachment). On the risk-based concentration table, I also
included ordnance compounds, because I hadn't made a table of those before that I can remember. The risk-based concentrations were calculated the same way as table II-1 and II-2 of the Region
10 Supplemental guidance; for soil, the same limitations apply, that the numbers presented do not consider pathways other than soil ingestion.
Toxicity Reference Vaules for Fuel Mixtures EPA Region 10 4/9/1992 Non-cancer effects-Gasoline (unleaded) RfD (mg/kg-day) Oral: 2.0E-1, Uncertainty Factor-Oral:1000, Level of Confidence-Oral: Low. Toxicity Data Source-Oral RfD: Memo 3/92. Carcinogenicity-Cancer Potency/(mg/kg/day): Oral 1.7E-3, Unit Risk (/ug/m3) 4.8E-7, Cancer Weight Of Evidence-C, Toxicity Data Source-Oral SF and Inhal. SF: Memo 3/1992.
Kerosene/JP-5 RfD2.0E-2, UF Oral: 10,000, LOC Oral: low, TDS Oral RfD: Memo 3/92
JP-4 RfD 8.0E-2, UF Oral: 10,000, LOC Oral: low, TDS Oral RfD: memo 3/92.
Screening Values for Water RBCs based on Ingestion, Residential
Gasoline-Risk = 10-6 (ug/L) 50, 10-4=5000 HI=1 (ug/L) 7000
JP-5 Kerosene Risk 10-6 10-4=NA HI = 1 (ug/L) 700
JP-4 Risk 10-6 10-4 = NA, HI = 1 (ug/L) = 3,000
Screening Values for Soils- RBCs Based on Soil Ingestion Residential
Gasoline-Risk = 10-6 (mg/kg) 400, 10-4 (mg/kg) 40,000, HQ = 1 (mg/kg) 50,000
JP-5 Kerosene Risk 10-6 10-4 NA, HQ =1 5,000
JP-4 Risk 10-6 10-4 NA, HQ = 20,000
IARC concluded that gasoline is possibly carcinogenic to humans (Group 2B). IARC concluded that marine diesel fuel is possibly carcinogenic to humans (Group 2B), but light diesel fuels and jet fuels are not classifiable as to their carcinogenicity in humans (Group 3). |
Louis Howard |
12/31/1992 |
Update or Other Action |
Vol. 1 Issue 1 Sparrevohn AFS Factsheet-Sites of Potential Environmental Contamination. White Alice Site-The White Alice Communication Site was in operation from 1958 to 1978. When these facilities were constructed, most electrical equipment had insulating oils containing PCBs. PCB equipment has since been removed and initial soil samples revealed no PCB contamination.
NOTE: Spill/Leak No. 1, Landfill No. 1 and Waste Accumulation Area and Spill Leak No. 3 were recommended for No Further Action in a July 1991 report. The document was reviewed by ADEC at this time and disapproved.
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.
|
Louis Howard |
4/30/1993 |
Update or Other Action |
While not listed on the NPL, the Air Force must follow CERCLA process per E.O. 12580 [e.g. CERCLA Sections 104(a), (b), and (c)(4), 113(k), 117(a), and (c), 119, and 121) with respect to releases or threatened releases where either the release is on or the sole source of the release is from any facility or vessel under the jurisdiction, custody, or control of their departments. These functions must be exercised consistent with CERCLA Section 120 Federal Facilities.
State laws. -- State laws concerning removal and remedial action, including State laws regarding enforcement, shall apply to removal and remedial action at facilities owned or operated by a department, agency, or instrumentality of the United States when such facilities are not included on the National Priorities List. The preceding sentence shall not apply to the extent a State law would apply any standard or requirement to such facilities which is more stringent than the standards and requirements applicable to facilities which are not owned or operated by any such department, agency, or instrumentality.].
|
Louis Howard |
8/16/1993 |
Update or Other Action |
Office of the Commissioner letter to Ted Stevens: Response to your inquiry of July 27, 1993, pertaining to PCB contamination of Alaskan Aircraft Control and Warning Sites (ACWS); Sparrevohn and Cape Newenham Long Range Radar Sites (LRRS). We received your letter and enclosure (a letter from Mr. Charles Swindle) on August 2, 1993. Our staff researched our records pertaining to the 1983 incinerator exposure incident and subsequent investigation and cleanup efforts at each of the sites. Both sites are currently being evaluated under CERCLA for possible inclusion on the National Priorities List (NPL).
If either of the sites is added to the NPL our staff will assist EPA in review of documents pertaining to environmental cleanup so that we can ensure Alaska's concerns are addressed. If the sites are not added to the NPL our staff will take the lead on oversight of the future investigations and cleanups. The following is a brief summary of significant actions at each site starting with the incinerator exposure incident.
Sparrevohn LRRS:
August 25, 1983 Ms. Agnes O'Conner was cleaning the incinerator and developed a severe skin irritation from exposureto smoke or ash from the incinerator.
October 4, 1983 The Anchorage Daily News published an article on the incident and stated the irritation may have resulted from exposure to PCBs.
October 19, 1983 Alaska Department of Environmental Conservation (ADEC) staff inspected the site with Air Force personnel. They conducted interviews,field screening, and sampled residue from the incinerator. The incinerator was found to be defective in that the stack burners were not working and the gaskets were not properly sealing the doors shut.
It was also reported that the incinerator had been overfilled which resulted in incomplete combustion of the wastes. Field screening showed chloride ions were present, however, persons conducting the tests were reasonably sure these were from incomplete combustion of plastics rather than from PCBs. Two samples of ash and residue from the incinerator were sent to the ADEC laboratory in Juneau for analysis. No PCBs were detected in either sample.
January 16, 1984 The Air Force submitted a memorandum to ADEC which outlined a schedule for initial cleanup of hazardous and solid waste at several remote Alaska sites. Sparrevohn LRRS was scheduled for June through September of 1984.
1989 - 1990 Woodward Clyde Consultants conducted a Remedial Investigation and Feasibility Study under the Installation Restoration Program (IRP). The report did not contain sufficient information to complete a Hazard Ranking Score (HRS) for the site. Hazard Ranking Scores are used to determine if a site should be added to the NPL. EPA requested additional information in order to complete the HRS.
1992 The US Air Force submitted a Preliminary Assessment (PA) report to EPA under the CERCLA program. EPA requested additional information be submitted in order to complete the review.
July 1993 The US Air Force submitted a Site Investigation (SI) Report under the CERCLA program. The report is currently under review.
Recent conversations with Air Force staff indicate up to 1,000 cubic yards of petroleum and PCB contaminated soil were excavated between 1984 and 1990. Some of the soil is currently stockpiled at the site and some appears to have been disposed of off-site. At this time we have been unable to locate written records of this work. The Air Force has been asked to provide additional information.
Planned actions:
ADEC staff intend to inspect the sites this fall and work with EPA and the Air Force on development of future plans for investigation and cleanup for both sites.
Conclusion:
Based on information available to us, it appears that in 1983 at least one worker at Sparrevohn LRRS was exposed to some chemical or compound related to the incinerator which resulted in a severe skin irritation. It is not readily apparent what caused the irritation. Samples of ash and residue from the incinerator, collected on October 19, 1983, did not contain PCBs. However, PCBs have been documented in soil at the site. PCB contaminated soil has also been documented in soil at the Cape Newenham LRRS.
Our Departmentis continuing to work with the Air Forceand EPA to further investigate and cleanup environmental contamination at both of these sites, The ADEC contact for both projects is John Halverson, with our Southcentral Regional Office. Please feel free to contact him at 563-6529 if we can be of further assistance to you.
Signed by Kit Ballentine for John A. Sandor. |
John Halverson |
8/16/1993 |
Update or Other Action |
Mark Ader Federal Facilities Site Assessment Mgr. (USEPA) sent letter to Patrick M. Coullahan. The letter informed the Air Force of EPA's review of the Site Inspection (SI) report for Sparrevohn Long Range Radar Site. From EPA's evaluation, it has been determined that the site does not score high enough to be proposed for inclusion on the NPL. Therefore, a recommendation of No Further Remedial Action Planned (NFRAP) on the EPA's part will be included in the federal agency hazardous waste compliance order docket tracking system.
If new or additional informaiton becomes available that suggests the facility may score high enough to be proposed for the NPL, EPA must reevaluate the facility accordingly. EPA's NFRAP decision will not relieve your facility from comlying with appropriate State of Alaska (environmental) regulations.
The Superfund Amendments and Reauthorization Act (SARA) of 1986, Section 120(a) (4) requires federal facilities to comply with State cleanup requirements and standards when not listed on the NPL. All contaminated soil should be removed to an approved disposal facility. This facility will not be removed from the Federal Agency Hazardous Waste Compliance Docket, but as noted earlier, will be listed for no further action by EPA.
SEC. 120 [42 U.S.C. 9620] Federal Facilities
(a) Application of Act to Federal Government.-
(4) State laws. -- State laws concerning removal and remedial action, including State laws regarding enforcement, shall apply to removal and remedial action at facilities owned or operated by a department, agency, or instrumentality of the United States when such facilities are not included on the National Priorities List. The preceding sentence shall not apply to the extent a State law would apply any standard or requirement to such facilities which is more stringent than the standards and requirements applicable to facilities which are not owned or operated by any such department, agency, or instrumentality. |
Jennifer Roberts |
2/6/1995 |
Update or Other Action |
Rodney L. Hunt, Lt. Col. USAF Commander sent letter to ADEC re: Compliance Advisory/Request for Additional Information and Remedial Action at Sparrevohn LRRS, AK
1. The following information is submitted in response to your 20 Dec 94 letter requesting information on the location and depth of the excavation(s) where the PCB impacted soil was removed, the volume of soil removed, the range of PCB concentrations in soil that was removed, the concentration of PCBs at the limits of the excavation, the volume of soil transported off-site, and the ultimate disposition of soil transported off-site. Your letter also requested that the 611 CES submit documentation of efforts taken during the fall of 1994 to contain the stockpiled soil.
2. Attached is a summary of the activities performed by the 611 CES to remove PCB contaminated soil from Sparrevohn LRRS. This is based upon a review of archived data provided by the operating engineers and conversations with the foreman who performed the work. Additional data and disposal certificates can also be provided upon request. The existing containment area at the lower camp contains approximately 400 cubic yards of PCB contaminated soil. The cover on top of this pile was replaced in September 1994.
3. With respect to the contaminated soil remaining on the installation, the 611 CES is planning on-site treatment for the remainder of the PCB contaminated soil in the containment area during the 1995 field season. We are exploring a solvent extraction process (Terra-Kleen) expected to be able to achieve PCB levels better than i0 to 25 ppm in the treated soil. A soil sample from Sparrrevohn was collected in January 1995 for design and optimization testing at the vendor's laboratory. The soil will also be analyzed for the presence of any semi-volatile compounds or metals that could interfere with the treatment process or with the reconstitution of the solvent for eventual reuse. Preliminary results are expected by the end of February 1995 which should indicate whether this treatment method will be feasible for the contaminated soil present at Sparrevohn LRRS and will indicate the levels to which the vendor expects to be able to treat the soil. |
John Halverson |
7/27/1995 |
Update or Other Action |
Management Action Plan (dated and received in July 1995).
While not listed on the NPL, Sparrevohn LRRS must follow CERCLA process per E.O. 12580 [e.g. CERCLA Sections 104(a), (b), and (c)(4), 113(k), 117(a), and (c), 119, and 121) with respect to releases or threatened releases where either the release is on or the sole source of the release is from any facility or vessel under the jurisdiction, custody, or control of their departments. These functions must be exercised consistent with CERCLA Section 120 Federal Facilities.
State laws. -- State laws concerning removal and remedial action, including State laws regarding enforcement, shall apply to removal and remedial action at facilities owned or operated by a department, agency, or instrumentality of the United States when such facilities are not included on the National Priorities List. The preceding sentence shall not apply to the extent a State law would apply any standard or requirement to such facilities which is more stringent than the standards and requirements applicable to facilities which are not owned or operated by any such department, agency, or instrumentality.].
|
Ray Burger |
4/5/1996 |
Document, Report, or Work plan Review - other |
The Department of Environmental Conservation received the Draft Work Plan, PCB Soil
remediation, Sparrevohn LRRS, on March 5, 1996. This work plan outlines further sampling to
identify PCB contaminated soil at the site and the treatment of up to 400 cubic yards of PCB
comaminated soil by solvent extraction. The Department has reviewed the plan and will approve
the plan if the following items are addressed:
GENERAL COMMENTS
The constituents of the Terra-Kleen Solvent Blend will need to be specified. Depending on the
solvent constituents, tests should be specified for the solvent remaining in the soil. All workers and site visitors need to be provided with information on PCBs. MSDSs and a briefing procedure should be specified in the workplan.
SPECIFIC COMMENTS
Page 21. Section 3.8 B, Site Restoration: The solvent disposal should be as specified in the March 20, 1996 letter from Alan Cash to Dave Rein, with the further caveats of:
- in the fuel burner there should be a 1.5 second dwell time per 40 CFR 761,70
-emissions should meet the standards in 18 AAC 50.050
Appendix A, Page 1. Section 1.l Proiect Overview: In the list of four sampling events:
field screenlng and confirmation analysis should be done to the 10 mg/kg PCB level
- number 3 is missing from the list.
Appendix A. Section 2.0 Samplin and Analysis a) The precision, accuracy, and completeness
parameters listed on Page3 should be corrected to match those in Table 1 of Attachment 1. b)
The sampling density of two samples for the first 250 sq.ft. and one per 250 sq. ft. thereafter
applies to the fixed lab samples but the field screening should be more numerous and include
areas of heavier staining.
Appendi A Section 2.4 Post Remediation Sampling Strategy: The composite sample of the uppoer soil layer at 13 points is not adequate for confirmation sampling for each stockpile should include screening the pile at these points at various depths (including the geotextile) then
confirming the maximum results with a fixed lab sample.
Appendix B. Waste Management Plan. Section 2.1 Site Characterization/Sampling Non-hazardous
rinsate is not defined. Water must meet the criteria in l8 AAC 70 prior to on site disposal.
While the Department cannot approve the plan as submitted, once the comments noted above are
satisfactorily addressed, approval will be granted. In order to expedite approval of the final plan, I am available to meet with you to discuss any of the above items. |
Gretchen Pikul |
9/11/1996 |
Update or Other Action |
Community Relations Plan, Remedial Investiation / Feasibility Study (draft dated August 1996, no final received). |
Ray Burger |
11/19/1996 |
Update or Other Action |
Summary Report for Stained Area Sampling (dated October 1996 and received November 19, 1996); sampled for PCBs. The purpose of the stained area sampling was to identify and delineate four on-site areas ldentified as follows: 1) Transmitter Pad SD-03 (Area A), 2) Spill/Leak #2 ST-06 (Area B), 3) White Alice Dump OT-04, and 4)Spill/Leak #1 ST-05.
Once site locations have been established, sampling is to be conducted of soil possibly contaminated by PCBs (polychlorinated biphenyls) Results of this investigation will assist site closure of select area(s) and/or determine soil volumes for excavation and treatment.
Deviation of the work plan-At the direction of the COE, GeoEngineers deviated from the original work plan to conduct closure sampling of Area A. The closure sampling strategy differed from the originally-proposed prospect sampling strategy by evaluating the on-site soil in accordance with ADEC (Alaska Department of Environmental Conservation) regulations governing site closure for contaminated sites. Prospect sampling, by comparison, was intended only to identify PCB-contaminated areas for possible excavation and treatment.
ANALYTICAL RESULTS- PCB compounds were detected in the soil samples collected from the hand excavations and test pits at concentrations from 0.0156 mg/kg to 147 mg/kg. Soil samples collected at Areas B and C were found to have PCB concentrations that were below the ADEC closure standard designated for the site. However, soil samples collected at nine of the 62 hand excavations in Area A were found to have PCB concentrations that exceeded the site's closure standard.
Additionally, soil samples collected at three of the 11 backhoe test plts in Area A exceeded this closure standard as well. Assuming the gravel pad fill section at Area A is 1.0 to 3.0 feet thick, we estimate that approximately 16 cubic yards of soil beneath the northwest site section will require excavation and treatment.
Additionally, we estimate that at least 244 cubic yards of sod beneath the southsoutheast site section will require excavation and treatment. This soil volume estimate could be 244 cubic yards of soil beneath the south-southeast site section will require excavation and treatment. This soil volume could be larger for the south section of Area A if additional test pits were excavated and to greater depth. |
Gretchen Pikul |
1/8/1997 |
Document, Report, or Work plan Review - other |
The Department of Environmental Conservation (DEC) received the Draft RI/FS Management Plan on September 11, 1996. We received the Draft Remedial Action Report, PCB Soil Remediation, and the Summary Report for Stained Area Sampling on November 19, 1996. We also received copies of letters from the Air Force (P. Striebich) and the Army Corps of Engineers (P. Roth, White and Ferrell) commenting on the Draft RI/FS Management Plan. DEC comments on the document referenced above and the other reviewer's comments are incorporated into separate sections below.
Based on the numerous concurrent reviews and the potential for substantial changes in the documents, DEC requests a red line/strike out version of the final document or a review conference to discuss the proposed changes. This would simplify review of the final plan.
Please note, the Draft Baseline Risk Assessment Work Plan, included in the Draft RI/FS Management Plan, is currently under review. A separate comment letter will be forwarded upon completion of the review.
Work Plan-Please incorporate the additional site characterization conducted in 1996 by the Corps, if available. If this further characterization does not refer to the Summary Report for Stained Area Sampling (dated October 1996), then this study should also be incorporated into the final work plan.
Remcdial Action Report PCB Soil Remediation
1.1. Background Information Page 1: The initial lab results from the stockpile soils should be noted.
3.5 Solvent Extraction Cell Operation 6/20/96 - 8/15/96 Page 25
An average of 3.27 mg/kg PCB was the reported concentration for the treated soil, please also state the maximum concentration.
The section also describes adding fertilizer, water, and bacteria to the treated soil to degrade residual solvent in the soil. It is not clear whether any testing was done to determine the effectiveness of this treatment. Please provide more details.
Please include information on the volume of solvent added to the treatment cells, the volume removed following treatment and estimates on the amount of volatilization and increased volume due to water from the soil (mass balance on the solvent used in the project).
3.6 Solvent Destruction 8/12/96-9/11/96 Page 32
It is stated that all regenerated solvent had PCB concentrations below the detection limit of 0.1 mg/L. However, Appendix C (Lab Analysis of Solvent Prior to Disposal) shows a level of 10.6 mg/L Aroclor-1260 for sample reference# 963490001. Please clarify this discrepancy.
4.0 Conclusions and Recommendations Page 38
As stated above, an average of 3.27 mg/kg PCB was the reported concentration for the treated soil, please also state the maximum concentration.
Analytical Results Page 6
The second sentence in this section concerning a designated closure standard is unclear. There appears to be some confusion regarding the DEC approved level of 15 ppm for PCB in stockpiled soil treated by the solvent extraction method. This level was approved for this specific stockpiled soil related to the treatment method and NOT for the remainder of the site.
As following with the Guidance on Remedial Actions for Superfund Sites with PCB Contamination OSWER Directive No. 9355.4-01, please state and reference the ADEC designated closure standard reported in this section.
Discussion and Conclusions Page 6
The statement, "Based on field observations of soil conditions and analytical results, the PCB compounds detected in the site soils appear to be immobile," needs clarification and sufficient data to show the PCB compounds are immobile.
4.3.4 Site OT04 White Alice Site Page 4-7
Please incorporate the additional site characterization oonducted in 1996 by the Corps, if available. If this further characterization does not refer to the Summmy Report for Stained Area Sampling (dated October 1996), then this study should also be Incorporated into the final work plan. |
Paul Pinard |
2/7/1997 |
Update or Other Action |
Remedial Action Report PCB Soil Remediation received. Soils containing PCBs were detected at the upper and lower camps during Sampling conducted in the summer of 1986. During the summer and fall of 1989, PCB contaminated soils were excavated at the lower camp. Some of the soil was overpacked, and shipped offsite for disposal. The remaining soil was stockpiled at the lower camp. This stockpile is the object of the current project.
Several issues were raised during the plan preparation process. The Terra-Kleen Solvent Extraction process was new to Alaska. Consequently, clarifications to the plans and modifications to the approach were required to assure all involved parties that process controls were in place to insure project success. A few of the major issues discussed and resolved during the planning process were as follows:
• Nature of Terra-Kleen Solvent: ADEC required and was provided the composition of the solvent. This had to be done in a manner that did not impact the proprietary nature of the Terra-Kleen process.
• Confirmation Sampling Protocol: There was concern that the solvent extraction process would cause PCBs to be concentrated in the lower layers of the soil treatment cells. The Sampling and Analysis plan was subsequently modified to incorporate separate composite samples from the surface and bottom of each cell, as well as one sample of the geotextile liner under the cell.
• Solvent Disposal: Concerns were raised on the residual PCB concentration in the solvent prior to disposal, method of incineration, and potential air emissions. These were resolved with the provision of additional information
The project consisted of two phases. Phase I was completed during the summer of 1995 and consisted of surveying and characterizing the stockpile to establish PCB and other contaminant concentrations. On July 18 and 19, 1995, the contaminated soil was surveyed and characterized. Analysis was performed for PCB by EPA method 8080. Additional sampling was performed on August 31, 1995. Grab samples were taken, and a full suite of analyticals were performed including: Total Metals (EPA 6010), Pb (EPA 7420), As (EPA 7061), Volatile Organics (EPA 8260), Semivolatile Organics (EPA 8270). PCB concentrations ranged from 13 to 68 ppm. Volatile Organic Compounds were not detected. 1,2,4 Trichlorobenzene (Semivolatile Organic Compounds) was detected at 0.6 mg/kg and 2.4 mg/kg. 17 different metals were detected ranging from Arsenic at 11 mg/kg to Iron at 39,600.
The primary objective of this project was to use Solvent Extraction to treat the stockpile characterized during Phase I. This objective was met. The soil from the stockpile was remediated to below 15 mg/kg.
The solvent extraction treatment process required constructing treatment cells and loading the contaminated soil into the cells. A proprietary solvent was used to extract the PCBs from the soil. The PCBs were removed from the solvent by passing the solvent through molecular sleeves. Confirmation sampling was performed on the remediated soil, and sub-stockpile samples taken of the former stockpile area. The sieve material containing the PCBs was shipped offsite for disposal at a permitted offsite facility. The soil remediated to below 15 mg/kg, was treated with a solution of microbes and nutrients to reduce solvent content; and disposed of in-place by capping the former treatment cells. The solvent was filtered repeatedly to remove PCB contamination and the PCB-free solvent disposed of onsite through incineration.
It was noted that cells treated later in the process had higher residual PCB contamination after treatment that the first two cells. This could be because dilution with soil moisture had weakened the solvent. Also, soil loaded in later cells came from lower Strata in the source stockpile. This soil could have had higher starting PCB concentrations.
The Solvent Extraction process effectively met the remediation performance requirements in the remote site environment It is an applicable technology at sites where metals treatment is not required and the soil is not heavily oiled. This report recommends further consideration of Solvent Extraction as one possible technology for PCB remediation at sites where soil conditions and allowable residual contamination levels would indicate economical remediation. This report further recommends that no further action be taken on the remediated soil at Sparrevohn LRRS or the stockpile site. |
Louis Howard |
2/14/1997 |
Document, Report, or Work plan Review - other |
Final Remedial Action PCB Soil Remediation Report, January 1997. ADEC comment letter dated February 14, 1997; The Department of Environmental Conservation (DEC) received the Final Remedial Action Report (dated January 1997), the Transmittal Comments for Draft Remedial Action Report (3 pages), and Action on Comments from Draft Remedial Action Report (3 pages) on February 7, 1997. Below are our comments.
3.5 Solvent Extraction Cell Operation 6/20/96 - 8/15/96, page 25
And 4.0 Conclusions and Recommendations, page 40
An average of 3.27 mg/kg PCB was the reported concentration for the treated soil, please also state the concentration range or refer to Table 5 on page 30.
Thank you for forwarding on the copies of the Transmittal Comments and the Action on Comments; some good points were raised by the Corps.
Amended pages for final report received on March 4, 1997. |
Gretchen Pikul |
5/30/1997 |
Update or Other Action |
Community Relations Plan received. has been prepared by Shannon & Wilson, Inc. and their team. subcontractor, Parsons Engineering Science, Inc., for the Remedial Investigation/Feasibility Study (bolded terms are defined in the glossary in Appendix A) (RI/FS) at the Sparrevohn Long Range Radar Site (LRRS). This CRP has been prepared as a companion document to the RI/FS Project Work Plans for the US Army Corps of Engineers (USACE), Alaska District, under Contract No. DACA85-94-D-0009, Delivery Order 0017, in general accordance with the project scope of work, Modification No. 001, dated June 12, 1996.
OT04-White Alice Site: This facility was demolished and removed by the Air Force under the Alaska Cleanup Effort in the early 1980s. As part of the Phase I Records Search(Engineering-Science, 1985), sixteen soil samples were taken at the site, and found no indication of PCB contamination. Subsequent sampling by Woodward-Clyde (1993) did detect the presence of PCBs in the site soil. |
Gretchen Pikul |
5/30/1997 |
Site Characterization Workplan Approved |
Remedial Investigation Workplan and associated plans, ADEC comment letter dated January 7, 1997; teleconferences on workplan comments during week of March 18, 1997; ADEC received final workplans dated May 1997 on August 11, 1998 |
Gretchen Pikul |
7/10/1997 |
Site Visit |
ADEC participated in a facility-wide site visit |
Gretchen Pikul |
8/5/1997 |
Update or Other Action |
Memorandum of Intent to Evaluate Risks Associated with Subsistence Hunting near Sparrevohn LRRS (dated August 6, 1997); received Response to ADEC Comments on the Approach for Evaluating Subsistence hunting (dated September 3, 1997) on September 11, 1997; and ADEC reviewed and commented on the Approach on September 12, 1997 |
Gretchen Pikul |
9/23/1997 |
Document, Report, or Work plan Review - other |
Environmental Assessment and Finding of No Significant Impact (FONSI) for Property Disposal (draft dated July 1997, no final version received); ADEC comment letter dated September 23, 1997.
1. (pg.6) Table 2.1 Active/Excess Facilities: The Excess Facilities portion of the table contains facility numbers, description, and number of tanks that do not correspond with subsequent tables and text within the report. Please address.
2. (pg.7) 3.1 Issues Studied but Eliminated from Further Consideration: The PCB-contaminated soil removal at the former White Alice site conducted this field season should be included within this section, and throughout the text where appropriate.
3. (pg.9) 3.3.3 Solid Waste: The reference to “AEDC” should be corrected to “ADEC”.
4. (pg.10) 3.3.5 Federal Permits, Licenses, and Fees: Any solid waste issues need to be coordinated with Mr. Paul McLarnon of the Solid Waste Management Program at (907) 269-7642. These disposal issues may include, but are not limited to, asbestos debris, lead-based paint debris, and landfill cell additions.
5. (pg.12/13) Figure 3-2 and 3-3: The Vehicle Fill Station is not shown on either figure. The figures should clearly show the excess facilities locations.
6. (pg.16) 3.4.4 Storage Tanks: Partially buried tanks are mentioned in Section 3.4.2 Hazardous Waste Management, and should also be discussed and clarified in this section.
7. (pg.19) Table 3.3 Aboveground Storage Tanks: The highlighted tanks (Tank ID 991, 992, and 993) do not have capacities noted. Please add the associated capacities to the table, or in the appropriate location in the text. Also, some of the table footnotes do not correspond with the table. Please address.
8. (pg.29) 4.2.3 Storage Tanks: Site characterization of the area during removal/reuse of the tanks and/or the weather observation station is not addressed in this report. Any contamination encountered during these activities needs to be reported to the Department as soon as possible, for discussion and to coordinate potential remediation efforts. |
Gretchen Pikul |
10/6/1997 |
Document, Report, or Work plan Review - other |
The Department of Environmental Conservation (DEC), DoD oversight group, received the Peer Review Summary for Sparrevohn LRRS (dated September 22-25, 1997) on October 3, 1997. The peer review general observations included that project documents need to be revised to show minimal sampling strategy rather than extensive long-term operating to support intrinsic remediation. The peer review recommendations included quarterly sampling in selected wells, with the possibility of annual sampling for two years of the well showing the presence of benzene.
Under the risk category, it was stated that the site risk is adequately addressed, and that pathways and receptors are clear. The unresolved issues portion of the peer review expressed that 1997 field data may alter the peer review remedial approach. Since the 1997 field work and analytical data has yet to be completed and incorporated into the Remedial Investigation/Feasibility Study and the Baseline Risk Assessment, it is the Department's view that a remedial approach should only be determined after a thorough evaluation of the 1997 field data. |
Gretchen Pikul |
12/8/1997 |
Document, Report, or Work plan Review - other |
The Department of Environmental Conservation (DEC), DoD Oversight group, received the Draft Management Action Plan (dated July 11, 1997) on July 18, 1997. Chapter 3 should include the history and status of community involvement activities, and proactive community relations strategy and description is necessary within Chapter 4. Please address in the appropriate sections throughout the text.
2.1 Installation-Wide Source Discovery and Assessment Status: Please update this section and Table 2-1 with the 1997 field activities performed on the site (including the PCB-contaminated soil removal at the former White Alice Communications System Site), and the RI/FS deliverable produced in November 1997.
Summary of Regulatory Agreements: The DEC approved cleanup level of 15 ppm for PCB-contaminated soil is related specifically to the stockpiled soil and the treatment method, and not for the remainder of the site. Please make this clarification wherever appropriate throughout this document.
4.1 Zone Designation, 4.3 Ongoing and Planned Removal Actions, and 5.1 Environmental Restoration Program: These sections should update the 1997 field activities performed on the site (including the PCB-contaminated soil removal at the former White Alice Communications System Site), and the RI/FS deliverable produced in November 1997. |
Gretchen Pikul |
12/17/1997 |
Meeting or Teleconference Held |
ADEC participated in teleconferences regarding the LAS Laboratory suspension and site samples awaiting analyses |
Gretchen Pikul |
1/12/1998 |
Update or Other Action |
Final Management Action Plan (dated and received in January 1998). |
Gretchen Pikul |
2/24/1998 |
Update or Other Action |
Status of Laboratory Data Problems from the 1997 Remedial Investigation (dated February 2, 1998; Update on Status of Laboratory Data Problems from the 1997 Remedial Investigation, and Progress Report on Other Activities (dated February 26, 1998) |
Gretchen Pikul |
7/28/1998 |
Update or Other Action |
Baseline Risk Assessment workplan (draft dated August 1996; staff position at ADEC started in November 1996; ADEC comment letter dated February 25, 1997; comment resolution meeting March 6, 1997; response to comments March 26, 1997; and Addendum to Baseline Risk Assessment Workplan - Approach to Evaluating a Subsistence Hunting Scenario (dated July 28, 1998) |
Gretchen Pikul |
8/5/1998 |
Document, Report, or Work plan Review - other |
Evaluation of the Usability of Laboratory Data from the 1997 Remedial Investigation (dated and received in July 1998); ADEC memorandum sent out on August 5, 1998 to Patricia Striebich USAF 611th CES through Robert Johnston USCOE. The Department of Environmental Conservation (DEC), DoD Oversight group, received the Evaluation of the Usability of Laboratory Data from the 1997 Remedial Investigation (dated July 14, 1998) on July 17, 1997. Dr. Alan Love of the DEC laboratory in Juneau reviewed this evaluation report. His comments are provided below. Please contact me at 269-3077 if you have any questions or concerns regarding this letter.
As to the volatiles results which lack the required data quality. The quality is known and the errors are estimated. Are the levels of contaminants in these samples high enough to warrant re-sampling and analysis which has not as its objective to confirm the levels but rather to confirm the quality of the data? As I am ignorant of both the agreed upon cleanup levels and the actual Calibration Verification Standard recoveries, I can't answer this question. Are the results biased high or biased low?
As to the problem of contamination due to the use of the wrong autosampler vial caps, I do not concur with estimating the level of "cap contamination" and subtracting this from the DRO or RRO value. Any samples not flagged "3N", "1Ay", or "3Y" from the decision tree should be flagged "J" and the value reported.
Any DRO and RRO samples not flagged "3N" and which have levels above the agreed upon action levels should be re-sampled. These are the analytes about which I would be the most concerned.
As to those analytes which are impacted by evaporation of solvent due to the improper vial caps, it seems to me that there should be a way to accurately calculate the actual error sample by sample. As part of the sample extraction procedure the volume of the sample aliquot extracted and the final volume of the extract should be recorded. Without this data, no concentrations can be calculated. The extracts could have been quantitatively transferred from the vials to the appropriate measuring device and the volumes adjusted to 1.0 ml. This would certainly not, in my opinion, create a plus or minus 25% error in the extract volume.
Being aware of the incompleteness of the picture that I have, and given the exceptions mentioned above, I would endorse Shannon and Wilson's plan. I pretty much concur with the comments made by the Corps, except for the matter of re-sampling for a few RRO analyses. |
Gretchen Pikul |
7/22/1999 |
Document, Report, or Work plan Review - other |
The Alaska Department of Environmental Conservation (ADEC), DoD Oversight group, received the Draft Remedial Investigation Report (dated April 1999) on May 14, 1999. We appreciate the extended review period, have completed our review, and provided comments below.
4.4.2 Operational History and Potential Waste Streams: It is stated that a smaller tank is visible in air photos along the eastern side of the site, and that the type of storage is unknown. Include this approximate location on the figure, and whether or not the area was investigated. If the area was not investigated, include the rationale.
It is stated that tanks were supplied by pipeline from the 2 large storage tanks. Include a discussion on how these pipelines were investigated and the subsequent findings. It is stated that asbestos material from the buildings was buried at a ridge-top site about 0.4 miles southwest of the White Alice facility. Include this approximate location on the figure, reference the appropriate documentation (Base Master Plan or a facility-wide land use plan), note the appropriate signage, include a discussion on the disposal methods used, and a description of the cap.
4.4.3 Observations and Characterization Activities: Clarify whether septic tank areas, their associated discharge points, and floor drains have been investigated within this study. If these areas have not been investigated, this may be considered a data gap at this site and evaluation may be necessary prior to site closure. Test pit activities were conducted at all tank locations, with the exception of a surface soil sample (SS-133) being collected adjacent to the current Alascom building. Provide the rationale for one surface soil sample instead of the test pit outlined in the approved workplan.
4.4.3 Observations and Characterization Activities: As stated above in the specific comments for the executive summary, if a less-stringent soil cleanup level is desired, then the more suitable pathway must be clearly demonstrated. Refer to the ADEC guidance on intermittently saturated zones and 18 AAC 75.350 to develop a clear demonstration that a less-stringent cleanup level is appropriate. |
Gretchen Pikul |
7/29/1999 |
Update or Other Action |
Addendum to Evaluation of the Usability of Laboratory Data from the 1997 Remedial Investigation, Comparison of Collocated 1997 and 1998 Sample Results (document not dated) |
Gretchen Pikul |
9/13/1999 |
Update or Other Action |
Screening-Level Human and Ecological Risk Assessment (draft dated July 1999, received on July 19, 1999); ADEC comment letter dated August 18, 1999; comment resolution meeting dated August 26, 1999; response to comments September 13, 1999 |
Gretchen Pikul |
9/22/1999 |
Update or Other Action |
Final RI Report revision no. 1 received. The White Alice Communications Site (OT04) was designated an IRP site due to the detected presence of PCBs in the soil (Engineering Science, 1985). In addition to PCBs, DRO and GRO are also COPCs; DRO because of its use as heating and equipment fuel, and GRO due to its potential use associated with vehicle operation and maintenance activities in the garages formerly located at the White Alice site.
The WACS facility occupied the ridge top southeast of Upper Camp and was used between 1957 and 1979 (Figure 3-6). Deactivation and equipment removal started in 1979, and the facilities were demolished in 1985. Only the cement footings for the tropospheric scatter antenna towers currently exist at the WACS site. An Alascom facility is currently present at the east side of the site. Upper Camp includes the: ridgetop IRP sites-SD03, OT04 and ST06, as well as the roads leading from the Lower Camp to the ridgetop and between the White Alice and Upper Camp IRP sites. Lower Camp=IRP sites include Spill/Leak No. 1 (ST05), Landfill No. 1 (LF01), the
Waste Accumulation Area (SS07), and portions of the Road and Runway Oiling Areas (SD02).
Conclusions for IRP Site OT04: Based on the analytical results for this site, elevated concentrations of diesel range organics were found at former fuel tank localities, including the four antenna sites, the two drum storage sites, pump house, and equipment building. These occurrences appear to be isolated, rather than an indication of widespread hydrocarbon contamination at this site. None of the results from this site exceeded cleanup levels.
Based on study findings, PCBs were detected at below-regulatory levels at numerous locations
around the equipment building and dormitory. However, only two samples at the site exceeded
10 mg/kg. One result was 13 mg/kg. The other result (18.7 mg/kg) was a triplicate sample in
which the original and duplicate samples were non-detect and subsequent resampling results
were less than 10 mg/kg. None of the PCB concentrations at the White Alice Site exceeded the
10 mg/kg surface soil or 25 mg/kg subsurface soil cleanup levels applicable to industrial sites.
Metals analyses indicate that arsenic and chromium concentrations, whale above regulatory
criteria, are comparable to background concentrations and are constituents of local bedrock.
There were only two other samples which exceeded ADEC soil cleanup levels for metals, both
from one test pit, TP-92. One sample exceeded the cleanup level for antimony (at 5.31 mg/kg)
and the other for selenium (at 3.62 mg/kg).
Other compounds including GRO, RRO, VOCs, SVOCs, and pesticides were not reported above
regulatory levels at the White Alice site. results of sampling at the White Alice site did not suggest the presence of contamination from structures such as fuel distribution lines, septic tanks, or floor drains separate from the contamination noted above. |
Gretchen Pikul |
9/30/1999 |
Update or Other Action |
Remedial Investigation for the facilty finalized which includes OT04 - White Alice Communications Site. The White Alice Site was designated an IRP site due to the detected presence of PCBs in the soil (Engineering Science, 1985). In addition to PCBs, DRO and GRO are also COPCs; DRO because of its use as heating and equipment fuel, and GRO due to its potential use associated with vehicle operation and maintenance activities in the garages formerly located at the White Alice site.
The White Alice site was investigated with 35 test pits. one surface sample and a limited geophysical survey. The test pits were located to target former tanks and structures. It is presumed that regrading of surficial soils was conducted during site demolition work in the 1980s. This could have resulted in potentzally-contaminated surface soils being moved from their original location. Some structures, such as the fuel distribution lines at the White Alice site were not directly investigated for that reason. In addition, structures such as
floor drains and septic tanks were not identified on historical site drawings (as-builts). However, the types and locations of samples around the White Alice site and adjacent hillsides would likely have identified contamination from these potential sources if any was present.
A total of 98 soil samples, not including field duplicates, replicates, or recollected samples, were collected from the 35 test pits. Three samples were collected from each test pit except for seven test pits that had two samples collected. In general, soil samples were collected in the nearsurface (0.5 feet), midway down, and at the base of fill/top of bedrock transition.
The depths of the test pits ranged from 1.5 to 9.0 feet, averaging 4 to 5 feet. Subsurface conditions generally consisted of silty, sandy gravel (fill) overlying weathered bedrock. The depth to bedrock was typically 4 feet, but ranged from 0.5 to 7.5 feet for the site. Groundwater was not encountered in any of the test pits. Several test pits surrounding the former equipment building and dormitory encountered metal and wood debris, presumably dating from the time of demolition. While originally planned as a test pit, a surface soil sample (SS-133) was collected at the location of a former fuel tank because of its proximity to the existing Alascom facility and adjacent buried communications and power lines.
Samples from these test pits were analyzed for DRO, RRO, PCBs, and pesticides. Samples from test pits TP-90 to TP-99 were also analyzed for GRO, VOCs, SVOCs, and metals. These latter excavations were in former drum storage areas and garage/shop buildings; there was a potential that waste oil or solvents may have been associated with these areas. None of the DRO concentrations exceeded the ADEC ingestion pathway soil cleanup level of 10,250 mg/kg. The maximum DRO concentration was 8,580 mg/kg DRO. None of the samples exceeded the most stringent ADEC soil cleanup levels for GRO or RRO.
The detected concentration range was 0.0055 mg/kg to 18.7 mg/kg. One sample was reported to contain the PCB Aroclor 1254; T79S2 (2.4 mg/kg at a depth of 2 feet). 87 samples were below 1 mg/kg (35 of these were non-detect) out of a total of 108 samples taken from 35 test pits at OT004.
11 samples were above 1 mg/kg unrestricted use cleanup level found in 18 AAC 75.341 (as amended in October 2008)as follows-
0.5 ft. bgs: 1.7 mg/kg, 2.9 mg/kg, 2.9 mg/kg, and 4.0 mg/kg;
2.0 ft. bgs: 2.2 mg/kg, 3.4 mg/kg, 4.8 mg/kg and 13.0 mg/kg;
2.5 ft. bgs: 18.7 mg/kg (This was a triplicate sample in which the original and duplicate samples were non-detect and subsequent resampling results were less than 10 mg/kg.);
3.5 ft. bgs: 2.9 mg/kg; and
6 ft. bgs: 2.6 mg/kg. |
Gretchen Pikul |
10/13/1999 |
Update or Other Action |
Air Force Fact Sheet on Quality of Drinking Water Supply (dated January 1999) received on October 13, 1999 |
Gretchen Pikul |
10/28/1999 |
Site Added to Database |
Fuels and PCBs. Waste materials contaminated with PCBs as the result of a spill, an intentional or accidental release or uncontrolled discharges of PCBs, or other unauthorized disposal of PCBs are called PCB remediation waste. PCB remediation waste is managed at its "as-found" PCB concentration and includes, but is not limited to:
soil, rags, and other debris generated during a cleanup;
environmental media containing PCBs, such as soil and gravel; buildings and other man-made structures contaminated with PCBs; and
porous and non-porous surfaces upon which PCBs were spilled or released (see the definition at 40 CFR §761.3).
PCB remediation waste sampling should be based on in-situ characterization data (i.e., "as found" per 40 CFR §761.61) rather than post-excavation or demolition composite samples collected from waste piles and roll-off containers. |
Gretchen Pikul |
11/2/1999 |
Site Characterization Report Approved |
Remedial Investigation Report Volumes 1 and 2 (draft dated April 1999, draft final dated September 1999, final replacement pages dated October 27, 1999); ADEC comment letter dated July 22, 1999; comment resolution meeting on July 29, 1999; ADEC approval letter dated October 9, 2003. |
Gretchen Pikul |
7/19/2000 |
Update or Other Action |
Management Action Plan (dated May 2000 and received on July 19, 2000). In 1951, the Sparrevohn location was selected to be one of two additional ground controlled intercept sites needed to cover radar gaps in interior Alaska. Communications were provided by a high frequency radio system until 1957, when a White Alice Communications System (WACS) was installed. The WACS was deactivated in 1978 and an Alascom-owned earth terminal became operational. The Sparrevohn WACS was subsequently demolished in 1985. |
Gretchen Pikul |
9/29/2000 |
Update or Other Action |
Baseline Human Health and Ecological Risk Assessment (draft dated November 1999 and received November 26; ADEC comment letter dated February 28, 2000; comment resolution meeting on April 13, 2000 - outstanding issues on residential vs. industrial scenarios; final report dated June 2000 and received July 13, 2000 - several issues still not resolved in final report; ADEC comment letter on unresolved issues dated August 4, 2000; comment resolution meeting on September 29, 2000; ADEC conditional approval letter dated October 9, 2003. |
Gretchen Pikul |
2/1/2001 |
Update or Other Action |
Addendum Workplan for the Baseline Risk Assessment (draft dated and received on December 13, 2000); ADEC comment letter dated January 16, 2001; comment resolution meeting on February 1, 2001; final addendum workplan not issue. |
Gretchen Pikul |
3/5/2001 |
Update or Other Action |
Background Screening Process for the Addendum to the Baseline Risk Assessment (dated January 29, 2001 and received February 2, 2001); ADEC comment letter dated March 5, 2001. |
Gretchen Pikul |
7/13/2001 |
Site Number Identifier Changed |
Sparrevohn LRRS site, Reckey 198925X106002, was disseminated into eight component sites and this is one of them. |
Former Staff |
10/16/2001 |
Update or Other Action |
Final Year 2000 Clean Sweep Environmental Survey Report (dated August 14, 2001) and the Administrative Record on CD (dated April 2001) received by ADEC on October 16, 2001. |
Gretchen Pikul |
1/15/2002 |
Document, Report, or Work plan Review - other |
Baseline Risk Assessment Addendum report - draft dated and received in June 2001; ADEC comment letter dated July 10, 2001; comment resolution meeting on October 31, 2001; final addendum report dated and received in January 2002. The objectives of this final addendum report are to
-Provide corrections within the Final BLRA through the development of inserts that will replace particular pages or sections of the Final BLRAR eport (comments 4, 8, 9, and 11 in the ADEC August 4, 2000, letter)
-Provide revised risk-based concentrations and risk estimates for human and ecological receptors as a result of the addition of a sediment-to-fish contaminant transport pathway for bioaccumulatlve chemicals (comment 7 in the ADEC August 4, 2000, letter).
-Provide additional calculated risk-based concentrauons and risk estimates for a residential exposure scenario (comments 1 and 5 in the ADEC August 4, 2000, letter) for the Lower Camp exposure areas, including: Residential soil- and groundwater-to-indoor air residentual exposures(comments 2 and 6 In the ADEC August 4. 2000, letter); Subsistence and recreational ingestion of berries that are collected from the former landfill (comment 2 in the ADEC August 4, 2000, letter); Residential exposure via direct (Ingestion and dermal) contact with surface and subsurface soil (comment 3 in the ADEC August 4, 2000, letter); Subsistence and resident child ingestion of game and fish (comment 5 in the ADEC August 4, 2000, letter); Ingestion of water and inhalation of vapors from household water use for residents (ADEC comment 28 on the Shannon & Wilson [1997a] BLRA Work Plan; Recreational and subsistence ingestion of and dermal contact with surface water and sediment for residents.
None of the other exposure pathways (e g., eating berries from the landfill, eating moose or caribou that have grazed on site, breathing indoor air impacted by volatiles released from groundwater, or direct contact with surface water or sediment) posed risks to human receptors in excess of ADEC risk management standards.
Based on the results of the baseline ERA, the Tier II ERA, and the Addendumn, no further action appears to be necessary for the protection of fish or wildlife at the Hook Creek exposure area
Similarly, fish-eating wildlife are unlikely to be significantly impacted by COPECs in the sediment within streams located in the Northern Hillside/Valley exposure area. While fish were predicted to be potentially impacted due to the presence of RRO in sediment of the Northern Hillside/Valley streams, these predicted risks are not considered to present a need for remediation within the potentially impacted streams. |
Gretchen Pikul |
5/9/2002 |
Update or Other Action |
Feasibility Study received. Fuel and water were delivered to OT004 (the WACS site) by truck. A 1976 air photo also shows two drum storage areas at the facility perimeter. No documentation has been found describing waste disposal practices at the site. It is known that solid, and possibly liquid, waste and debris were disposed offthe hill slopes below the camp. It is not knownif any material was transported to LowerC ampfo r disposal or incineration.
Based on the analytical results for this site, elevated concentrations of DRO were found at former fuel tank locations, including the four antenna sites, the two drum storage sites, the pump house, and the equipment building. Because of the absence of groundwater at the ridge-top IRP sites, none of the results from this site exceeded the ADEC soil cleanup criterion based on the ingestion pathway at the WACS site. PCB were detected at numerous locations around the
equipment building and dormitory. None of the PCB reported in soil samples at the White Alice
Site exceeded industrial soil cleanup levels. Metals detected in the samples collected throughout the White Alice site were generally reported to be within background ranges, and are interpreted to represent naturally-occurring constituents of the bedrock.
Analytical results for the White Alice site indicated isolated occurrences of petroleum
hydrocarbons not exceeding cleanup levels. Low-level PCBc ontammaUown as detected in
numerous samples at the site below ADEC risk managemen sttandards. Metals were detected
within background concentrations.
Other compounds including VOCs, SVOCs, and pesticides were not reported above regulatory levels at the White Alice stte. A 350 determination is presented in Appendix C of this FS report to justify the use of ingestion pathway cleanup levels for DRO, and the boundaries of the site will be surveyed for inclusion in land records because of the presence of buried debris. The survey of the construction debris landfill and asbestos burial cell west of the White Alice site will be entered into the site’s land record Risk management decisions will be used to support an NFRAP with ICs for this site. Nor emovala ction will be conducted at this site. |
Gretchen Pikul |
5/31/2002 |
Document, Report, or Work plan Review - other |
The Alaska Department of Environmental Conservation (ADEC) DoD Oversight group, received
the Draft Feasibility Study Report(dated May 2002) on May 9, 2002. We have completed our review
and provide the comments below.
General Comments-
1. The report transition from the background section in introducing all the remaining IRP sites and contaminant exceedences, to the specific remedial actions proposed for only the Lower Camp contaminated soil and groundwater IRP sites is not complete; there are IRP sites with contaminant exceedences that are not being addressed within this FS.
One example is SD03 where PCB has been detected in the site soil as high as 620 mg/kg. Another example is LF01 where Section 2.0 Background states that based on the results of analytical testing of these soil, rock, sediment, and water samples, various hydrocarbon, volatile organic compounds PCB, pesticide, and metals compounds were detected. However there is no further mention of this site or proposed action. A clear transition from contaminant exceedences to proposed remedial action or supporting information warrant ACLs, NFRAP or site closure is necessary.
2. The final RI report shows PCB sample results above 50 mg/kg, which requires EPA involvement. The Department sttrongly encourages the 611 CES/CEVR to inform EPA about the PCB contaminated soil at SD03 and Lower Camp Power House, if this has not been accomplished earlier. 40 CFR 761.61 regulates PCB remediation waste. In most cases, contaminated soil in Alaska is the result of spills or releases from transformers. Soil contaminated with PCBs from spills from such things as transformers may be considered PCB remediation waste and EPA involvement maybe required. To determine this the 611 CES/CEVR needs to look at the definition of PCB remediation waste under The Toxic Substances Control Act (TSCA) of 1976 15 U.S.C. s/s 2601 et seq. (1976): 40 CFR 761.3 Definitions. PCB Remediation waste means waste containing PCBs as a result of spill release or other unauthorized disposal, at the following concentrations:
-Materials disposed of prior to April 18, 1978, that are currently at concentrations >50 ppm
PCBs, regardless of the concentration of the original spill;
-materials whic I are currently at any volume or concentration where the original source was
>500 ppm PCBs beginning on April 18, 1978, or >50 ppm PCBs beginning on July 2, 1979;
and,
-materials which are currently at any concentration if the PCBs are spilled or released from a
source not authorized for use under this part. PCB remediation waste means soil, rags, and
other debris generated as a result of any PCB spill cleanup, including, but not limited to:
1. Environmental media containing PCBs, such as soil and gravel; dredged materials, such as
sediments, settled sediment fines, and aqueous decantate from sediment.
2. Sewage sludge containing <50 ppm PCBs and not in use according to § 761.20(a)(4); sewage sludge: commercial or industrial sludge contaminated as the result of a spill of PCBs
including sludges located in or removed from any pollution control device; aqueous decantate
from an industrial sludge.
3 Buildings and other man-made structures (such as concrete floors, wood floors, or walls
contaminated from a leaking PCB or PCB-Contaminated Transformer), porous surfaces, and
non-porous surfaces.
Table 3-5 Calculation of ACLs: Not all of the IRP site exceedences are shown within this ACL table, and supporting information in unclear. For example, Figure 2-8b shows GRO and cis 1,2-dichloroethene ACL exceedences, but there are no GRO and cis 1,2-diehloroethene ACLs proposed within this table for soil. Please address.
• The ADEC soil cleanup level for DRO applicable to the Lower Camp soil is the migration to groundwater pathway; include the rationale for proposing the ingestion pathway.
• The ADEC Technical Memorandum 01-007 (dated December 18, 2001) - Calculated Cleanup Levels for Compounds without Tabular Values in Site Cleanup Rules, offers a list of calculated cleanup levels for compounds that have been detected at contaminated sites in Alaska but no cleanup level exists in Table B1 or Table C. Calculation cleanup levels for 1,2,4-trimethylbenzene, 1,3,5-trimethylbenzene, and 2-methylnaphthalene are included within this memorandum. |
Gretchen Pikul |
9/11/2002 |
Document, Report, or Work plan Review - other |
Gretchen Pikul (ADEC) sent Scott Tarbox (611th Air Support Group) letter on the Draft Feasibility Study Report, Remedial Investigation / Feasibility Study, Sparrevohn LRRS, Alaska
The Alaska Department of Environmental Conservation (ADEC), DoD Oversight group received the Draft Feasibility Study Report (dated May 2, 2002) on May 9, 2002, an ADEC comment letter was submitted on May 31, 2002, a comment resolution meeting was held on June 10, 2002, a response to comments were received on July 22, 2002, ADEC sent e-mails on July 25 and August 8, 2002 regarding the response to comments, a final response to comments was received on August 19, 2002, and a second comment resolution meeting was held on August 21, 2002; all issues were resolved within the last meeting. Based on the above noted reviews, meetings, and documentation, ADEC concurs with the feasibility study, and therefore approves this document based on the incorporation of these responses, as stated, within the final document The inclusion of agency review comment letters, the Air Force response to comments, and this approval letter within in the final document appendices is requested.
Please note ADEC review and concurrence on this document 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 concurrence on this document does not relieve responsible persons from the need to comply with other applicable laws and regulations. |
Gretchen Pikul |
9/30/2002 |
Update or Other Action |
Final Feasibility Study for several sites which includes the White Alice Communications System facility (White Alice Site OT04). OT04 is part of the Upper Camp exposure area which is composed of: composite of the ridge-top IRP sites; White Alice, Transmitter Pad and Opportunity Site, Upper Camp, and portions of the Road and Runway Oiling site. The WACs Site is located midway between Lower Camp and Upper Camp, at elevation 2,650 feet. It had high power requirements and used many transformers, capacitors, and switchgear, most of which used insulating oil containing PCB. It was normal practice to dispose of waste oils on the ground near the buildings. Power was supplied to the WACS facility by two, 140-kw diesel generators. Diesel fuel was stored in two 10,000-gallon aboveground storage tanks.
In addition, each 60-foot antenna had an aboveground 1,600-gallon fuel storage tank located behind the antenna. These tanks were supplied by pipeline from the two large storage tanks. Fuel and water were delivered to the WACS site by truck. A 1976 air photo also shows two drum storage areas at the facility perimeter. No documentation has been found describing waste disposal practices at the site. It is known that solid, and possibly liquid, waste and debris were disposed off the hill slopes below the camp. It is not known if any material was transported to Lower Camp for disposal or incineration.
Based on the analytical results for this site, elevated concentrations of DRO were found at former fuel tank locations, including the four antenna sites, the two drum storage sites, the pump house, and the equipment building. Because of the absence of groundwater at the ridge-top IRP sites, none of the results from this site exceeded the ADEC soil cleanup criterion based on the ingestion pathway at the WACS site. PCBs were detected at numerous locations around the
equipment building and dormitory. None of the PCB reported in soil samples at the White Alice Site exceeded industrial soil cleanup levels (NOTE To FILE: "Industrial" PCB cleanup levels are no longer used. ADEC's cleanup level for Total PCBs is 1 mg/kg for unrestricted land use and 1-10 mg/kg for ICs and cap or risk-based level via a risk assessment with ICs per 18 AAC 75.341). Metals detected in the samples collected throughout the White Alice site were generally reported to be within background ranges, and are interpreted to represent naturally-occurring constituents of the bedrock.
Analytical results for the White Alice site indicated isolated occurrences of petroleum hydrocarbons not exceeding cleanup levels. Low-level PCB contammination was detected in numerous samples at the site below ADEC risk management standards. Metals were detected within background concentrations. Other compounds including VOCs, SVOCs, and pesticides were not reported above regulatory levels at the White Alice site. A 350 determination is presented in AppendixC of this FS report to justify the use of ingestion pathway cleanup levels for DRO and the boundaries of the site will be surveyed for inclusion In land records because of the presence of buried debris. The survey of the construction debris landfill and asbestos burial cell west of the White Alice site will be entered into the site’s land record Risk management decisions will be used to support an NFRAP with ICs for this site. No removal action will be conducted at this site. |
Gretchen Pikul |
9/30/2002 |
Cleanup Level(s) Approved |
HYDROGEOLOGIC MODEL IN SUPPORT OF NO POTENTIAL FUTURE WATER USE (350 DETERMINATION)-The conceptual site hydrogeologic models described in the 1999 RI report were developed based on the available site information, observations made during the 1996 site visit, and a general understanding of the site hydrogeology. They served as hypotheses that describe how the near-surface hydrologic systems work, and have been used in a preliminary evaluation of how COPCs are likely to migrate in these systems. The premise for the groundwater (GW) use determination under 18 AAC 75.350 for the ridge-top IRP sites is that GW is not present, and those sites do not contribute to the recharge area for the Lower Camp water gallery.
Sparrevohn LRRS is underlain by rock consisting of a very thick-bedded sandstone and pebbly to cobbly sandstone, with thin bedded sandstone and shale beds at the ridge-top IRP sites, to shale and thin interbeds of siltstone and fine to medium grained sandstone at Lower Camp. Generally, the bedrock along the ridge top is tightly jointed with no water or ice and covered by a thin layer of broken, weathered rock. At the lower elevations, talus and alluvial deposits have accumulated in the valley floors of the tributary streams. Alluvial deposits of silt, sand, and gravel are also present along the active stream channels.
The primary purpose of the Lower Camp was to provide runway and maintenance facilities, as well as utility support (water, power, and fuel) to the ridge-top radar and communications installations. Water supply systems have ever been developed at the ridge-top IRP sites. The water supply system developed provided a year-round supply to the Lower Camp facilities and served Upper Camp and OT04 site with water pumped by pipeline to storage tanks. The original water supply system for the station consisted of a subsurface gallery located immediately west of Lower Camp. The gallery collected shallow GW from the valley-fill sediments, and was reportedly constructed to a depth of 14 feet. A second gallery system was constructed about 250 feet upstream from the original location to a depth about 20 feet below the stream bed level. Apparently, the first gallery was abandoned because of hydrocarbon contamination.
A shallow, unconfined GW system exists within the valley-fill alluvium with a water table surface that probably closely approximates the surface topography. Groundwater in the alluvium is recharged by precipitation falling directly on the ground in the stream valley, surface water runoff from the surrounding hillsides, and presumably limited GW discharge from bedrock fractures at the base of the slope below the former Power House. This discharge is evidenced by the two seeps located at the west end of Lower Camp at the base of the Power House hill. The tributary streams that are fed primarily by precipitation and snowmelt from higher elevations, cross the alluvium and are in hydraulic communication with the alluvial aquifer. The current water collection gallery for Sparrevohn is located upgradient of the Lower Camp IRP sites, the drinking water supply has not been affected by site operations. There are no viable GW resources suitable for development at Upper Camp.
There are no drinking water sources at the ridge-top sites, including Upper Camp, OT04 site, and the Transmitter Pad. Groundwater that may exist at these sites is not likely to be a viable drinking water source due to its being very deep and contained within a rock formation. Data suggest the bedrock aquifer is anticipated to have low storage capacity and transmissivity potential. The GW that may exist in the bedrock is not a reasonably expected potential future source of drinking water because no one resides at the ridge-top sites, and GW, if present, is not currently needed as a drinking water source.
The USAF has no intention to house people at these sites, and it is unlikely that people would live at this location in the future. There is no known future use scenario that would require development of GW, if present, as a drinking water source. The nearest drinking water source at Sparrevohn LRRS is the gallery system located on the west side of Lower Camp, approximately one mile from Upper Camp. Based on the topography of the ridge-top IRP sites, only Upper Camp (i.e., IRP site ST06) could reasonably be considered contribute to the recharge area of the Lower Camp water gallery. Even so, rainfall runoff or snowmelt emanating from Upper Camp is as likely or more so to flow to drainages either north of Sparrevohn or east of Lower Camp, neither of which contribute to the water gallery recharge area. None of the other ridge-top IRP sites are within the drainage basin for the Lower Camp water collection gallery. The absence of contaminants in the site drinking water system supports the conclusion that historical activities at the ridge-top sites have not affected water quality in that system. |
Gretchen Pikul |
11/4/2002 |
Update or Other Action |
Proposed Plan – 1st draft received October 30, 2002; ADEC comments submitted to Air Force and comment resolution meeting on November 4, 2002. |
Gretchen Pikul |
10/9/2003 |
Risk Assessment Report Approved |
The Alaska Department of Environmental Conservation (ADEC), DoD Oversight group received the Final Baseline Human Health and Ecological Risk Assessment (dated June 2000) on July 13, 2000, and the Final Baseline Risk Assessment Addendum (dated January 2002) on January 15, 2002. The ADEC concurs with the contents of the Final Baseline Human Health and Ecological Risk Assessment used in conjunction with the Final Baseline Risk Assessment Addendum.
Please note that the ADEC review and concurrence on this document is to ensure that the work
is done in accordance with State of Alaska environmental conservation laws and regulations.
While the ADEC may comment on other state and federal laws and regulations, our concurrence on this document does not relieve responsible persons from the need to comply with other applicable laws and regulations. |
Gretchen Pikul |
10/9/2003 |
Document, Report, or Work plan Review - other |
Gretchen Pikul (ADEC) sent letter to Scott Tarbox (USAF 611 ASG) re: RI Report, Sparrevohn LRRS. The Alaska Department of Environmental Conservation (ADEC), DoD Oversight group received the Draft Remedial Investigation Report (dated April 1999) on May 14, 1999, received the Air Force Comment Response on July 29, 1999, and participated in the comment resolution meeting on July 29, 1999; the ADEC comment letter is dated July 22, 1999. No ADEC approval letter was issued in 1999. For clarification purposes, this letter is being issued stating that ADEC concurs with the contents of the Final Remedial Investigation Report (dated September 1999) and received on September 24, 1999.
Please note that the ADEC review and concurrence on this document is to ensure that the work is done in accordance with State of Alaska environmental conservation laws and regulations. While the ADEC may comment on other state and federal laws and regulations, our concurrence on this document does not relieve responsible persons from the need to comply with other applicable laws and regulations. |
Gretchen Pikul |
7/12/2004 |
Update or Other Action |
Proposed Plan – 2nd draft (prepared by Air Force project manager) received on December 7, 2002; ADEC comments dated December 31, 2002; ADEC internal briefing and final comments submitted on January 8, 2003; e-mails and calls from ADEC to Air Force on finalizing Proposed Plan from January to October 2003; several comment resolution meetings from January to September 2003; October 9 received final Proposed Plan and ADEC submitted conditional approval letter; Final Proposed Plan sent to PACAF for review in October 2003; ADEC called/e-mailed from October 2003 through May 2004 on Plan status - no progress. PACAF comments on the 2nd draft Proposed Plan were received by Air Force on March 19, 2004 and were forwarded to ADEC on July 12, 2004. |
Gretchen Pikul |
7/21/2004 |
Meeting or Teleconference Held |
Proposed Plan – Meeting with EPA on June 10, 2004; Air Force and ADEC met with EPA on Proposed Plan and general remedial direction; EPA agreed to plan and submitted a letter of non-objection dated June 21, 2004 and received by ADEC on July 21, 2004. |
Gretchen Pikul |
9/3/2004 |
Update or Other Action |
Proposed Plan – 3rd draft received on July 29, 2004; August 12, 2004, ADEC staff participated in a teleconference with Air Force 611th project managers, Air Staff, and PACAF on the Air Force direction for the review and content of Proposed Plans and RODs; September 3, 2004, ADEC sent a comment letter on the 3rd draft Proposed Plan.
Based on the Remedial Investigation (RI) (page 4-20), there is an asbestos landfill associated with OT04 demolition wastes generated during 1984 and 1986. Please elaborate on how will this asbestos landfill be documented for future reference. This is a Facility issue and does not need to be included within the Proposed Plan.
OT04 notes a cleanup level of 10 mg/kg which does not correspond to cleanup levels or the risk assessments levels. Please delete or clarify in the text. |
Gretchen Pikul |
11/19/2004 |
Update or Other Action |
File number issued 2652.38.005 |
Aggie Blandford |
9/18/2006 |
Update or Other Action |
Work Plan - Water Sampling and Sign Installation for Sites ST005, SD003, and OT004; draft dated May 2006 received May 31; ADEC comment letter dated July 12; Air Force Comment Response on August 15; August 18 ADEC submitted email to Air Force re-emphasizing importance of collecting sediment samples as well as the proposed surface water samples from the groundwater seeps day-lighting into creek downgradient of Site ST005; September 11, 2006 ADEC received correspondence which confirmed the revised Air Force plan to collect five sediment samples along creek downgradient of Site ST005; ADEC approval letter dated September 11; final Work Plan dated September 2006 received September 18, 2006.
A sign will be posted to warn site personnel and visitors of the PCB contaminated soil in the area. The sign will be located facing the road as one would approach OT004 from the road. |
Jeff Norberg |
2/19/2008 |
Exposure Tracking Model Ranking |
Initial ranking with ETM completed. |
Louis Howard |
8/22/2008 |
Update or Other Action |
The Air Force sent a copy of the draft Proposed Plan to ADEC for Review. The Proposed Plan presents the Preferred Alternatives for remediation at seven United States Air Force (USAF) Environmental Restoration Program (ERP) contaminated sites at Sparrevohn Long Range Radar Site (LRRS), Alaska. The sites addressed in this plan include Waste Accumulation Area (SS007) and six other sites.
Risk Evaluation Summary: The WACS site was included as a source in the Upper Camp exposure area risk assessment. The baseline human health and ecological risk assessment found minimal risk to human and ecological receptors at Upper Camp. Because PCBs are stable compounds, they do not readily degrade in the environment. PCBs do bioaccumulate and reach higher concentrations in the
upper levels of the food chain. PCBs are generally insoluble in water; therefore, the primary migration pathway would be through erosion or dispersion of contaminated soil by vehicle traffic. However, the site has limited access and no activities currently occur or are likely to occur at the site in the future that would result in exposure. In addition, the PCBs were
detected primarily in the subsurface soil; as a result, the likelihood of receptors coming into contact with the contaminated soil is relatively low because the receptor would likely only contact surface soil. Cumulative cancer risk calculations for a worker resident at Upper Camp was calculated to be 4.16 x 10-6 and the non-cancer HI was 0.07. Both values are below ADEC risk management standards.
Proposed Action: Although the results of the risk assessment indicate that ADEC risk management standards are not exceeded in the Upper Camp exposure area, the WACS site does contain soil that exceeds the ADEC Method Two soil cleanup levels for PCBs (Table 6). As a result, this site is proposed for remedial action under CERCLA and Alaska State laws and regulations to address the PCB-contaminated soil.
The Preferred Alternative was selected based on a comparative analysis of remedial alternatives following CERCLA guidance. The three alternatives considered for this site included no action, institutional controls, and excavation and offsite disposal. The area of PCB-impacted soil with concentrations exceeding the ADEC Method Two soil cleanup level of 1 mg/Kg is limited to discrete locations at the WACS site. Most PCB detections occurred in subsurface soil, and the risk of exposure is low. Additionally, the WACS site is located on a ridge-top and within the boundaries of Sparrevohn LRRS, making access to the site relatively difficult. Currently, no activities occur at the WACS site. As a result of the low risk of exposure and the difficulties in accessing the area and implementing active remediation, institutional controls were selected as the Preferred Alternative. Institutional controls will consist of signage identifying the compounds present at the site and updates to the Base Master Plan documenting site conditions.
Excavating and disposing of the soil offsite is significantly more expensive than institutional controls, and would not provide better protection of human health and the environment. The no action alternative fails to satisfy the threshold criteria and therefore was not evaluated.
Section 121 of CERCLA requires that remedial actions which result in any hazardous substances remaining at the site above concentrations that allow for unlimited use and unrestricted exposure are subject to a Five-Year Review. The purpose of the Five-Year Review is to assess the remedy’s performance and protectiveness. Because PCBs exceeding the ADEC soil cleanup level will remain on site, a CERCLA Five-Year Review will be part of the remedy. Additionally, ADEC approval will be obtained prior to moving or disposing of soil contaminated above the Method Two soil cleanup levels. |
Louis Howard |
9/5/2008 |
Proposed Plan |
The Alaska Department of Environmental Conservation (ADEC) received the Proposed Plan for review and comment via electronic mail on August 22, 2008. Below are ADEC’s comments regarding Spill Sites: Road and Runway Oiling (SD002), Transmitter Pad/Opportunity Site (SD003), White Alice Communication System (OT004), Spill/Leak No 1 and Lower Camp (ST005), Spill/Leak No. 2 (ST006), Waste Accumulation Area (SS007), and the Hillside Disposal Areas (DP008).
Summary Page 1-The text in the last sentence states: “Finally, ADEC approval will be obtained prior to moving or disposal of soil contaminated above the appropriate cleanup level.” In accordance with 18 AAC 75.325(i), ADEC requests the Air Force rephrase the text that states “Finally, ADEC approval will be obtained prior to moving or disposal of soil or groundwater which were subject to site cleanup rules (18 AAC 75.325).” Specifically, 18 AAC 75.325(i) states: “A responsible person shall obtain approval before moving or disposing of soil or groundwater from a site:(1) that is subject to the site cleanup rules; or (2) for which the responsible person has received a written determination from the department.” This notification requirement applies to soil and groundwater at sites which were subject to 18 AAC 75.325 as well as those sites which do not meet the “appropriate” cleanup levels.
Figure 1 ERP Site Locations Page 2 and Page 7-ADEC requests clarifying text be included in the document regarding who owns the surrounding land and whether or not wastes and contaminants off the Air Force controlled land.
Introduction (Continued) Pages 2 and 3-The text in the third paragraph on page two should be revised to state “In Alaska, sites that are contaminated with releases of petroleum products or other hazardous substances are addressed by ADEC under contaminated sites regulations (18 AAC 75 Article 3)...”. The second to last sentence in the paragraph should be revised to state, “All the sites are required to meet 18 AAC 75 regulations.” ADEC does have promulgated cleanup levels (18 AAC 75.341 and 18 AAC 75 for non-petroleum contaminants in soil and groundwater. There even cases where the ADEC cleanup levels are more stringent than federal cleanup levels (e.g. Table B1 Method Two-Soil Cleanup Levels Table: PCBs 1 mg/kg). The facility is not on the National Priorities List and the EPA has deferred its regulatory authority to ADEC as stated in this section.
The text in the first paragraph on page 3 states “Final decisions on the recommended alternatives are not made until all comments submitted during the public comment period...” ADEC requests the Air Force change the text to be consistent with the introductory statement in the “Summary” and the last sentence in this section: “Final decisions on the preferred alternatives are not made until all comments submitted during the public comment period...”
Table 3—Summary of ADEC Soil Cleanup Levels for Petroleum Contaminants in the Under 40-Inch Zone Page 7-The table heading should be changed to “Soil Cleanup Levels for Oil and Hazardous Substances in the Under 40-Inch Zone”. ADEC requests the Air Force add Total PCBs to this table with the value of 1 mg/kg for each of the two categories (ingestion/inhalation and migration to groundwater). The table lists 11,000 mg/kg residual range organics (RRO) as the migration to groundwater cleanup level, which is correct, but the footnote states that it applies for sites in the Lower Camp. Since the ingestion level is the lower value, it would be the applicable cleanup level for RRO.
WACS OT004 Proposed Action Page 14-There are elevated levels of PCB are present as in SD003, but the measured results are much lower than at SD003. The text states PCBs were detected primarily in the subsurface; more information should be provided on the depths to and concentrations of PCBs at OT004. The site may already have an adequate soil/rock cap from past demolition work and backfilling, but it is not very clear in the PP. ADEC requests the Air Force provide additional text regarding fill material/rock cap placed at the site over the PCBs.
The text states: “Additionally, ADEC approval will be obtained prior to moving or disposing of soil contaminated above the Method Two soil cleanup levels.” In accordance with 18 AAC 75.355(i), ADEC requests the Air Force change the text to read “ADEC approval shall be obtained before moving or disposing of soil which was subject to the site cleanup rules.”
Table 6—WACS (OT004) Summary Page 14-ADEC requests the Air Force delete reference to the heading: Regulatory Standard & Proposed Cleanup Level and simply change the table heading to “Cleanup Standard”.
Table 7 — Comparison of Remedial Alternatives Addressing WACS (OT004) Page 15-ADEC requests the * footnote be changed to read: ADEC has participated in the development of this plan. Final state acceptance will be evaluated following public comment. |
Louis Howard |
2/26/2009 |
Update or Other Action |
Draft Record of Decision received. The White Alice Communication System (WACS) (OT004) is one of eight individual sites located at Sparrevohn LRRS being addressed under the U.S. Air Force (USAF) Environmental Restoration Program (ERP). Fuel storage tanks were present at each WACS (OT004) tropospheric antenna and adjacent to industrial buildings. When the buildings were demolished, the majority of debris was buried on site and as a result, the original ground surface is no longer exposed. The WACS had high power requirements, and most electrical equipment used at the time contained polychlorinated biphenyl (PCB)-laden insulating oil. While active, it was not an uncommon practice to dispose of waste oil on the ground outside the buildings. Because this site is located on the ridge top and there is no groundwater.
The selected remedy for the WACS (OT004) will
protect human health and the environment, and allow for continued site use. The USAF has
selected Institutional Controls as the remedy for the WACS (OT004), with the following
components:
• Implementation of institutional controls to identify areas of contamination and restrict
land use at the White Alice Communication System site to achieve remedial action
objectives. Institutional controls will include:
o Installation of signs warning of the presence of soil contamination exceeding
ADEC residential cleanup levels;
o Restriction on residential land use;
o Restrictions on digging that could disturb soil acting as a cover to PCBcontaminated
areas; and
o Requirement for all operators to utilize USAF construction review and dig permit
systems or similar systems to prevent uses or activities inconsistent with the
remedial action objectives.
• Notations regarding residual contamination and land use restrictions will be recorded in
the appropriate Sparrevohn LRRS land records, including the Base Master Plan. As part
of the update to the Base Master Plan, the USAF will produce maps showing locations of
residual contamination, and will provide these maps to ADEC.
• Institutional controls will remain in effect for as long as the contaminated media exceeds
ADEC unrestricted residential use criteria. The USAF is responsible for enforcing
institutional controls and the USAF will monitor the effectiveness of the institutional
controls. The USAF will provide an annual report regarding institutional control
monitoring to ADEC, with copies filed in the administrative record and information
repository.
• The USAF will provide prompt notification to the ADEC of institutional control
deficiency/failure, along with corrective measures taken. The USAF will obtain
regulatory concurrence of significant changes to use and activity restrictions. The USAF
will provide prior notification to ADEC for transfer of property subject to institutional
controls.
In the future, if soil is removed from the site, it must be characterized and managed following
regulations applicable at that time. Pursuant to 18 AAC 75.325(i)(1) and (2), ADEC approval is
required prior to moving or disposing of soil that is, or has been, subject to the cleanup rules
found in 18 AAC 75.325-.370.
The USAF will submit an Institutional Control Performance Report to the ADEC on an annual
basis for the first five years. The frequency of the Institutional Control Performance Report will be evaluated with the Five-Year Review under 42 U.S.C. 9621(c). This report shall include
visual inspection of the site, replacement of signs on the property if necessary, any information pertaining to breaches of institutional controls, and corrective actions taken to prevent such breaches in the future.
|
Louis Howard |
4/14/2009 |
Update or Other Action |
After an internal briefing with management and Dept. of Law, additional comments were provided to the 611 CES/CEVR regarding the draft ROD for OT004. ADEC requests the Air Force clarify in the text whether the facility is on land actually owned by the Air Force, leased from the Bureau of Land Management or permitted for use by the Air Force from another entity. 1.2 Statement of Basis and Purpose Page 1-2: ADEC requests the second sentence be changed to read: “ADEC agrees that successful implementation of the selected remedy will meet state regulatory requirements.”
1.4 Description of Selected Remedy-ADEC requests the Air Force add a fourth bullet (and throughout the document where the remedy is discussed in such a manner): The Air Force will provide a map to ADEC showing the location of residual contamination for posting on the ADEC Contaminated Sites website. The text states the selected remedy represents the maximum extent to which permanent solutions can be used in a practicable manner at the site. It provides the best balance or trade-offs in terms of balancing criteria while also considering the bias against offsite treatment and disposal and considering state and community acceptance.
ADEC requests the Air Force change the text to read: “The selected remedy represents the maximum extent to which permanent solutions can be used in a practicable manner at the site. It provides the best balance or trade-offs in terms of balancing criteria.”
The text states: “Based on the evaluation of alternatives discussed in the FS, institutional controls consisting of signage are the most cost-effective and readily implementable approach to reduce the risk posed by PCBs exceeding the ADEC Method Two soil cleanup level of 1 mg/Kg.” ADEC requests the Air Force mention not only signage as part of the institutional controls, but documentation in the Base Master Plan and real property records that PCB contaminated soil remains in place.
2.1.3. Statutory Determinations - The text states: “In addition, CERCLA includes: 1) a preference for remedies that employ treatment which permanently and significantly reduces the volume, toxicity, or mobility of hazardous wastes as a principal element; and 2) a bias against offsite disposal of untreated wastes.”
ADEC requests the Air Force change the text to read: “Under CERCLA §121 and the NCP, the Air Force must select a remedy that is protective of human health and the environment, complies with ARARs, is cost-effective, and utilizes permanent solutions and alternative treatment technologies. In addition, CERCLA includes a preference for remedies that employ treatment that permanently and significantly reduce the volume, toxicity, or mobility of hazardous wastes.”
2.10.8 State/Support Agency Acceptance- ADEC requests the Air Force change the first sentence for this section to read as follows “ADEC agrees that proper implementation of Alternative 2 will meet state ARARs.”
2.13.6 Five-Year Review Requirements-ADEC requests the text be changed to read: “...a statutory review will be required at least every five years after initiation of the remedial action to verify....”
Please note, ADEC second set of review comments on this decision document 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 review on the document does not relieve the Air Force, its contractors, agents or other persons acting on its behalf from the need to comply with other applicable laws and regulations. |
Louis Howard |
5/22/2009 |
Document, Report, or Work plan Review - other |
Staff provided a third set of comments on the ROD for OT004. 1.1 Site Name and Location Page 1-1
ADEC requests the Air Force replace the reference to the Record Key (Reckey) Number with the Hazard ID: 694. Reckey numbers are no longer used as a specific site identification in the Contaminated Sites database.
1.5 Statutory Determination Page 1-4: The text states: “The selected remedy for WACS (OT004) is protective of human health and the environment, complies with promulgated requirements that are applicable or relevant and appropriate to the remedial action, and provides an overall cost benefit to the USAF.” ADEC is unaware of CERCLA guidance where the statutory determination requires an overall cost benefit to the responsible party. Per EPA Guidance OSWER 9200.1-23P EPA 540-R-98-031 July 30, 1999:
The ROD Declaration shall conclude with the finding that the Selected Remedy satisfies the statutory requirements of CERCLA. This can be accomplished by making confirmatory statements that the Selected Remedy attains the mandates of CERCLA §121, and, to the extent practicable, the NCP.
Specifically, the remedy must do the following: (1) Be protective of human health and the environment; (2) Comply with ARARs (or justify a waiver); (3) Be cost-effective; (4) Utilize permanent solutions and alternative treatment technologies or resource recovery technologies to the maximum extent practicable; (5) Satisfy the preference for treatment as a principal element of the remedy which permanently and significantly reduces the toxicity, mobility, or volume of hazardous substances, pollutants, or contaminants.
ADEC requests the Air Force change the text to reflect EPA Guidance on the selected remedy being cost effective and strike the phrase: “...provides and overall cost benefit to the USAF.”
2.13.6 Five-Year Review Page 2-41: In section 1.4 Description of the Selected Remedy on page 1-4 it states: “The USAF will submit an Institutional Control Performance Report to the ADEC on an annual basis for the first five years. The frequency of the Institutional Control Performance Report will be evaluated with the Five-Year Review under 42 U.S.C. 9621(c).” ADEC requests the Air Force include text in section 2.13.6 that the Annual Institutional Control Performance Report will be submitted annually in addition to the Five-Year Review required by this section.
The text states: “Pursuant to CERCLA §121(c) and NCP §300.430(f)(5)(iii)(C), because the selected remedy will result in hazardous substances, pollutants, or contaminants remaining on site above levels that allow for unlimited use and unrestricted exposure, a statutory review will be required within at least every five years after initiation of the remedial action to verify that the remedy is, and will continue to be, protective of human health and the environment.”
A five-year review should determine whether the remedy at a site is or upon completion will be protective of human health and the environment. ADEC requests the Air Force delete the portion of the text “... and will continue to be,” protective of human health and the environment.
Please note, ADEC third set review comments on this decision document 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 review on the document does not relieve the Air Force, its contractors, agents or other persons acting on its behalf from the need to comply with other applicable laws and regulations. |
Louis Howard |
9/18/2009 |
CERCLA ROD Approved |
John Halverson (ADEC Environmental Project Manager Federal Facilities Section) signed the Record of Decision (ROD) for WACS (OT0004) at Sparrevohn LRRS. The United States Environmental Protection Agency (EPA) has been consulted consistent with the requirements of 10 U.S.C. 2705, and has chosen to defer to ADEC for regulatory oversight of OT004. ADEC agrees that successful implementation of the selected remedy (signage on the property noting the presence of PCBs in excess of ADEC cleanup levels, Base Master Plan and other land records updated to indicate PCBs remain in the soil, residential land use restrictions, implementation of USAF excavation permit system, and prior ADEC approval obtained before moving/disposing of soil which was subject to site cleanup rules) will meet state regulatory requirements.
The selected remedy for the WACS (OT004) will protect human health and the environment, and allow for continued site use. The USAF has selected Institutional Controls as the remedy for the WACS (OT004), with the following components:
- Implementation of institutional controls to identify areas of contamination and restrict
land use at the White Alice Communication System site to achieve remedial action
objectives listed on page 2-25. The institutional controls will include:
- Installation of signs warning of the presence of soil contamination exceeding ADEC residential cleanup levels;
- Restriction on residential land use;
- Restrictions on digging that could disturb soil acting as a cover to PCB-contaminated areas; and
- Requirement for all operators to utilize USAF construction review and dig permit systems or similar systems to prevent uses or activities inconsistent with the remedial action objectives.
- Notations regarding residual contamination and land use restrictions will be recorded in
the appropriate Sparrevohn LRRS land records, including the Base Master Plan. As part of the update to the Base Master Plan, the USAF will produce maps showing locations of residual contamination, and will provide these maps to ADEC.
- Institutional controls will remain in effect for as long as the contaminated media exceeds
ADEC unrestricted residential use criteria. The USAF is responsible for enforcing institutional controls and the USAF will monitor the effectiveness of the institutional controls. The USAF will provide an annual report regarding institutional control monitoring to ADEC, with copies filed in the administrative record and information repository.
- The USAF will provide prompt notification to the ADEC of institutional control deficiency/failure, along with corrective measures taken. The USAF will obtain regulatory concurrence of significant changes to use and activity restrictions. The USAF will provide prior notification to ADEC for transfer of property subject to institutional controls.
Remedial Action Objectives (RAOs) define what the remedial actions should accomplish to
protect potential receptors. Consistent with EPA guidance and the NCP [40 CFR §
300.430(e)(2)(i)], these objectives consider COPCs, exposure routes and receptors, and cleanup
goals.
The overall objectives of the Sparrevohn LRRS environmental site restoration are to ensure that
conditions at each site are protective of human health and the environment, and to comply with
state and federal regulations. RAOs are the specific goals that the remedial action is designed to achieve. OT004 RAOs have been developed which meet the requirements of both CERCLA and
State of Alaska Contaminated Site Regulations.
The RAOs for the WACS (OT004) are:
? To prevent human exposure to PCB-contaminated soil exceeding 1 mg/Kg;
? To prevent migration of PCBs;
? To protect human health and the environment; and
? To comply with applicable Federal, State, and local laws and regulations.
Following completion of the Selected Remedy, cleanup will be considered complete with
institutional controls under CERCLA, 18 AAC 75, and ADEC Site Closure and Policy Procedures (ADEC 2008a). Cleanup levels for the site are provided in Table 2-13. However, in accordance with 18 AAC 75.325(i), the landowner or its operator shall obtain approval from ADEC prior to disposing of or transporting soil from the site.
Pursuant to CERCLA §121(c) and NCP §300.430(f)(5)(iii)(C), because the selected remedy will
result in hazardous substances, pollutants, or contaminants remaining onsite above levels that
allow for unlimited use and unrestricted exposure, a statutory review will be required at least
every five years after initiation of the remedial action to verify that the remedy is protective of human health and the environment. |
John Halverson |
9/18/2009 |
Institutional Control Record Established |
The selected remedy for the WACS (OT004) will protect human health and the environment, and allow for continued site use. The USAF has selected Institutional Controls as the remedy for the WACS (OT004), with the following components:
- Implementation of institutional controls to identify areas of contamination and restrict
land use at the White Alice Communication System site to achieve remedial action objectives listed on page 2-25. The institutional controls will include:
- Installation of signs warning of the presence of soil contamination exceeding ADEC residential cleanup levels;
- Restriction on residential land use;
- Restrictions on digging that could disturb soil acting as a cover to PCB-contaminated areas; and
- Requirement for all operators to utilize USAF construction review and dig permit systems or similar systems to prevent uses or activities inconsistent with the remedial action objectives.
- Notations regarding residual contamination and land use restrictions will be recorded in
the appropriate Sparrevohn LRRS land records, including the Base Master Plan. As part of the update to the Base Master Plan, the USAF will produce maps showing locations of residual contamination, and will provide these maps to ADEC.
- Institutional controls will remain in effect for as long as the contaminated media exceeds
ADEC unrestricted residential use criteria. The USAF is responsible for enforcing institutional controls and the USAF will monitor the effectiveness of the institutional controls. The USAF will provide an annual report regarding institutional control monitoring to ADEC, with copies filed in the administrative record and information repository.
- The USAF will provide prompt notification to the ADEC of institutional control deficiency/failure, along with corrective measures taken. The USAF will obtain regulatory concurrence of significant changes to use and activity restrictions. The USAF will provide prior notification to ADEC for transfer of property subject to institutional controls. |
Louis Howard |
9/18/2009 |
Cleanup Complete Determination Issued |
John Halverson signed the ROD which determined no further remedial action is necessary at OT004. It is assumed that the site will be maintained for industrial use, and that ownership and site access will continue to be controlled by the USAF for the foreseeable future. Currently, there are no plans to remove PCB-contaminated soil. As a result, the USAF will maintain institutional controls (the selected remedy) at OT004 for as long as PCB concentrations in soil remain greater than 1 mg/Kg.
The selected remedy for the WACS (OT004) is protective of human health and the environment,
by limiting potential contact with, and migration of, contaminated media. The selected remedy
for the site complies with promulgated requirements that are applicable or relevant and
appropriate to the remedial action, and is cost-effective. The selected remedy represents the maximum extent to which permanent solutions can be used in a practicable manner at the site. It provides the best balance or trade-offs in terms of balancing criteria.
|
John Halverson |
2/23/2010 |
Update or Other Action |
Environmental Site Summary Report received. The purpose of this project was to implement the selected remedies approved in each Record of Decision (ROD) for the following ERP sites:
Transmitter Pad / Opportunity Site (SD003)
White Alice Communications System (OT004)
Spill/Leak No.1 and Lower Camp Facility (ST005)
Spill/Leak No. 2 (ST006)
Waste Accumulation Area (SS007)
Specific objectives of the October 2009 field event included:
Installation of warning signs at five ERP sites as part of implementation of Institutional Controls;
Initiation of long-term monitoring of groundwater and surface water to evaluate natural attenuation of dissolved phase petroleum hydrocarbons and chlorinated compounds at Spill/Leak No. 1 and Lower Camp Facility (ST005); and
Survey boundaries of Institutional Controls at each ERP site.
3.3 Warning Sign Installation: Signs were installed at ERP sites ST005, SD003 (Transmitter Pad only), OT004, ST006, and SS007 to alert site workers and visitors that contaminants are present at concentrations exceeding State cleanup levels as per 18 AAC 75. Signs were installed
in the general locations shown in the QPP; however, final locations were determined in the field. Sign locations were discussed with and approved by the facility operations manager to ensure that the signs would not interfere with facility operations. Each sign location was surveyed and coordinates are provided in Appendix C. The sign locations for each site are shown on Figure 3-2.
Signs were constructed of 3-feet by 5-feet aluminum panels with reflective print. Each sign was affixed to a galvanized steel post set in concrete. The concrete supports were built by digging a hole approximately 3-feet deep, pouring concrete, and setting a receiver post. The metal sign posts were attached to the receiver posts and secured with appropriate hardware. Sign height ranged from approximately 8-feet in the Lower Camp Facility to 5-feet at the Upper Camp sites. Sign height varied to accommodate site activities and climate conditions.
3.4 Land Surveying: F. Robert Bell and Associates, an Alaska-licensed surveyor, was contracted to survey the boundaries of the Institutional Control areas at each ERP site. Survey activities were completed October 9 to 11, 2009. The corners of Institutional Control areas were staked
by HCG personnel prior to surveying. In addition to the Institutional Control areas, the
survey crew also surveyed the locations of each sign after installation. Surveying was completed in Alaska State Plane Zone 5, NAD 83 coordinate system, and NAVD 88 (Geoid 06) vertical datum. Surveyed Institutional control boundaries for each ERP site are shown on Figures 3-3 through 3-8 and all survey data is provided in Appendix C. |
Louis Howard |
12/2/2011 |
Institutional Control Compliance Review |
Draft Sparrevohn LRRS Annual Institutional Controls Inspection Summary Report Contract No. FA8903-10-D-8593, Project No: VYLK20118888 received. This Annual Institutional Controls Inspection Summary Report presents the results of field activities conducted September 6 and September 7, 2011 at the Sparrevohn Long Range Radar Station (LRRS), Alaska. Visual inspections were conducted at the Transmitter Pad I Opportunity Site (SD003), White Alice Communications System (OT004), Spill/Leak No. 1 and Lower Camp Facility (ST005), Spill/Leak No. 2 (ST006), and Waste Accumulation Area (SS007) on September 6 and September 7, 2011. The purpose of these inspections is to verify the effectiveness of Institutional Controls (ICs) as the selected remedies approved in each site’s Record of Decision (ROD).
OT004
One CERCLA hazardous substance, PCBs in soil, was identified as a COC at OT004. No other COCs were identified at OT004 under 18 AAC 75. PCBs were addressed in the “Final Record of Decision WACS (OT004) Sparrevohn LRRS, Alaska, May 2009” ICs were selected as the remedy in accordance with CERCLA as amended by SARA, and the NCP to prevent exposure and alert site workers and residents to hazardous substances in the area . The ICs at OT004 are the restriction of land use to commercial and industrial activities which include digging that could disturb soil acting as a cover to PCB contaminated areas. Existing ICs require all operators to utilize USAF construction review and dig permit systems or similar systems to prevent uses or activities inconsistent with the remedial action objectives. In October 2009, a survey was performed of the IC area boundary. Additionally, a sign was installed to alert site workers and visitors that contaminants are present at concentrations exceeding State cleanup levels as per 18 AAC 75.
Summary and Recommendations
OT004
During the inspection in September 2011, there were no indications of a change in land use in this area. No residential construction had occurred at the site. Signage remains intact and legible at the OT004 Transmitter Pad. There were no indications of excavation activities, and no excavation notifications had been filed the previous year for this site. Minor debris has been documented on the ground surface consisting of scrap metal. Therefore, ICs appear to be functioning as intended to protect human receptors from exposure
|
Louis Howard |
10/4/2012 |
Document, Report, or Work plan Review - other |
The Alaska Department of Environmental Conservation (ADEC) received the Draft Sparrevohn LRRS Annual Institutional Controls Inspection Summary Report dated September 27, 2012 for review and comment on September 28, 2012. The document applies to the following ADEC CS Database Hazard IDs: 689 (ST005), 688 (ST006), 697 (SS007), 693 (SD003), and 694 (OT004) at Sparrevohn Long Range Radar site. ADEC has reviewed the document and concurs with the summary and recommendations in the report. The document may be f111alized. |
Louis Howard |
11/5/2012 |
Update or Other Action |
Final ICs Inspection Summary Report received. The WACs Site (OT004) is located midway between Lower Camp and Upper Camp, at elevation 2,650 feet. OT004 had high power requirements and used many transformers, capacitors, and switchgear, most of which used insulating oil containing PCB. Power was supplied to the OT004 facility by two, 140-kw diesel generators. Diesel fuel was stored in two 10,000-gallon aboveground storage tanks. In addition, each 60-foot antenna had an aboveground 1,600-gallon fuel storage tank located behind the antenna. These tanks were supplied by pipeline from the two large storage tanks.
When the buildings were demolished, the majority of debris was buried onsite and as a result, the original ground surface is no longer visible. The WACS had high power requirements, and most electrical equipment used at the time contained PCB-laden insulating oil. During the historical operation of the facility, it was not an uncommon practice to dispose of waste oil on the ground outside the buildings.
One CERCLA hazardous substance, PCBs in soil, was identified as a COC at OT004. No other COCs were identified at OT004 under 18 AAC 75. PCBs were addressed in the “Final Record of Decision WACS (OT004) Sparrevohn LRRS, Alaska, May 2009” ICs were selected as the remedy in accordance with CERCLA as amended by SARA, and the NCP to prevent exposure and alert site workers and residents to hazardous substances in the area. The ICs at OT004 are the restriction of land use to commercial and industrial activities which include digging that could disturb soil acting as a cover to PCB contaminated areas. Existing ICs require all operators to utilize USAF construction review and dig permit systems or similar systems to prevent uses or activities inconsistent with the remedial action objectives.
During the July 17, 2012 inspection, there were no indications of a change in land use in this area. No residential construction had occurred at the site. Signage remains intact and legible at the OT004 Transmitter Pad. There were no indications of excavation activities, and no excavation notifications had been filed the previous year for this site. Minor debris has been documented on the ground surface consisting of scrap metal. Therefore, ICs appear to be functioning as intended to protect human receptors from exposure to soil. At this time, no additional actions are necessary to improve and/or correct ICs at OT004. |
Louis Howard |
11/26/2012 |
Document, Report, or Work plan Review - other |
Staff reviewed and approved the final Annual ICs inspection report which included SD003 OT004, ST005, ST006 snd SS007. |
Louis Howard |
7/11/2013 |
Update or Other Action |
Draft ICs report receieved for ST005, SS007, OT004, SD003, & ST006.
This Annual Institutional Controls Inspection Summary Report presents the results of field activities conducted June 25, 2013 at the Sparrevohn Long Range Radar Station (LRRS), Alaska. Visual inspections were conducted at the following sites in the order inspected: Spill/Leak No. 1 and Lower Camp Facility (ST005), Waste Accumulation Area (SS007), White Alice Communications System (OT004), Transmitter Pad Opportunity Site (SD003) and Spill/Leak No. 2 (ST006). The purpose of these site inspections was to verify the effectiveness of Institutional Controls (ICs) as per the selected remedies approved in each site’s Record of Decision (ROD).
During the 25 June 2013 inspection, there were no indications of a change in land use in this area. No residential construction had occurred at the site. Signage remains intact and legible at the OT004 Transmitter Pad. There were no indications of excavation activities, and no excavation notifications had been filed the previous year for this site.
Vegetation appears to have increased in coverage from the previous inspection. Some debris was seen on the ground surface consisting of scrap metal, rebar and construction material. None of the debris appeared to pose a threat to human health or the integrity of the IC. Additionally, several survey markers were located that were labeled “Institutional Controls” which marked the extents of the IC. Any such markers were photo logged and field surveyed to collect GPS coordinates. Therefore, ICs appear to be functioning as intended to protect human receptors from exposure to soil. At this time, no additional actions are necessary to improve and/or correct ICs at OT004. |
Louis Howard |
1/10/2014 |
Update or Other Action |
First 5Yr Review draft received for OT004, SD003, SS007, ST005 & ST006. The selected remedy for ERP Sites OT004, SD003, SS007, ST005, and ST006 is institutional controls (ICs) for all sites. The RODs for ERP Sites OT004, SD003, SS007, ST005, and ST006 require that site inspections
and inspection reports should be completed annually; however, only two inspections have been documented since the 2009 RODs were finalized.
This first five-year report concludes that the remedial actions at ERP Sites OT004, SD003, SS007, ST005, and ST006 are protective of human health in the short-term because all known soil exposure pathways have been restricted, the remedial action objectives have been met, and there is no indication of current exposure. For the remedies to remain protective in the long term, a site-specific operation and maintenance manual should be prepared to provide the methods and reporting requirements for annual inspections, and site inspections should be conducted and documented annually.
In addition, the 2009 Draft Quality Program Plan should be reviewed and revised as needed prior to the next groundwater sampling event at the site, which should occur by October 2014. Implementation of these requirements and other routine O&M activities, such as review and approval of the 2009 Draft Quality Program Plan in anticipation of the next groundwater sampling event (scheduled for 2014), will ensure continued protectiveness.
During the June 25, 2013, site inspection, there were no indications of a change in land use in this area. No residential construction had occurred at the site. Signage remains intact and legible at the Site OT004 Transmitter Pad. There were no indications of excavation activities, and no excavation notifications had been filed the previous year for this site. Vegetation appears to have increased in coverage from the previous inspection in and around the IC. Some debris was seen on the ground surface consisting of scrap metal, rebar and construction material.
None of the debris appeared to pose a threat to human health or the integrity of the IC. Additionally, several survey markers were located that were labeled “Institutional Controls” which marked the extents of the IC. During the June 25, 2013, site inspection, the markers were photographically logged and field surveyed to collect global positioning system (GPS) coordinates (BEM, 2013).
The site inspection report concluded that ICs appear to be functioning as intended to protect human receptors from exposure to soil. The site inspection report recommended that no additional actions are necessary to improve and/or correct ICs at Site OT004 (BEM, 2013). |
Louis Howard |
9/30/2014 |
Update or Other Action |
Draft ICs report received for review & comment.
The report presents the results of field activities conducted 17 through 19 June 2014 at the Sparrevohn Long Range Radar Station (LRRS), Alaska. Visual inspections were conducted at the following sites: Transmitter Pad Opportunity Site (SD003), White Alice Communications System (OT004), Spill/Leak No. 1 & Lower Camp Facility (ST005), Spill/Leak No. 2 (ST006), & Waste Accumulation Area (SS007). The purpose of the completed site inspections & GW monitoring was to verify that the selected remedies continue to remain protective of preventing potential exposure to impacted media, as indicated in each site’s specific 2009 Record of Decision.
SUMMARY & RECOMMENDATIONS
SD003
During the inspection, there were no indications of a change in land use in this area. No residential construction had occurred at the site. Signage remains intact & legible. There were no indications of excavation activities, & no excavation notifications had been filed the previous year for this site. Vegetation was present across the site at approximately 25 to 30 %. Minimal debris was observed on the ground surface consisting of scrap metal & weathered lumber materials. It was deemed that the debris posed no threat to human health or the integrity of the IC. Therefore, ICs appear to be functioning as intended to protect human receptors from exposure to contaminated soil. At this time, no additional actions are necessary to improve &/or correct ICs.
OT004
During the inspection, there were no indications of a change in land use in this area. No residential construction had occurred at the site. Signage remains intact & legible. There were no indications of excavation activities, & no excavation notifications had been filed the previous year for this site. Vegetation was present across the site at approximately 40 to 50 %. Some debris was seen on the ground surface consisting of scrap metal, rebar & construction material. None of the debris appeared to pose a threat to human health or the integrity of the IC. Therefore, ICs appear to be functioning as intended to protect human receptors from exposure to soil. At this time, no additional actions are necessary to improve &/or correct ICs.
ST005
This section provides the GW monitoring results associated with the 2014 LTM field effort conducted at ST005. The analytical results for the GW samples are summarized in Tables 3-1. All sample results were below their corresponding ADEC Table C GW Cleanup Level, therefore, only those analytes with at least one result above their corresponding lab detection limit are included in the table. ADEC GW cleanup levels for each analyte are also included for reference. The complete Lab Report is included in Appendix D.
During the inspection, there were no indications of a change in land use in this area. No residential construction had occurred at the site. The site & adjacent area appeared to be undisturbed. Vegetation was present across the site at approximately 60 %. Signage remains intact & legible. The area down-gradient of ST005 is overgrown & vegetated with brush & typical mid-elevation flora.
The slope below the tank farm is steep & shows no sign of human/animal or mechanical impacts. The drainage ditch adjacent to the Lower Camp was inspected, with no evidence of POL contamination or anomalies of any type observed. There were no indications of excavation activities, & no excavation notifications had been filed the previous year for this site. Therefore, ICs appear to be functioning as intended to protect human receptors from exposure to soil & GW. At this time, no additional actions are necessary to improve &/or correct ICs.
ST006
During the inspection, there were no indications of a change in land use in this area. No residential construction had occurred at the site. There were no indications of excavation activities, & no excavation notifications had been filed the previous year for this site, & no debris was noted at the site or adjacent areas. Signage remains intact & legible. Vegetation was present across the site at approximately 40 to 50 %. Therefore, ICs appear to be functioning as intended to protect human receptors from exposure to soil. At this time, no additional actions are necessary to improve &/or correct ICs.
SS007
During the inspection, there were no indications of a change in land use in this area. No residential construction had occurred at the site. There were no indications of excavation activities, & no excavation notifications had been filed the previous year for this site. Signage remains intact & legible. Vegetation was present across the site at approximately 40 to 70 %. Therefore, ICs appear to be functioning as intended to protect human receptors from exposure to soil. No additional actions are necessary at this time to improve &/or correct ICs. |
Louis Howard |
10/2/2014 |
Document, Report, or Work plan Review - other |
Staff provided comments on the draft ICs and groundwater sampling report. The document is well written and ADEC has no significant comments on it. One minor editorial comment: The “raw” analytical data, e.g. bench sheets, chromatograms, calibration data, etc., are not required submittals, however, must be retained on file by the laboratory for at least ten [10] years after the analysis date (“Environmental Laboratory Data and Quality Assurance Requirements” Technical Memorandum March 2009). Please finalize the document. |
Louis Howard |
3/18/2015 |
Institutional Control Update |
One of several sites with Land Use Controls in effect (LUCMP)in 2015 Pacific Air Forces Regional Support Center Installations, JBER, AK, March 13, 2015.
This LUCMP identifies the LUCs in place for ERP (or Defense Environmental Restoration Account [DERA]-funded) sites at PRSC installations in Alaska, JA, & WIA & documents the responsibilities & procedures for maintaining, managing, tracking, enforcing, & when appropriate, modifying or terminating the LUCs.
Note that the current version of this LUCMP covers the following sites:
• ERP sites & landfills determined to contain hazardous waste, waste assumed hazardous, or nonhazardous waste
• Sites regulated by the U.S. Environmental Protection Agency (EPA), Alaska Department of Environmental Conservation (ADEC), & the ERP
• ERP sites for which information regarding the contamination & LUC status was readily available during the development of this LUCMP
• Landfill sites managed by PRSC determined to contain hazardous waste, waste assumed hazardous, or nonhazardous waste that are not regulated by the ERP
“CZ” is the abbreviation for the Environmental Engineering Directorate of AFCEC, & “CZOP” is the abbreviation for Environmental Engineering Directorate, Operations Division, Pacific.
LUCs on active installations are not recorded in deeds. The USAF uses existing land use planning & management systems to track & manage LUCs at its installations. These systems typically involve including LUC boundaries & attributes into geographic information system (GIS) layers, incorporating LUCs into the installation master plan, & filing LUCs with the installation offices that are responsible for managing the buildings & grounds, utility systems, & construction.
Once LUCs are implemented, they must be maintained as long as site conditions exist that prevent unrestricted land use &/or unlimited exposure. LUCs can be maintained using a variety of separate & collective processes, including the site approval process, LUC boundary markers, periodic site inspections, environmental self-audits, training, internal notices, & 5-year reviews. If it appears a LUC is being violated, then appropriate installation officials should be notified immediately. Furthermore, regulatory agencies may be notified of the violation as applicable & as detailed in DDs, RODs, signed action memoranda, or ADEC letters of concurrence. The officials should take steps to ensure the integrity of the LUC is restored & the necessary corrective action & notifications are made. In addition, if the type of land use at an ERP site changes, the LUCs for the site should be reviewed to ensure that the new land use is compatible with the LUCs. If it is not, then the site remedy & DDs may need to be revised before implementing a land use change.
In addition to ICs established as part of LUCs of the ERP for landfill sites with LUCs in effect, both ERP landfill & non-ERP landfill sites in Alaska under the management of PRSC must also comply with regulations set forth by the ADEC solid waste regulations in 18 AAC 60. Furthermore, landfill sites under the management of PRSC but not categorized as an ERP site must also comply with ADEC 18 AAC 60.
Landfills are defined in 18 AAC 60 as “an area of land, or an excavation in which solid wastes are placed for permanent disposal, & that is not an application site, injection well, reserve pit, or waste pile.” This definition applies to most PRSC ERP & non-ERP sites in Alaska designated as landfills, dumps, or caches. Small PRSC ERP & non-ERP landfill sites at remote installations, such as the long-range radar stations, are regulated as Class III landfills as defined by ADEC.
General requirements to manage landfills in place are established by ADEC. However, alternative criteria can & often are adopted through negotiation with ADEC (see 18 AAC 60.900, Waivers).
Sparrevohn LRRS WACS OT004
Sparrevohn LRRS Transmitter Pad SD003
Sparrevohn LRRS WAA SS007
Sparrevohn LRRS Spill/Leak No.1 ST005
Sparrevohn LRRS Spill/Leak No. 2 ST006
LUC_RESTRICTION Institutional controls will include:
* Installation of signs warning of the presence of soil contamination exceeding ADEC residential cleanup levels;
* Restriction on residential land use;
* Restrictions on digging that could disturb soil acting as a cover to PCB contaminated areas; and
* Requirement for all operators to utilize USAF construction review and dig permit systems or similar systems to prevent uses or activities inconsistent with the remedial action objectives. |
Louis Howard |
8/18/2015 |
Document, Report, or Work plan Review - other |
Staff reviewed and approved the draft ICs summary report as a final version. Sites included OT004, SD003, SS007, ST005 and ST006. |
Louis Howard |
1/20/2017 |
Update or Other Action |
Staff received a summary report of the 2016 Environmental Long-term mgt. program at Sparrevohn. The annual visual inspections of Institutional Controls (IC) were conducted on 23 September 2016 at the following five sites: Transmitter Pad and Opportunity Site (SD003), White Alice Communications System (WACS) Site (OT004), Spill/Leak No. 1 and Lower Camp Facility (ST005), Spill/Leak No. 2 (ST006), and Waste Accumulation Area (SS007). The purpose of these site inspections was to verify the effectiveness of the ICs in accordance with the selected remedies approved in each site’s Record of Decision (ROD).
At this time, no additional actions are necessary to improve and/or correct ICs at OT004.
Continued annual inspections are recommended in accordance with the ROD (USAF 2009b). The next five-year review will evaluate revising the frequency of these annual IC inspections to once every five years, as referenced in the ROD.
See site file for additional information. |
Louis Howard |
2/2/2017 |
Document, Report, or Work plan Review - other |
Staff reviewed and approved the Draft Remedial Action Operations, Land Use/Institutional Control LUC Summary Report Sparrevohn LRRS, Alaska dated January 2017. |
Louis Howard |
1/17/2018 |
Document, Report, or Work plan Review - other |
Draft RAO LUC/ICs report received for review and comment.
ADEC concurs with the statements that ICs appear to be functioning as intended and annual inspections be conducted in accordance with the ROD. The second Five-Year Review (2019) will evaluate revising the frequency of the inspection as referenced in the ROD. |
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 Sparrevohn Long Range Radar Site. 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 |
3/28/2019 |
CERCLA ROD Periodic Review |
2nd 5YR for OT004, SD003, SS007, ST005 and ST006 approved by ADEC. 3rd 5YR is due approximately January 2024. |
Louis Howard |
2/5/2020 |
Document, Report, or Work plan Review - other |
Staff provided comments on the draft preliminary assessment report for AFFF. Main comments were regarding the regulatory authority of ADEC to develop site specific PFAS contaminant cleanup levels in soil and water that are not listed in Table B1 and Table C per 18 AAC 75.340(g). Additional comments were made on the ability of PFAS contamination to travel hundreds, thousands of feet from the point of release/discharge/spill at a source area.
|
Louis Howard |
5/5/2021 |
Document, Report, or Work plan Review - other |
Staff provided comments on the Draft 2021 Remedial Action-Operation and Long-Term Management Work Plan, Sparrevohn Long Range Radar Station, Sites OT004, SD003, SS007, ST005, and ST006, April 2021. The document was received on April 15, 2021. The Work Plan describes the approach and procedures for site-specific long-term management and remedial action-operation activities at Sparrevohn long-range radar site, including a single groundwater sampling event at site ST005. The WP covers work being performed over a 5-year period and will be reviewed on an annual basis between field seasons. |
Axl LeVan |
5/13/2021 |
Document, Report, or Work plan Review - other |
Staff provided comments on the Draft 2020 Remedial Action-Operation Institutional Control/Land Use Control Report, Sparrevohn Long Range Radar Station, Sites SD003, OT004, ST005, ST006, and SS007, April 2021. The report was received April 13, 2021 and presents the results of the 2020 Environmental Long-Term Management (LTM) program at the Sparrevohn Long Range Radar Site. The 2020 LTM activities included the annual inspection of institutional controls/land use controls implemented at sites SD003, OT004, ST005, ST006, and SS007. |
Axl LeVan |
7/30/2021 |
Document, Report, or Work plan Review - other |
DEC approved the Final 2021 Remedial Action-Operation and Long-Term Management Work Plan, Sparrevohn Long Range Radar Station, Sites OT004, SD003, SS007, ST005, and ST006, July 2021. The document was received on July 22, 2021. The Work Plan describes the approach and procedures for site-specific long-term management and remedial action-operation activities at Sparrevohn long-range radar site, including a single groundwater sampling event at site ST005. The WP covers work being performed over a 5-year period and will be reviewed on an annual basis between field seasons. |
Axl LeVan |
10/6/2021 |
Document, Report, or Work plan Review - other |
Staff approved the Final 2020 Remedial Action-Operation Institutional Control/Land Use Control Report, Sparrevohn Long Range Radar Station, Sites SD003, OT004, ST005, ST006, and SS007, August 2021. The report was received October 5, 2021 and presents the results of the 2020 Environmental Long-Term Management (LTM) program at the Sparrevohn Long Range Radar Site. The 2020 LTM activities included the annual inspection of institutional controls/land use controls implemented at sites SD003, OT004, ST005, ST006, and SS007. |
Axl LeVan |
2/11/2022 |
Document, Report, or Work plan Review - other |
Staff provided comments on the Draft-Final 2021 Long-Term Management Report, Sparrevohn Long Range Radar Station, January 2021. The report was received February 10, 2021 and presents the results of the 2021 Environmental Long-Term Management (LTM) program at the Sparrevohn Long Range Radar Site. The 2021 LTM activities included the annual inspection of institutional controls/land use controls implemented at sites SD003, OT004, ST005, ST006, and SS007. |
Axl LeVan |
5/17/2022 |
Document, Report, or Work plan Review - other |
The Alaska Department of Environmental Conservation (DEC) Contaminated Sites Program reviewed and approved the "Final 2021 Long-Term Management Report, Sparrevohn Long Range Radar Station, Alaska, May 2022" that was received on May 4, 2022. The report presents the work performed during long-term management activities at Sparrevohn Long Range Radar Site under the 611 Civil Engineer Squadron North Group Optimized Remediation Contract during the 2022 field season. The work was performed on September 13, 2021 and included institutional control and land use control inspections. No groundwater sampling was performed during this event. |
Axl LeVan |
9/13/2022 |
CERCLA SI |
On 9/13/2022 ADEC approved the FINAL Quality Assurance Project Plan, Off-Base Drinking Water Site Inspections and Miscellaneous Tasks, Three U.S. AF Long Range Radar Stations, Alaska, Dated September 2022. The objective of the Quality Assurance Project Plan (QAPP) is to provide a response action for per- and polyfluoroalkyl substances (PFAS)-impacted drinking water for areas surrounding three remote U.S. Air Force (USAF) Installations, Cape Romanzof Long Range Radar Station (LRRS), Indian Mountain LRRS and Sparrevohn LRRS. The project goals are to determine if off-site migration of polyfluoroalkyl substances (PFAS) has potentially impacted off-site groundwater and surface water used as drinking water used by residences or commercial businesses, and if a response action will be needed and required for applicable PFAS impacted drinking water sources. The USEPA Lifetime Health Advisory levels for perfluorooctane sulfonate (PFOS) and perfluorooctanoic acid (PFOA), and the sum of the concentrations (PFOS+PFOA) of 70 nanograms per liter (ng/L) will be used as the action level for drinking water sources (both groundwater and surface water). |
Axl LeVan |
1/25/2023 |
Document, Report, or Work plan Review - other |
The Alaska Department of Environmental Conservation Contaminated Sites Program received a copy of "Draft-Final 2022 Long-Term Management Report, Sparrevohn Long Range Radar Station, Alaska, December 2022" on January 11, 2022. The report presents the work performed during long-term management activities at Sparrevohn Long Range Radar Site. The work was performed on August 9, 2022 and included both institutional controls and land use control inspections. DEC provided comments on January 25, 2023 |
Axl LeVan |
3/29/2023 |
Document, Report, or Work plan Review - other |
The Alaska Department of Environmental Conservation (DEC) Contaminated Sites Program reviewed and approved the "Final 2022 Long-Term Management Report, Sparrevohn Long Range Radar Station, Alaska, March 2023" on March 29, 2023. The report presents the work performed during long-term management activities at Sparrevohn Long Range Radar Site. The work was performed on August 9, 2022 and included both institutional controls and land use control inspections. |
Axl LeVan |
5/16/2023 |
CERCLA SI |
DEC reviewed and approved the "Final Site Inspection and No Further Response Action Planned Report for Per and Polyfluoroalkyl Substances at Cape Romanzof Long Range Radar Station, Alaska, May 2023". The report recommends a Remedial Investigation (RI) be performed at the General Lower Camp area, FTA #1 – Lower Camp, and Non-FTA #1 – Soil Stockpiles at lower camp based on exceedances of PFAS compounds. The report recommended No Further Response Action Planned (NFRAP) at FTA #2 – Upper Camp based on all results indicated concentrations of non-detect. DEC agrees with the recommendations for NFRAP or RI for all sites. |
Axl LeVan |
8/26/2024 |
Document, Report, or Work plan Review - other |
DEC reviews and provided comments on the "Draft Third CERCLA Five-Year Review for Sites OT004, SD003, SS007, ST005, and ST006 at Sparrevohn LRRS Alaska, July 2024." This Five-Year Review (FYR) exists to evaluate the implementation and performance of a remedy for the site to determine if the remedy is and will continue to be protective of human health and the environment. The methods, findings, and conclusions of reviews are documented in FYR. |
Axl LeVan |
8/28/2024 |
Document, Report, or Work plan Review - other |
DEC reviewed and approved the "Final 2023 Long-Term Management Report, Sparrevohn LRRS Alaska, August 2024" based on updates from USAF. Field activities included institutional control (IC)/land use control (LUC) inspections at all five sites, groundwater monitoring at ST005, monitoring well inspections, LUC
and sign replacement. |
Axl LeVan |
10/24/2024 |
CERCLA ROD Periodic Review |
DEC reviewed and approved the "Draft-Final Third CERCLA Five-Year Review for Sites OT004, SD003, SS007, ST005, and ST006 at Sparrevohn LRRS Alaska, October 2024" This Five Year Review (FYR) exists to evaluate the implementation and performance of a remedy for the
site to determine if the remedy is and will continue to be protective of human health and the
environment. |
Axl LeVan |
4/16/2025 |
Document, Report, or Work plan Review - other |
DEC reviewed and approved the "Final 2024 Long Term Management Report, Sparrevohn LRRS, Alaska, April 2025." The report presented the long term management activities performed at sites OT004, SD003, SS007, ST005, and ST006. Field activities included groundwater monitoring at ST005. |
Axl LeVan |