| Action Date |
Action |
Description |
DEC Staff |
| 12/30/1985 |
Update or Other Action |
Kotzebue Air Force Station (AFS) was originally built as a temporary aircraft control and warning (AC&W) site to fill a radar coverage gap while two permanent sites were being built at Cape Lisburne and Tin City. Kotzebue AFS was equipped with a lightweight search radar when it first became operational in 1950. In 1954, the Alaskan Air Command (AAC) decided to convert the site to a permanent station. Construction of the facilities was completed in 1958. Kotzebue AFS operated as a ground controlled intercept site until 1973 when it was converted to a North American Air Defense Command (NORAD) surveillance station. Communications for Kotzebue AFS were provided by White Alice Communications System (WACS) from 1957 until 1979, when a commercial satellite earth station replaced WACS.
During the site visit for this Phase I Installation Restoration Program (IRP) study the soil in the area behind the power plant was stained with diesel fuel. Fuel was observed at the surfaces of the trenches and in a small stream that flows behind the power plant. Areas of vegetative stress between the installation facilities and the beach were observed. The odor of diesel fuel was present in the area. |
Louis Howard |
| 1/2/1990 |
Update or Other Action |
1988 Stage 1 RI/FS received. Seven soil samples were analyzed for total petroleum hydrocarbons (TPH) and volatile organic compounds in 1988 at ST05 (Beach Storage Tanks). The highest level of TPH was 5,300 mg/kg, exceeding the interim cleanup goal of 1,000 mg/kg. Based on these results, further work was recommended for the site. |
Louis Howard |
| 6/30/1991 |
Update or Other Action |
Stage 2 IRP remedial investigation/feasability (RI/FS) Final Report (July 1989 - September 1990) received. KOT-8 Tanks: This site is southwest of the Composite Facility where petroleum, oil and lubricant (POL) Tank Nos. 1, 2, and 3 are sited adjacent to the installation road near Kotzebue Sound. The site covers an area of about 250 by 900 feet along the beach, where coarse sand and gravel occur without observed permafrost. The tanks were drained in 1985 to suction level, but 3-5 inches of product remains in the tanks. Product measurements from tanks and calculations of the capacities of each tank gave a total estimated amount of 13,900 gallons of product and 2,570 gallons of water in the three POL tanks.
Tank No. 2 was known to leak and was taken out of service prior to the other two tanks. The tanks contained diesel fuel. In 1988, a sheen surrounding Tank 2 was observed, and the site was recommended for further investigation.
In 1989, test pits were monitored for organic vapors with an HNu photoionization meter during excavation to identify zones contaminated with diesel fuel and to comply with health and safety procedures. *NOTE to File: Moist atmospheric conditions (E.G., rain) and high relative humidity (>90%) “quench” signal resulting in low readings. Responses may change if gas mixtures are present yielding misleading results. For concentration >150 ppm TOV, the PID may provide nonlinear or erratic responses.
Dust particles may absorb ultraviolet energy and cause erratic responses in PIDs that do not have filters. Uses lead acid battery which loses power in cold weather. Readings may be affected by power lines, transformers, or radio wave transmitters. Accuracy ± 15% Detection range 0.5 - 2,000 ppm.
Analytical results for total petroleum hydrocarbons (TPH) detected it in all but three soil samples at concentrations ranging from 70 to 21,000 mg/kg. NOTE: the top three analytical results of 21,000 (KOT 8-10) PID 45 ppm, 12,000 (KOT 8-17) PID 45 ppm and 9,800 mg/kg DRO (KOT 8-24) PID 50 ppm did NOT correlate with the top three PID readings: KOT 8-12 PID 85 ppm (9,550 mg/kg diesel range organics DRO), KOT 8-11 and 8-19 PID 75 ppm (1,000 mgkg DRO and 9,300 mg/kg DRO respectively). Analytical results indicate that diesel fuel was present in the soil and was seeping vertically through the underlying sand and gravel to the water table, where it was migrating southwest to Kotzebue Sound. |
Louis Howard |
| 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.
POL TANKS (KOT-8 TANKS) - Interim Remedial Measure-3 Petroleum Oil and Lubricants (POL) tanks located along the beach southwest of the Composite Facility are releasing product to the beach soils and groundwater. Due to the occurrence of coarse sands and gravel at the beach area without any observed permafrost, migration of product towards Kotzebue Sound is considered likely. Sampling during the 1990 field season found total petroleum hydrocarbons (TPH) levels as high as 21,000 ppm TPH in the soil matrix and 8,700 ppm TPH in the groundwater (EPA Method 418.1). Benzene was non-detect in the groundwater, although xylenes and ethyl benzenes and toluene were found. It is estimated that the tanks contain a total of approximately 13,900 gallons of product and 2570gallons of water.
This ongoing release constitutes violations of AS 46 03.710 (Pollution of the Air, Land, Subsurface Land or Water of the State Prohibited), AS 46.03.740 (Discharge of Petroleum or Petroleum Products without a Permit Prohibited), and associated regulations, including Water Quality Standards. According to AS 46 04 020(a) (Removal of Oil Discharges), a person causing or permitting the discharge of oil shall immediately contain and cleanup the discharge. According to AS 46.04 020(b), the containment and cleanup activities must be carried out in a manner approved by the Department.
During recent phone conversations with members of the 5099th it is apparent that the Air Force recognizes the need to remove the product from the tanks and prevent further requests that source control measures be performed as soon as possible and before the end of the 1992 construction season. This removal action should be considered a definite priority to receive, funding and personnel.
Remedial Action During the 1989 field season 24 soil samples and 9 groundwater samples were collected and analyzed at the KOT-8 Tank site. Seven out of nine groundwater samples were found to contain TPH contamination ranging from 560 ppm - 8,700 ppm. The highest values were found within 50 feet of Kotzebue Sound. The sampling conducted thus far at the site may not completely define the lateral extent of the contamination, particularly groundwater contamination. Because the levels of contamination exceed the solubility of diesel the possibility exists that free product exists at the KOT-8 Tank site.
WCC has recommended in situ bioremediation for both soils and groundwater as the most appropriate remedial alternative for the KOT-8 Tank site. The Department agrees with this determination, however, the need for additional containment, such as a slurry wall may should be considered in subsequent work plans.
A boundary may need to be installed to prevent further petroleum hydrocarbon releases to the Kotzebue Sound during the course of remedial activities at the site which, due to climatic conditions, may be expected to last several years. The WCC report also recommends a cleanup level of 1000 ppm TPH for the soils at the KOT-8 Tank site. Cleanup levels for groundwater are not addressed. Alternative Cleanup Levels (ACLs), for soil and groundwater, may be adopted for a site if a risk assessment is conducted and approved by the Department. |
Laura Noland |
| 1/13/1992 |
Update or Other Action |
Dept. of Air Force Letter to ADEC Fairbanks Office:
1. The Air Force agrees that the KOT-8 (Beach Tanks) site is the
highest priority site at Kotzebue AFB. We are currently making
preparations to clean and demolish the Beach Tanks during the
upcoming field season. Present plans include retrograde of the
demolished tanks to Anchorage for disposal. The Air Force also
l'ecognizes the necessity for further remedial activities at this
site once tank removal is accomplished. Present plans also call
for this additional activity to commence in FY93.
2. The landfarm must be maintained and the leachate problems must be addressed. This is an important study to the Air Force. Not
only have we already invested a great deal of money on this project but the proof of concept for arctic environments is very valuable to both the state and the Air Force. Efforts are underway to obtain funding and reestablish this effort.
3. It is our understanding that the major portion of Spill No. 2
is commingled with Spill No. 3. The funding and effort being
sought above for the landfarm will include continuation of all
bioremediation projects at Kotzebue AFB. The II CEOS/DEVR also
plans to determine the condition of the remaining portion of Spill No. 2 (SS012) during the upcoming field season. |
Laura Noland |
| 12/28/1992 |
Update or Other Action |
1992 Tank Removal-The Air Force removed fuel and three above ground storage tanks (ASTs) from the site. The three diesel fuel storage tanks were located approximately 0.25 mile southwest of the Composite Facility, adjacent to Kotzebue Sound. Two of the tanks were 50 feet in diameter and 22 feet high, each with a storage capacity of 7,890 barrels. The third tank measured 44 feet in diameter and 24 feet high, with a storage capacity of 6,500 barrels.
Approximately 39,500 gallons of diesel fuel were estimated to remain in the three storage tanks. Remaining accessory structures included the bermed containment areas, asphalt tank pads within the bermed areas, and a fuel pumphouse. No samples were collected during this project |
Louis Howard |
| 3/16/1993 |
Document, Report, or Work plan Review - other |
Staff reviewed and provided comments on the: Site Investigation or Remedial Investigation Status at Fort Yukon LRRS, Nome Tank Farm, Kotzebue LRRS, Indian Mountain LRRS, Cape Lisburne LRRS and Bear Creek LRRS.
The Alaska Department of Environmental Conservation requests official information regarding the status of the above named facilities. These facilities represent some of the Northern Region's top ranked 11th CEOS facilities or facilities where initial indications are that a serious contamination problem may exist, such as Cape Lisburne LRRS and Bear Creek LRRS.
As you know, the Department prioritizes contaminated sites work based on the Alaska
Ranking Model which helps determine which sites pose the most significant threat to human health and the environment. Ranking can be accomplished with limited environmental data and sampling results. A list of 1lth CEOS facilities and their rankings is included, as well as a list of all NRO sites complete with rankings. To date, the Department is encouraged by the level of work and funding that the 11th CEOS has dedicated to addressing environmental problems at facilities such as Galena AFS, and the seven active Dewline stations.
Kotzebue LRRS
The Department has written several letters to the 11th CEOS documenting our concerns at this facility. Specifically, letters dated November 26, 1991, December 20, 1991, and
January 13, 1992 outline the Department's requests for the emergency removal of POL tanks, additional site investigation, and no further action issues. The Department commends the 11th CEOS on their removal action conducted during the summer of
1992, which addressed the suspected release of product from three POL tanks located on the beach.
Seven, out of nine groundwater samples taken at the KOT-8 (Beach) Tank site during the 1989 field season, were found to contain TPH contamination ranging from 560 ppm - 8,700 ppm. The highest values were found within 50 feet of Kotzebue Sound. The sampling conducted thus far at the site does not completely define the lateral extent of the groundwater contamination. |
Laura Noland |
| 3/26/1993 |
Update or Other Action |
Air Force Response to Site Investigation or Remedial Investigation
Status at Fort Yukon LRRS, Nome Tank Farm, Kotzebue LRRS,
Indian Mountain LRRS, Cape Lisburne LRRS and Bear Creek
LRRS (your Ltr 3 Mar 93).
1. The 11 CEOS has received your letter concerning the status of
the above Air Force installations. In response to your letter the 11 CEOS would like to present the current funding information and future Installation Restoration Program (IRP) activities for each site of concern.
A RI/FS for Kotzebue LRRS has been programmed and validated for FY93, but did not receive funding due to the higher funding priority of other sites throughout Alaska. It is anticipated the project will be funded in FY94.
Projected dates of projects are dependent on funding levels,
Air Force priorities, and A DEC priorities throughout the Northern
and Southcentral Regions. We look forward to working with you in
conjunction with the Southcentral Region in the future. Programming for FY94 is currently underway and is scheduled for
completion in early June. Please contact us to arrange a meeting
to discuss all sites of concern, FY94 programming, and priorities. |
Laura Noland |
| 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. Since 1991, the Department has directed letters to the Air Force (see 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:
1) KOT-8 Beach Tank Site- Three Petroleum Oil and Lubricants (POL) tanks located along the beach southwest of the Composite Facility released product to beach soils and groundwater. Because of the occurrence of coarse sands and gravel at the beach site, migration of product towards Kotzebue Sound is considered likely. Seven, out of nine groundwater samples taken at the KOT-8 Tank site during the 1989 field season, contain Total Petroleum Hydrocarbon (TPH) contamination ranging from 560 ppm- 8,700 ppm. The highest values were found within 50 feet of Kotzebue Sound. The sampling conducted thus far at the site does not completely define the lateral extent of the groundwater contamination, thus the area of contamination may be greater than presently defined.
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 or 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 |
| 6/15/1993 |
Long Term Monitoring Established |
Natural attenuation of POL soil has been monitored since 1993. The results of a risk assessment revealed possible human health and ecological risks from xylenes detected in the soil. The site was recommended for limited remedial action and long-term biannual groundwater monitoring to confirm that natural attenuation is occurring. |
Kevin Oates |
| 3/3/1994 |
CERCLA PA |
Mark Ader EPA sent Lt. Colonel Rodney L. Hunt a letter. This letter is to inform you that EPA Region 10 has completed the review of the Preliminary Assessment (PA) report and all other documents contained in the Regional files for the Kotzebue Air Force Station. The PA and other documents have been evaluated in accordance with 40 CFR part 300 Appendix A, which is EPA!s Hazard Ranking System-(HRS) used to evaluate federal facilities for inclusion on the National Priorities List (NPL).
From our evaluation, EPA has determined that the facility could score high enough to be proposed for inclusion on the NPL. Therefore, additional information is needed in order for EPA to complete the evaluation of the site. Specifically, a Site Inspection (SI) should be completed at the facility.
-Collect 3 collocated surficlal and subsurface soil samples from Waste Accumulation Area 2. Collect 3 beach sediment samples from the mean high water line near the probable point of entry (PPE) from the source.
-Collect 3 surficial soil samples from the White Alice area, 2 wetland sediment samples, on 530 centerz from the PPE from the source to the wetland, and 1 beach sediment sample below the mean hlgh water llne.
-Collect 2 sediment samples from the lake near the sources.
-Collect background soil and sediment samples.
All samples should be analyzed for the complete EPA target compound list (TCL) (organic) and target analyte list (TAL) (inorganic). Data generated should be equivelant to the Contract Laboratory Program (CLP) level 4 data quality. Additionally, response to several of the comments from EPA on the draft PA were incompletely responded to in the final PA.
NOTE to File: CHAPTER 103--COMPREHENSIVE ENVIRONMENTAL RESPONSE, COMPENSATION, AND LIABILITY SUBCHAPTER I--HAZARDOUS SUBSTANCES RELEASES, LIABILITY, COMPENSATION Sec. 9620. Federal facilities (a) Application of chapter to Federal Government
(1) In general Each department, agency, and instrumentality of the United States (including the executive, legislative, and judicial branches of government) shall be subject to, and comply with, this chapter in the same manner and to the same extent, both procedurally and substantively, as any nongovernmental entity, including liability under section 9607 of this title. Nothing in this section shall be construed to affect the liability of any person or entity under sections 9606 and 9607 of this title.
(2) Application of requirements to Federal facilities All guidelines, rules, regulations, and criteria which are applicable to preliminary assessments carried out under this chapter for facilities at which hazardous substances are located, applicable to evaluations of such facilities under the National Contingency Plan, applicable to inclusion on the National Priorities List, or applicable to remedial actions at such facilities shall also be applicable to facilities which are owned or operated by a department, agency, or instrumentality of the United States in the same manner and to the extent as such guidelines, rules, regulations, and criteria are applicable to other facilities.
No department, agency, or instrumentality of the United States may adopt or utilize any such guidelines, rules, regulations, or criteria which are inconsistent with the guidelines, rules, regulations, and criteria established by the Administrator under this chapter. (3) Exceptions This subsection shall not apply to the extent otherwise provided in this section with respect to applicable time periods. This subsection shall also not apply to any requirements relating to bonding, insurance, or financial responsibility. Nothing in this chapter shall be construed to require a State to comply with section 9604(c)(3) of this title in the case of a facility which is owned or operated by any department, agency, or instrumentality of the United States.
(4) State laws State laws concerning removal and remedial action, including State laws regarding enforcement, shall apply to removal and remedial action at facilities owned or operated by a department, agency, or instrumentality of the United States or facilities that are the subject of a deferral under subsection (h)(3)(C) of this section when such facilities are not included on the National Priorities List. The preceding sentence shall not apply to the extent a State law would apply any standard or requirement to such facilities which is more stringent than the standards and requirements applicable to facilities which are not owned or operated by any such department, agency, or instrumentality. |
Louis Howard |
| 5/16/1994 |
Update or Other Action |
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 |
| 6/30/1995 |
Update or Other Action |
1995 Baseline Human Health and Ecological Risk Assessment
A human health and ecological risk assessment was conducted in 1995. Results of the risk assessment revealed no unacceptable risk to human health existed at ST005. An unacceptable risk to ground squirrels was noted due to 2-methylnaphthalene and total xylenes.
The Air Force has found no logical food source for ground squirrels at Former Beach Tanks (ST005) and does not expect them to ingest soil at the site. The Air Force estimates that there is no unacceptable ecological risk at ST005. |
Louis Howard |
| 9/30/1995 |
Update or Other Action |
1995 RI/FS—USAF drilled 24 soil borings; nine of these borings were converted into groundwater monitoring wells. The wells were used to monitor groundwater flow rates and direction, tidal influence, and natural attenuation. Twenty-seven soil samples, nine groundwater samples, and three seawater samples were collected and tested for CERCLA hazardous substances. No CERCLA hazardous substances were identified in soil and seawater samples above EPA cleanup levels.
However, 18,000 mg/kg total diesel range hydrocarbons was detected in soil at 8 ft. below ground surface. In groundwater, Total BTEX and Total PAHs were detected at levels of 562 and 505 ppb, respectively, which exceeded the cleanup levels of 10 and 15 ppb. DRO in groundwater exceeds the ADEC groundwater cleanup level (1,500 ug/L) at a maximum sample concentration of 34,000 ug/L in one well. |
Louis Howard |
| 12/31/1996 |
Update or Other Action |
If specimens are identified as Oxytropis arctica 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 |
| 2/20/1997 |
Site Added to Database |
Site added by Shannon and Wilson. See also Reckey 198932X902515. |
S&W |
| 6/30/1997 |
Update or Other Action |
A synopsis and limited review of investigative and remedial activities at the Kotzebue LRRS prepared for the USDOI BIA prepared by Montauk Environmental Engineering.
Site ST05 - Beach Tanks This is the former location of three large above-ground fuel
storage tanks located along the beach area adjacent to Kotzebue Sound. The fuel storage
tanks were used to store arctic-grade diesel fuel to heat and power the station Petroleum
hydrocarbons in soil (up to 18000 ppm) and in near-beach groundwater (up to 34 ppm) are
primary environmental concerns at the site.
Tetra Tech recommends that based on past IRP activities conducted at Site ST05, the
remaining levels of contaminants detected, and a review of associated ARARs and baseline
risk assessment, limited remedial action be taken, including monitoring of natural attenuation and long-term groundwater monitoring, to evaluate potential contaminant migration to Kotzebue Sound and measure the effectiveness and rate of natural attenuation The natural attenuation and long-term monitoring alternative represents a non-invasive, non-destructive alternative to material removal actions or other approaches that would negatively impact the beach area and local ecosystem at the LRRS In response to concerns regarding the fragility of tundra flora, the USAF has, in cooperation with the State of Alaska Department of Fish and Wildlife, instituted a pilot revegetation program centered around a rare (although not officially endangered) plant, Oxytropts arcbca var. bemebyana (Barneby’s Arctic Oxytrope) This plant is endemic to only several localized populations in the Kotzebue area, and could be severely impacted by remedial excavation activities.
Groundwater monitoring was recommended on a biannual basis, to include sampling of all available site monitoring wells for volatile organics, semivolatile organics, and diesel range organic compounds. The extenuation of site SS02 to encompass site ST05 is planned for the near future, and the monitoring programs instituted at SS02 will be designed to address those concerns associated with the beach tanks area. |
Laura Noland |
| 12/1/1997 |
Update or Other Action |
ST05 is the site of former beach fuel storage tanks. This site consisted of three POL tanks
used to store fuel offloaded from the annual barge shipment for installation use. In 1985,
some fuel product was removed from the tanks, leaving 3 to 5 inches of tank bottom sludge in each. In 1988, a sheen surrounding Tank 2 was observed, and the site was recommended for further investigation (WCC 1991).
In 1989, 28 test pits were excavated and sampled at the beach tank area. Analytical results indicated that diesel fuel was present in the soil and was seeping vertically through the underlying sand and gravel to the water table, where it was migrating southwest to Kotzebue Sound (WCC 1991).
In 1992, the Air Force removed the three storage tanks and their contents from the site.
Remaining accessory structures included the bermed containment areas, asphalt tank pads
within the bermed areas, and a fuel pump house (Tetra Tech 1995). In 1993, ADEC requested more information, expressing a concern about potential ongoing hazardous releases. The results of a risk assessment revealed possible human health and ecological risks from xylenes detected in the soil. The site was recommended for limited remedial action and long-term biannual groundwater monitoring to confirm that natural attenuation was occurring. |
Kevin Oates |
| 12/31/1997 |
Update or Other Action |
Management action plan for the facility received and lists a zone approach for the facility. Zone 2 is ;defined as the beach area and former landfill, located downgradient of the main facility. This area contains the former fuel storage and transfer facilities, including three large former fuel tank locations and a former tar disposal pit. The following areas are identified in Zone 2: Site SS02 - Waste Accumulation Area No. 2/Landfill, Site ST05 - Beach Tanks, AOC 2 - POL Line (recommended for closure). |
Louis Howard |
| 7/31/1998 |
Update or Other Action |
1998 Operation CLEAN SWEEP and soil washing report. The asphalt tank pands, pipeline, bermed containment areas and fuel pump house were removed in 1998 and the site was regraded. The 2,000,000 gallon water above-ground storage tank (AST) was also demolished and removed from the site. Oil or weathered diesel fuel was spread on the ground beneath the ASTs as a corrosion control measure.
Soil samples from the stained area beneath the tank were analyzed for DRO, RRO, VOCs, SVOCs, pesticides, PCBs, and metals. DRO and RRO were detected at maximum concentrations of 10,100 and 2,950 mg/kg resepectively. An estimated of 375 cubic yards of contaminated soil were recommended for excavation and offsite treatment. |
Louis Howard |
| 5/5/1999 |
Meeting or Teleconference Held |
Community Meeting-Public asked whether the site road will be left in place when regrading is done to the facility. Air Force stated the site road will be preserved and site access will not be restricted. |
Ann Farris |
| 12/24/1999 |
Update or Other Action |
As part of the long-term groundwater monitoring (LTMP), the Air Force conducted groundwater, surface water, and sediment sampling in 1999. All water samples were analyzed for VOCs, SVOCs, PAHs, total/dissolved metals, and TOC. Sediment samples collected in 1999 were analyzed for DRO, VOCs, SVOCs, total metals, total mercury, and TOC.
In 1999, only four groundwater monitoring wells out of the nine installed during the RI were located. No contaminants were detected in groundwater above cleanup criteria from the four monitoring wells (ST05-MW3, MW4, MW5, and MW7). No contaminants were detected above cleanup levels. |
Louis Howard |
| 12/31/1999 |
Update or Other Action |
Draft Data Advancement Package for SS02 and ST05. No PAHs, TAH, TAqH did not exceed applicable cleanup levels for surface water and groundwater. DRO was below cleanup levels in groundwater and sediment sampling did not show any contamination above applicable cleanup levels. No further cleanup is recommended at SS02 and ST05. |
Louis Howard |
| 8/23/2000 |
Update or Other Action |
The Alaska Department of Environmental Conservation (Department) has received the Draft 2000 Groundwater Monitoring Workplan, Kotzebue LRRS, Alaska. This workplan details the historical soil, sediment, groundwater, and surface sampling completed at sites SS02 and ST05 at the referenced installation, as well as plans for the year 2000 to install seven additional monitoring wells and complete a sampling event. The Department offers the following general review comments:
1. Thank you for your thoroughness in describing the past sampling efforts and results at the two sites. This made the document significantly easier to review.
2. It was unclear if the groundwater and surface water samples would be tested for alkalinity. The Department recommends testing the alkalinity in each of the water samples since this parameter can be valuable in determining the interconnectedness of the surface and groundwater.
3. We also recommend collecting conductivity and temperature data on the surface water samples. Again, these data can be valuable in determining the communication between the groundwater and surface water.
4. The request to dispose of the monitoring well purge water to the land surface is approved, with the following provisions:
•Any water with a noticeable sheen or free-phase product cannot be disposed to the land surface;
•Dispose of the water in a manner that avoids surface runoff and/or surface pooling; and
•Do not dispose of the water on or near sensitive vegetation.
Specific Comments:
1. Page 2-3, 1st paragraph, second sentence. Remove the word “that” before “no residual contamination.”
2. Page 2-4, 1st paragraph, third sentence beginning “The pesticides 4,4’-DDE ….” This sentence does not follow Table 2-1, which indicates pesticides were found in more than one well and not at particularly low concentrations. Please clarify this statement.
3. Page 3-5, Table 3-1. At ST05, the number of groundwater/surface water samples should be nine groundwater and one surface water in order to match the text. |
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.
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Ann Farris |
| 12/21/2000 |
Update or Other Action |
As part of the LTMP, the Air Force conducted groundwater, surface water, and sediment sampling in 2000. All water samples were analyzed for VOCs, SVOCs, PAHs, total/dissolved metals, and TOC. DRO analysis was added to the groundwater analytical suite for the 2000 sampling event. Sediment samples collected in 2000 were analyzed for DRO, VOCs, SVOCs, total metals, total mercury, and TOC.
During 2000 field activities, a total of nine groundwater samples, one marine surface water sample, and one sediment sample were collected. Results from groundwater sampling showed DRO above the regulatory levels in four wells. DRO was found in both the seawater and sediment samples at concentrations below ADEC cleanup levels. |
Louis Howard |
| 3/23/2001 |
Update or Other Action |
Letter from ADEC to Bonnie Smith re: Pacific West Mobile Soil Burning Unit. Inquiry about the air permit requirements for Pacific West's mobile soil burning unit was made with Tim Pilon (Air & Water Quality Division). He stated that he sent Pacific West a letter on July 15, 2000 detailing ADEC's requirements for the unit. Pacific West must "submit a plan to test the maximum throughput of the unit, along with engineering drawings and design specifications," which will allow ADEC to evaluate if the unit meets the throughput limitations as well as the emission standards. As of yesterday, the company has not submitted these documents and does not have the ADEC's approval to operate this unit.
The Pacific West approval is independent of the Kotzebue Air Force Station activities. There the workplan for ST05 should simply state that the soil will be treated using a treatment unit that has been approved for operation by the ADEC. You should be aware, that the approval of the Pacific West unit may not occur in a short time period. |
Ann Farris |
| 5/17/2001 |
Meeting or Teleconference Held |
Staff attended 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 |
Update or Other Action |
ADEC letter to AF (M. Rhoads) re: review comments on draft work plan soil removal and treatment at ST05. Draft proposed plans list volume of soil at 375 c.y. Please verify the volume of soil and indicate how the estimate was determined. Please clarify whether the 1500 c.y. of soil was discovered either across the LRRS or just at ST05. Alternative cleanup levels will not be approved at this time since the Air Force and ADEC are still working on the approval of the proposed plans and cleanup levels for this installation. This work constitutes an interim remedial action and the goal of the excavation is to merely remove the stained soil. Recommend use the 18 AAC 75 "Under 40-inch" "Migration to groundwater" levels (e.g. 250 mg/kg DRO). Although the groundwater is non-potable, it is connected to the surface water and the soil is being placed back on the beach where it may get washed into Kotzebue Sound. A minimum of five samples must be collected from the treated soil stockpile to be in compliance with 18 AAC 78.605. Field screening sample should be collected every 10 c.y. per the UST Procedures Manual, Section 4.5.3. |
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 |
| 7/16/2001 |
Interim Removal Action Approved |
Letter sent to Air Force RE: Approval of the Work Plan for Soil Removal and Treatment at ST05. The work plan describes activities to be completed at the Kotzebue Long Range Radar Site (LRRS) in the 2001 field season. The work includes excavation and thermal treatment of 300 cubic yards of soil from the former water tank footings at ST05 using an on site thermal treatment unit (TTU). After characterization sampling, the treated soil will be used for backfill.
The Department approves this work plan, at the request of the Air Force, prior to the establishment of cleanup levels at the site. This removal is considered an interim action and a treatability study for Pacific West's TTU. The Air Force agrees that further remediation may be necessary if the treated soil does not meet cleanup levels to be contained in a pending decision document for the site.
As discussed with the Air Force's contractor on July 10, the soil, post treatment, should be sampled for residual range organics (RRO) by Alaska Method AK103 in addition to other analyses.
Please contact Ann Farris at 907-451-2156 immediately if the TTU is not performing adequately (i.e. field screening indicates there is not a significant reduction in contaminant concentrations or the post treatment analytical soil results indicate high contaminant concentrations). |
Greg Light |
| 12/23/2001 |
Update or Other Action |
2001 Final Environmental Site/Project Summary, Soil Removal and Treatment Approximately 300 cubic yards of fuel-contaminated soil from beneath the former 2,000,000-gallon water AST were removed and treated in 2001. Prior to the excavation, two samples of contaminated material were collected, and each was analyzed for Resource Conservation and Recovery Act (RCRA) metals and DRO/RRO.
Although numerous metals were detected, none exceeded regulatory criteria. DRO and RRO were detected at concentrations of 5,760 and 4,750 mg/kg, respectively. Following the excavation of contaminated material, soil samples were collected at four locations within the former tank footprint to confirm the absence of residual contamination exceeding the DRO regulatory limit. DRO was not detected in the excavation pit samples. Excavated soil was thermally treated onsite and then used to backfill the excavation. Eight samples of post-treatment backfill material were collected to verify acceptable treatment results. Results indicated a maximum concentration of 91.6 mg/kg DRO and 146 mg/kg RRO, well below their respective regulatory criteria. |
Louis Howard |
| 2/27/2002 |
Update or Other Action |
A. Farris letter M. Rhoads (USAF) re: Sampling at Kotzebue Long Range Radar Site. The ADEC has reviewed the results from groundwater, sediment, and surface water sampling events at sites ST05 and SS02. Wells from ST05 and data obtained during 1994 and 2000 events were presented. These sites were not sampled in 2001 and there is no current plan to sample them in 2002 due to funding issues within your program. After reviewing the groundwater data, ADEC feels sampling in 2002 is critical. The results show that there is contamination significantly above regulatory limits and there are not enough data to determine if there are any trends in the concentrations. The SS02 site does not have as high of levels in groundwater, but the past use as a dumpsite and the historical presence of pesticides make it a significant concern.
Due to the close proximity of the sites to the Kotzebue Sound, the elevated contaminant concentrations at ST05, and the toxicity of the chemicals of concern at SS02, it is critical that we are diligent in our monitoring activities at these site.
For these reasons, the ADEC formally requests that the Air Force complete groundwater, surface water and sediment sampling at the ST05 and SS02 sites in 2002. In addition, we hope you will continue to work with us towards getting Proposed Plans and Decision Documents for both the SS02 and ST05 sites so we can both be clear on the remedial requirements and exit strategies for these sites. |
Ann Farris |
| 4/1/2002 |
Update or Other Action |
AF M. Rhoads to A. Farris re: SS02 & ST05 update. Per ADEC's letter dated February 27, 2002, the Air Force agrees with the necessity to obtain additional sample data from the two beach area sites at Kotzebue Long Range Radar Site (LRRS) during the summer season of 2002. As you correctly state, we do have contamination well above the regulatory limits at the two beach area sites. Because of these factors, we have examined our plans for the Kotzebue LRRS for FY02.
The Air Force has decided to initiate an "out of cycle" effort to establish a new Remedial Investigation/Feasibility (RI/FS) phase of work for sites SS02 and ST05. They should be able to initiate sampling on the RI/FS during the summer of 2002. This effort will allow us to gather additional information to better assess the best options to assure human health and the environment are not endangered. This additional information will be used to complete a Feasibility Study that will address the monitoring needs of the entire facility and allow us to do modeling to help both the State of Alaska and the Air Force to develop clear remedial goals and exit strategies for the environmental restoration of Kotzebue LRRS. |
Ann Farris |
| 10/9/2002 |
Document, Report, or Work plan Review - other |
Staff provided Comments on the Draft 2002 Groundwater Monitoring Workplan Addendum, Kotzebue Long Range Radar Station, Alaska, October 2002.
1. Page 2-1, 1st Paragraph, 2nd Sentence: Please replace “2000” with “2002.”
2. Page 2-1, 1st Paragraph, 3rd Sentence: Please state that this report is intended as an addendum to the 2000 workplan, which was approved by the ADEC.
3. 2-1, Last Paragraph, Last Sentence: Please clarify in this sentence that the nine wells scheduled for sampling are ST05MW01 through ST05MW09 or their respective replacement wells.
4. Page 2-3, 3rd Paragraph, 3rd Sentence: Please clarify the reference to the ADEC “waiver” for direct discharge. Approval for wastewater discharge activities associated with monitoring wells and waste characterization are permitted via the State of Alaska DEC Wastewater General Permit No. 0240-DB002, which can be found at http://info.dec.state.ak.us/DECPermit/wq/0240db002_pmt.pdf. Since this is a Department of Defense site, the substantive requirements of this permit apply, which in this case, allow the discharge with no specific sampling requirements
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Ann Farris |
| 12/20/2002 |
Update or Other Action |
As part of the LTMP, the Air Force conducted groundwater monitoring was conducted in 2002. All water samples were analyzed for VOCs, SVOCs, PAHs, total/dissolved metals, and TOC. All nine groundwater monitoring wells at ST05 were sampled in 2002. Bis(2-ethylhexyl)phthalate was detected above the regulatory criteria (6 µg/L). DRO was also detected above the regulatory level in five wells. Neither arsenic nor nickel was detected above cleanup criteria. Aluminum, copper, iron, and/or manganese were detected at levels above cleanup criteria in all monitoring wells at ST05. |
Louis Howard |
| 2/11/2003 |
Update or Other Action |
Staff reviewed the results of the 2002 groundwater sampling. Nine wells were sampled between the site and Kotzebue Sound. Samples were analyzed for the full suite of chemicals, including VOCs, SVOCs, DRO, metals, and TAH and TAqH. Four wells exceeded the TAH and TAqH standards and the DRO cleanup level. Iron and Manganese were elevated in 8 of the 9 wells. |
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 |
| 1/15/2004 |
Update or Other Action |
Remedial Investigation conducted in Fall 2003 at facility. The 2003 sampling program at ST05 was intended to evaluate existing contaminant concentrations, the potential for contaminant migration to Kotzebue Sound, and to measure the effectiveness and rate of natural attenuation at the site. Activities performed at ST05 in 2003 included the collection of groundwater samples from the monitoring well network in accordance with the workplan. A potentiometric water-level survey was also conducted. Monitoring well SS02-MW3 was included as part of the ST05 monitoring well network to evaluate the presence of fuels which may have potentially migrated to SS02.
DRO was detected in 9 of the 10 monitoring wells sampled. The reported concentrations of DRO in groundwater at ST05 ranged from 11,000 µg/L in wells ST05-MW2 and ST05-MW8, ST05-MW6 at 10,000 ug/L to below detection limits in well ST05-MW4.
When exclusively comparing the 2003 and 1994 RI results for qualitative purposes, 6 of the 10 ST05 monitoring wells decreased in DRO concentrations. Monitoring wells SS02-MW3, ST05-MW3, ST05-MW6, ST05-MW7, ST05-MW8, and ST05-MW9 all decreased in DRO concentration. Reported DRO concentrations in wells ST05-MW1, ST05-MW2, and ST05-MW5 all increased. The concentration of DRO in well ST05-MW1 increased from undetectable levels in 1994 to 79 µg/L in 2003; however, more significantly, the concentration of DRO in well ST05-MW2 increased from 4,700 µg/L in 1994 to 11,000 µg/L in 2003. While no groundwater well showed exceedances above the screening level of 15,000 ug/L for DRO, TAH and TAqH were exceeded in five wells.
The calculated concentrations of total aromatic hydrocarbons (TAH), and total aqueous hydrocarbons (TAqH) exceeded surface screening criteria in wells: ST05-MW2, ST05-MW6, ST05-MW8, ST05-MW9. The groundwater sample from well ST05-MW6 reported the highest TAH and TaqH concentrations at 854.5 ug/L and 1,0887.17 ug/L respectively.
Based on historical and current data, it appears that the plume is relatively stable in contaminant concentration and location. Seasonally influenced infiltration and groundwater flow rates, storm surge events, and tidal influences are affecting the groundwater flow regime at the site. The net effect of these variables appears to be creating a relatively stable plume. Furthermore, the occurrence of natural attenuation processes may contribute to the stability of the contaminant plume.
Values equal to 10 times (10x) the groundwater cleanup levels presented in Table C of 18 AAC 75.345 were used as primary groundwater screening criteria. In accordance with criteria listed in 18 AAC 75.341(b)(2)(A), groundwater that does not constitute a potential drinking water source can be considered for 10x cleanup levels. Due to the brackish character of near-beach groundwater at SS02 and ST05, the groundwater is considered to not be a likely future drinking water source. Geochemical testing of near-beach groundwater at ST05 during the 1994 RI reported chloride concentrations as high as 760 mg/L. According to surface water quality criteria set forth in 18 AAC 70.020, the reported chloride concentration exceeds the maximum allowable chloride concentration of 250 mg/L for a fresh drinking water supply.
Due to the proximity of groundwater to Kotzebue Sound and the shallow nature of the aquifer, Alaska surface water quality criteria (18 AAC 70) and surface water quality regulations were also used to establish groundwater screening criteria. The selected screening criteria were used only to evaluate the nature and extent of groundwater contamination and determine COPCs. The groundwater screening criteria were evaluated on an analyte- or chemical-specific basis. Potential and selected groundwater screening criteria are summarized in Section 7 and include the preliminary ARARs; ADEC 18 AAC 75 Table C, national MCLs (primary drinking water standards), national maximum contaminant level goals (MCLGs), and Alaska surface water quality criteria (18 AAC 70).
A localized area of near-beach groundwater is present at SS02 and ST05. Because contaminated groundwater is considered the environmental media of concern at these sites, and groundwater monitoring is likely to continue, the migration of residual fuels in soil would be evident in future groundwater results. No soil samples were collected at SS02 and ST05 during the 2003 RI/FS. |
Ann Farris |
| 1/27/2004 |
CERCLA Proposed Plan |
Approval of the Kotzebue Long Range Radar Site, Sites SS02 and ST05, Kotzebue, Alaska Proposed Plan for Cleanup, dated January 2004
The Alaska Department of Environmental Conservation (ADEC) has completed review of the Kotzebue Long Range Radar Site, Sites SS02 and ST05, Kotzebue, Alaska Proposed Plan for Cleanup, dated January 2004. The plan presents cleanup options and cleanup levels for the SS02 and ST05 sites, which are located on the beach adjacent to Kotzebue Sound. Site SS02 was a former waste accumulation area and landfill. Two removal action have been completed and there have not been any concentrations above screening criteria or ADEC cleanup levels in the soil, sediment, surface water, or groundwater since 1999.
Site ST05 was the location of three above ground storage tanks. The groundwater and soil have elevated concentrations of diesel-range organics and the water quality parameter total aromatic hydrocarbons (TAH) and total aqueous hydrocarbons (TAqH). The U.S. Air Force’s preferred cleanup alternative is closure at SS02 and monitored natural attenuation at ST05. The proposed cleanup levels for the groundwater are 18 AAC 70 Alaska Water Quality Standards for TAH and TAqH and the 18 AAC 75 Table C cleanup level for diesel range organics of 1.5 mg/L.
ADEC concurs with the January Proposed Plan. We additionally request that Site SS02 have an administrative control (i.e. notice in the Base Management Plan) such that anyone doing work in that area would be notified the site was a former landfill. This item does not need to be included in the proposed plan.
The plan should now be submitted for public comment. Once public comments are received, the Air Force should prepare a responsiveness summary for inclusion in the final decision document. Please advise our office of the commencement date of the public comment period and schedule for any public meetings.
Please note that ADEC’s review and concurrence with this Proposed Plan is to ensure that the remedial efforts are completed 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 with the plan does not relieve responsible persons from the need to comply with other applicable laws and regulations. |
John Halverson |
| 1/12/2005 |
Update or Other Action |
File number updated with subfile 410.38.002.06. |
Aggie Blandford |
| 6/1/2005 |
Update or Other Action |
Final version of the Proposed Plan received. ST05 PROPOSED CLEANUP ACTION-After careful consideration of the cleanup alternatives, USAF selected Alternative 2--Monitored Natural Attenuation as the proposed cleanup action. ADEC agrees with this selection. The final remedy proposed for ST05 includes the following parts:
Long-term monitoring will be performed according to a plan that would evaluate if fuel levels in groundwater are decreasing as part of natural attenuation. The amount of time necessary for groundwater to reach cleanup goals is not well known.
Groundwater cleanup levels proposed in this Proposed Plan are based on 18 AAC 75 and 18 AAC 70. 18 AAC 75 indicates that groundwater closely connected to surface water must meet the surface water quality standards (18 AAC 70). Proposed cleanup levels are included in the following table and have been modified by the ten times (10X) rule for 18 AAC 75 Table C values because groundwater cannot be used for drinking due to its high salt content.
Institutional controls will be documented in the Base General Plan. USAF will implement, monitor, maintain, and enforce the institutional controls until such time as cleanup goals are met. USAF’s established dig permit and construction review system will continue to be utilized to restrict incompatible activities from contaminated groundwater. Periodic visual inspections will be performed to verify the effectiveness of the institutional controls. |
Louis Howard |
| 7/19/2005 |
Meeting or Teleconference Held |
A public meeting was held in the Kotzebue IRA offices on 19 July 2005. The meeting was open to the public and was advertised in the local newspaper and on the local radio station (KOTZ) but was sparsely attended. Because of the small number of people in attendance, an open discussion was encouraged as the Proposed Plan was presented. Most comment offered during the meeting was in the form of questions for clarification and did not reflect direct comment on the Proposed Plan.
Public questioned whether there is fuel contamination present in groundwater at site ST005.
Air Force response: As stated in the Proposed Plan, fuel contamination is present in groundwater at the site and will be the subject of the monitoring planned for ST005.
Community asked whether the Air Force introduce bacteria during the operation of the Landfarm.
Air Force response: No bacteria was introduced at the landfarm but naturally occurring bacteria are present in soil at Kotzebue LRRS and bioremediation did take place during the operation of the Landfarm.
There was a question regarding the source of the gravel used to build the site.
Air Force response: That information is unknown, however, the gravel may have been barged in to the site because there are no obvious borrow source areas in the Kotzebue area.
Community asked whether there is any PCB contamination remaining onsite.
Air Force response: No known PCB contamination remains.
Community member wanted to address the land transfer issue associated with the clean up of Kotzebue LRRS.
Air Force response: During the normal course of events, land transfer is accomplished after cleanup is complete and is handled through the Bureau of Land Management. One other avenue that is sometimes available is through intervention of the Congressional delegation via inserts to public law or congressional mandates included in legislation.
No formal written comments were received during the open comment period. Neither were comments received by the toll free telephone line. |
Louis Howard |
| 11/3/2006 |
Document, Report, or Work plan Review - other |
ADEC Comments on Air Force's Proposed Plan for Cleanup at Sites SS02, ST05, SS12, and SS15 at Kotzebue Long Range Radar Site. ADEC has reviewed 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. I 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.
Specific comments are as follows:
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.
At this point, the Department is unable to approve the Proposed Plan. Please address the above-comments and resubmit as a draft. |
Ann Farris |
| 6/28/2007 |
Document, Report, or Work plan Review - other |
Staff reviewed and commented on the draft Record of Decision for SS02 and ST005 dated May 1, 2007. The Alaska Department of Environmental Conservation (ADEC) obtained the above document for review and comment on May 29, 2007 via electronic mail.
Table 2 references Total aqueous hydrocarbons (TAqH) and Total aromatic hydrocarbons (TAH), but does not list them in the table as an analyte. Perhaps the intent of the Air Force was to add the reference to TAH and TAqH to Table 3. Please correct tables.
ADEC requests adding a row to the top of the Table 3 similar to Table 2 which includes: Regulatory Level, Year, Analyte (units), TAH 10 µg/L and TAqH 15 µg/L.
ADEC requests Table 4 include reference to diesel range organics (DRO) found in groundwater during the 2003 Remedial Investigation/Feasibility Study (RI/FS) at 11,000 µg/L and the ADEC groundwater ten times (10X) Table C Groundwater Cleanup levels. Table 2 of the document references the “Ten times rule” which was exceeded in 2002, but not in 2003 for wells: ST05-MW2, ST05-MW8, ST05-MW9. ADEC also requests adding regulatory citation to 18 AAC 75 -- Alaska Oil and Other Hazardous Substances Pollution (ADEC, 2006) and reference to contaminant of concern DRO – diesel range organics.
The text states the Air Force will provide notice to the State of Alaska prior to any transfer or sale of property encompassing SS002 and ST005, including transfers to private, state, or local entities. ADEC requests the text be changed to state: “…the Air Force will provide no less than a ninety (90) day written notice….” Similar comment will apply to the Air Force providing ADEC with notice for federal-to-federal transfer of property accountability and administrative control. ADEC requests the text be changed to state: “…the Air Force further agrees to provide ADEC with a similar ninety (90) day written notice for federal-to-federal transfer of property accountability and administrative control.”
ADEC requests the following changes to bullet items describing land use controls (LUCs) at SS002 and ST005:
The third bullet should state, “An annual report on the status of LUCs will be submitted to ADEC.”
The fourth bullet should state, “The Air Force shall provide written notice to ADEC as soon as practicable after discovery of any activity that is inconsistent with the LUC requirements, objectives or controls…”
The fifth bullet should state, “If the Air Force requires a substantial LUC modification or termination of the LUCs inconsistent with this ROD, the Air Force and ADEC will evaluate whether the proposes modification/termination is appropriate and whether the ROD will be amended.”
ADEC requests changes to the text as follows: “LUCs will continue to be required at SS002 indefinitely because the site is a former landfill with undocumented contents.”
ADEC requests text be changed as follows for first paragraph: “No COCs have been found at SS002.” ADEC also requests the text for the last paragraph be changed to include the following: “However, periodic reports for LUCs and groundwater monitoring will be required under State of Alaska regulations until TAH and TaqH cleanup levels are met.”
ADEC requests text be added as follows: However, periodic reports for LUCs and groundwater monitoring will be required under State of Alaska regulations until TAH and TAqH cleanup levels are met. |
Louis Howard |
| 8/16/2007 |
GIS Position Updated |
66° 50' 26"N, 162° 36' 09"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.
ST005 (Former Beach Tanks) is located along the beach of Kotzebue Sound and on both the northwest and southeast sides of the POL Pump House. ST005 was the location of three large fuel aboveground storage tanks (ASTs) and one large water AST located along the beach adjacent to Kotzebue Sound. The fuel storage tanks were used to store arctic-grade diesel fuel to heat and power the LRRS. The water tank stored potable water for operational use at the facility. In 1992, the Air Force removed the three fuel storage tanks from the site. The Air Force removed the water storage tank in 1998 as part of Clean Sweep. Fuel contamination linked to past installation operations and activities is the primary environmental concern at ST005. There were no documented spills or leaks at ST005. It is suspected that incidental spills of unknown quantities occurred during the more than 20 years (1950s to 1976) of fuel handling at the site. Due to the proximity of Kotzebue Sound to ST005 and the shallow nature of the near-beach groundwater, the surface water adjacent to the site has been shown to have a definite mixing effect with the groundwater at ST005.
Because of the mixing of surface and groundwater, the non-degradation provision under the surface water cleanup criteria (18 AAC 70) is applicable to this site. The non-degradation provision requires demonstration that the surface water will not be degraded to a point of non-compliance with the surface water cleanup criteria provided in 18 AAC 70 by this groundwater/ surface water interchange.
Land use controls (LUCs) will be implemented and maintained as long as sampling/modeling of surface water and near-beach groundwater TAH and TAqH concentrations indicate possible groundwater migration from ST005 and contribution to surface water contaminant levels nearby. Notice in Air Force land records to prohibit disturbance within ST005 of surface or sub-surface soil without ADEC concurrence to prevent possible exposure to fuel contaminants.
Sampling of surface water and near-beach groundwater TAH and TAqH concentrations to develop a model of groundwater migration and possible contribution to surface water contaminant levels.
Provide for a survey and document LUC boundaries in the Kotzebue LRRS BGP and Air Force Land Records.
|
Louis Howard |
| 11/1/2007 |
CERCLA ROD Approved |
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. John Halverson (ADEC) signed the ROD on November 1, 2007.
Groundwater diesel range organics are as high as 11 mg/L at ST005. Surface water TAH is as high as 854.5 ug/L and TAqH is as high as 1,088.17 ug/L. Selected remedy will demonstrate non-degradation of surface water due to off-site migration of TAH and TAqH-contaminated groundwater. The principal components of the selected remedies are LUCs to include notice in the Air Force land records to prohibit disturbance of surface or sub-surface soil at either site without ADEC approval and sampling/modeling of groundwater at ST005 to demonstrate non-degradation of surface water.
The decision may be reviewed and modified in the future if new information becomes available that indicates the presence of undiscovered contaminants or exposures that may cause unacceptable risk to human health or the environment. If additional contaminants are discovered, the Air Force and ADEC will determine the compliance levels for cleanup actions. |
John Halverson |
| 11/1/2007 |
Institutional Control Record Established |
Land Use Controls (LUCs) will be implemented and maintained as long as sampling/modeling of surface water and near-beach groundwater TAH and TAqH concentrations indicate possible groundwater migration from ST005 and contribution to surface water contaminant levels nearby. Notice in Air Force land records to prohibit disturbance within ST005 of surface or sub-surface soil without ADEC concurrence to prevent possible exposure to fuel contaminants. |
Louis Howard |
| 11/1/2007 |
Long Term Monitoring Established |
Sampling of surface water and near-beach groundwater TAH and TAqH concentrations to develop a model of groundwater migration and possible contribution to surface water contaminant levels. Sampling of the surface water and near-beach groundwater will continue until TAH (10 ug/L) and TAqH (15 ug/L) are reached (currently expect to be less than five years). |
Louis Howard |
| 11/5/2007 |
Cleanup Complete Determination Issued |
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).
ST005 Former Beach Tanks
ADEC concurs no further remedial action is warranted at this site. However, Total Aromatic Hydrocarbons (TAH) was found to be 854.5 µ/L and Total Aqueous Hydrocarbons (TAqH) 1,088.17 µg/L. Surface water monitoring will occur until cleanup levels are met – TAH 10 µg/L and TAqH 15 µg/L, currently assumed to be five years or less. The site will be assigned a “Conditional Closure” action in our contaminated sites database.
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 |
Document, Report, or Work plan Review - other |
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 |
| 8/22/2008 |
Update or Other Action |
The Air Force sent a copy of the draft Proposed Plan to ADEC for Review. The Proposed Plan presents the Preferred Alternatives for remediation at seven United States Air Force (USAF) Environmental Restoration Program (ERP) contaminated sites at Sparrevohn Long Range Radar Site (LRRS), Alaska which included the Spill/Leak No. 1 site (ST005).
Risk Summary: The 2000 baseline risk assessment included the Spill/Leak No. 1 site as part of the Lower Camp exposure area. The baseline risk assessment concluded that for a worker resident, the only current receptor at the site, the cumulative cancer risk was 4.8 x 10-6 and the noncancer hazard index (HI) was 0.25. Both of these risk values are below ADEC risk management standards. For a potential future worker resident exposed to contaminated groundwater, the baseline risk assessment calculated the risk on a well-by-well basis. Based on the chemical concentrations in each well, cumulative carcinogenic and noncarcinogenic risk values were calculated. Risk values exceeded the ADEC risk management standards in the vicinity of monitoring wells MW5, MW9, MW11, MW22, MW33, MW34, MW35, or MW36, with the highest cumulative cancer risk of 1.6 x 10-3 and noncancer HI of 23.9 occurring in the vicinity of MW36. Cumulative risk calculations for a future resident worker exposed to site soil did not exceed the ADEC risk management standards.
Proposed Action: The Preferred Alternative was selected based on a comparative analysis of five remedial alternatives following CERCLA guidance. The five alternatives considered for this site included no action, institutional controls, capping of PCB contamination, excavation and offsite disposal, and natural attenuation with long term monitoring. Three additional alternatives for groundwater remediation, seepage water control and treatment, capping of seeps, and enhanced bioremediation, were considered as part of an initially screening completed for the Feasibility Study. The initial screening evaluated effectiveness, implementability, and cost. All three failed the initial screening because they did not provide greater protection of human health or the environment then the other more cost effective alternatives evaluated.
Petroleum hydrocarbons exceeding ADEC Method Two screening levels are found in soil across a large area of the site. Additionally, PCB-impacted soil with concentrations exceeding the ADEC Method Two soil cleanup levels of 1 mg/Kg are found to be localized near the former powerhouse area and in the central region of the Lower Camp. Institutional controls were selected as the Preferred Alternative to address soil contamination at the site. Institutional controls will consist of signage identifying the compounds present at the site, updates to the Base Master Plan documenting site conditions, and land use restrictions on construction of residential structures.
Capping of PCB-contaminated soils in the Lower Camp was reviewed. This alternative did not provide significantly better protection than institutional controls for current and reasonable future land use and was more expensive. Excavating and disposing of the soil offsite is significantly more expensive than institutional controls, and would not provide better protection of human health and the environment for site workers. The no action alternative for soil fails to satisfy the threshold criteria, and therefore was not evaluated.
For groundwater and surface water, the Preferred Alternative is natural attenuation with long term monitoring and institutional controls. Petroleum hydrocarbon concentrations in groundwater at the site have shown a decreasing trend over time and natural attenuation parameters measured at select wells suggest that natural attenuation processes are active. A long term monitoring program is proposed to track natural attenuation and determine when groundwater concentrations fall below ADEC groundwater cleanup levels. Additionally, institutional controls are proposed to restrict groundwater use in areas of contamination. Section 121 of CERCLA requires that remedial actions which result in any hazardous substances remaining at the site be
subject to a Five-Year Review. The purpose of the Five-Year Review is to assess the remedy’s performance and protectiveness. Because PCBs exceeding ADEC soil cleanup levels will remain on site, a CERCLA Five-Year Review will be part of the remedy. Additionally, ADEC approval will be obtained prior to moving or disposing of soil contaminated above the Method Two soil cleanup levels. |
Louis Howard |
| 11/25/2008 |
Document, Report, or Work plan Review - other |
Draft Long Term Management Report SS012, SS018, SS002, and ST005 October 2008
Dear Ms. Roy:
The Alaska Department of Environmental Conservation (ADEC) obtained the above document for review and comment on November 14, 2008. ADEC has the following comments on the document.
3.1 Site Reconnaissance Page 3-21
The text states that Well ST05MW09 was damaged. ADEC requests the Air Force address the well protection measure and repair the monitoring well in accordance with the ADEC April 1992 Monitoring Well Guidance adopted by reference [18 AAC 75.345(j)] or replace it with an identical well for future monitoring activities at ST005 if the well is damaged beyond repair. The monitoring well should be permanently decommissioned by sealing with grout, or equivalent, at the end of the post-closure care period, when no longer in active use, when irreparable leakage in the well or annular space is known or suspected, or when the integrity of the well is permanently compromised in some other manner. Wells should be decommissioned by completely sealing the well bore to prevent the entrance of surface contents into the groundwater. Decommissioning must also to prevent vertical movement of water or contaminants between water-bearing zones in both the well casing and the annular space.
4.5 Conclusions and Recommendations Pages 4-34 and 4-35
ST005
The text states there is no need for annual or additional monitoring at wells ST05MW9, ST05MW08, ST05MW06, ST05MW02 since the expected trend of contaminant migration was observed at these wells. ADEC disagrees. The Air Force will monitor contamination at ST005 for total aqueous hydrocarbons (TAqH) and total aromatic hydrocarbons (TAH) annually as long as they remain above those levels specified in the Record of Decision (July 17, 2007).
Page 1-1 of the final Work Plan (June 2008) states monitoring annually groundwater under the direct influence of surface water at the selected beach wells down-gradient to SS002 and ST05 for potential migration of TAH and TAqH off-site into the surface water body (Kotzebue Sound).
Page 36 of the 2007 Record of Decision for SS002 and ST005 states: “A response action is necessary under state petroleum cleanup regulations because of the mixing of surface water and groundwater under the non-degradation provision under the surface water criteria (18 AAC 70). The non-degradation provision requires demonstration that the surface water will not be degraded to a point of non-compliance with the surface water cleanup criteria provided in 18 AAC 70 by this groundwater/surface water interchange.”
Section 2.9 Description of Alternatives: Page 40 of the ROD states: “Monitoring would be performed according to a monitoring plan that would evaluate if TAH and TAqH potential for migration to surface water is occurring at a level that would cause an exceedence of ADEC surface water criteria (1 8 AAC 70). Sampling would be completed in accordance with the comprehensive monitoring plan to be developed by the Air Force and approved by ADEC and would be consistent with the State of Alaska regulations 18 AAC 75.360 and 18 AAC 70. The amount of time necessary for sampling and modeling should be two to five years. Section 2.10 Selected Remedy: Approval from the ADEC is required for any modification of the remedy inconsistent with the objectives of this ROD.”
Table 6 Estimated costs for Alternative 2 Sampling/Modeling of Groundwater Migration with LUCs for ST005 assumed 10 rounds of sampling at twice a year for five years. ADEC approved the 2008 Work Plan with a reduced sampling frequency of once a year for five years. At this time ADEC and the Air Force will review the data and decide on further sampling activities/frequency to comply with the 2007 ROD. |
Louis Howard |
| 2/23/2010 |
Document, Report, or Work plan Review - other |
Draft Long Term Management Report SS002, ST005, SS012, and SS018 dated February 2010 Kotzebue Long Range Radar Station, Alaska
The 2007 Record of Decision requires an annual report be submitted to ADEC for the Land Use Controls (LUCs) at SS002 and ST005.
2.10.2 Description of the Selected Remedy-The LUCs at SS002 and ST005 will be enforced by the following:
- The Air Force will conduct annual inspections that will consist of an administrative evaluation of the LUCs in the Kotzebue LRRS BGP.
- The implementation and enforcement of the LUCs at SS002 and ST005 will be reported to ADEC by the following procedures:
-An annual report on the status of LUCs will be submitted to ADEC for informational purposes only. The report shall include (1) a statement as to whether all LUCs defined herein are being adhered to; and (2) a description of any deficiencies in the LUCs and what efforts or corrective measures have been or will be taken to correct these deficiencies. The report will be filed in the Information Repositories.
6.0 References
Please update the list of references for the following:
Alaska Department of Environmental Conservation (ADEC). 2009. 18 AAC 70 Water Quality Standards (Amended as of September 19, 2009)
Please note, ADEC’s review and comments on this document is to ensure that the work is done in accordance with State of Alaska environmental conservation laws and regulations. While ADEC may comment on other state and federal laws and regulations, our comments on the document does not relieve the Air Force from the need to comply with other applicable laws and regulations. |
Louis Howard |
| 4/7/2010 |
Exposure Tracking Model Ranking |
Initial ranking with ETM completed for source area id: 71810 name: auto-generated pm edit Kotzebue ST05 Beach Tanks |
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. |
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 TAH and TAqH concentrations for site ST005 monitoring wells ST05-MW2, ST05-MW6, ST05-
MW8, ST05-MW9B and ST05-MW10 are shown in Table 5-2 and Figure 2-1. With the exception of
the newly-installed upgradient well (ST05-MW10), the TAH and TAqH concentrations at each of the
ST005 site wells were greater than the established ADEC Water Quality Standards of 10 µg/L and
15 µg/L, respectively. During purging of the wells at ST005, a slight sheen was observed on the purge water from both ST05-MW2 and ST05-MW8, with a moderate sheen observed on water purged from ST05-MW9B.
Hyporheic water samples were collected in accordance with the 2010 Work Plan at the interface
where the groundwater recharges Kotzebue Sound surface water through upwelling. The
concentrations of TAH in two hyporheic zone samples slightly exceeded the surface water quality
standard of 10 µg/L. TAH concentrations at locations ST05-P1 and ST05-P2 were 11.6 µg/L and
15.6 µg/L, respectively. Only the sample from ST05-P2 exceeded the 15 µg/L surface water quality
standard for TAqH, with a reported concentration of 18.9 µg/L. The remaining hyporheic water
samples were below the surface water quality standards for TAH and TAqH.
Two surface water samples (ST05-SW1 and ST05-SW2) were collected from the beach area
downgradient of the ST005 site. The water samples from the beach of Kotzebue Sound were
analyzed for TAH, TAqH and natural attenuation parameters. At the time of sample collection,
wave action was negligible with relatively calm water surface conditions. Since hyporheic water
upwelling into the Kotzebue Sound was not being rapidly mixed and diluted with seawater by wave
agitation, results likely represent worst case concentrations for contaminants in surface water
downgradient of the site at that point in time.
Target analytes were not detected at or above the reporting limit from the surface water samples. Surface water samples did not exceed the criteria for TAH and TAqH.
Contamination resulting from site ST005 continues to impact the site groundwater, and the local
observation of sheen (ST05-MW6, ST05-MW8, and ST05-MW9B) indicates that non-aqueous phase liquid (NAPL) source material is still present. Concentrations of TAH and TAqH remain above the regulatory limits, but continue to show a generally decreasing trend. Surface water at Kotzebue Sound downgradient of the site appears to be minimally impacted. TAH and TAqH was detected from two surface water samples, however detected concentrations are below the regulatory limit. |
Louis Howard |
| 7/11/2011 |
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.
At site ST005, monitoring well ST05-MW9 had been identified as damaged and water samples could not be obtained. As part of this field program, the damaged 9 ft deep well was observed to be filled with gravel and was subsequently decommissioned in accordance with ADEC’s Monitoring Well Guidance (ADEC 2009a) by pulling the 2-inch diameter steel casing out of the ground using a GeoProbe 6610 drill rig operated by GeoTek Alaska. During the removal process, the resulting borehole collapsed and was filled in with the native sandy soils from 9 ft to 3 ft bgs. Bentonite pellets were used to fill the borehole from 3 ft bgs to the ground surface.
A new well (ST05-MW9B) was installed as a replacement for the removed well and is located within 3 feet of the former well location. A second well (ST05-MW10) was installed to the east and upgradient of the ST005 site to provide samples of groundwater that should be unaffected by the known releases at the site. Both wells are constructed of 2-inch outside diameter PVC materials, are finished flush with the ground surface with no stickup, and were installed and developed in accordance with ADEC’s Monitoring Well Guidance (2009).
At site SS002, a groundwater sample was collected from one well (SS02-MW3). As shown in Table 5-4, the analytical results for BTEX and PAHs were all below the method detection level or practical quantitation limit (PQL) and well below the established ADEC Water Quality Standards, showing a TAH concentration of 1.95 µg/L and a TAqH concentration of 2.63 µg/L.
With the exception of the newly-installed upgradient well (ST05-MW10), the TAH and TAqH concentrations at each of the ST005 site wells were greater than the established ADEC Water Quality Standards of 10 µg/L and 15 µg/L, respectively.
During purging of the wells at ST005, a slight sheen was observed on the purge water from both ST05-MW2 and ST05-MW8, with a moderate sheen observed on water purged from ST05-MW9B.
Four hyporheic water (pore water) samples were collected from the Kotzebue Sound water line downgradient of SS002 and ST005. The hyporheic samples from the beach of Kotzebue Sound were analyzed for TAH and TAqH, as well as natural attenuation parameters.
The concentrations of TAH in two hyporheic zone samples slightly exceeded the surface water quality standard of 10 µg/L. TAH concentrations at locations ST05-P1 and ST05-P2 were 11.6 µg/L and 15.6 µg/L, respectively. Only the sample from ST05-P2 exceeded the 15 µg/L surface water quality standard for TAqH, with a reported concentration of 18.9 µg/L. The remaining hyporheic water samples were below the surface water quality standards for TAH and TAqH.
Two surface water samples (ST05-SW1 and ST05-SW2) were collected from the beach area downgradient of the ST005 site. Target analytes were not detected at or above the reporting limit from the surface water samples.
Conclusions
Former Beach Tanks Site (ST005)
Contamination resulting from site ST005 continues to impact the site groundwater, and the local observation of sheen (ST05-MW6, ST05-MW8, and ST05-MW9B) indicates that non-aqueous phase liquid (NAPL) source material is still present. Concentrations of TAH and TAqH remain above the regulatory limits, but continue to show a generally decreasing trend.
Surface water at Kotzebue Sound downgradient of the site appears to be minimally impacted. TAH and TAqH was detected from two surface water samples, however detected concentrations are below the regulatory limit.
|
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:
? Conduct environmental monitoring of GW at the beach wells downgradient of ST005and SS002, & surface water, for potential migration of petroleum contamination off site into the Kotzebue Sound.
? Perform GW modeling using historic & current hyporheic water analytical results to evaluate site contaminant migration through the soil column, into the active layer & toward the Kotzebue Sound.
4 monitoring wells planned for sampling (ST005-MW2, MW6, MW8, & MW9B) were not sampled because there was sheen & strong hydrocarbon odor observed at each well during water level measurements. Based on the 2011 Water Quality Standards, 18 AAC 70, Note 7, which states that samples that determine concentrations of TAH & TAqH must be collected away from any observable sheen.
There were no exceedances for TAH or TAqH from GW samples collected at ST005, as per Alaska Water Quality Standards of 10 µg/L for TAH & 15 µg/L for TAqH.
4 hyporheic water (pore water) samples were collected from the Kotzebue Sound water line downgradient of ST005. Hyporheic water samples were collected in accordance with the 2011 Work Plan at the interface where the GW recharges Kotzebue Sound surface water through upwelling. Hyporheic samples from the beach of Kotzebue Sound were analyzed for TAH & TAqH, as well as natural attenuation parameters. There were no exceedances for TAH or TAqH from hyporheic samples collected.
3 hyporheic water samples were collected (ST005-P1, ST005-P2, & ST005-P3). TAH ranged from 1.75 µg/L to 4.07 µg/L. TAqH ranged from 3.19 µg/L to 10.55µg/L. There were no exceedances for TAH or TAqH from the hyporheic samples collected. 2 surface water samples (ST005-SW1 & ST005-SW2) were collected from the beach area downgradient of Site ST005. The surface water samples were analyzed for TAH, TAqH & natural attenuation parameters.
At the time of sample collection, wave action was negligible with relatively calm water surface conditions. Since hyporheic water upwelling into the Kotzebue Sound was not being rapidly mixed & diluted with seawater by wave agitation, results likely represent worst case concentrations for contaminants in surface water downgradient of the site at that point in time.
Surface water results were ND for TAH & TAqH. There were no exceedances for TAH & TAqH from the surface water samples collected. GW contaminant plume behavior modeling was conducted for the 3 hyporheic sample locations to determine the potential trends for surface water loading into the Kotzebue Sound from previously excavated UST Sites SS002 & ST005. The analysis, monitoring & evaluation process utilized historic data & recent data collected from the existing hyporheic water sampling point data.
These statistical results can assist in developing & finalizing a conceptual site model for the GW migration & to evaluate site contaminant migration through the soil column, into the active layer & toward the Kotzebue Sound. This analysis is also performed to meet requirements set forth by the ROD, to confirm that active zone water downgradient of ST005 continues to meet LTM goals (USAF, 2007).
A Mann-Kendall statistical test was implemented, utilizing 4 years of consecutive hyporheic analytical data, to determine plume behavior surrounding sample compliance points. The test results are indicated by the Mann-Kendall statistic (S), which suggests an increasing trend for positive values, a decreasing trend for negative values or no determinable trend for values equal to zero.
Periodic monitoring through visual inspection & photo documentation has been completed at ST005. Additionally, hyporheic, surface & GW monitoring samples were collected & analyzed to determine TAH & TAqH. As part of the required Environmental LTM & Maintenance, this event will occur at ST005 until deemed unnecessary by USAF & ADEC.
In accordance with the ROD, GW modeling through a single well statistical analysis was performed using historic & current hyporheic water analytical results to evaluate site contaminant migration through the soil column, into the active layer & toward the Kotzebue Sound. As a result of the statistical analysis performed for historic & recent hyporheic sampling events downgradient of ST005, no increasing trend in the three temporary well points (ST005-P1, ST005-P2 & ST005-P3) was observed. |
Louis Howard |
| 8/8/2012 |
Update or Other Action |
Draft Environmental LT Mgt. work plan Kotzebue LRRS received.
Six GW monitoring wells, SS02-MW3, ST05-MW2, ST05-MW6, ST05-MW8, ST05-MW9B & ST05-MW10 will be sampled for:
- TAH by EPA Method 624 or SW846 8260B
- TAqH by EPA Method 625
- Nitrate/Nitrite by EPA Method 353.2 or SM4500-NO3-E
- Total Organic Carbon (TOC) by EPA Method SM5310B
- Ammonia by EPA Method 350.1
- Iron by EPA Method SW846 6010B
- Manganese by EPA Method SW846 6010B
- Chloride by EPA Method 300.0
- Fluoride by EPA Method 300.0
- Sulfate by EPA Method 300.0
- Sulfide by EPA Method 376.2 or SM4500-S-2 D & E
It should be noted that, per ADEC recommendation, all planned GW monitoring wells will be sampled for the full list of planned analytical parameters, even if sheen or a measurable thicknesses of product is encountered at a well.
Two locations will be sampled in the ST005 areas. The samples will be collected from the surface water in the Kotzebue Sound. Surface water sampling locations have been selected based on previous LTM sampling event locations, ST05-SW1 & ST05-SW2.
The samples will be analyzed for:
- TAH by EPA Method 624 or SW846 8260B
- TAqH by EPA Method 625
- Nitrate/Nitrite by EPA Method 353.2 or SM4500-NO3-E
- TOC by EPA Method SM5310B
- Ammonia by EPA Method 350.1
- Iron by EPA Method SW846 6010B
- Manganese by EPA Method SW846 6010B
- Chloride by EPA Method 300.0
- Fluoride by EPA Method 300.0
- Sulfate by EPA Method 300.0
- Sulfide by EPA Method 376.2 or SM4500-S-2 D & E
Pore water (hyporheic water) samples are collected annually at 4 temporary locations within the SS002 & ST005 areas, including SS02-P1, ST05-P1, ST05-P2, & ST05-P3. Samples will be analyzed for:
- TAH by EPA Method 624or SW846 8260B
- TAqH by EPA Method 625
- Nitrate/Nitrite by EPA Method 353.2 or SM4500-NO3-E
- TOC by EPA Method SM5310B
- Ammonia by EPA Method 350.1
- Iron by EPA Method SW846 6010B
- Manganese by EPA Method SW846 6010B
- Chloride by EPA Method 300.0
- Fluoride by EPA Method 300.0
For the SS002 & ST005 areas, surface water samples will be obtained from their designated annual sample collection location. The field team will utilize a GPS unit to navigate to the designated surface water sample collection points for SS002 & ST005. Sediment samples are not collected from these areas.
Contaminant GW modeling will be conducted at Site ST005, adjacent to ST002, to determine the potential for surface water loading into the Kotzebue Sound from previously excavated USTs. The analysis, monitoring & evaluation process will utilize historic data & recent data collected from the existing well network & pore water sampling point data. This data will assist in developing & finalizing a conceptual site model for the ST005 GW migration & to evaluate site contaminant migration through the soil column, into the active layer & toward the Kotzebue Sound. This analysis is also being performed to meet requirements set forth by the ROD, to confirm that active zone water downgradient of ST005 continues to meet LTM goals (USAF, 2007).
A Mann-Kendall statistical test will be implemented, utilizing five years of consecutive ST005 hyporheic analytical data, to determine plume behavior surrounding sample compliance points. M-K is a simple, non-parametric statistical test that provides an end result indicating an increasing or decreasing contaminant trend. Test requirements are a sample group of at least four consecutive rounds of analytical data.
For this statistical model, hyporheic well points ST005-P1, ST005-P2, & ST005-P3 have been identified as downgradient from the potential source locations capable of providing GW contaminant concentrations from within & surrounding the active layer interface where GW recharges the surface water of Kotzebue Sound. ST005-MW2, ST005-MW3, ST005-MW6, ST005-MW8, ST005-MW9B & ST005-MW10 are also planned for sampling in the 2012 field activities, but will not have 4 consecutive data sets to facilitate a statistical model of this type. The ST005 sample group of ST005-P1, ST005-P2, & ST005-P3 has been collected during August & September field activities, from 2008 to 2011, meeting the test requirements. Field studies have indicated that the hydrocarbon contamination had emanated from the previous source areas indicated in Figure 2-2, directly upgradient of the three hyporheic sample locations.
With no existing source, & with natural attenuation occurring in this area over time, TAH & TAqH should decrease over time. This scenario will be considered under the M-K analysis, to determine plume behavior with statistical confidence. Results of the GW migration modeling will be included in the Technical Project Report following field activities. |
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.
The remedies at ST005 may not be protective of human health and the environment because sheen was observed in several wells, which were not sampled in 2011. Additionally, the well casing of monitoring well ST05-MW3 requires maintenance and all monitoring wells should be marked and/or
vegetation cleared.
Issues and Recommendations
Wells cannot be located due to thick vegetation
Recommendation
Clear vegetation around monitoring wells and/or make GPS coordinates available to next Periodic Review team.
Issue
Monitoring Well ST05-MW3 has broken well casing head and is unmarked.
Recommendation
Fix well casing
Issue
Northwest corner of site has been used as a target shooting area and debris dump
Recommendation
Remove surface debris.
Protectiveness is deferred at Site ST005 (Former Beach Tanks) based on a lack of
data to support the model. The protectiveness statement will be revised when sufficient data is
available to make a determination. Additionally, the well casing of Monitoring Well ST05-
MW3 should undergo maintenance to ensure that it is functioning properly. The exposure
assumptions, toxicity data, and cleanup levels, used at the time of the remedy implementation
are still valid. |
Louis Howard |
| 2/4/2014 |
Update or Other Action |
Environmental Long-Term Management report received for review and comment.
Sample results for ST005 monitoring wells for TAH ranged from 1.9 to 152.3 µg/L. Results for TAqH ranged from ND to 480.7 µg/L. The, highest concentrations of both TAH and TAqH were observed from ST005-MW6.
Concentrations of TAH ranged from 1.8 µg/L to 33.9 µg/L, with ST005-P2 and ST005-P3 results in exceedance of Alaska Water Quality Standard of 10 µg/L. Concentrations of TAqH ranged from 31.1 µg/L to 152.9 µg/L, with all three sets of results in exceedance of Alaska Water Quality Standard of 15 µg/L.
Site ST005 surface water results for TAH and TAqH were ND for ST005-SW1 and ST005-SW2. However, there were exceedances for TAqH from the surface water samples collected at Site ST005, in accordance with Alaska Water Quality Standards.
Annual monitoring through visual inspection and photo documentation has been completed at ST005 for the 2013 calendar year. Additionally, hyporheic, surface and groundwater monitoring samples were collected and analyzed to determine TAH and TAqH concentrations. As part of the required LTM for this site, LTM will continue to occur at ST005 until deemed no longer necessary by the USAF and ADEC. Further remediation at ST005 is not recommended at this time.
In accordance with the Kotzebue LRRS ROD, Site ST005 groundwater modeling through a single well statistical analysis was performed using historic and current hyporheic water analytical results to determine if site contaminant migration is occurring and moving towards Kotzebue Sound. The modeling results from the statistical analysis performed for six consecutive years of historic and recent hyporheic sampling events downgradient of ST005 indicate an increasing trend in the two temporary well points (ST005-P1 and ST005-P2), representing an advancing contaminant plume, and suggesting that natural attenuation rates are less than the existing residual contaminant plume’s contribution of dissolved concentrations of TAH and TAqH to ST005 groundwater. |
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 will be implemented and maintained as long as near-beach groundwater TAH
and TAqH concentrations indicate possible groundwater migration from ST005 and contribution to surface water contaminant levels nearby. Notice in Air Force land records to prohibit disturbance within ST005 of surface or sub-surface soil without ADEC concurrence to prevent possible exposure to fuel contaminants. LUCs will continue until TAR and TAqH- concentrations reach the cleanup criteria in this ROD. The areas of LUCs for ST005 are shown in the shaded areas of Figure 1.*Provide for a survey and document LUC boundaries in the Kotzebue LRRS Base General Plan
and Air Force Land Records. |
Louis Howard |
| 11/3/2015 |
Update or Other Action |
Draft environmental monitoring report received for review & comment. Four ST005 monitoring wells were sampled during the 2015 LTM. A fifth ST005 well, ST005-MW9B, was planned for sampling, however as first documented in 2014, the well could not be located at its GPS coordinate-documented historic location. A transient gravel/sand bar is now located in the area where ST005-MW9B is documented to be, & field staff equipped with shovels & a handheld GPS device were not able to locate the well (USAF 2015a). Sample results for ST005 monitoring wells for TAH ranged from ND to 353.1 J µg/L. Results for TAqH ranged from 3.93 to 404.3 µg/L. As is typical for ST005, the highest concentrations of both TAH & TAqH were observed from ST005-MW6.
Overall, evidence for aerobic / anaerobic biodegradation appears extremely low throughout Site ST005 GW. At this time there is inadequate historical data for the remaining ST005 monitoring locations ST005-P3, ST005-MW2, ST005-MW3, ST005-MW6, ST005- MW8, ST005-MW9B, & ST005- MW10 to facilitate a statistical analysis of this type. The selected ST005 sample group of ST005-P1 & ST005-P2 has been sampled during summer field activities from 2008 to 2013, & 2015. There are no 2014 sample results available, therefore in order to allow continuation of the statistical analysis without a gap for 2014, averages of 2013 & 2015 TAH & TAqH results were utilized as placeholders for 2014 values.
With no existing source remaining, & with natural attenuation occurring in this area over time, TAH & TAqH concentrations should decrease over time. This scenario is not at all confirmed by the results of the Mann-Kendall analysis which shows increasing, or advancing plume test results for TAH & TAqH at ST005-P1 & P2. ST005-P1 results indicate positive Mann-Kendall statistics of S = 4 for TAH & S = 10 for TAqH. ST005-P2 results indicate positive Mann-Kendall statistics of S = 6 for TAH & S = 10 for TAqH.
As a result of the statistical analysis performed for historic & recent hyporheic sampling events downgradient of ST005, an increasing trend in the two temporary well points (ST005-P1 & ST005-P2) was observed, indicating an advancing contaminant plume, & the suggestion that natural attenuation rates are less than the existing contaminant plume’s contribution of dissolved concentrations of TAH & TAqH to ST005 GW. In order for a plume to be confidently considered in an advancing state, wells must demonstrate increasing contaminant levels over three or more consecutive rounds of sampling. At this time, ST005 hyporheic water has not demonstrated three consecutive years of increasing contaminant levels, & therefore the ST005 plume cannot be confidently considered in an advancing state. |
Louis Howard |
| 12/29/2015 |
Update or Other Action |
Staff assigned changed to Joy Whitsel |
Joy Whitsel |
| 4/3/2017 |
Institutional Control Periodic Reporting |
DEC approved the Technical Project Report, 2016 Environmental Long Term Monitoring Activities, Kotzebue LRRS, which presented results of collection and analysis of groundwater, surface water, and hyporheic water samples from Sites SS002 and ST005; performance of a Land Use Control (LUC) inspection of SS002 and ST005; and performance of groundwater modeling for Site ST005 using eight years of historic data. Some hyporheic and surface water analytic results exceeded Alaska Water Quality standards for Total Aromatic Hydrocarbon (TAH) and Total Aqueous Hydrocarbon (TAqH) concentrations. As required by the ROD, LTM will continue at ST005 on an annual basis until deemed no longer necessary by the USAF and ADEC. |
Joy Whitsel |
| 3/9/2018 |
Document, Report, or Work plan Review - other |
DEC evaluated the “Draft Technical Project Report, 2017 Environmental Long Term Monitoring Activities, Kotzebue LRRS” dated January 2018. The report presents the results of the 2017 Environmental Long Term Management program at the Kotzebue Long Range Radar Station (LRRS), which consisted of: collection and analysis of groundwater, surface water, and hyporheic water samples from Sites SS002 and ST005; inspection of land use controls (LUCs) at SS002 and ST005; and performance of groundwater modeling for Site ST005 using historic and current hyporheic water analytical results to evaluate site contaminant migration through the soil column, into the active layer and toward the Kotzebue Sound. The sampling of surface water and hyporheic water found no exceedances of Alaska Water Quality standards for Total Aromatic Hydrocarbon (TAH) and Total Aqueous Hydrocarbon (TAqH) concentrations. Comments on the draft report were provided to the U.S. Air Force on 9 March 2018. |
Melinda Brunner |
| 8/13/2018 |
Document, Report, or Work plan Review - other |
DEC has completed a review of the “2018 Periodic Review Report for Sites SS002 and ST005 at Kotzebue Long Range Radar Station, Alaska, Draft” dated May 2018 (the report). The report evaluated the remedies for two sites (SS002 and ST005) that were a part of the Kotzebue LRRS. The USAF certifies that the remedies at the two sites remain protective of human health and the environment, and complies with Federal and State requirements. DEC agrees with the USAF’s recommendation that additional community outreach is needed to eliminate incompatible site use by trespassers; the report has an identified milestone date of 31 October 2018 for this outreach. |
Rachael Petraeus |
| 11/14/2018 |
Document, Report, or Work plan Review - other |
ADEC received the “Final Periodic Review Report for Sites SS002 and ST005 at Kotzebue Long Range Radar Station, Alaska” dated October 2018. The report evaluated the remedies for two sites (SS002 and ST005) that were a part of the Kotzebue Long Range Radar Station (LRRS). The USAF certifies that the remedies at the two sites remain protective of human health and the environment, and complies with Federal and State requirements. ADEC agrees with the USAF’s recommendation that additional community outreach is needed to eliminate incompatible site use by trespassers; the report has an identified milestone date of 31 October 2019 for this outreach.
ADEC approves of the report as final.
|
Rachael Petraeus |
| 11/25/2019 |
Document, Report, or Work plan Review - other |
On November 25, 2019, ADEC received the draft "Draft Technical Project Report 2019 Environmental Long Term Monitoring Activities Kotzebue LRRS dated November 2019". |
Rachael Petraeus |
| 1/28/2020 |
Document, Report, or Work plan Review - other |
ADEC has reviewed the “Draft Technical Project Report, 2019 Environmental Long Term Monitoring Activities, Kotzebue LRRS” dated November 2019. The characterization report summarizes the long term monitoring activities of groundwater, surface water, and pore water at the Kotzebue Long Range Radar Station (LRRS), Sites ST005 and SS002 located in Kotzebue, AK.
|
Rachael Petraeus |
| 2/12/2020 |
Document, Report, or Work plan Review - other |
On February 12, 2020 ADEC has reviewed the “Final Technical Project Report, 2019 Environmental Long Term Monitoring Activities, Kotzebue LRRS” dated February 2020. |
Rachael Petraeus |
| 6/17/2020 |
Site Characterization Workplan Approved |
The Department received the “Draft Supplemental Work Plan 2020 Remedial Action Operations, Land Use/Institutional Control Kotzebue Long Range Radar Station Site ST005” dated February 2020 on March 19, 2020 via email. The document provides a description of work tasks associated with site ST005 at the Kotzebue Long Range Radar Station. The Department provided comments on May 20, 2020, and received a response to comments on June 03, 2020. On June 17, 2020, the Department received a response via email confirming a schedule of work for site SS002 that is planned for September 2020.
All responses are accepted, therefore the work plan is approved for work at site ST005.
|
Rachael Petraeus |
| 9/16/2020 |
Update or Other Action |
DEC approved the "Final Supplemental Work Plan, 2020 Remedial Action Operations, Land Use/Institutional Control, Kotzebue Long Range Radar Station, Alaska, Sites ST005 and SS002” dated August 2020. This work plan addresses monitoring of institutional controls (ICs), as well as groundwater, surface water, pore water, soil, and sediment sampling activities associated with long term monitoring at the Kotzebue Long Range Radar Station (LRRS), Sites ST005 and SS002, located in Kotzebue, Alaska. |
Melinda Brunner |
| 2/9/2021 |
Update or Other Action |
ADEC received the "Draft 2020 Technical Project Report, 2020 Remedial Action Operations, Land Use/Institutional Control Kotzebue Long Range Radar Station Site ST005" dated January 2021, on January 20, 2021. The document describes field activities conducted at the ST005 site near Kotzebue, Alaska. Review comments were provided to the U.S. Air Force on February 9, 2021. |
Erica Blake |
| 2/25/2021 |
Document, Report, or Work plan Review - other |
DEC approved the "Final 2020 Technical Project Report, 2020 Remedial Action Operations, Land Use/Institutional Control Kotzebue Long Range Radar Station Site ST005" dated February 2021. The report discusses groundwater monitoring activities and an institutional controls (IC) inspection at ST005. Five primary samples and one duplicate sample were collected and analyzed for semi-volatile organic compounds (SVOCs). Because only SVOCs were collected total aromatic hydrocarbons (TAH) and total aqueous hydrocarbons (TAqH) could not be calculated. Report recommendations are to continue monitoring contaminants of concern at ST005, and sample for analyses that will allow for the TAH and TAqH calculations. During the IC inspection all six monitoring wells were found not labeled, but in tact. There are continued signs of trespassing. The land use control (LUC) signs were upright, intact, legible and visible. Long-term monitoring work will continue at this site. |
Erica Blake |
| 5/24/2021 |
Document, Report, or Work plan Review - other |
DEC received the Draft Final Work Plan, Remedial Action-Operation and Long-Term Management, Kotzebue Long Rage Radar Station, dated April 2021, received on May 3 2021. The work plan addressed the LUCs and ICs for Kotzebue LRRS, sites SS002 and ST005. A Predicted Degradation Curve/Statistical Trend Analysis is being performed on groundwater contaminants (TAH, TAqH and DRO) to compare concentrations to cleanup goals at ST005.
The 2021 work plan, and 2020 report, noted increased recreational activities such as vehicle traffic, a dog kennel, a fishing shack, and an unpermitted small arms shooting range. The conditional closure requirements and LUCs at SS002 and ST005 are designed to limit disturbances and to control exposure and protect human health and the environment. DEC responded to the work plan on this date requesting for recommendations for evaluating and implementing additional site restrictions as needed. |
Axl LeVan |
| 6/8/2021 |
Document, Report, or Work plan Review - other |
DEC received the Draft 2020 Remedial Action-Operation, Land Use/Institutional Control Report Kotzebue Long Range Radar Station, Sites SS002 and ST005, dated April 2021, received on May 12 2021. The report presents the results and findings of the 2020 Environmental Long-Term Monitoring (LTM) Program at the Kotzebue Rong Range Radar Station (LRRS) and documents the land use controls (LUCs) and institutional controls (ICs) inspections for the two source areas. Additionally, groundwater, surface water, and sediment pore water monitoring activities were performed at Site ST005. DEC provided comments on the document. DEC also noted concerns with the increasing observations of recreational access occurring at the site, potentially disrupting the effectiveness of LUCs for SS002 and ST005. |
Axl LeVan |
| 8/10/2021 |
Document, Report, or Work plan Review - other |
DEC approved the Final 2020 Remedial Action-Operation, Land Use/Institutional Control Report Kotzebue Long Range Radar Station, Sites SS002 and ST005, dated August 2021, received on August 6, 2021. The report presents the results and findings of the 2020 Environmental Long-Term Monitoring (LTM) Program at the Kotzebue Rong Range Radar Station (LRRS) and documents the land use controls (LUCs) and institutional controls (ICs) inspections for the two source areas. Additionally, groundwater, surface water, and sediment pore water monitoring activities were performed at Site ST005. DEC provided comments on the document. DEC also noted concerns with the increasing observations of recreational access occurring at the site, potentially disrupting the effectiveness of LUCs for SS002 and ST005. |
Axl LeVan |
| 8/11/2021 |
Document, Report, or Work plan Review - other |
DEC received the Draft Final Work Plan, Remedial Action-Operation and Long-Term Management, Kotzebue Long Rage Radar Station, dated August 2021, received on August 9 2021. The work plan addressed the LUCs and ICs for Kotzebue LRRS, sites SS002 and ST005. A Predicted Degradation Curve/Statistical Trend Analysis is being performed on groundwater contaminants (TAH, TAqH and DRO) to compare concentrations to cleanup goals at ST005. The 2021 work plan, and 2020 report, noted increased recreational activities such as vehicle traffic, a dog kennel, a fishing shack, and an unpermitted small arms shooting range. The conditional closure requirements and LUCs at SS002 and ST005 are designed to limit disturbances and to control exposure and protect human health and the environment. DEC responded to the work plan on this date requesting for recommendations for evaluating and implementing additional site restrictions as needed. |
Axl LeVan |
| 6/24/2022 |
Document, Report, or Work plan Review - other |
The Alaska Department of Environmental Conservation (DEC) Contaminated Sites Program received a copy of the "Draft-Final 2021 Long-Term Management Report, Kotzebue Long Range Radar Site, Sites SS002 and ST005, dated June 2022" on June 6, 2022. This Report presents the work performed during long-term management (LTM) activities at the Kotzebue Long Range Radar Site (LRRS) under the 611 Civil Engineer Squadron North Group Optimized Remediation
Contract. This work was performed on between August 8-12, and September 21-22, 2021 and included institution control (IC) and land use control (LUC) inspections. Groundwater, porewater, and surface water was sampled for volatile organic compounds, diesel range organics, polycyclic aromatic compounds, and natural attenuation parameters. DEC provided comments on June 24, 2022. DEC reviewed and provided comments on USAF responses on 7/19/2022. |
Axl LeVan |
| 9/1/2022 |
Document, Report, or Work plan Review - other |
The Alaska Department of Environmental Conservation (DEC) Contaminated Sites Program approved the "Final 2021 Long-Term Management Report, Kotzebue Long Range Radar Site, Sites SS002 and ST005, dated July 2022" received on August 31, 2022. This Report presents the work performed during long-term management (LTM) activities at the Kotzebue Long Range Radar Site (LRRS) under the 611 Civil Engineer Squadron North Group Optimized Remediation Contract. This work was performed on between August 8-12, and September 21-22, 2021 and included institution control (IC) and land use control (LUC) inspections. Groundwater, porewater, and surface water was sampled for volatile organic compounds, diesel range organics, polycyclic aromatic compounds, and natural attenuation parameters. All DEC comments were addressed in the final document. |
Axl LeVan |
| 12/8/2022 |
Document, Report, or Work plan Review - other |
DEC reviewed and commented on the Draft 2022 Long-Term Management Report, Kotzebue Long Range Radar Site, Sites SS002 and ST005, November 2022. The report was received November 30, 2022 and presented the results of long-term monitoring sampling at ST005. |
Axl LeVan |
| 3/29/2023 |
Document, Report, or Work plan Review - other |
DEC reviewed and approved the "2022 Final Long-Term Management Report, Kotzebue Long Range Radar Site, Sites SS002 and ST005, January 2023." The report was received March 10, 2022 and presented the results of long-term monitoring sampling at ST005. |
Axl LeVan |
| 9/14/2023 |
CERCLA PA |
DEC reviewed the "Draft Preliminary Assessment Report for Aqueous Film-Forming Foam Areas, Kotzebue Long Range Radar Station, Alaska, August 2023". The report presented results of assessments conducted to identify locations at the Kotzebue LRRS, where potential releases of PFAS may have occurred that pose a potential threat to human health and the environment. |
Axl LeVan |
| 10/10/2023 |
Document, Report, or Work plan Review - other |
DEC reviewed and provided comments on the "Draft 2023 Five-Year Review Report for Sites SS002 and ST005 at Kotzebue Long Range Radar Station, Alaska". The Five-Year Review reviews the past five years of progress at the site since the last review. |
Axl LeVan |
| 11/22/2023 |
CERCLA ROD Periodic Review |
DEC reviewed and approved the "2023 Five-Year Review Report for Sites Ss002 and ST005, Kotzebue Long Range Radar Site, Alaska, November 2023". The purpose of the Five-Year Review is to evaluate the implementation and performance of a remedy to determine if the remedy is and will continue to be protective of human health and the environment. |
Axl LeVan |
| 5/21/2024 |
Long Term Monitoring Workplan or Report Review |
DEC reviewed and provided comments on the "Draft 2023 Long-Term Management Report, Kotzebue Long Range Radar Site, Sites SS002 and ST005, April 2024." This Report presents the work performed during long-term management (LTM) activities at the Kotzebue Long Range Radar Site (LRRS). |
Axl LeVan |
| 6/20/2024 |
Long Term Monitoring Workplan or Report Review |
DEC reviewed and approved the "Final 2023 Long-Term Management Report, Kotzebue Long Range Radar Site, Sites SS002 and ST005, June 2024." This Report presents the work performed during long-term management (LTM) activities at the Kotzebue Long Range Radar Site (LRRS). |
Axl LeVan |
| 3/11/2025 |
Document, Report, or Work plan Review - other |
DEC reviewed and provided comments on the Draft 2024 Long-Term Management Report, Kotzebue Long Range Radar Site, SS002 and ST005, March 2025. |
Axl LeVan |
