| Action Date |
Action |
Description |
DEC Staff |
| 12/11/1985 |
Update or Other Action |
SS12 is the location of fuel Spill Nos. 2 and 3, located west-southwest of the Composite
Facility. Two distinct diesel fuel spills were identified in 1985. Phase 1 Preliminary Assessment identified site as a source area. The Air Force conducted the PA/SI effort for several northern Alaska LRRS installations, including the Kotzebue LRRS. This was the initial source discoyery effort at the start of the Air Force IRP. The PA effort entailed a review of installation records, interviews with past and present employees, an analysis of facility use, and a site visit to observe actual site conditions. The resulting report incorporated the information gathered and evaluated potential human and ecological risks, such as contaminant toxicity and persistence, migration pathways, and sensitive receptor routes.
The ES report identified 13 potential source areas and evaluated each for potential risk factors. Based on the evaluation, nine were recommended for further investigation under the IRP.
Spill No. 2 reportedly occurred in 1979-1980 when the day tank behind the power plant was overfilled; and Spill No. 3 reportedly resulted from a leak in the fuel line between a 50,000-gallon tank and the steam boiler day tank. Spill No. 3 was first observed in 1984 during an ADEC site inspection. Approximately 4,000 gallons of diesel from Spill No. 3 were collected by pumping from recovery trenches, and the fuel line was repaired. Absorbent material was used to assist in the cleanup for both spills.
Prior to 1970, June Creek was used by the Air Force Station for a drinking water supply, and after that Grom Lake was used (J.R. Williams and D.A. Moms, U.S. Geological Survey, written commun., 1974). |
Louis Howard |
| 8/24/1987 |
Site Visit |
Long Range Radar Site (LRRS) Site Visit notes August 24-27, 1987 Draft copy. Sites visited include a large fuel spill site (downslope from the main station complex), a waste accumulation area, the diesel fuel storage/power plant area, a fuel spill site at the White Alice complex, and the areas surrounding the main building doors at the White Alice site. The barracks area, power plant area, and White Alice spill site were not identified in the Phase I documents (Engineering Science Phase I Report. 1985).
Large Fuel Spill site: The Phase I reports describe 4,000 gallon diesel fuel spill originating at the power plant fuel tank, which is adjacent to the radome on the south side. The filed team observed what they thought were the effects of more than one spill, and may have been the effects of two or three large spills of the results of many years of minor spills. The trajectories of three large spills were plainly visible, marked by dead and stressed vegetation. If these paths were not the result of three spills, but rather three arms of one spill, then the spill volume was considerably larger than reported. The spill trajectories (marked by dead and stressed vegetation) reached all the way down to the beach (300-400 yards).
A strong diesel odor was discernible in the soils all along this path. About 100 feet downslope of the source, there was diesel visible as blackish staining in the margins of the drainage channel on the north end of the spill site. The area of the spill(s) was roughly 1,200 feet EW and 400 feet NS, in a generally isosceles triangular shape, with the large end at the source. Within this area, about 30 to 40 percent of the land was contaminated, for a total contaminated area of about 3.3 to 4.4 acres. |
Louis Howard |
| 5/31/1988 |
Update or Other Action |
IRP remedial investigation/feasability (RI/FS) Stage I Final Workplan: This document includes a site assessment for observing any evidence of contamination, determining the hydrogeologic setting, and defining the work plan and approach to be used in accomplishing the field work effort. Field work will take place in the summer of 1988 and will be followed by development of general response actions that may be employed for identified contamination.
Large Fuel Spill (Phase I Spill/Leak No. 3, KOT-1) Description - A large fuel spill encompasses a total area of approximately 12 acres, with 3 to 4 acres visibly impacted by the spill. The spill is described in the Phase I report and the 1987 reconnaissance report.
Setting - The fill is on sloping ground between the power plant fuel tank and the beach, approximately 300 to 400 yards away. The originally uniform slope was benched in places to collect part of the spilled fuel. Fuel is visible in places at the surface.
Recommended Action - The purpose of this action is to evaluate the effectiveness of low pressure flooding in collecting remaining liquid fuel. For this purpose, a pilot-scale test of this technique will be implemented in a small area of the large fuel spill. Sampling and contamination mapping will be conducted prior to contamination removal by flooding. Sampling to determine the removal effectiveness will additionally be conducted during and after the pilot testing.
Low pressure flooding of vegetated surfaces during thawed periods has proven successful in mobilization of considerable amounts of spilled product. Residual amounts of contaminant will, however, remain as surface coatings and bound by capillary forces. The degree to which material can be removed is dependent on factors including viscosity, specific gravity, surface tension and degree of weathering of the spilled fuel, and the surface configuration and near-surface soil types. Other clean-up measures may be needed later. The technique will require collection points such as excavated pits for fluid recovery, separation of fuel and water, and removal and disposal of the recovered fuel. Water for low pressure flooding will either be pumped to the contaminated areas through hoses or piping, or will be brought by tank truck. |
Louis Howard |
| 12/12/1988 |
Update or Other Action |
In 1988, a Stage 1 Remedial Investigation Feasibility Study was conducted to assess past hazardous materials disposal and spill sites at Kotzebue LRRS, and to develop remedial actions for sites thought to pose a threat to human health and welfare or to the environment. Twelve (12) sites were initially identified for investigation, two sites were excluded from investigation based on a lack of evidence regarding contamination and environmental stress.
The work included soil/sediment sampling at all sites, surface water sampling at SS07 Lake, a soil gas survey at SS12-Spills No. 2 and 3 sites, water flooding pilot testing at SS12 Spill No. 3 site, and aeration of soils at SS11 Fuel Spill Site. Analytical results indicate that total petroleum hydrocarbons (TPH) constitute the primary soil contamination at the facility. Additionally, PCBs, pesticides, and benzene, ethylbenzene, toluene/xylenes (BTEX) were detected in soil samples. No organic compounds were detected above lab detection limits in a surface water sample from the former water supply lake. However, the pesticide 4,4'-DDT (2.6 mg/kg *NOTE-the soil ingestion cleanup level is at 24 mg/kg NOAA SQRT Infaunal community impacts level is 50 ug/Kg), and the PCB Arochlor 1260 (3.4 mg/kg-NOTE soil cleanup level is 1 mg/kg and NOAA SQRT microtox bioassay level is 26 ug/Kg).
Soil gas survey was non-quantifiable due to extreme variability of soil moisture content within soils. The water-flooding pilot studies were conducted at SS12 Spill No. 3 site in an attempt to recover free product from contaminated soils. Study results indicate that water flooding is not a viable remedial alternative; this conclusion was based on inadequate volumes of free product at the site and the low permeability of site soils. NOTE to File: “free product” means a concentration of a hazardous substance that is present as a nonaqueous phase liquid; for purposes of this paragraph, a “nonaqueous phase liquid” is a liquid that is not dissolved in water.
The document also recommended cleanup levels developed for contaminated soils based on federal criteria and a modified California leaking underground fuel tank (LUFT) manual scoring procedure for TPH. Contaminant:TPH (ST05-Beach Tanks)-1,000 mg/kg, TPH (All other sites)-10,000 mg/kg, PCBs 1 mg/kg, Benzene 1 mg/kg, ethylbenzene 50 mg/kg, toluene 50 mg/kg, xylenes 50 mg/kg.
Despite the absence of significant health or environmental risks identified in the risk screening process, it was recommended that several sites have further remedial action based upon soil analyses indicating contamination above recommended cleanup levels: SS12-Spill No. 2 (10,700 mg/kg TPH) SS12-Spill No. 3 (99,200 mg/kg TPH), SS01-Waste Accumulation Area No. 1 (16,200 mg/kg TPH), SS09-PCB Spill (4,600 mg/kg TPH), SS10-Solvent Spill (1,460 mg/kg TPH), SS11-Fuel Spill (23,100 mg/kg TPH), and ST05-Beach Tanks (5,300 mg/kg TPH) Sites.
A landfarm was constructed on a level pad (part concrete and part fill) on the east side of the installation access road directly east of the Composite facility. TPH contaminated soils and fill were excavated from the SS01-Waste Accumulation Area No. 1 (approximately 50 cy), the SS12-Spill No. 2 (approx. 100 cy), and the SS12-Spill No. 3 (approx. 350 cy) sites, and were stockpiled on 6 mil plastic within the landfarm area. Soils were spread, emulsification (Toxigon) and micronutrient agents (Medina) were applied. The landfarm was mixed weekly over the course of two field seasons (1989-1990) to promote microbial activity, and was subsequently sampled over the course of two field seasons on an intermittent basis to evaluate TPH reductions. |
Louis Howard |
| 1/30/1991 |
Update or Other Action |
Stage 2 IRP RI/FS Final Report (July 1989-Sept 1990). KOT-1 Spill No. 2 (now known as SS12 and combined with KOT-1 Spill No. 3): is located west-southwest of the power plant within the Composite Facility, where a spill reportedly occurred in 1979-80. The spill covers approximately an area 40 by 80 feet, within a diked containment area. Diesel fuel was apparently discharged through a base drain in the dike which exits to a tundra covered hillside sloping westerly towards Kotzebue Sound. This hillside is the site of KOT-1 Spill No. 3. KOT-1 Spill No. 3 consists of the area west-southwest of the Composite Facility extending to the beach at Kotzebue Sound. A diesel fuel leak occurred through a hole in a distribution line in 1984, spilling over the tundra-covered hillside and forming a subsurface hydrocarbon plume. KOT-1 Spill No. 2 commingled with this plume. Spill No. 3 has affected approximately 2 acres, including an upper area overlain by gravel fill and a lower area generally undisturbed with the exception of localized areas that were disturbed by heavy equipment during past cleanup activities.
Approximately 100 cubic yards (12 dump truck loads of approximately 8 cubic yards each) of TPH contaminated fill material were excavated from KOT-1 Spill No. 2 using the bulldozer and the front-end loader and placed on the landfarm pad. The one sample location with a TPH concentration greater than the proposed cleanup level of 10,000 mg/kg was over-excavated. The vertical limits of the excavation were advanced into silt, approximately 4 feet deep. No attempts were made to excavate all the TPH contaminated material at KOT-1 Spill No. 2 since additional lateral excavation would have required the undermining of existing and active pipes, pumps, storage tanks, security fences and roadways.
KOT-1 Spill No. 3: Approximately 350 cubic yards (44 dump truck loads) of TPH contaminated fill material were excavated from site. The lateral limits of excavation were constrained to the west by an undisturbed tundra slope and to the north and east by roadways. To the south, areas of TPH contamination greater than the proposed cleanup levels of 10,000 ppm were over-excavated.
Landfarming activities were conducted at the Jet Fuel Spill site in an attempt to aerate the soil
and enhance biodegradation of petroleum hydrocarbons in the soil. Twenty-four cubic yards of clean fill were mixed with native soils, fertilizer and emulsification agents were applied. The purpose of the soil mixing was to encourage microbial activity to break down petroleum hydrocarbons in situ. This method met with some success but was not attempted at other spill areas because it would have disturbed large areas of the tundra. |
Laura Noland |
| 7/31/1991 |
Update or Other Action |
IRP RI/FS Stage 1 Final Remedial Action Decision and Final Technical Document to Support a Remedial Action Alternative at KOT1 Spill No. 2/KOT-1 Spill No. 3, KOT-4 Waste Accumulation Area No. 1, KOT-5 Fuel Spill, KOT-5 Solvent Spill, KOT-5 PCB Spill.
WCC has concluded that the Alaska interim cleanup standard for TPH of 100 mg/kg is too stringent,and a cleanup level of 10,000mg/kg is suggested for the four TPH-contaminated sites at KotzebueAFS. The 10,000 mg/kg cleanup standard is the level recommended for diesel spills by the California Leaking Underground Fuel Tank (LUFT) guidance when the distance ii
to groundwater is greater than 100 feet and certain other conditions are met. The FS for these sites recommends the bioremediation alternative for the affected areas. For those sites comprised of fill material, excavation and on-site landfarming of the contaminated soil is recommended. For those sites characterized as undisturbed tundra, in situ enhanced biodegradation is recommended.
The recommened alternatives are excavation and on-site landfarming for sites on soil and fill: KOT-1, Spill No. 2, KOT-1 Spill No. 3 and KOT-4 Waste Accumulation Area No. 1; in-situ enhanced bioremediation for soils and native tundra: KOT-1 Spill No. 3 and KOT-5 Fuel Spill. |
Louis Howard |
| 1/2/1992 |
Update or Other Action |
Air Force (AF) response to Laura Noland’s November 26, 1991 letter on the Installation Restoration Program (IRP) document entitled "Stage I, Final No Further Action Decision and Technical Document to Support No Further Action, Kotzebue Air Force Station, July l991".
I. Waste Accumulation Area No. 2: A review of a Records Search document dated September 1985 did not yield information on the types and quantities of waste or depth of burial. Efforts are underway to attempt to determine the extent of the "clean up" which took place in 1975 and how much (if any) waste was buried in the landfill. However, we have not been able to find any additional information. Thus, we believe the Kotzebue Air Force Station site, Waste Accumulation Area No. 2/Landfill,is acceptable to the state of
Alaska as a no further action site unless additional information becomes available to indicate a substantial environmental problem exists.
2. Barracks (KOT 6): We agree the area described at the KOT-6 site is unclear. We believe the area designated(25 feet by 40 feet) is the total area of the site and the spill or stained area is but a part of the total. This 25 feet by 40 feet area is roughly the area between two wings of the barracks. The tanks in question are still in place; however, they are no longer in use. Clarification of this information and addressing the stated concerns of the ADEC will be undertaken in future studies to be conducted at the installation.
3. Supply Lake (KOT 7): ADEC's concerns regarding this site will be addressed in future studies to be conducted at the installation. These studies will concentrate on the location of possible sites which could contribute to the contaminates found in the lake sediments, as well as, more completely characterizing the lake sediments.
4. In addition to the areas covered in your letter, the Air Force is awaiting comment on the following reports. Your assistance in obtaining a timely response will greatly help us further quantify our actions at Kotzebue LRRS..
a. Stage l, Final Remedial Action Decision and Final Technical Document to Support a Remedial Action Alternative, for Kotzebue Air Force Station, Alaska, July 1991.
KOT-I Spill No. 2 KOT-I Spill No. 3 KOT-5 Fuel Spill
b. Stage 2, Final Remedial Action Decision and Final Technical Document to Support a Remedial Action Alternative, for Kotzebue Air Force Station, Alaska, July 1991.
KOT-8 Tanks |
Laura Noland |
| 1/13/1992 |
Document, Report, or Work plan Review - other |
Staff reviewed and commented on the IRP RI/FS Report, Stage 2, Kotzebue Air Force Base: KOT-8 Tanks, Landfarm, KOT- 1 Spills No. 2 & 3, and KOT-5 Fuel Spill.
KOT-1 Spill No. 2: A pilot study demonstrating in-situ enhanced bioremediation was conducted at Spill No. 2 which is characterized by petroleum hydrocarbon contaminated sand and gravel fill over tundra which was left in place after an excavation and removal action. Structures in the area restricted the removal of soils and contamination remains at the site at unknown concentrations. The lateral site boundaries of contamination have not been determined. The pilot study did not incorporate sampling or chemical analyses. Emulsifiers and nutrients were injected into three trenches. Infiltration rates at the site are very slow and the effect of this remediation technique appears negligible.
On two separate occasions, ADEC personnel observed a fuel seep which appears to originate at the Spill No. 2 site. This seep provides further indication that the contamination at this site has not been contained and that remedial efforts have not been successful. The Department recommends that the Air Force determine the extent of contamination before proceeding with WCC's recommendation that contaminated soils be excavated from surrounding structures.
KOT-3 Spill No. 3: Due to sampling difficulties at the Spill No. 3 site, which characterized by undisturbed tundra (plant tissue may be influencing TPH analysis), it is difficult to evaluate the effectiveness of the bioremediation effort. WCC did note that revegetation patterns may be an effective indicator of TPH concentrations and considerable revegetation was noted during the summer of 1990. Bioremediation at Spill No. 3 appears to be progressing well and the Department recommends that bioremediation efforts continue at this site. |
Laura Noland |
| 1/31/1992 |
Update or Other Action |
In January 1992, ADEC identified a fuel seep during a site visit. The seep appeared to
originate from the area of Spill No. 2. ADEC requested a plan for further remedial action at
the site. |
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
USEPA Office of Research and Development, Environmental Criteria and Assessment Office Cincinnati, OH Subj: Oral Reference Doses and Oral Slope Factors for JP-4, JP-5; similar to Kerosene (CAS no. 8008-20-6), Diesel Fuel (CAS No. 68334-30-5), and Gasoline (CAS No. 8006-61-9) (AVGAS) [McChord AFB (Wash Rack/Treatment)/Tacoma, WA]. From Joan S. Dollarhide Associate Director, Superfund Health Risk Techncial Support Center, Chemical Mixtures Assessment Branch TO Carol Sweeney USEPA Region X.
This memorandum is in response to your request for oral systemic and carcinogenic toxicity values for JP-4, JP-5, diesel fuel, and gasoline (AVGAS) found to contaminate soil and
groundwater at McChord AFB (Wash Rack/Treatment), Tacoma, WA. We have attempted to derive RfDs and slope factors for the above fuel mixtures. We have derived provisional RfDs for
gasoline, JP-4, JP-5 and diesel fuel; provisional cancer weight-of-evidence classifications of C for gasoline and D for JP-4, JP- 5 and diesel fuel; and a provisional slope factor (adapted from an interim Agency value) for gasoline
Based on the available evidence, unleaded gasoline can be assigned to U.S. EPA (1986) weight-of-evidence Group C: possible human carcinogen. An earlier U.S. EPA document assigned unleaded
gasoline to Group B2 as a probable human carcinogen (u.s. EPA, 1987a), but that document predates the U.S. EPA (1991d) conclusion that the male rat kidney tumors produced by gasoline
are not predictive for humans, and therefore should not contribute to the weight-of-evidence or dose-response assessment of carcinogenicity. IARC concluded that marine diesel fuel is possibly carcinogenic to humans (Group 2B), but light diesel fuels and jet fuels are not classifiable as to their carcinogenicity in humans (Group 3). |
Jennifer Roberts |
| 5/4/1993 |
Update or Other Action |
The Alaska Department of Environmental Conservation (ADEC) has not received a 1993 Field season work plan for the Kotzebue Long Range Radar Station (LRRS) Contaminated sites. Since1991, the Department has directed letters to the Air Force
(see letters-November26, 1991, December 20, 1991, January 13, 1992, and March 16, 1993) which detail the environmental problems observed and documented at the Station. These letters have requested remedial action which has not been forth coming. The Department has received complaints from Kotzebue community members regarding a dump covered near the LRRS which is located on private lands and may have been used by the Air Force. To date these concerns have not been addressed.
The following environmental problems need to be addressed at Kotzebue:
KOT-1 Spill No. 2-On two separate occasions ADEC personnel observed a fuel seep which appears to originate at the Spill No. 2 site. Product was seen weeping out of the gravel end a fuel smell was noted in 1991. This seep provides further indication that the contamination at this site has not been contained and that remedial efforts have not been successful.
The ongoing hazardous substance releases at Kotzebue LRRS represent violations of
Alaska statutes and regulations. Potential violations include:
AS 46.03.710 POLLUTION PROHIBITED. A person may not pollute or add, to the pollution of the air, land, subsurface land, or water of the state.
AS 48.03.740 OIL POLLUTION. A person may not discharge, cause to be discharged, or permit the discharge of petroleum ... into, or upon the waters of land of the state....
AS 46.04.020 REMOVAL OF OIL DISCHARGES. A person causing or permitting the discharge of oil shall immediately contain and clean up the discharge.
18 AAC 75.140 CLEANUP Immediately upon becoming aware of a discharge of a hazardous substance to the water or land of the state, persons responsible , for that discharge shall clean up and dispose of the material collected using methods for which prior approval, oral or written, has been given by the regional supervisor or his designee. The discharge must be cleaned up to the satisfaction of the regional supervisor or his designee. |
Laura Noland |
| 5/16/1994 |
Document, Report, or Work plan Review - other |
Staff reviewed and approved the Draft Final Work Plan and Draft Field Sampling Plan
Remedial Investigation/Feasibility Study Kotzebue Long Range Radar Station, Alaska dated April 1994.
The Department of Environmental Conservation has received and reviewed the above named documents which describe Remedial Investigation/Feasibility Study (RI/FS) activities planned for the summer of 1994 at Kotzebue Long Range Radar Station. The RI/FS will address six known contaminated sites and investigate ten areas of concern which were identified during 1993 site reconnaissance.
Air Force personnel and their contractor have previously met with Department staff and explained their work plan. This type of presentation greatly facilitates Department review. The Department approves of the work plans as written and looks forward to working further with the Air Force as the RI/FS proceeds at Kotzebue LRRS.
NOTE: Six Sites include: 1) Site SS02-Waste Accumulation Area No.2/Landfill; 2) Site ST05-Beach Tanks; 3) Site SS07-Lake; 4) Site SS08-Barracks Pad; 5) Site SSll-Fuel Spill; and 6) Site SS12-Spills No. 2 and 3.
Areas of concern include: AOC-1 Landfarm Landfarm Seeps, AOC-2 POL Lines, AOC-3 East Tanks, AOC-4 Power Plant Garage, AOC-5 Small Day Tanks, AOC-6 Nav Aid Bldg., AOC-7 Steel Pilings, AOC-8 White Alice Garage, AOC-9 White Alice Tanks, AOC-10 Septic Holding Tank. |
Laura Noland |
| 9/30/1994 |
Update or Other Action |
1994 Remedial Investigation-The Air Force collected 38 soil samples, four surface water samples, and two sediment samples to define the extent of fuel contamination noted by ADEC. All samples were analyzed for DRO, pesticides, PCBs, SVOCs and VOCs. A sample depths at 1 ft below ground surface detected 53,000 mg/kg total diesel range hydrocarbons and at 7.0 ft. bgs had 18,000 mg/kg and exceeded the 1,000 mg/kg ADEC-approved soil cleanup level.
Several contaminants exceeded the interim cleanup levels for surface water samples. Among those were pesticides and various VOC and SVOC compounds. DRO was also detected at concentrations up to 8.8 mg/L (NOTE DRO is not a COC for surface water quality criteria-Total aromatic hydrocarbons and Total aqueous hydrocarbons are more appropriate).
A risk assessment completed using the results from the 1994 RI/FS indicated a limited number of pesticide, PCB, total xylene and 2-methyl-naphthalene sample results that could potentially pose a risk to humans or the environment. The Air Force also completeed a natural attenuation assessment of the surface water and soil during this study. Results showed that natural attenuation was actively occurring in the site soil. Surface water samples also showed a decreas in DRO at the source and downgradient locations.
Based on this study, the Air Force recommended that contaminated soils at or below the gravel pad surface with greater that 1,000 mg/kg DRO should be excavated and treated onsite. The Air Force recommended natural attenuation with long-term monitoring for both gravel pad and tundra soils and surface water monitoring to measure natural attenuation of surface water. It was noted that contamination identified at SS12 had commingled with contaminated fill associated with SS15 (Power Plant Garage site). |
Louis Howard |
| 10/9/1995 |
Update or Other Action |
Applies to ST04 (ASTs), ST14 (East Tank Sites), SS12 and SS13 (Landfarm) soil washing project. Jacobs Engineering sent a fax to Kalu Kalu re: memorandum for request for concurrence on a one-time discharge of 100,000 gallons of conditioned water at Kotzebue long range radar site.
Follow-up to discussion with Chris Williams on Oct. 6 and 9, 1995 and the technical proposal presented on Oct. 6, 1995. Based on this information, a request is being made for the State's concurrence on the one-time discharge of approximately 100,000 gallons of water conditioned by granular activated carbon. The water is a result of the soil washing project performed this summer at Kotzebue LRRS. Per the State's request, conditioned water will meet the 10 part per million (ppm) total BTEX requirement and will be discharged onto gravel pads. Total BTEX will be analyzed by method SW8020 as opposed to method 602. Indications were made to Chris Williams that this approach would be acceptable. Furthermore, there is no visible sheen or visible hydrocarbons present on the water.
Attached please find the results for the first two effluent BTEX samples. Both samples represent the initial 30,000 gallons of water to be discharged. The results are well below the 10 ppm BTEX limit. One more sample will be collected at the 70,000 gallon stage. These sample results will be forwarded to you for your records. Discharge of water will commence on October 9, 1995 and be completed by October 13, 1995. |
Kalu Kalu |
| 9/30/1996 |
Update or Other Action |
Interim Remedial Action Project Activities Work Plan Addendum received. It has been
prepared to address disposition of the remaining fines generated from soil washing in 1995
and closure of remediated gravel pads at the Kotzebue Long Range Radar Station in Kotzebue, Alaska. The Interim Remedial Action includes:
Treating the approximately 15,000 gallons of wastewater remaining from the 1995 soil washing activities;
Sampling the fines containment cells and conducting a leachability assessment;
Consolidating fines from containment cells into one cell for future disposition; and
Producing the Interim Remedial Action Technical Report and assisting the Air Force in
preparing decision documents to obtain final closure for the remediated gravel pads.
First, as described in the draft work plan, samples were collected from two existing fines containment cells and analyzed for TCLP analytes. The analysis was completed 23 August 1996. The
I analytical results are the basis for a leachability assessment that supports the IRA closure plan for the fines. Second, the wastewater remaining from the 1995 soil washing remedial activity, estimated to be 15,000 gallons or less, will be conditioned and discharged.
Next, fines will be excavated from containment cell #2, hauled to containment cell #1, and
evenly distributed within the cell. Care will be taken to avoid any spillage; however, if any
spillage may occur, it will be immediately picked up and placed in containment cell #1.
Before, during, and following fines excavation, reusable pieces of HDPE covers and liners for
containment,cells #1 and #2 will be rolled or folded. Potentially contaminated pieces will be
wrapped with Visqueen® or placed in supersacks. Scraps of liner will be contained in
supersacks. All liner pieces and supersacks containing liner will be stored onsite in the
vehicle maintenance garage for future use or disposal during Operation Clean Sweep.
Berms for containment cell #1 will be raised or graded as necessary, to conform to the profile
of the deposited fines. Berms for containment cell #2 will be kept intact as much as possible
to be used for frees containment temporarily during Operation Clean Sweep.
A 20 mil thickness HDPE cover will be placed over containment cell #1. Sandbags and clean
gravel from the site will be placed over the cover to secure it in place.
Surveying will be conducted to delineate sample locations from 1995 activities. As-built J
drawings will be provided in the IRA technical report.
Jacobs will coordinate the disposal of the wastes from the 1995 and 1996 field work. This
includes coordination of waste characterization, transportation, and disposal in a manner that
complies with state and federal regulations.
Jacobs will also coordinate funding and technical activities with DNR in their efforts to study the rare Oxytropis arctica var. barnebyana, which was discovered on site during the 1995 remedial activities. Field operations will be conducted in a manner that minimizes contact with the endangered plants and protects them to the greatest extent possible.
Production of the Draft and Final IRA Technical Reports that detail the results of remedial
actions at the Kotzebue LRRS comprise the final element of the 1996 IRA effort. Jacobs will assist in preparing decision closure documents that will be reviewed and approved by ADEC
for closure of the gravel pads that were remediated in 1995.
|
Kalu Kalu |
| 12/31/1996 |
Update or Other Action |
If specimens are identified as Oxytropis arctica var. barnebyana (OAB), this will change the rarity status of this species
significantly. It should be noted that the taxonomy of OAB should be analyzed, preferably by DNA analysis. Although anecdotal, two morphological variations were observed; one morph appeared tall and robust with few large leaflets; another morph appeared shorter, more prostrate and had more, but smaller leaflets. A few purple-flowered variants were also found.
Oxytropis arctica has a purple flower and is the only purple-flowered species of the O. campestris type native to the "American segment of the Arctic circle" (Barneby, 1952). As far as any perceived morphological differences, without further analysis, it is impossible to conclude this is genetic versus phenotypic. Polyploidy has been reported in the Oxytropis campestris complex of species which includes OAB (Dawe and Murray, 1981). Murray(1987) states polyploidy is a common characteristic of Arctic species. Polyploid taxa are adaptively superior. Murray goes on to state, "hybridization and formation of polyploids provided recombinants superior to the parental stock in the new environments."
In arctic alpine Draba species from the Nordic, ecological amplitude increased significantly with increasing ploidy levels (Broehmann et. al., 1992). OAB had a much wider 'habitat amplitude' than was expected. It was observed in the following habitat types: riparian, gravel bars and outwash areas, mixed-herb meadow, sedge-dryas tundra, cliff faces, grassy bluffs, and alpine tundra. Obviously, the more generalized a species is in its habitat preferences, the less vulnerable it is to extirpation. While speculative, perhaps polyploidy enables OAB to have a wider habitat amplitude. It serves to exemplify that variation between and within the species deserves additional genetic analyses, such as electrophoresis (allozyme) or DNA studies.
Conclusions that it is no longer necessary to take protective actions to conserve all
OAB populations owing to the discovery of many more plants in the Squirrel River drainage are incorrect. If anything, all populations (or the total known gene pool) should be conserved in order to complete needed genetic analyses. During this study, a total of 15,782 new plants were estimated for five habitat types of the No Name and North Fork Squirrel River drainages. In order to conclude this species is secure, taxonomic studies are necessary and should be made a priority. Until these studies can be conducted, all populations should be protected and the measures outlined in the Conservation Agreement and accompanying plan should be followed next year. |
Louis Howard |
| 1/3/1997 |
Update or Other Action |
1995 & 1996 Remediation Report Soil Washing received. This area, approximately 1.5 acres, was impacted by historical diesel fuel spills. Approximately 4,750 cy of contaminated soil was targeted for remediation. In addition, seep collection trenches were to be constructed hydraulically down-gradient of this site, if required, to prevent the migration of fuel contaminants into the adjacent tundra.
The scope of work addressed the possible construction of surface water & seep collection trenches at SS12 (Spills Nos. 2 & 3). At the time of the field effort, no active seeps or surface water was present at the site. As a result, these collection trenches were not constructed.
Clean soil from the soil washing system was backfilled at source area excavations at ST14, ST04, SS12, & SS13. The clean gravel 3/8-inch & larger was backfilled at SS02 (the Beach Landfill) to fill large holes remaining from previous remediation & landfill closure activities.
SS12 - Spills 2 & 3 Site: Approximately 3,430 cubic yds of soil was excavated from this site & treated by the soil washing process. The priority for treating the soils at this site was lower than the other sites due to estimated quantities of petroleum contaminated soils. Therefore, it was the last site to be excavated. Treated soil was used for backfilling a portion of the excavation. Excavation of contaminated soils & soil washing was discontinued due to limitation of funding & the onset of adverse weather. Therefore, this site cannot be recommended for NFRAP at this time. At SS12, fixed laboratory DRO test results were reported up to 9,200 ppm.
ADEC established target levels for DRO that would be used to initiate additional treatment at the site; the target level for treated soil to be used as fill was set at 200 mg/kg diesel range organics (DRO), & the target level for soil sent for disposal was set at 1,000 mg/kg DRO.
Steps were taken during cleanup activities to minimize disturbance of the rare plant Barneby’s Milkvetch, which was found at the site. The Contractor toured the site with the BLM & USF&WS personnel to determine where the plants existed & whether excavation activities had impacted the plants. These plants were found at ST04, ST14, SS12, & in the tank berms at the beach south of SS02. Some of the plants at ST04 & ST14 had been destroyed during excavation of contaminated soil. During the site tour, the Contractor flagged plant locations to avoid any further impact on this species.
At SS12, where most of the clean soil was expected to be encountered, a contaminated zone was found approximately six inches below ground surface. The SS12 area is close to the power plant, & used oil from the diesel generators may have been distributed or dumped on the ground in this area. Consequently, all surficial soils at SS12 & other source areas were considered to be contaminated.
Four samples were collected from the excavation. Benzene was not detected in any of the samples collected. However, 2 of the samples reported DRO in excess of 1,000 mg/kg. These samples were K-SSI2-103A (2,9011 mg/kg) & K-SS12-104A (6,800 mg/kg). Treated gravel was placed in the area adjacent to the power plant to provide a cap over the contaminated subsurface. The open excavation was backfilled with clean soil from the soil washing system (DRO levels less than 1,000 mg/kg). The Air Force recommended further treatment of the soil at SS12. A leachability test was performed on approximately 400 cubic yards of residue material remaining after soil washing.
GRO contamination at 5.4 mg/kg to 110 mg/kg was found in every sample collected from the soil stockpile. Only 2 samples exceeded 100 mg/kg GRO (110 mg/kg for each sample). Similarly, DRO contamination was detected in each stockpile sample. The contamination ranged in concentration from 140 mg/kg to 830 mg/kg. Since most of the GRO & DRO, samples had levels above the treatment goals (100 mg/kg for GRO & 200 mg/kg for DRO), the treated soil could not be deposited in the Beach Landfill. However, because the DRO in the soil was less than 1,000 mg/kg, it could be placed back into the excavations of origin in accordance with an agreement between the Air Force & ADEC. Therefore, all treated soil < 1,000 mg/kg DRO was deposited at source areas ST04, ST14, & SS12.
Recommendations: More soil could be excavated at SS12 and processed through the soil washing system. In addition, further contamination may be present under the composite building (particularly under the former power plant). If the buildings are demolished, the underlying soil could be sampled and, if required, excavated and processed through the soil washing plant (which is currently still onslte). Since this is an area of gravel fill on tundra, it is believed that further discussions with A.DEC are required to determine if closure of SS12 can be achieved. |
Louis Howard |
| 2/20/1997 |
Site Added to Database |
Site added by Shannon and Wilson. See also Reckey 198932X902515. |
S&W |
| 4/25/1997 |
Update or Other Action |
Final March 1997 Interim Remedial Action: Includes the: Environmental Cleanup Plan (ECP) which has been prepared for the remediation of contaminated soil at the Kotzebue Long Range Radar Station (LRRS) in Kotzebue, Alaska. The ECP constitutes one of the planning documents. Other planning documents include the Project Activities Work Plan (Work Plan), the Environmental Operations and Maintenance Plan (O & M Plan), and the Quality Program Plan (QPP), which includes the Health and Safety Plan (HSP), the Environmental Sampling and Analysis Plan (SAP), and the Construction Quality Plan (CQP).
The ECP describes procedures for securing the site against theft, details for excavation and
stockpile construction in compliance with Alaska Department of Environmental Conservation (ADEC) standards, surface water management, erosion control measures, emission and spill control and countermeasures, and waste handling and demobilization procedures. Field activities scheduled for the Kotzebue LRRS include mobilization of personnel and supplies to the site in early June 1998, excavating and treating approximately 7,265 cubic
yards (yds 3) of petroleum-contaminated soil from two source areas, and demobilization of
personnel, equipment, and materials from the site in August 1998.
Soil will be excavated from the following locations at the LRRS:
• Spill Site 12 (SS12), Spills 2 and 3; approximately 6,931 yds3 of soil will be excavated from this area.
• Spill Site 15 (SS15), formerly known as Area of Concern No. 4 (AOC04): approximately
334 yds of soil will be excavated from this area. |
Louis Howard |
| 6/30/1997 |
Update or Other Action |
A syopsis and limited review of investigative and remedial activities at the Kotzebue LRRS, Alaska prepared by USDOI BIA contractor-Montauk Environmental Engineering June 1997.
Stte SS12 - Spills No. 2 and 3 This site is located west-southwest of the Composite Facility and is comprised of two diesel fuel spills (Spill No 2 and 3) which have commingled Petroleum hydrocarbons in soil (up to 53000 ppm) and in ponded surface water (at 88 ppm) are the primary environmental concerns at the site. In support of the 1994 RI, a baseline risk assessment was conducted which indicates a potential risk to human health for the dermal contact pathway, based on the detection of PCB (Aroclor 1260 at 0 96 ppm) in one of 39 soil samples collected The baseline risk assessment also indicated a potential ecological risk for the dietary pathway based on the detection of total xylenes in two soil samples at 18 ppm and 440 ppm.
A potential ecological nsk was also indicated for the dietary pathway based on the detection of 2-methyl-naphthalene in four soil samples, at concentrations ranging from 76 to 95 ppm. These six soil samples were collected from gravel fill matenals at the site.
Native tundra substrate located downgradient of gravel fill materials exhibit elevated concentrations of diesel range organics.
Limited remedial actions are recommended native tundra impacted by the spill at Site SS12, including natural attenuahon and long-term soil and surface water monitonng to measure the reduction in petroleum hydrocarbon contamination. The natural attenuation and long-term momtoring alternative represents a non-lnvaslve, or destructive altemative to matenal removal actions or other approaches that would negatively impact the fragile tundra environment and local ecosystem.
Biannual monitoring was recommended for native tundra, including visual inspection and photographic documentation to demonstrate the natural restoration (revegetation) occurnng the site Biannual monitoring should also incorporate Iimited surface water and soil sample collection for diesel range organics to evaluate the effectiveness of the natural attenuation alternattve. Tetra Tech also recommended excavation and removal of contaminated fill
materials which currently exceed the ADEC diesel soil target level of 1000 ppm. Portions of the site have been remediated by soil-washing, and future remedial efforts are anticipated.
Additional Recommendations Conclusion- 3.1 The following recommendations are in addition to those made by Tetra Tech Inc in their reports (and presented above), and are solely the opinions of Montauk Environmental Engineering.
Fencing and/or signs should be placed about contaminated sites to prevent or mitigate exposure of area inhabitants to remaining site contaminants.
The rationale for the ADEC’s PCBs cleanup level of 10 ppm in site soils (although such concentration is almost certainly conservative) should be presented, so that the appropriateness of that cleanup level can be determined.
It is understood that a report of site flora/fauna chemical analyses is scheduled for publication in the summer of 1997, and that the sampling efforts presented in the report are meant to compliment the Baseline Human Health and Ecological Risk Assessment.
According to anecdotal information, preliminary chemtcal analyses results suggest very little in the way of detected target contaminants in plant and animal tissues. It is recommended these findings be presented to local area representatives in a "face to face" setting, so that responses and answers to concerns and questions can be expedited.
3 2 Conclusions Given the multi-spill complexity of the site and the unusual challenges associated with the site’s physical setting, the USAF and its Contractors have demonstrated what appear to be effective approaches toward solving the LRRS’ environmental problems. By identifying and successfully remediating contaminant sources, it is anticipated that future monitoring efforts will record a decrease of contaminant concentrations in those areas where contaminant removal is not recommended or feasible. |
Louis Howard |
| 12/1/1997 |
Update or Other Action |
SS12 is the location of fuel Spill Nos. 2 and 3, located west-southwest of the Composite
Facility. Two distinct diesel fuel spills were identified in 1985 by ES. Spill No. 2 reportedly occurred in 1979-1980 when the day tank behind the power plant was overfilled; and Spill No. 3 reportedly resulted from a leak in the fuel line between a 50,000-gallon tank and the steam boiler day tank. Spill No. 3 was first observed in 1984 during an ADEC site inspection (ES 1985). Approximately 4,000 gallons of diesel from Spill No. 3 were collected by pumping from recovery trenches, and the fuel line was repaired. Absorbent material was used to assist in the cleanup for both spills. The sites were addressed again during the 1989-1990 Stage 1 RI/FS, which categorized them as one site due to contaminant commingling. The Stage 1 effort included water flooding pilot studies at Spill No. 3, and as a result of the pilot study further remedial action was recommended.
Further pilot studies of preferred remedial alternatives, including excavation/landfarming and in situ bioremediation, were conducted. Approximately 100 cubic yards (cy) of DRO contaminated soil was removed from the site of spill No. 2 and taken to the landfarm area. Not all of the contaminated soil at the spill site could be removed due to the potential to compromise the structural integrity of installation buildings. Approximately 50 cy of clean backfill were placed in the excavation and graded to conform with the surrounding topography.
Approximately 350 cy of DRO contaminated fill was excavated at Spill No. 3 and spread at the landfarm area. About 240 cy of clean backfill material was placed in the excavation and graded. For the affected native tundra at the site, three water flooding pilot studies were conducted in an attempt to collect free product and reduce hydrocarbon concentration in the tundra soil. However, the effectiveness of the studies was limited by low soil permeability, lack of naturally occurring groundwater to aid in the transport of free-product, and the small amount of free-product present.
In January 1992, ADEC identified a fuel seep which appeared to originate from the area of Spill No. 2. ADEC requested a plan for further remedial action at the site. The 1994 RI/FS found that, although potential ecological and human health risks were present from soil and surface water contaminants, natural attenuation was actively occurring in the tundra soils. Biodegradation was thought to be a potential significant process acting to reduce DRO over time on the tundra. However, DRO concentrations remaining in gravel fill material was recommended for remedial action. Excavation and onsite treatment of an estimated 11,000 cubic yards of DRO affected fill material was recommended.
Long-term soil and surface water monitoring was also recommended to confirm and measure the reduction in DRO concentrations at the site by natural attenuation. During the 1995 remedial activities, approximately 3,430 cy of soil was excavated at SS12 and treated by the soil washing process. The treated soil was used for backfilling a portion of the excavation. Excavation of contaminated soils was terminated before completion due to limitation of funding and the onset of adverse weather. SS12 is currently programmed for further excavation and treatment of impacted soil in the summer of 1998. |
Kevin Oates |
| 12/31/1997 |
Update or Other Action |
Management action plan lists a zone approach to the facility. Zone 1 has been defined as the former main activity area of the installation. This area contained the housing and most of the operation facilities, including the Composite Facility. The following IRP sites and AOCs are identified within Zone 1: SS01 - Waste Accumulation Area No. 1 (closed), SS08- Barracks, SS15 - Garage/Power Plant (AOC 4),
SS06 - Spill No. 1 (closed), SS13 - Landfarm (AOC 1) (recommended for closure), SS14 - East Tanks (AOC 3), SS19 - PCB Spill South Fence (AOC 12), SS18 - Truck Fill Stand (AOC 11), SS20 - Septic Holding Tank (AOC 10), SS12 - Spill Nos. 2 and 3, AOC 5 - Day Tanks, AOC 7 - Steel Pilings (recommended for closure). |
Louis Howard |
| 6/10/1998 |
Update or Other Action |
Memorandum for Kotzebue RAB from HQ Human Systems Center Brooks Air Force Base. Consultative Letter AL/OE-CL-1997-0194 Health Risk Assessment for Berries and Greens at Kotzebue Long Range Radar Site (LRRS). Summary: The U.S. Public Health Services' Agency for Toxic Substances and Disease Registry (ATSDR) and the 611th Civil Engineering Squadron (CES) requested the U.S. Air Force's Health Risk Assessment Branch (OEMH) evaluate potential risks due to past waste practices (e.g. spills and landfill) at the Kotzebue LRRS. The potential food chain risk is from consumption of plants grown on the facility.
A review of the Kotzebue LRRS IRP documents lead OEMH to determine that plant and not fish consumption was more appropriate to evaluate for risks from contamination, since fish can travel great distances and the potential levels of chemicals from Kotzebue LRRS that could reach the Sound would be low. This was discussed and supported by some area residents who described that area fish do not spend much time near the Kotzebue LRRS. Mr. Walter Sampson, Kotzebue resident, took OEMH staff to the Kotzebue LRRS and identified edible plants (berries and greens) commonly gathered by local residents. He also said crop yield was below normal during the 1996 harvest season. OEMH had a difficult time collecting enough berries and greens to meet sampling analytical requirements. OEMH staff collected surface soil samples to identify if contaminants measured in berries and greens were present in the soils and at what concentrations.
The list of contaminants evaluated in the berries and greens included those contaminants detected in previous water and soil at SS12 and other LRRS IRP sites. Based on this information, berries and greens were analyzed for semi-volatile organic chemicals (including polychlorinated biphenyls (PCBs), pesticides, and petroleum products. SS12: Four samples were collected from each location-one each for salmon berries, bog blueberries, sourdock and surface soil.
A "background" location was chosen based on previous IRP sampling and availability of berries and greens not influenced by site contamination. The background location is adjacent to the "Old Water Supply Lake" (SS07 formerly KOT-7).
The results were well below health based comparison values used by ATSDR, ADEC and EPA. This indicates that the consumption of berries and greens from Kotzebue LRRS and incidental ingestion of surface soils from SS12 pose no significant risk to Kotzebue residents. The safety factors used in the toxicity assessment and conservative (maximum) exposure estimates used to calculate berry and greens consumption and incidental ingestion of surface soil supports this conclusion. No further action is required at Kotzebue LRRS. It is safe for the residents of Kotzebue to continue collecting and eating berries and greens from the Kotzebue LRRS. |
Louis Howard |
| 9/29/1999 |
Update or Other Action |
Operation Clean Sweep and Soil Washing report received. All facilities at the Kotzebue installation were removed from the site as part of the 1998 Operation Clean Sweep. Debris was disposed of in the Kotzebue Municipal Landfill. In addition, the site was regraded to inhibit the formation of surface water ponds.
The on-site soil washing system was again used in 1998 to treat an additional 3,583 cubic yards of contaminated soil excavated primarily from the SS12 source area, though some soil from SS15 (Former Power Plant) was also included. Soil/gravel with field screening results in excess of 1,000 mg/kg was excavated down to the tundra-gravel interface; the underlying tundra was not excavated in order to prevent exposure of the permafrost. Confirmation samples collected from the excavation had a maximum TPH concentration of 5,330 mg/kg.
Samples of treated soil were analyzed to determine the effectiveness of multiple soil treatments using soil washing technology at SS12. All soil with DRO concentrations above 200 mg/kg was re-washed and sampled. Following the second round of treatment, the average TPH concentration was 536 mg/kg. No additional soil washing was performed due to limited funding and time constraints. Treated gravel was backfilled into the pad area, and additional washed soil was stockpiled in containment cells on the gravel pad adjacent to SS15. the water from the soil washing system was treated and discharged to the gravel pad, with care taken to keep water from the exposed tundra surface. |
Louis Howard |
| 11/30/1999 |
Update or Other Action |
Stockpiled soil from the 1998 soil washing project was sampled in 1999 to compare the contaminant levels to current ADEC cleanup levels. Samples were analyzed for DRO, gasoline range organics (GRO), RRO, and BTEX. None of the soil sample results exceeded ADEC 18 AAC 75 Method 2 cleanup levels. The stockpiled soil has since been used as daily cover at the Kotzebue Municipal Landfill. |
Louis Howard |
| 12/20/1999 |
Update or Other Action |
Soil Washing Post Construction Report received. This report documents the activities performed under Contract Number F41624-94-D-8115-0034. This project consisted of the screening & excavation of contaminated soil, & processing the soil through a remediation system using a soil washing technology. In addition, the project also consisted of characterizing & disposing of all waste encountered onsite (that waste generated from the field effort & that which was generated from previous investigations).
Soil was to be excavated was primarily from Source Area SS12 (SSI2). Soil was also excavated from SS12 during the 1995 field effort. During the course of the field effort, the Contractor used field screening techniques (screening with a photoionization detector [PID] & with "Petroflag ®" field test kits) to identify areas of DRO contamination greater than 1,000 ppm. Soil from these areas was excavated & stockpiled for processing through the soil washing system.
Soil washing began on 30 Aug 98, after water had been pumped into the clarifier pond & a water balance through the system was achieved. After the Initial day of production, a smaller screen was required for the shaker deck. The screen was procured in Anchorage, shipped to Kotzebue, & soil-washing operations were restarted on 1 Sep 98.
Soil washing production continued to be performed onsite, although the high levels of contamination were slowing production & generating higher levels of contamination in the process water. An additional settling pond was constructed to hold contaminated water adjacent to the surge tanks. An average production rate of 20 cy/hour was being achieved at this time.
One of the problems onsite, as was the case during the 1995 field effort, was the buildup of fine-grained material which is generated from the soil washing process. To deal with this problem, additional fines holding pits were constructed. However, during soil washing operations, removal of the fines from the main clarifier pond was necessary, & to accomplish this, the entire soil washing system had to be shut down. This happened on several occasions, which impacted production.
On 13 Sep 99, the attrition mill experienced a failure, which caused soil washing to cease production. The attrition mill has 2 counter-rotating propellers inside the unit to grind the together, thus cleaning it. One of the propellers failed, meaning the blades were torn off the central hub of the propeller. The unit was shut down for four days until 16 Sep 98, when operations began again. The 4 days of lost production impacted the field effort greatly as the winter weather was coming quickly to the area.
At the time the attrition mill failed, approximately 3,000 cy of soil had been processed through the unit. Throughout the operation of the unit, the test kit data indicated that the soil was not being cleaned to the cleanup level of 200 mg/kg DRO. Analytical data supported these results.
After soil washing began again on 16 Sep 98, it continued until winter weather & budgetary considerations forced the crews to demobilize. Soil washing operations were discontinued on 29 Sep 98. By the time the soil washing effort had been completed, all the soil that had been excavated was processed at least once through the soil washing unit. Re-washing of soil that did not meet the cleanup level of 200 mg/kg of DRO had begun before soil washing had to be discontinued.
This study incorporated a leachability assessment to determine whether or not the fines would leach hydrocarbon contamination into the surrounding soil in levels unacceptable to human health or the environment. Approximately 250 cy of fine-grained material was generated during this year's field effort. The leachability assessment was undertaken after the 1995 field effort in an effort to determine the hazards associated with the fines & to select an appropriate treatment technology for that material.
Using toxicity characteristic leaching procedure (TCLP) analyses, leachable levels of GRO, DRO, benzene, toluene, ethylbenzene & xylenes BTEX), polynuclear aromatic hydrocarbons (PAHs), pesticides/polychlorinated biphenyls (PCBs), & metals generated from soil samples taken from the fines impoundments. The compound specific constituents (this excludes GRO & DRO) were compared to TCLP regulatory levels & also to EPA Region III RBCs. In the case of GRO & DRO, guidance for performing toxicity assessments from the Massachusetts Department of Environmental Protection was used to determine concentrations that would not pose a risk to human health.
Since the results of the leachability assessment indicated the fines did not pose an unacceptable risk to human health, it was decided to place the fines in lined impoundments & cover the material to prohibit contact by any potential receptors. The final Remediation Report for the 1995 & 1996 field efforts documents this data.
See site file for additional information. |
Louis Howard |
| 5/5/2000 |
Meeting or Teleconference Held |
Community Meeting- Public questioned the appropriateness of using a higher cleanup level than what was originally used for the soil washing project. The first proposed levels excavated soil greater than 1,000 mg/kg diesel range organics (DRO) for treatment, and identified 100 mg/kg as the post treatment contaminant level.
Question was asked why the Air Force wasn’t planning to follow the original cleanup level. Air Force responded: There was no formal agreement between the Air Force, ADEC, and community of Kotzebue to clean the soil to 100 mg/kg DRO. This was a voluntary goal established by the Air Force. This goal proved unattainable with the soil washing technology used to treat the soil. In the time between the start of the soil washing project and the abandonment of the technology, ADEC published Final Regulations for DRO cleanup in soil. ADEC and the Air Force determined that 18 AAC 75 Method 2, Table B2 cleanup values were appropriate cleanup levels. The new level would be 12,500 mg/kg DRO. The soil at the facility is well below this level and requires no further remedial action. Further, the soil could be spread onsite, regraded and re-vegetated to ensure runoff and erosion control. |
Ann Farris |
| 8/29/2000 |
Cleanup Plan Approved |
Div. of Env. Health, SW Program Sent letter to Tim Rabern City of Kotzebue. RE: Approval for Use of Remediated Soils as Cover Material in Kotzebue Landfill, Permit #9632-BA003
The Department has reviewed your request to use remediated soils fxom the Kotzebue LRRS as
cover material at the Kotzebue Landfill/Balefill, and the documentation provided by Steve Eng.
a certified hydrologiwst with ASCG,Inc. The remediated soil exceeds ADEC's regulatory
standard for placement in a unlined landfill. The soils exceed the "over 40-inch migration
to groundwater" standard for diesel range organic (DRO). We have considered your request under
the provision of 18 AAC 60.025 and grant approval for the use of the remediated soil as cover
materiail in the Kotzebue Landfill. You must comply with the following conditions.
1. The remcdiated soil can only be used as a daily or intermediate cover. They cannot be used in the top two feet of the four foot final cover required by your permit.
2. The remediated soil shall be applied uniformly when used as cover material and must be applied and compacted at grade to prevent low spots that may result in water ponding.
3. Any accumulated surfac water in a cell where the remediated soil are used for cover material must be examined for visible sheen per 18 AAC 70.020, before the water can be discharged to the sewage lagoon (if water is in contact with waste) or to the tundra. If a visible sheen is present on the water surface, then the product causing the sheen must be sskimmed off with absorbents or the water pumped through an oil/water separator before discharging to the sewage lagoon. The skimmed or separate product must be dispose of according to applicable Federal and State statutes and regulations.
This approval is for the remediated soils stockpiled at the Kotzebue LRRS only, and does not
constitute permission to dispose or landfill any other polluted or contaminated soils. Any future proposals for disposal of polluted or contaminated soils at the Kotzebue Balefill/Landfill will be considered on a case-by-case basis. Signed Kent Monroe Environmental Specialist. |
Ann Farris |
| 11/3/2000 |
Document, Report, or Work plan Review - other |
Staff reviewed and commented on the Proposed Plan for Cleanup, Kotzebue Long Range Radar Site, Sites SS08 and SS16, Kotzebue, Alaska, dated September 1999. The Proposed Plan summarizes the site history, previous site investigations, and a cleanup alternatives analysis for the Waste Accumulation Area No. 2/Landfill (SS02), Beach Tanks (ST05), Spills No. 2 and 3 (SS12), and the Garage and Power Plant (SS15). The Department has the following general comments on the Plan:
1. As a whole, the document is very confusing and does not adequately discuss the specific environmental issues at each of the four sites. The sections “Results of Previous Investigations” and “Summary of Interim Action” may be clearer if they were combined and each site was discussed separately. However it is presented, though, please include specific dates of the report or investigation, a list of contaminants of concern (COCs), potential or proven sources, the impacted media (soil, surface water, and/or groundwater), the estimated volume or magnitude of the contamination, and the specific interim remedial action (IRA) taken along with the estimate of the extent of contamination remaining at the site after the IRA. In order for the public to make comments, they have to be able to understand the type and extent of contamination.
2. Throughout the document indicate what type of fuel is being discussed (e.g. DRO, GRO).
3. Recommend that investigations and reports not related to the four sites be left out of this Proposed Plan. They are not necessary and confuse the relevant issues.
4. Please include a discussion of proposed soil, groundwater (if necessary), and surface water cleanup levels. This should refer to the contaminated sites regulations (18 AAC 75), the surface water regulations (18 AAC 70), and, if necessary depending on the COCs, EPA risk-based concentrations.
5. Please indicate the SS or ST numbers on Figure 1.
6. Page 3, 2nd paragraph, 6th sentence: ADEC does not define suprapermafrost as surface water. However, the water does need to be evaluated as a possible mechanism for contaminant transport to a surface water body. If the contaminant is migrating via this pathway, the cleanup criteria for the suprapermafrost water is set such that the surface water body does not exceed the water quality regulations.
7. Page 3, 2nd paragraph: The explanation of the geology in the area is confusing. It may be clearer to define the separate areas (i.e. beach, near beach, tundra) and explain the soil type, permafrost, and groundwater characteristics for each area.
8. Page 6, under Alternative 2, 5th sentence: “Natural attenuation of fuels has been demonstrated at Kotzebue LRRS.” Please include a reference for this and indicate the type of fuel.
|
Ann Farris |
| 2/23/2001 |
Update or Other Action |
Letter to AF RE: Proposed Plan for SS02, ST05, SS12, and SS15. Recommend dividing the plan into two separate documents, handling SS02 and ST05 separately from SS12 and SS15. The sites along the beach: SS02 and ST05 are very different than the two sites on the gravel pad and tundra. The sites along the beach are physically close to Kotzebue Sound, a marine surface water body, and have groundwater issues. The other two sites are underlain by continuous permafrost, have had significant cleanup work completed, and have surface fresh water issues.
SS12 & SS15
Surface water quality criteria of "No Sheen" is not applicable in this case because the surface ponds at these sites are fresh water and must be tested for total aromatic hydrocarbons (TAH) and total aqueous hydrocarbons (TAqH). Cleanup levels for these parameter is 10 ug/L and 15 ug/L respectively. It is unclear why SS15 needs further treatment. The plan indicates that all of the contaminated gravel was excavated and treated. The area was backfilled with clean soils. Please clarify in the plan the type and location of contamination remaining at the site. |
Ann Farris |
| 5/17/2001 |
Meeting or Teleconference Held |
Staff attended restoration advisory board (RAB) meeting - issues discussed were publishing reports in the newspaper, better explanation of ecological risk assessment, proposed plans pending, need to explain cleanup levels well, historical grave on the facility, program for the school, and need to present GW results. |
Ann Farris |
| 6/12/2001 |
Document, Report, or Work plan Review - other |
ADEC letter to USAF re: review comments on the sampling and analysis plan for post thermally-treated soils from the Long Range Radar Site Location, Kotzebue, Alaska dated May 2001.
The sampling and analysis plan (SAP) describes details of the thermal treatment of contaminated soils to be completed at the Kotzebue Long Range Radar Station (LRRS) in the 2001 field season. The SAP includes the stockpile and sampling details for the pre- and post-treated soils. ADEC has the following comments on the plan:
1. Page 4, Section 4.6, 1st Sentence: The ADEC Cleanup Level A Standards apply as indicated unless site-specific cleanup levels have been approved by the ADEC and the treated soil will remain on the original site.
2. Page 5, Section 5.0 Table: The minimum lab samples are accurate, however, the minimum field screening is not. 18 AAC 78.605 refers to UST Procedures Manual for field screening. The manual indicates in Section 4.5.3 that one field screening sample must be collected every 10 cubic yards, unless otherwise approved by ADEC. Please correct the text to indicate this requirement. If on specific sites you wish to alter this requirement, you may submit a request to the appropriate ADEC Project Manager. For the Kotzebue Long Range Radar Site, this requirement is not waived.
3. Page 6, Section 5.2, 1st Sentence: The most recent version of the UST Procedures Manual is dated December 1, 1999. Please update the reference.
4. Page 6, Section 5.4: For the Kotzebue Long Range Radar Site specifically, the analyticals that will be required post-treatment will be dependent on the analysis collected prior to excavation. Residual range organics (RRO) and polynuclear aromatic hydrocarbons (PAHs) may or may not be necessary.
Please note, ADEC review and concurrence on this workplan 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 the plan does not relieve responsible persons from the need to comply with other applicable laws and regulations. |
Ann Farris |
| 3/3/2003 |
Update or Other Action |
Draft Proposed Plan received. Spills No. 2 & No. 3 (SS12) are located southwest of the former Power Plant/Garage site (SS15), & south of the former Composite Building. This site consists of two diesel fuel spills that were combined to form one site. Fuels in gravel fill, tundra, & in surface water ponds are the primary environmental concerns at this site.
According to the 1985 Phase I PA/SI report, SS12 was created by overfills & leaks in the fuel pipeline system. Spill No. 2 occurred between 1979 & 1980 when a day tank behind the power plant was overfilled. The spill area consisted of a 40’ by 80’ area of gravel fill. Spill No. 3 was the result of a leaking fuel line. The leak was discovered in 1984 & affected a 1.5-acre area that included a 1-acre section of tundra. A follow on investigation was recommended, including soil & surface water sampling, geophysical studies & groundwater monitoring.
In 1988, the AF conducted a RI/FS. A soil gas survey, soil borings, trenches, soil & sediment sampling, & small-scale water flood tests were conducted at SS12. Soil samples were analyzed for total petroleum hydrocarbons (TPH), VOCs, pesticides & PCBs. Low-levels of pesticides (up to 5.7 ppm 4-4’ dichlorodiphenyltrichloroetherne [DDT]) & no PCBs were detected in the soil samples. Maximum levels of TPH in soil was above interim cleanup levels set in 1988. The FS recommended contaminated material at Spill No. 2 be excavated & landfarmed on site & that downgradient tundra be sprayed with fertilizer to enhance in-situ biodegradation.
In 1989 & 1990, the AF performed a RI/FS. SS12 underwent three small-scale studies to see if soil could be treated using enhanced bioremediation. These studies included landfarming of excavated materials, in-situ treatment of disturbed contaminated tundra & in-situ treatment of contaminated native tundra. Excavated soil for the landfarming study was placed in a constructed soil stockpile containment cell at the Landfarm (SS13).
Results showed that the levels of contaminants could be greatly reduced using these methods. The AF recommended the study continue at the landfarm & perform cleanup activities around active pipelines, tanks, roadways & the security fence.
In 1992, during a site inspection, ADEC personnel observed a fuel seep in the tundra that appeared to originate from Spill No. 2. The agency recommended that the Air Force determine the extent of diesel fuel contamination at Spill No. 2 prior to proceeding with any additional remedial action
In 1994, an RI/FS was done to determine the amount of contamination still on site. Thirty eight soil samples, four surface water samples & two sediment samples were taken & analyzed for DRO, pesticides, PCBs, SVOCs & VOCs. In soil, DRO (up to 53,000 ppm) was found at levels that exceeded the interim cleanup levels of 1,000 ppm. One of the two sediments samples contained DRO & pesticides above interim cleanup levels. DRO was also found above interim cleanup levels in surface water.
A natural attenuation study of surface water & soil was performed & showed biodegradation may be a reducing the levels of fuels over time.
The AF recommended contaminated soils with more than the interim cleanup level of 1,000 ppm DRO be excavated & treated on site. The Air Force also recommended natural attenuation with LTM for native tundra & surface water. It was noted that contamination identified at SS12 had commingled with contamination associated with the Power Plant/Garage site (SS15).
A risk assessment completed using the results of the 1994 RI/FS indicated a potential risk to human health due to contact with soil containing PCBs or pesticides (heptachlor epoxide). Only one sample out of 39 had a level high enough to pose a risk to human health. The level detected was 0.96 ppm, which is below current ADEC cleanup levels. A possible risk to human health was also present due coming into contact with pesticides (heptachlor epoxide) in surface water.
A potential risk to ground squirrels due to fuel contaminants (xylene & 2-methyl-naphthalene) in soil was also present at this site. All samples used in the human health & ecological risk assessment were taken from the gravel pad area. During Operation Clean Sweep in 1998, contaminated soil that was part of the gravel pad was excavated & treated & the site was regraded to prevent surface water ponds.
Based on past studies, risk to human health & the environment, review of the possible alternatives, & the cleanup actions already done, Alternative 2 (access restrictions, confirmation sampling, & natural attenuation/monitoring) is the AF’s preferred cleanup method for the 9 sites at Kotzebue LRRS. Alternative 2 is the most cost-effective & will meet cleanup levels in an acceptable amount of time.
Alternative 2 will meet the goals of the 1996 Conservation Agreement Plan for the protection of the rare plant, Barneby’s milkvetch. |
Ann Farris |
| 5/22/2003 |
Meeting or Teleconference Held |
Staff attended a Restoration Advisory Board (RAB) meeting in Kotzebue regarding the Kotzebue Long Range Radar Site. The meeting focused on whether or not the community wanted to continue the RAB as meetings have been sporadic and attendance low. The radar site was demolished and the majority of active cleanup has already occurred, however, Proposed Plans and Decision Documents still need to be prepared and signed. These documents are expected to be forthcoming in the next year. The community decided they wanted to attempt to continue with the RAB in order to actively participate in the proposed plan/decision document stage. The next meeting is scheduled for July 22-23. The local community members that were in attendance agreed to contact several organizations and other community members by the July meeting in an effort to revitalize the RAB. |
Ann Farris |
| 6/16/2003 |
Update or Other Action |
ADEC Comments on the Proposed Plan for Cleanup, Sites SS07, SS12, SS13, SS14, SS15, SS17, SS18, SS19, and SS20, Kotzebue Long Range Radar Station, Kotzebue, Alaska, dated April 2003
The Alaska Department of Environmental Conservation (ADEC or the Department) has completed a review of the above referenced Proposed Plan. The Plan describes the Air Force’s proposed cleanup levels and selected remedy for the following sites:
•Former Water Supply Lake (SS07)
•Spill No.2 and No.3 (SS12)
•Abandoned Landfarm (SS13)
•East Tanks (SS14)
•Former Power Plant/Garage (SS15)
•PCB Spill Building 102 (SS17)
•Truck Fill Stand (SS18)
•PCB Spill South Fence (SS19)
•Septic Holding Tank (SS20)
The Department has the following review comments:
1. Page 1, Side Note, “Alaska Department of Environmental Conversation:” The ADEC is responsible for protecting the human health and the environment, not “safety.” Please clarify the note.
2. Page 1, 4th Paragraph, 2nd Sentence: The “How You Can Participate Box” in the back of the proposed plan indicates the information repository is at the Kotzebue Hall, not the Alaska Indian Reorganization Act Office. Are they the same office? Please clarify this issue. Please also include a physical address for the City Hall. |
Ann Farris |
| 1/15/2004 |
Update or Other Action |
Remedial Investigation/Feasibility Study conducted in 2003. The objective of the 2003 sampling program at SS12 was to confirm whether cleanup levels had been achieved and to assess any remaining site-related impacts to downgradient surface water. An area of stressed vegetation measuring approximately 70 feet by 45 feet was also present approximately 30 feet north of field screening sample SS12-S6. Immediately west of field screening sample SS12-S14, an area of iron-stained gravel appeared to have been spread on the tundra. The gravel area measured approximately 40 square feet and 1 foot in thickness. Hydrocarbon odors were observed in the gravel approximately 2 to 3 inches below the gravel surface.
One sediment sample was collected from the far-downgradient pond where sediment sample SS12-SD4 was collected in 1994. DRO exceeded cleanup level (12,500 mg/kg) at
two soil sampling locations. No surface water analytes exceeded screening criteria.
NOTE: summary of soil screening results and corresponding analytical results-SS12 S14 U03-SS13-S14-01 at 2.9 ft. bgs had PID (ppmv VOCs) of 1,645 .0 and a HANBY (mg/kg) result of 200-500, and the lab result for DRO of 4,600 mg/kg. However, soil screen sample S2 Sample ID U03-SS12-S2-01 at 1.0 ft. bgs, had a PID (ppmv VOCs) of 87.4 and HANBY (mg/kg) result of 200-500 with laboratory DRO result of 38,000 mg/kg. |
Ann Farris |
| 1/12/2005 |
Update or Other Action |
File number updated with subfile 410.38.002.01. |
Aggie Blandford |
| 6/1/2005 |
Proposed Plan |
After minor ADEC comments being incorporated into the document, Final version of Proposed Plan received. SS12 Summary of Site Conditions-Based on the 2004 RI/FS, no CERCLA hazardous substances were found at SS12 above EPA cleanup levels that require further action. Based on the 2004 human health and ecological risk assessment, it is unlikely that exposures to CERCLA hazardous substances will harm human health or the environment at SS12.
SS12 Proposed Action Under CERCLA-In accordance with CERCLA requirements, USAF concludes that no remedial action is necessary to ensure protection of human health and the environment at SS12. Following consideration of public comments received, USAF will prepare a Record of Decision (ROD) to document the final selected remedy for SS12. |
Louis Howard |
| 8/16/2007 |
GIS Position Updated |
66° 50' 29"N, 162° 35' 49"W (NAD83/WGS84) USGS Kotzebue D-2 |
Louis Howard |
| 10/31/2007 |
Update or Other Action |
April 4, 2007 Final Record of Decision For No Further Action received for signature - SS007 (Former Water Supply Lake), SS013 (Landfarm), SS014 (East Tanks), SS015 (Former Power Plant/Garage), SS016 (Buildings 101 and 102), SS017 (PCB Spill at Building 102), SS019 (PCB Spill South Fence), SS020 (Spill Nos. 2 and 3), SS018 (Former Truck Fill Stand), SS002 (Waste Accumulation Area No. 2/Landfill) and ST005 (Former Beach Tanks). Signed by Brent A. Johnson, Colonel, USAF, Commander, 611th Air Support Group on October 23, 2007.
Spill Nos. 2 and 3 (SS12) are located southwest of the former Power Plant/Garage (SS15) and south of the former Composite Building. This site consists of two diesel fuel spills that were combined to form one ERP site. Spill No. 2 occurred between 1979 and 1980 when a day tank behind the power plant was overfilled. The spill area consisted of a 40-foot by 80-foot area of gravel fill. Spill No. 3 was the result of a leaking fuel line. The leak was discovered in 1984 and affected a 1.5-acre area that included a one-acre section of tundra. Fuels in gravel fill and in surface water ponds are the primary environmental concerns.
The principal components of the selected remedy are monitored natural attenuation and land use controls (LUCs). Monitoring for natural attenuation parameters and contaminants will occur every five years. Visual inspection for presence of sheen at seasonal surface water ponds located at the downgradient edge of the sites every five years. Long-term monitoring for potential migration of DRO off-site and into downgradient groundwater will be addressed by monitoring groundwater at ST005 located on the beach adjacent to Kotzebue Sound for five years.
LUCs (also known as institutional controls under 18 AAC 75.375) will be implemented and maintained as long as DRO in soil remains above 12,500 milligrams per kilogram (mg/kg). Inspections will be conducted every five years. LUCs will consist of notice in the Base General Plan (BGP) to inform site workers that DRO contaminated soil is not to be moved or disturbed without notifying ADEC. |
Louis Howard |
| 11/1/2007 |
Record of Decision |
April 4, 2007 Final Record of Decision For No Further Action - SS007 (Former Water Supply Lake), SS013 (Landfarm), SS014 (East Tanks), SS015 (Former Power Plant/Garage), SS016 (Buildings 101 and 102), SS017 (PCB Spill at Building 102), SS019 (PCB Spill South Fence), SS020 (Spill Nos. 2 and 3), SS018 (Former Truck Fill Stand), SS002 (Waste Accumulation Area No. 2/Landfill) and ST005 (Former Beach Tanks).
Signed by Brent A. Johnson, Colonel, USAF, Commander, 611th Air Support Group on October 23, 2007. John Halverson (ADEC) signed the ROD on November 1, 2007. Diesel range organics as high as 38,000 mg/kg (Arctic zone = 12,500 mg/kg) is above cleanup levels and the selected remedy is monitored natural attenuation with institutional controls. |
John Halverson |
| 11/1/2007 |
Long Term Monitoring Established |
Monitoring for natural attenuation parameters and contaminant levels will occur every five years. Long-term groundwater monitoring for potential migration of DRO off-site and into downgradient groundwater will be addressed by monitoring at ST005 for five years. Soil containing residual contamination may not be placed in surface water or other environmentally sensitive areas.
The depth of highest concentration of DRO at SS012 for two areas was determined to be down to one foot in 2004 (RI/FS). Once an area is below the established cleanup level and the RAOs outlined in the Nov. 2007 Record of Decision are met, each area will be evaluated for removal from future sampling efforts. RAOs will be met once confirmation sampling from each area indicates that DRO contamination is below the established cleanup level of 12,500 mg/kg.
Monitoring of the ponds located downgradient from SS012 will be conducted visually for sheen. If a sheen is noted, surface water and sediment samples will then be collected. Samples will be for DRO, BTEX, and SVOCs in sediement and total aromatic hydrocarbons and total aqueous hydrocarbons in surface water. Once an indication of contaminant migration to surface water is noted, surface water and sediment samples will continue to be collected for the remainder of the program until DRO concentrations in soil are below cleanup levels or no sheen is noted on the surface water. |
Louis Howard |
| 11/1/2007 |
Institutional Control Record Established |
LUCs (also known as institutional controls under 18 AAC 75.375) will be implemented and maintained as long as DRO in soil remains above 12,500 mg/kg. Inspections will be conducted every five years. LUCs will consist of a notice in the Base General Plan (BGP) to inform workers that DRO contaminated soil is not to be moved or disturbed without notifying ADEC. |
Louis Howard |
| 11/5/2007 |
Conditional Closure Approved |
ADEC John Halverson sent the Air Force a cover letter to accompany the Final April 4, 2007 Final Record of Decision For No Further Action received for signature. The source areas covered by the document include - SS007 (Former Water Supply Lake), SS013 (Landfarm), SS014 (East Tanks), SS015 (Former Power Plant/Garage), SS016 (Buildings 101 and 102), SS017 (PCB Spill at Building 102), SS019 (PCB Spill South Fence), SS020 (Spill Nos. 2 and 3), SS018 (Former Truck Fill Stand), SS002 (Waste Accumulation Area No. 2/Landfill) and ST005 (Former Beach Tanks).
SS012 Spill Nos. 2 and 3 - ADEC concurs no further remedial action is warranted at the site. However, DRO contamination is present at levels as high as 38,000 mg/kg, which does exceed ADEC’s most stringent cleanup levels in 18 AAC 75.341 Table B2. Method Two – Petroleum Hydrocarbon Soil Cleanup Levels (as amended through December 30, 2006) and the Arctic Zone established cleanup level for DRO. The site will be assigned a “Conditional Closure” action in our contaminated sites database.
Monitoring for natural attenuation parameters and contaminant levels will occur every five years. Visual inspection for presence of a sheen at seasonal surface water ponds located at the downgradient edge of the sites every five years will be conducted. Long-term groundwater monitoring for potential migration of DRO off-site and into downgradient groundwater will be addressed by monitoring at ST005 for five years. Soil containing residual contamination may not be placed in surface water or other environmentally sensitive areas.
Please note, per 18 AAC 75.325(i), department approval is required prior to disposing of soil or water from a site that is, or has been, subject to the site cleanup rules. Furthermore, these decisions may be reviewed and modified in the future if new information becomes available that indicates contaminants at a site may cause unacceptable risk to human health or the environment. |
John Halverson |
| 5/28/2008 |
Update or Other Action |
ADEC sent letter to 611 CES/CEVR (M. Ghebresllassie) RE: Draft Long Term Management Work Plan for SS012, SS002, SS018, and ST005 dated May 2008. General Comments- ADEC requests the Air Force, while conducting its sampling at the facility, also document and report on the land use controls (LUCs) at SS012 and SS018, as required by the March 29, 2007 Final Record of Decision (ROD) for SS012 and SS018. The LUCs are designed to limit disturbance and off-site transport to control exposure and protect human health, welfare, safety and the environment. The ROD states that LUCs (also known as institutional controls under 18 AAC 75.375) will be implemented and maintained as long as diesel range organics (DRO) in soil remains above 12,500 mg/kg.
Inspections will be conducted every five years. LUCs will consist of notice in the Base General Plan (BGP) to inform site workers that DRO contaminated soil is not to be moved or disturbed without notifying ADEC. ADEC requests a copy of the most recent version of the BGP for the facility outlining LUCs and LUC boundaries. ADEC requests the Air Force provide a report on the status of LUCs to include: the inspection checklists completed during the reporting period; a statement as to whether all LUCs defined in the 2007 ROD are being adhered to; and a description of any deficiencies in the LUCs and what efforts or corrective measures have been or will be taken, by the Air Force, to correct these deficiencies. The report will also be filed in the Kotzebue LRRS Information Repository.
The LUCs include the following: The LUCs will restrict the excavation of soil that contains the COC above the cleanup level listed in this ROD. The LUCs and LUC boundaries will be documented in the Kotzebue LRSS BGP. The LUCs will be incorporated into an administrative procedure (i.e. dig permits) for the approval of construction activities.
For Table 3-1, in a separate table, or in the text: ADEC requests the Air Force list the parameter, analytical method, sample containers for each method being considered as part of this work plan as well as the method specific preservation and holding times.
Table 3-1 states DRO, BTEX and SVOCs will be sampled at SS012 and SS018 for surface water only if sheen is observed. The March 29, 2007 Final SS012 and SS018 Record of Decision states at 2.10.2 Description of the Selected Remedy on page 32:
“Monitoring of the ponds located downgradient from SS012 and SS018 will be conducted visually for sheen. If a sheen is noted, surface water and sediment samples will then be collected. Samples will be for DRO, BTEX, and SVOCs in sediment and total aromatic hydrocarbons and total aqueous hydrocarbons in surface water. Once an indication of contaminant migration to surface water is noted, surface water and sediment samples will continue to be collected for the remainder of the program until DRO concentrations in soil are below cleanup levels or no sheen is noted on the surface water.”
ADEC will require the Air Force to include in Table 3-1, sampling for: DRO, SVOCs, BTEX in sediments and Total aqueous hydrocarbons (TAqH) via method 625CSIM and Total aromatic hydrocarbons (TAH) via method 602/624 if a sheen is observed.
ADEC requests the Air Force state in this section that it will comply with Technical Memorandum 06-002 (October 9, 2006) which specifies the minimum requirements for laboratory data packages and quality assurance (QA) summaries (data reduction, verification, evaluation, etc.) that must be included in all reports submitted to ADEC under 18 AAC 75 and 18 AAC 78. All reports submitted to ADEC containing analytical laboratory sample results shall contain a completed Laboratory Data Review Checklist and a QA Summary. |
Louis Howard |
| 9/1/2010 |
Update or Other Action |
Environmental Long Term Monitoring and Maintenance for Kotzebue LRSS, Alaska received for review and comment.
Purpose and Scope
The efforts described in this plan consist of environmental monitoring of groundwater, soil,
sediments, surface water, pore water, as well as installing, replacing, and repairing monitoring
wells.
The scope of the field work includes the following tasks:
? Perform planning and permit coordination.
? Repair or replace well ST05-MW9 and install a new upgradient well (ST05-MW10).
? Survey new monitoring well(s).
? Collect groundwater, surface water and pore water (hyporheic zone) samples from areas SS002 and ST005 annually.
? Collect soil samples and visually monitor seasonal ponds on the down-gradient edge of SS012 and SS018. Collect surface water and sediment samples if a sheen is observed.
Soil Sampling – SS012 & SS018
Five soil samples will be collected at approximately 1 ft below the organic layer at each location. Soil sampling locations will be based on past maximum observed concentrations.
SS012 - Three sample locations will be centered at the location where elevated concentrations
of DRO have been observed during past sampling episodes, with two of the samples being located across-slope a distance of approximately 25 ft in either direction from the center sample.
Two additional samples will be located downslope approximately 50 ft from the center sample
location. The purpose of these five samples is to attempt to better characterize the area that
has exceeded ADEC cleanup levels.
Surface Water Monitoring and Sampling – SS012 & SS018
Seasonal surface water ponds located at the down-gradient edge of SS012 and SS018 will be
visually inspected for the presence of sheen. If a sheen is present, two surface water samples
will be collected.
The samples will be analyzed for:
? TAH
? TAqH
Sediment Sampling – SS012 & SS018
Sediment samples will only be collected if a sheen is observed during the surface water visual
inspection. If a sheen is present, two sediment samples will be collected from the same
locations as the surface water samples.
The samples will be analyzed for:
? DRO
? BTEX
? Semi-Volatile Organic Compounds (SVOCs)
Surface Water Sampling
The seasonal surface water ponds located at the down-gradient edge of SS012 and SS018 will
be visually monitored for sheen. Surface water and sediment samples will only be collected if a
sheen is observed. Surface water and sediment samples are to be collected at the same
location, with the surface water sample collected first. |
Louis Howard |
| 2/25/2011 |
Update or Other Action |
Staff received the Quality Assurance Project Plan for Environmental This QAPP describes the QA/QC procedures and other technical field sampling and laboratory analytical procedures to be conducted as part of the environmental long-term monitoring and maintenance effort at Kotzebue LRRS, Sites SS002, SS012, SS018, and ST005. The QAPP defines the project-specific QA/QC requirements that will be followed to obtain quality, interpretable data. The QAPP presents procedures including specific measurement objectives for chemical analyses, sampling and calibration procedures, sample custody, data review and reporting, and internal QC checks. This document meets the requirements and elements set forth in the Intergovernmental Data Quality Task Force Uniform Federal Policy (UFP) for QAPPs (United States Environmental Protection Agency
[USEPA], 2005) and the USEPA Requirements for Quality Assurance Project Plans QA/R-5 (2001).
LTM will be performed at Kotzebue LRRS, Sites SS002, SS012, SS018, and ST005 to include
the following:
Repair/replacement of one monitoring well with installation of one additional upgradient
monitoring well.
Soil samples will be collected from Sites SS012 and SS018 every five years to
monitoring for natural attenuation parameters and contaminant levels and evaluate
trends of reduction of total petroleum hydrocarbons as diesel range organics (DRO)
levels. Five soil samples will be collected from each site.
Surface water samples will be collected annually from Sites SS002 and ST005.
Additionally, every five years, ponds consisting of seasonal surface water located downgradient
of Sites SS012 and SS018 will be visually inspected for the presence of sheen.
If a sheen is present, two samples will be collected (one in each of the two ponds)
Sediment samples will only be collected from Sites SS012 and SS018 if sheen is
observed during the visual inspection which occurs every five years. If sheen is present,
two samples will be collected in the same locations as the additional surface water
samples.
Seven groundwater monitoring wells will be sampled annually from Sites SS002 and
ST005, including the newly installed background well
Pore water samples will be collected at four locations within Sites SS002 and ST005
areas.
Environmental Site/Project Summary Reports will be prepared upon completion of field
activities. The report will document field activities and include a summary of all data
collected, along with data interpretation and significant findings.
It is anticipated that the well repair/replacement and the initial round of sampling will occur
during early Fall of 2010.
Investigations have shown that the groundwater downgradient of areas ST005 and SS002 contains high levels of total aromatic hydrocarbons (TAH) and total aqueous hydrocarbons (TAqH), while DRO contamination was identified in areas SS012 and SS018. TAH and TAqH concentrations downgradient of ST005 and DRO concentrations in SS012 and SS018 exceed the cleanup standards set forth in 18 Alaska Administrative Code (AAC) 75.341, Table B2 Method Two for the Arctic Zone.
TAH includes the compounds benzene, chlorobenzene, toluene, ethylbenzene, 1,2-
dichlorobenzene, 1,3-dichlorobenzene, 1,4-dichlorobenzene, and total xylenes. TaqH consists
of the total of the TAH compounds as well as polycyclic aromatic hydrocarbons (PAHs).
The goal of the environmental long term monitoring and maintenance effort at Kotzebue LRRS
is to assess the presence of contaminants in soil, surface water, sediment, and groundwater
through annually monitoring at Sites SS002 and ST005 and monitoring of natural attenuation at
Sites SS012 and SS018 on a five-year basis.
Soil and potential surface water/sediment sampling (at the seasonal ponds) will occur every five
years at Sites SS012 and SS018 to monitor natural attenuation. Surface water samples from
Sites SS002 and ST005 will occur annually. Long-term groundwater monitoring will occur
annually at Sites SS002 and ST005. The first sampling event will be conducted after the
repair/relocation and installation of monitoring wells during the 2010 field work.
For Sites SS002 and ST005, two surface water samples will be collected from each site; sediment
samples are not collected from these areas.
Monitoring Wells – Seven water samples will be collected at Sites SS002 and ST005 from
beach monitoring wells SS02-MW1, SS02-MW2, SS02-MW3, ST05-MW9 (repaired/replaced), ST05-MW8, ST05-MW6, and ST05-MW2.
Pore Water Locations– Four pore water (hyporheic water) samples will be collected downgradient
of SS02-MW3, ST05MW9, ST05-MW8, and ST05-MW6 within Sites SS002 and ST005 |
Louis Howard |
| 3/2/2011 |
Update or Other Action |
Long Term Monitoring and Maintenance for Kotzebue LRRS received. The purpose of the LTM effort is to meet the requirements for groundwater, hyporheic water (pore water), and surface water monitoring at the ST005 and SS002 sites, and for monitored natural attenuation (MNA) sampling at the ST005, SS002, SS012, and SS018 sites, in accordance with the Record of Decision (ROD) (USAF 2007). The objectives of the LTM program include the following:
• Environmental monitoring of groundwater at the beach wells downgradient of SS002 and ST005, and surface water, for potential migration of petroleum contamination off site into the Kotzebue Sound.
• Replace and repair wells, as needed.
• Monitor for natural attenuation parameters and contaminant levels at SS012 and SS018 to evaluate trends in diesel range organics (DRO) concentrations in soils.
• Visually inspect for presence of sheen at seasonal surface water ponds located at the downgradient edge of SS012 and SS018.
The two seasonal ponds located at the downgradient edge of SS012 and SS018 were visually
inspected for the presence of sheen or other evidence of hydrocarbon impacts as specified in the
work plan. No indication of sheen was observed and therefore no surface water samples were
collected.
The 2010 LTM sample locations were determined by first establishing Global Positioning System
(GPS) coordinates for the two sample locations where elevated concentrations of petroleum
hydrocarbons were reported in the 2004 RI/FS (U03-SS12-S2-01 and U03-SS18-S8-01). The GPS
coordinates for these sample locations were calculated by digitizing the site figures from the RI/FS and overlaying them into Arc GIS software where coordinates were then established.
At SS012, three sample locations were centered at the location of U03-SS12-S2-01, with two of the samples being located across slope, approximately 25 ft in either direction from the original sample location. Two additional samples were located in a downslope direction approximately 50 ft from the original sample location.
All surface soil samples were collected at a depth of one foot below the surface. The soil samples were analyzed to evaluate the current DRO, BTEX and semi-volatile organic compound (SVOC) concentrations at the sites, as well as nitrate/nitrite to monitor natural attenuation parameters.
Concentrations of DRO in soil samples from the SS012 site ranged from 320 mg/kg to 1,800 mg/kg
and are approximately an order of magnitude or more below the 12,500 mg/kg ADEC Method 2,
Table 2 arctic zone cleanup cited in the ROD.
It appears that the 2010 LTM sampling program reestablished the location where elevated DRO
concentrations were identified in the RI/FS. The concentrations observed during this sampling
program are at the same order of magnitude as those reported in the RI/FS.
The two seasonal ponds located at the downgradient edge of sites SS012 and SS018 were visually
inspected and found to be free of sheen, hydrocarbon odor, or other evidence of hydrocarbon
impact.
Reestablishing the location of the original soil samples, as identified in the 2004 RI/FS, and
increasing the number of samples retrieved from one per site to five per site has improved the
accuracy of the LTM program. The DRO concentrations in the soil samples collected at site SS012
are below the 12,500 mg/kg arctic zone cleanup level. |
Louis Howard |
| 4/6/2011 |
Update or Other Action |
Draft Work Plan for Environmental Baseline Surveys for Multiple 611th CES Installations including Kotzebue LRSS, Alaska March 2011 received. A Phase I EBS & possibly a Phase II EBS will be performed at each of the four installations which includes Kotzebue LRRS. Phase I EBS activities will be performed to meet the requirements of Air Force Instruction (AFI) 32-7066 (Environmental Baseline Surveys in Real Estate Transactions), BLM Manual Handbook H-2000-1 (Pre-Acquisition Environmental Site Assessments), & American Society for Testing & Materials (ASTM) E1527-05 (Standard Practice for Environmental Assessments: Phase I Environmental Site Assessment Process).
A records review will be performed & the purpose of the records review will be to obtain & examine records that will help identify recognized environmental conditions in connection with each subject property. Work will be planned to meet requirements of AFI-32-7066 Sections 2.1.1.1, 2.1.1.2, & 2.1.1.4; BLM H-2000-1 Chapter IV, F. 8, & ASTM E1527-05 Section 8. The records review will utilize Worksheet No.1 (Records) from BLM H-2000-1.
Records will be obtained for review from standard sources that are reasonably ascertainable, including federal, state, & local environmental record sources. Reasonably ascertainable topographic maps, aerial photos, fire insurance maps, city directories, & land title records will also be obtained, if available, for review.
If potential environmental contamination is suspected at any of the 4 installations based on the information collected during the Phase I EBS, a Phase II EBS will be performed at the identified locations. The Phase II EBS will consist of limited soil sampling. Soil sampling will be limited to surface soil & shallow (up to 1 foot) soil sampling. No deep soil (greater than 1 foot), surface water, or groundwater sampling is anticipated.
Soil sampling will be performed at each installation in areas where potential environmental contamination is suspected. The objective of the soil sampling will be to confirm the presence or absence of contamination.
Because the Phase I EBS has not yet been conducted, the potential for contamination to be present is currently unknown. Therefore, for purposes of this work plan, the number of samples to be collected per installation has been estimated. Likewise, because the type or types of contamination that may be present is unknown, a relatively broad analytical suite has been specified for each sample. Based on the results of the Phase I EBS, this sampling plan may be adjusted to better meet Phase II sampling objectives.
Soil sampling will be limited to the collection of surface or shallow subsurface (up to 1 foot) soil samples. It is estimated that about 8 samples will be collected from each installation. Based on historical research & field observations, samples may be analyzed for GRO AK101, for DRO AK 102, for RRO AK 103, for VOCs by EPA Method 8260B, for semi-VOCs by EPA Method 8270C, for PCBs by EPA Method 8082, &/or for metals by EPA Methods 6010B, 6020, & 7471A.
The 611th CES will also supply available reports, records, & reference documents pertaining to the subject property, including the following: previous environmental baseline surveys, titles, deeds, other property records, surveys, maps, photos including aerials, hazardous waste management plans, spill plans, installation comprehensive plans, utility drawings, hazardous materials & petroleum supply records, pesticide management plans, permits pertaining to environmental regulated activities, NOV or noncompliance documentation, environmental incident reports, solid waste disposal plans & records, drinking water quality records, & records pertaining to PCBs, radon, & lead-based paint. In addition, the 611th CES will supply ERP & CERCLA documents related to potentially contaminated or contaminated areas within each subject property.
Soil sampling will be performed in accordance with SOP-04 (Surface Soil Sampling). Soil samples will be collected using a stainless steel trowel or spoon and will be transferred directly into pre-cleaned sample containers supplied by the analytical laboratory. Samples collected from each installation will be named, labeled, and handled in accordance with SOP-06 (Sample Handling and Custody). All sampling packing and shipment will follow SOP-05 (Packing and Shipping of Environmental Samples).
To the extent practicable, all soil samples will be collected using pre-cleaned, disposable, stainless steel sampling instruments. The use of pre-cleaned and disposable sampling equipment will negate the need for equipment decontamination and will help to minimize investigation-derived waste (IDW). All disposable sampling equipment and any generated IDW will be bagged and carried back by the sampling team to be properly disposed of in either Fairbanks or Anchorage. |
Louis Howard |
| 7/1/2011 |
Update or Other Action |
Long Term Monitoring and Maintenance for Kotzebue LRRS received. The LTM for LRRS includes four sites: the Former Beach Tanks (ST005), Waste Accumulation Area No. 2 (SS002), Spill No. 2 & 3 (SS012), and Former Truck Fill Stand (SS018). The purpose of the LTM effort is to meet the requirements for groundwater, hyporheic water (pore water), and surface water monitoring at the ST005 and SS002 sites, and for monitored natural attenuation (MNA) sampling at the ST005, SS002, SS012, and SS018 sites, in accordance with the Record of Decision (ROD) (USAF 2007).
The objectives of the LTM program include the following:
-Environmental monitoring of groundwater at the beach wells downgradient of SS002 and ST005, and surface water, for potential migration of petroleum contamination off site into the Kotzebue Sound.
-Replace and repair wells, as needed.
-Monitor for natural attenuation parameters and contaminant levels at SS012 and SS018 to evaluate trends in diesel range organics (DRO) concentrations in soils.
-Visually inspect for presence of sheen at seasonal surface water ponds located at the downgradient edge of SS012 and SS018.
Surface Water Pond Inspection at SS012 and SS018
The two seasonal ponds located at the downgradient edge of SS012 and SS018 were visually inspected for the presence of sheen or other evidence of hydrocarbon impacts as specified in the work plan. No indication of sheen was observed and therefore no surface water samples were collected.
For the 2010 sampling program, sample locations were based on the figures and descriptions as presented in the 2004 RI/FS and rather than as presented in recent LTM events, as it was difficult to establish whether the recent sampling events had successfully retrieved samples from the locations where elevated DRO concentrations had originally been identified. For this sampling event, five surface soil samples were retrieved from each site.
Concentrations of DRO in soil samples from the SS012 site ranged from 320 mg/kg to 1,800 mg/kg and are approximately an order of magnitude or more below the 12,500 mg/kg ADEC Method 2, Table 2 arctic zone cleanup cited in the ROD.
Concentrations of DRO in soil samples from the SS018 site ranged from 140 mg/kg to 21,000 mg/kg. Two of the five sample sites (SS018-S3 and SS018-S4) reported concentrations that exceed the ADEC Method 2 cleanup level of 12,500 mg/kg (15,000 mg/kg and 21,000 mg/kg, respectively).
It appears that the 2010 LTM sampling program reestablished the location where elevated DRO concentrations were identified in the RI/FS. The concentrations observed during this sampling program are at the same order of magnitude as those reported in the RI/FS.
Conclusions
Spill No. 2 and 3 Site (SS012) and Truck Fill Stand Site (SS018)
The two seasonal ponds located at the downgradient edge of sites SS012 and SS018 were visually inspected and found to be free of sheen, hydrocarbon odor, or other evidence of hydrocarbon impact.
Reestablishing the location of the original soil samples, as identified in the 2004 RI/FS, and increasing the number of samples retrieved from one per site to five per site has improved the accuracy of the LTM program. The DRO concentrations in the soil samples collected at site SS012 are below the 12,500 mg/kg arctic zone cleanup level.
Two of the five samples from site SS018 exceed the target cleanup level of 12,500 mg/kg. Additional sampling in this area during the next LTM sampling event would better define the extent of the DRO-affected soils |
Louis Howard |
| 10/25/2011 |
Update or Other Action |
Draft EBS report dated October 2011 for AFCEE Contract FA8903-08-D-8769 Task Order 0275 received by staff. The purpose of this EBS is to document the environmental condition of the subject property.
Under the proposed action, USAF intends to reduce its l& holdings at Kotzebue LRRS so that the property is easier to maintain & supervise. The subject property is considered excess & is under consideration for transfer to the U.S. Department of Interior, Bureau of L& Management (BLM).
The information contained in this EBS was obtained through a records search, VSI, physical site inspection, & one personnel interview. The records search included an analysis of historical aerial photographs & a review of available USAF & regulatory agency records. No samples were collected during the visual site inspection (VSI).
NOTE TO FILE ADEC does not accept visual observations as confirmation whether or not a particular area is clean or does not have any contamination that exceeds Tables B1, B2 or Table C of 18 AAC 75. Absence of positive field screening results or those field screening results below an arbitrary threshold cannot be used alone as justification for not taking the associated number of laboratory analytical samples. Unless ADEC indicates otherwise, wherever there is a requirement for field screening, instrumental or analytical methods of detection must be used, NOT olfactory or visual screening methods.
A VSI was conducted July 23 - 25, 2011. The VSI included a walk-through of accessible areas of the subject property. One of the primary objectives of the VSI was to note visual evidence of contamination or potential sources of contamination, including leaks, spills, & any other evidence of releases. Windshield inspections were conducted for small portions of the subject property specifically, along Air Force Road from the City of Kotzebue municipal waste site to the north toward Ralph Wien Airport. Some portions of the subject property were heavily vegetated. These areas were accessed on foot; however, a complete visual survey of these areas was not possible.
Northwest Portion by Junkyard. The VSI included the southern end of the municipal junkyard (from outside the fence line) that is located just north (& outside) the tundra lake area. The junkyard is an adjacent property with potential environmental concerns. At the southwest corner of the junkyard property (just south of the access road), approximately 75 feet east of Air Force Road, were two 55-gallon drums. The drums were in a low spot on the east side of the gravel road & were situated on their sides. The soil next to the drums was black & appeared to be stained with oil. Tire tracks were observed over the stained soil. Based on the local topography, the drums & stained soil appear to be upgradient of the USAF property.
Observations on neighboring property included the following:
• City of Kotzebue l&fill & asbestos disposal area
• Two 55-gallon drums with stained soil located between the City of Kotzebue landfill & the subject property
• Dumpsite on the west side of the road, just north of the City of Kotzebue landfill.
Of these observations, the City of Kotzebue landfill & two 55-gallon drums with stained soil have the potential to affect the subject property because they are approximately 75 feet away (to the north) & upgradient. The city landfill also had one unused AST that was formerly used to contain stove oil. The subject property is downgradient from the city landfill & is, therefore, susceptible to surface runoff or windblown deposition of contaminants. Shallow groundwater may also be affected, because seasonal groundwater has been documented in the area surrounding the tundra lake.
Conclusions
Of the surrounding properties assessed during the VSI & records search, the findings at the neighboring City of Kotzebue landfill have the potential to have an impact on the subject property. These findings include two 55-gallon drums next to stained soil & an unused AST labeled as containing stove oil. These items have the potential to release contaminants to the surface soil by overflow or to seep into the soil & shallow groundwater. Because the subject property is downgradient, these contaminants have the potential to migrate beneath the subject property.
The subject property has been classified as ECP Category 1, 2, 4 & 7 as described in Section 6 & shown in Figure 6-1. No additional work is recommended for the portion of the property that has been assigned as Category 1, 2, or 4. However, additional surface & subsurface soil sampling is recommended at the area designated as Category 7 because contaminants from the adjoining City of Kotzebue landfill have the potential to have an impact on the subject property. |
Louis Howard |
| 4/6/2012 |
Update or Other Action |
Draft LTM & Maintenance technical project report received. This report presents the results of the 2011 Environmental Long Term Monitoring & Maintenance (LTM) program at the Kotzebue LRRS. The LTM for the 4 sites: Waste Accumulation Area No. 2/ Landfill (SS002), the Former Beach Tanks Site (ST005), Spill Sites No. 2 & 3 (SS012), & Former Truck Fill Stand (SS018).
The objectives of the LTM program include the following:
- Monitor for natural attenuation parameters and contaminant levels at SS012 and SS018 to
evaluate trends in diesel range organics (DRO) concentrations in soils.
- Visually inspect for presence of sheen at seasonal surface water ponds located at the
downgradient edge of SS012 and SS018.
Surface Water Pond Inspection at SS012 and SS018
The two seasonal ponds located at the downgradient edge of SS012 and SS018 were visually
inspected for the presence of sheen or other evidence of hydrocarbon impacts as specified in the
work plan. No indication of sheen was observed and therefore no surface water or sediment
samples were collected.
Concentrations of DRO in soil samples from Site SS012 ranged from 526 mg/kg to 21,500
mg/kg, with one exceedance above the ADEC Method 2, Table 2 arctic zone cleanup level of
12,500 mg/kg cited in the ROD. The exceedance was observed at sample location SS012-S3
(21,500 mg/kg), and confirmed with SS012-S30 (field duplicate, 33,600 mg/kg) DRO results
also exceeding the cleanup level. Concentrations in four of the five sample points monitored in
this 2011 Environmental Long Term Monitoring event were higher than in the 2010 event.
Periodic monitoring through visual inspection and photo documentation has been completed at SS012. Additionally, five soil samples were collected and analyzed for DRO and natural attenuation parameters. As part of the required Environmental Long Term Monitoring and Maintenance, this event will occur at SS012 until deemed unnecessary by USAF and ADEC.
Further remediation at SS012 is not recommended at this time. However, if in the future, DRO
contamination in the soil is observed to increase, or negatively affect the surrounding area, the USAF may decide at that time to further investigate additional remediation alternatives. |
Louis Howard |
| 6/12/2012 |
Document, Report, or Work plan Review - other |
Staff reviewed and approved the final version of the Kotzebue Long Range Radar Station
Environmental Long Term Monitoring and Maintenance Final Technical Project Report. This report covers SS002, ST005, SS012, and SS018. Sent via email. |
Louis Howard |
| 8/8/2012 |
Update or Other Action |
Draft Environmental LT Mgt. work plan Kotzebue LRRS received.
The efforts described in this plan consist of environmental monitoring of groundwater, soil,
sediments, surface water, and pore water.
The scope of the field work includes the following tasks:
- Collect groundwater, surface water and pore water (hyporheic zone) samples from Sites
SS002 and ST005 annually.
- Collect soil samples and visually monitor seasonal ponds on the down-gradient edge of
SS012 and SS018. Collect surface water and sediment samples if a sheen is observed.
A total of five discrete soil samples will be collected at SS012, with three sample
locations centered at the location where elevated concentrations of DRO have been observed
during past sampling episodes. Two of the three samples shall be located approximately 10 feet
northwest and southeast from the center sample location. Two additional discrete samples will
be located downslope approximately 25 ft southwest from the center sample location.
Seasonal surface water ponds located at the down-gradient edge of SS012 and SS018 will be
visually inspected for the presence of sheen. If a sheen is present, the two surface water samples
will be collected from the seasonal pond. Surface water samples will not be collected from the
seasonal pond if no evidence of sheen is observed.
The samples will be analyzed for:
- TAH by EPA Method 624or SW846 8260B
- TAqH by EPA Method 625
Sediment samples will only be collected if a sheen is observed during the surface water visual
inspection. If a sheen is present, two sediment samples will be collected from the same locations as the surface water samples and their collection locations will be logged with the GPS unit.
Sediment samples will not be collected from the seasonal pond if no evidence of sheen is
observed. |
Louis Howard |
| 3/7/2013 |
CERCLA ROD Periodic Review |
Periodic review received which includes SS012, SS018, and ST005.
Under the direction of the 611th Civil Engineer Squadron (611 CES), a Periodic Review was conducted for Sites SS012, SS018, and ST005 at the Kotzebue Long-Range Radar Site (LRRS), Alaska. This is the first Periodic Review for the Kotzebue LRRS. The review was conducted pursuant to Section 121(c) of the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA), as amended by the Superfund Amendments and Reauthorization Act (SARA) , U.S. Code (USC) Title 42 Part 9601, and Code of Federal Regulations, Title 40, Part 300.430(f)(4)(ii) and undertaken in accordance with the Comprehensive Five-Year Review Guidance (Office of Solid Waste and Emergency Response Directive 9355.7-03B-P [June 2001]. Although no CERCLA hazardous substances are present at any of sites included in this Periodic Review Report for the Kotzebue LRRS, the U.S. Environmental Protection Agency Comprehensive Five Year Guidance has been followed for the approach, format, and content for this Periodic Review.
This Periodic Review is intended to ensure that the remedial actions selected in the Records of
Decision (ROD) for the Kotzebue LRRS, Alaska are being implemented and that they continue to be protective of human health and the environment. To achieve this purpose, this review evaluates the implementation status of the selected remedies, identifies significant variances from the ROD, and makes recommendations for reconciling variances and improving the performance of remedial actions.
On 10 July 2012, Jacobs conducted inspections at SS012, SS018, and ST005 as part of the
Periodic Review process. The purpose of the inspections was to assess the protectiveness of
the remedies and ICs. No evidence of excavations or soil disturbance was identified during
the inspections.
The ICs that are in place include prohibitions on the use or disturbance of soil and
groundwater until cleanup levels are achieved. No activities were observed that would have
violated the ICs. The site areas and boundaries were relatively undisturbed except for minor
damage to a well casing at ST005 and/or miscellaneous debris accumulated from trespassers
at SS018. No groundwater use was observed.
Based on the information contained in this Periodic Review Report, the remedies for SS012
and SS018 have been implemented, meet the remedial action objectives (RAO) defined in the
ROD, and are protective of human health and the environment. A second periodic review is to be conducted in 2017. |
Louis Howard |
| 5/17/2013 |
Update or Other Action |
ADEC has received the final version of the First Periodic Review Report for SS012, SS018, ST005 on April 26, 2013. ADEC has no further comments on the final document and approves the document. |
Louis Howard |
| 6/14/2013 |
Exposure Tracking Model Ranking |
Initial ranking with ETM completed for source area id: 71805 name: auto-generated pm edit Kotzebue SS12 Spill No. 2 and 3 |
Louis Howard |
| 2/4/2014 |
Update or Other Action |
Environmental Long-Term Management report received for review and comment.
The two seasonal ponds located at the downgradient edge of SS012 (Figure 3) and SS018 (Figure 4) were visually inspected for the presence of sheen or other evidence of hydrocarbon impacts, as specified in the Work Plan. No indication of sheen was observed across the ponds, and therefore no surface water or sediment samples were collected.
Sites SS012 soil results for DRO ranged from 146 to 3,490 mg/Kg, BTEX ranged from 0.0244 to 0.1946 mg/Kg, and PAHs ranged from 0.299 to 0.346 mg/Kg. All Site SS012 soil results were below ADEC Method Two Soil Cleanup levels (AAC 2012).
As part of the required LTM for this site, annual LTM will continue to occur at SS012 until deemed no longer necessary by the USAF and ADEC. Further remediation at SS012 is not recommended at this time. However, in the future, if contamination in the soil is observed to increase, or negatively affect the surrounding area, the USAF may decide at that time to further investigate additional remediation alternatives. |
Louis Howard |
| 2/21/2014 |
Document, Report, or Work plan Review - other |
Staff provided comments on draft document.
Qualified Person
Ying Wang is not listed in the final approved Environmental Long Term Management work plan for Kotzebue LRRS Appendix D “Qualified Personnel Form”. Please include the education & relevant work experience [include specific years &/or months of fulltime experience, not just a generic years of experience & list them per project (i.e. 2002-2004)] achieved after the degree or “equivalent” was obtained to satisfy 18 AAC 75.990(100).
ADEC is not interested in any work experience prior to the bachelor's degree or “equivalent” was obtained from an accredited postsecondary institution in environmental science or engineering, geology, hydrology, physical science, or a related field.
General Comments
The list of resumes in future work plans will need to be improved with regards to the years of “Relevant Project Experience”. ADEC is looking for specific years of experience in the resumes for each project worked on by the individual after the degree was obtained.
Currently it cannot be determined by ADEC what years a person worked for which project with the current resumes: “For over a 3-year period…. has conducted various environmental tasks…”
Which three year period was the work conducted? 2007, 2008 & 2009? 1996, 1997 & 1998?
“For more than two years, … conducted a variety of quarterly, semi-annual & annual environmental sampling…”
Which two year period was the work conducted? 2007 & 2008? 1996 & 1997?
Another example, Adam Mastro has a degree in Business Administration obtained in 2009 & lists 6 years of experience. Only four of those years of experience should be listed & could potentially count towards 18 AAC 75.990(100) minimum requirement of 12 months of work experience after the degree was obtained in 2009 [assuming degree was obtained in January 2009 not May 2009 & the degree was applicable to 18 AAC 75.990 (100) which a business administration degree is not eligible]. Unless Adam Mastro has other information otherwise indicating he meets 18 AAC 75.990(100) for a “qualified person” his work must be directly supervised by another that meets 18 AAC 75.990(100).
GW Sampling
Page 15
Once purge stabilization had been achieved, the laboratory-provided sample containers were filled using a low-flow peristaltic pump equipped with disposable Teflon®-lined tubing in accordance with ADEC’s Draft Field Sampling Guidance (ADEC 2010).
GW samples were then submitted to the laboratory for analysis of BTEX & polycyclic aromatic hydrocarbons (PAHs) to determine levels of TAH & TAqH, to measure the current contaminant concentrations at the site. BTEX results were summed to determine TAH, & BTEX & PAH results were summed to determine TAqH.”
Page 16
Please be aware in the future for GW monitoring of BTEX, peristaltic pumps (regardless if “low flow”) are not allowed due biasing sample results of volatiles & other air sensitive parameters low. ADEC will require the Air Force to use other acceptable sampling equipment in lieu of peristaltic pumps. Please amend all future sampling work plans to incorporate these changes. See comment below.
ADEC’s Draft Field Sampling Guidance (May 2010) states:
Disadvantages:
• Depth limitation of ~25 feet.
• Potential for loss of volatile fraction due to negative pressure gradient.
• Unless using an in-line flow through cell for field readings, may not provide reliable or reproducible data for air sensitive parameters e.g. dissolved oxygen, pH, carbon dioxide or iron & its associated forms.”
EPA’s “Low Stress (low flow) Purging & Sampling Procedure for the Collection of GW Samples from Monitoring Wells” Quality Assurance Unit Region 1 EQASOP-GW-001 (rev. January 19, 2010) states:
“The following cautions need to be considered when planning to collect GW samples when the below conditions occur. If the GW degasses during purging of the monitoring well, dissolved gases & VOCs will be lost. When this happens, the GW data for dissolved gases (e.g., methane, ethene, ethane, dissolved oxygen, etc.) & VOCs will need to be qualified. Some conditions that can promote degassing are the use of a vacuum pump (e.g., peristaltic pumps), changes in aperture along the sampling tubing, & squeezing/pinching the pump's tubing which results in a pressure change.
Therefore, ADEC requests the Air Force cease the use of peristaltic pumps at Kotzebue LRRS as part of the GW monitoring program (where BTEX & other air sensitive parameters are being sampled) & sample with one of the following: bladder pumps, positive pressure submersible pumps, gear pumps, samplers like Hydrasleeve, Snap Samplers to reduce the loss of volatiles (GRO, BTEX) during sampling.
SS012 Soil Results & SS018 Soil Results
Please use the reference (18 AAC 75.341) instead of (AAC 2012).
|
Louis Howard |
| 3/18/2015 |
Institutional Control Update |
One of several sites with Land Use Controls in effect (LUC Mgt Plan 2015 Pacific Air Forces Regional Support Center Installations, JBER, AK) March 13, 2015.
In addition to ICs established as part of LUCs of the ERP for landfill sites with LUCs in effect, both ERP landfill and 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. Table 1-3 describes PRSC non-ERP landfill sites.
Landfills are defined in 18 AAC 60 as “an area of land, or an excavation in which solid wastes are placed for permanent disposal, and that is not an application site, injection well, reserve pit, or waste pile.” This definition applies to most PRSC ERP and non-ERP sites in Alaska designated as landfills, dumps, or caches. Small PRSC ERP and 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 and included in Table 2-2. However, alternative criteria can and often are adopted through negotiation with ADEC (see 18 AAC 60.900, Waivers). Post-closure notification requirements for Class III landfills, including notifications to ADEC and to potential future landowners, are summarized in Table 2-3. Tables 2-2 and 2-3 both generally assume the subject landfill is closed, has been reasonably well characterized, and a monitoring program for media of concern has been established and approved by ADEC.
Kotzebue LRRS KOT-3 Road Oiling SD003
Kotzebue LRRS KOT-4-Waste Oil No. 1 SS001
Kotzebue LRRS WAA No. 2/Landfill SS002
Kotzebue LRRS Spill/Leak No. 1 SS006
Kotzebue LRRS KOT-6 Barracks/Barracks Area SS008
Kotzebue LRRS KOT-5 PCB Spill SS009
Kotzebue LRRS KOT-5 Solvent Spill SS010
Kotzebue LRRS Fuel Spill SS011
Kotzebue LRRS Spills No. 2 and No. 3 SS012
Kotzebue LRRS Former Truck Fill Stand SS018
Kotzebue LRRS White Alice Tanks (AOC 9) ST004
Kotzebue LRRS KOT-8 Site/Beach Tanks ST005
LUC_RESTRICTION * LUCs (also known as institutional controls under 18 AAC 75.375) will be
implemented and maintained as long as DRO in soil remains above 12,500 mg/kg. Inspections will be conducted every five years.
* LUCs will consist of notice in the BGP to inform site workers that DRO contaminated soil is not to be moved or disturbed without notifying ADEC. |
Louis Howard |
| 4/9/2015 |
Update or Other Action |
Supplemental work plan received.
Minor amendments to the Work Plan for 2015 are listed below and further summarized in Table
1- Summary of Amendments to 2013 ADEC-Approved Work Plan. Supporting information
is provided to document these modifications.
? BEM-Bay West anticipates commencing field work and sampling at Kotzebue LRRS for the
2015 LTM in July/August 2015.
? BEM-Bay West will continue to use qualified persons to conduct or supervise all field work
and sampling at Kotzebue LRRS for the 2015 LTM. Current ADEC Qualified personnel
forms and resumes for all staff potentially performing work on site are presented as
Attachment A. Should other key samplers be required to support the 2015 field sampling
effort, then the resume of the proposed alternate will be provided to ADEC for review and
concurrence prior to commencement of the sampling activities.
? BEM-Bay West will continue to utilize Accutest Laboratories Northern California for
analysis of the groundwater samples associated with the 2015 LTM. Accutest Laboratories
Northern California is an off-site, ADEC-approved, Environmental Laboratory Accreditation
Program (ELAP)-accredited fixed-base laboratory in San Jose, California. Current ELAP
and ADEC certificates and approved analytical parameter and method lists are presented as
Attachments B and C, respectively. |
Louis Howard |
| 4/9/2015 |
Document, Report, or Work plan Review - other |
The Alaska Department of Environmental Conservation (ADEC) has received the Draft Kotzebue Long Range Radar Station Supplemental RA-O Work Plan 2015 Environmental Long Term Management and Remedial Action-Operations,on March 27, 2015 for review and comment. Please provide additional employment history on Jaimlyn Korol with months and year for each of the five relevant projects listed for her and provide the month that she graduated from UAA – Anchorage AK with a Bachelor of Science degree to show that she meets the definition of a “qualified person” as specified in 18 AAC 75.990.
|
Louis Howard |
| 4/20/2015 |
Document, Report, or Work plan Review - other |
Staff received the final version of the Final Kotzebue Long Range Radar Station Supplemental RA-O Work Plan 2015 Environmental Long Term Management and Remedial Action-Operations, Kotzebue LRRS, AK dated April 2015, on April 16, 2015. ADEC will approve the document without further comments. |
Louis Howard |
| 11/3/2015 |
Update or Other Action |
Draft environmental monitoring report received for review and comment. Sites SS012 soil results for DRO ranged from 153 to 4,950 mg/Kg, BTEX ranged from ND to 0.51 mg/Kg, and PAHs ranged from ND to 0.88 mg/Kg. All Site SS012 soil results were below ADEC Method Two Soil Cleanup levels (18 AAC 75.341)
Annual monitoring through visual inspection and photograph documentation has been completed
at SS012 for the 2015 calendar year. A total of five soil samples were collected and analyzed to
determine BTEX, DRO, PAH and natural attenuation parameter concentrations. As part of the
required LTM for this site, annual LTM will continue to occur at SS012 until deemed no longer necessary by the USAF and ADEC. Further remediation at SS012 is not recommended at this
time. |
Louis Howard |
| 12/29/2015 |
Update or Other Action |
Staff assigned changed to Joy Whitsel |
Joy Whitsel |
| 9/26/2016 |
Cleanup Complete Determination Issued |
Issued "Cleanup Complete" determination that removes the institutional controls established with the 2007 Record of Decision. Long term monitoring of Site SS012 occurred in 2008, 2009, 2010, 2011, 2013, 2014, and 2015. No concentrations of benzene, toluene, ethylbenzene, and xylenes or polycyclic aromatic hydrocarbons were above DEC Method Two Soil Cleanup levels (18 AAC 75.341) in any year. Two DRO samples were greater than 12,500 mg/kg for diesel range organics (DRO) – one in 2011 and one in 2014; however, subsequent sampling of these locations detected DRO below the cleanup level. This "Cleanup Complete" determination is subject to the following standard conditions:
1. Any proposal to transport soil or groundwater off-site requires ADEC approval in accordance with 18 AAC 75.325(i).
2. Movement or use of contaminated material in a manner that results in a violation of 18 AAC 70 water quality standards is prohibited. |
Joy Whitsel |
| 9/26/2016 |
Institutional Control Record Removed |
Institutional Controls have been removed. |
Joy Whitsel |
