| Action Date |
Action |
Description |
DEC Staff |
| 9/30/1985 |
Update or Other Action |
IRP Phase I Records Search conducted by Engineering - Science (ES) for the AAC Northern Region. The hydrogeology of Kotzebue Air Force Station (AFS) is dominated by glacial moraine and drift deposits. Permafrost has been reported to exist within a few feet below grade, measured at a USGS test well drilled near the municipal airfield. Brackish water is contained in the fine-grained sediments underlying the permafrost. Salinity of the water increases with depth below land surface. This condition has prompted the development of surface water sources to provide for local water requirements.
The installation uses a small lake and conjunctive storage to provide water for its needs. The community of Kotzebue uses nearby June Creek as its source of municipal supplies.
Findings: The only active industrial shop that results in the generation of hazardous waste at Kotzebue AFS is the radar maintenance shop. A small quantity of waste oil from the radar gearbox is generated in this shop.
The waste oil is collected in a drum for shipment off base. The station support and maintenance shops were closed in 1985.
Previously, larger quantities of wastes were generated at Kotzebue AFS. Some of the wastes were used for dust control on roads. Prior to 1974, some of the wastes were accumulated adjacent to a landfill that was located along Kotzebue Sound, north of the POL tanks. The landfill was closed in approximately 1974. When the landfill was closed, drummed wastes that had accumulated
over the years were removed from the base. Shipment of waste oil not used for dust control to DPDO was initiated in approximately 1976.
Until the early 1970's, there was a waste accumulation area (Waste Accumulation Area No. 2) along the beach on Kotzebue Sound. The accumulation area was northeast of the fuel storage tanks on the beach. This
accumulation area was adjacent to a landfill (Landfill No. 1) that was used up to approximately 1972. In approximately 1974, the waste accumulation area and the landfill were cleaned up. The cleanup involved removal of most of the waste oil drums and grading of the site.
This landfill was used until approximately 1972; burning of waste occurred on a regular basis. The landfill was located on a triangular
piece of land northeast of the fuel storage tanks on the beach. The landfill was located adjacent to Waste Accumulation Area No. 2. In
1975, the landfill and waste accumulation area were cleaned up. The wastes that were stored an drums in the accumulation area ware shipped to DPDO at Elmendorf AFB for disposal. Petroleum based wastes in drums
that were leaking were used for dust control. empty drums ware disposed of in the community dump. The ground in the vicinity of the landfill
and the waste accumulation area was graded. Although most of the wastes were removed from the area, some of the wastes were buried in the landfill.
There are no active landfills at Kotzebue AFS. Since 1972 garbage and rubbish have been disposed of in the community dump. Waste oil,
spent solvents and waste diesel fuel have been used for dust control or shipped to DPDO at Elmendorf AFB for disposal. |
Louis Howard |
| 12/31/1985 |
Update or Other Action |
1985 Preliminary Assessment/Site Investigation (PA/SI) listed SS02 as a potential source of contamination following a records review and personal interviews conducted as part of the 1985 preliminary assessment/site investigation (PA/SI) records search. SS02 was recommended for further investigation at that time. |
Louis Howard |
| 8/24/1987 |
Site Visit |
Long Range Radar Site (LRRS) Site Visit notes August 24-27, 1987 Draft copy. Sites visited include a large fuel spill site (downslope from the main station complex), a waste accumulation area, the diesel fuel storage/power plant area, a fuel spill site at the White Alice complex, and the areas surrounding the main building doors at the White Alice site. The barracks area, power plant area, and White Alice spill site were not identified in the Phase I documents (Engineering Science Phase I Report. 1985).
Waste Accumulation area (KOT-4 Waste Accumulation Area no. 1)-This area is located south of the main LRRS complex. There are no drums or waste containers on the site anymore. Several dark stains were observed, apparently the results of dumping out waste oil and/or waste solvents from mostly empty drums. Some of the vegetation on the southwestern fringe of this waste accumulation area was dead or stressed, and dark tarry deposits were observed in among some of the grasses in this area. The identities of the compounds in the stains are unknown. The depth of the stains appears to be five to six inches.
NOTE in site visit document: The station chief said that some of the conditions we noted (the pallets of hazardous materials, the small spills, and generally unclean circumstances) were due to the manner in which the station was abandoned by RCA. According to the station chief, RCA was in the process of cleaning up and decommissioning the entire complex when the Air Force ordered them to evacuate the station immediately. The windows were boarded up and a large number of supplies and wastes were hastily gathered up and trucked off. This process only took a couple of days. Some the items were left behind and in disarray. The station is still operated by RCA, but as a "minimally attended radar station" (MARS) facility, so there is only one person there at any one time. |
Louis Howard |
| 11/30/1987 |
Update or Other Action |
In 1987, a survey was conducted at Site SS02. The site was reported as revegetated with no visual signs of surface contamination (e.g. no signs of staining or stressed vegetation). SS02 was excluded from the 1988 Remedial Investigation/Feasability Study (RI/FS) investigation based on the 1975 cleanup and regrading of the site, and the results of the 1987 site reconnaissance. |
Louis Howard |
| 1/11/1988 |
Update or Other Action |
Potential Hazardous Waste Site-Preliminary Assessment for Kotzebue White Alice Communication Station EPA AK 7572728742. Owner/Operator notification on file: B. Uncontrolled Waste Site date received August 1, 1981. On site inspection conducted July 1983 by the 5099th CEOS/DEMG. Description of substances possibly present, known or alleged: petroleum products, acids, bases, solvents, heavy metals, inorganic chemicals are possibly present. No drinking water near the site only possible contamination of Kotzebue Sound with small potential for adjacent lake. Site was cleaned of debris in 1983, covered and graded. One old landfill is now inactive, but the installation is minimally manned by contractor. Continued site investigations of the installations are ongoing under the USAF environmental restoration program. Priority of inspection is "Medium"-Inspection required. Sources of information: 5099 CEOS Records, Site Visits in 1983, AAC Real Estate Records, IRP Phase I Record Search September 1985. |
Louis Howard |
| 8/11/1988 |
Update or Other Action |
EPA Potential Hazardous Waste Site Disposition filled out by Douglas S. Johnson for Kotzebue White Alice Communications Station AK 7572728742. Recommendation: Investigation action(s) needed-Insufficient site sample data supplied. USAF/AAC must include additional sample plans and sample results in order to determine non-presence of hazardous materials at this site. |
Louis Howard |
| 5/30/1989 |
Update or Other Action |
EPA memorandum David Bennet-National Priority List (NPL) Coordinator to Doug Johnson AK Federal Facility Program Reviewer. In accordance with the Region 10 Policy for Processing of Federal Facility Preliminary Assessments, dated June 30, 1988, I have reviewed the above subject site information for Hazard Ranking System (HRS) adequacy and potential. The information supplied (by the Air Force) is inadequate. I agree with your recommendation for a site inspection to confirm absence of contamination. |
Louis Howard |
| 6/5/1989 |
Update or Other Action |
AF sent draft Technical Report and Draft Work plan for EPA's review and comments. These documents are part of the ongoing remedial investigation/feasibility study work at Kotzebue AFS. Request was made to forward any comments to the Air Force by June 23, 1989. The time period for review was short to allow for work to be accomplished this summer. If no comments are received by the above date, concurrence will be assumed and the work will proceed as outlined. |
Louis Howard |
| 9/29/1989 |
Update or Other Action |
EPA letter to Commanding Officer USARNG 3rd Sct. BN HQ re: Kotzebue Air Force Site AK4211890054. Your facility was listed on the November 16, 1988 Federal Agency Hazardous Waste Compliance Docket (Docket). In accordance with CERCLA as amended by SARA, your agency must submit a preliminary assessment (PA, and if necessary, a site investigation (SI) to EPA no later than 18 months after the Docket listing. The PA/SI must contain sufficient information so that EPA can evaluate your facility for potential inclusion on the National Priorities List. |
Louis Howard |
| 1/29/1990 |
Update or Other Action |
EPA memorandum David Bennet to Doug Johnson RE: USAF/White Alice Site Kotzebue. In accordance with the Region 10 Policy for Processing of Federal Facility Preliminary Assessments, dated June 30, 1988, I have reviewed the above subject site supplemental information for Hazard Ranking System (HRS) adequacy and potential. The information supplied is still inadequate. Now that the Air Force has confirmed contamination (at the facility), I strongly recommend that the Air Force conduct a listing site inspection and supply the necessary information when the new HRS is in place. In addition, the Air Force should be reminded of its docket responsibilities quickly as they seem to be rolling along without any oversight. |
Louis Howard |
| 12/31/1990 |
Update or Other Action |
Stage 2 remdial investigation/feasability study (RI/FS) found no visual confirmation of contamination at SS02 due to new soil cover placed on the site during grading activities in 1975. No further action was recommended for SS02.
*Note to file for KOT-4 Waste No. 1 (SS01):Approximately 50 cubic yards (six dump truck loads) of TPH contaminated soil were excavated from KOT-4 Waste No. 1. Enlargement of the excavation was guided with an HNu photoionization meter equipped with an 11.7-eV lamp. *NOTE: 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.
Contaminated fill material was excavated until background measurements of organic vapors were achieved at the excavations margins. |
Louis Howard |
| 7/31/1991 |
Update or Other Action |
Final No Further Action Decision and Final Technical Document to Support No Further Action for Kotzebue Air Force Station (July 1991) Contract no. F33615-85D-4544, Delivery Order No. 0007 received.
Waste Accumulation Area No. 2/Landfill. The Waste Accumulation Area No. 2 was used to store used oil in drums and other wastes generated from base operations. Potential contaminants are waste oil, fuels, solvents, herbicides, pesticides, and various chemicals associated with operation of the base. The landfill was used to collect wastes which were regularly burned at the site. The waste accumulation/landfill area was located along Kotzebue Sound, northeast of the POL tanks.
The waste accumulation area was closed in 1972, and the landfill was closed in 1974. In 1975, the landfill and the waste accumulation area were cleaned and regraded, and drummed wastes that had accumulated were removed from the installation. Some waste which remained at the landfill was buried there. Drums of oil were shipped to Elmendorf m AFB for disposal. Empty drums were taken to the Kotzebue landfill. Subsequently, all oil generated at the Kotzebue AFS has been shipped to Elmendorf AFB, or used for road oiling. Material suitable for landfill disposal has been taken to the Kotzebue landfill since 1974.
Summary of Sites Requiring No Further Action. Based on the two tiered screening evaluation conducted, three sites were found to have insignificant risk and did not exceed the regulated cleanup levels. Sites not considered for further remedial actions include:
• KOT-3 Road Oil
•KOT-6 Barracks
• KOT-7 Lake
Two additional sites, Spill/Leak No. 1 and Waste Accumulation Area No. 2/Landfill, were recommended for no further action after the 1987 Field reconnaissance. |
Laura Noland |
| 9/3/1991 |
Site Visit |
Trip Report for Northern Alaska DEW Line and LRRS Sites from Benjamin Thomas to Pete McGee. Summary of Findings and Recommendations for the North Slope District Office by Benjamin Thomas the Nome and Interior Districts by Ed Armstrong (visited Kotzebue LRRS, Granite Mtn. LRRS, Indian Mt. LRRS).
August 12 and 18 11 military installations were visited by Ben Thomas and three site inspections were conducted by Ed Armstrong. Kotzebue LRRS is owned by the USAF and minimally manned by GE. On August 14, 1991, we visited the Kotzebue White Alice and Radar site. We visited the bioremediation area (landfarm site) set up last year (1990) to treat old contaminated soil. The soil smells faintly of petroleum. The visqueen cover was tattered, rendering it an ineffective cover. The old landfill and waste accumulation areas appeared unused for several years.
The southeast sloping side of the main compound was the site of an old spill, which appears to have been covered with gravel fill. Contamination covered a large area as was evidenced by a sheen, rust, dead vegetation, and disturbed soils possibly from cleanup. (Free) Product was seen weeping out of the gravel and has a diesel smell. We recommend that further soil and water analysis be done to better delineate the extent of contamination. The lower tank farm along the beach, the southernmost diesel tank has a joint which was leaking (fuel), and the contamination area smells of diesel. We also tipped upright a drum which had fallen over and was leaking blackened oil. |
Ed Armstrong |
| 11/26/1991 |
Document, Report, or Work plan Review - other |
Letter to Patrick M Coullahan RE: Stage 1 Final NFA Decision and Final Tech. Document to Support no futher action (NFA) for Five sites on Kotzebue Air Force Station July 1991.
The Waste Accumulation Area (WAA) No. 2 was used to store used oil in drums and other wastes generated from base operations. Potential contaminants are: waste oil , fuels, solvents, herbicides, pesticides, and various chemicals associated with operation of the base. The wastes stored at the landfill were regularly burned at the site. In 1972 the WAA No. 2 was closed and in 1974, the landfill was also closed. Both areas were cleaned, regraded and drummed wastes removed from the installation in 1975.
The report indicates that "Some waste which remained at the landfill was buried there." This proposed No Further Action (NFA) Area is located near Kotzebue Sound; a potential receptor if burned wastes should be released. We understand that during a 1987 site visit, Woodward Clyde Consultants were unable to distinguish the waste accumulation and landfill areas from the surrounding vegetation which had reclaimed the site. However, the Department requests you conduct a file or record review and attempt to determine the following information:
1) What type of wastes are buried at the landfill?
2) What is the estimated quantity of those wastes?
3) How deep are the wastes buried?
If it can be determined that the quantity of wastes is minimal and that the possibility of a release to the environment is unlikely, the Department will concur with this site being established as a NFA site.
Summary: ADEC concurs with the No Further Action alternative for the Waste Accumulation Area No. 2/Landfill site (NOTE: also included Spill/Leak No. 1 and Road Oil (KOT-3) as NFA). If further site conditions should change, or if additional information should become available which indicates that more substantial environmental problems exist, the Air Force will need to provide additional analytical data and possible corrective action. |
Laura Noland |
| 1/2/1992 |
Update or Other Action |
AF response to November 26, 1991 letter on the Stage 1 Final NFA Decision and Final Tech. Document. At Waste Accumulation Area No. 2: A review of a Records Search document dated September 1985 did not yield information on the types and quantities of waste or depth of burial. Efforts are underway to attempt to determine the extent of the "clean up" which took place in 1975 and how much (if any) waste was buried in the landfill.
However, we have not been able to find any additional information. Thus, we believe the Kotzebue Air Force Station site, Waste Accumulation Area No. 2/Landfill,is acceptable to the state of Alaska as a no further action site unless additional information becomes available to indicate a substantial environmental problem exists. |
Laura Noland |
| 6/24/1993 |
Update or Other Action |
spill# 93320112501 file# 410.02.003 Martin Marietta Ted Alexander reporting spill on 6/24/1993 (knowledge of spill June 19, 1993). One-hundred ninety-seven gallons of diesel fuel (arctic) from a 300 gallon tank at abandoned building. Rusted through tank bottom was the cause of release. Plastic to be laid under tank and site to be cleaned up after instructions from the Air Force. |
Laura Noland |
| 3/3/1994 |
Update or Other Action |
EPA Letter to AF re: review of Preliminary Assessment report and other documents. The PA and other documents have been reviewed 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 their evaluation, EPA has determined that the facility could score high enough 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 surficial and subsurface soil samples from Waste Accumulation Area 2. Collect 3 beach sediment samples below 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 centers from the PPE from the source to the wetland, and 1beach sediment sample from below the mean high water line.
-Collect 2 sediment samples from the lake near the sources.
-Collect background sell and sediment samples.
All samples should be analyzed for the complete EPA target compound list (TCL) organic and inorganic. Data generated should be equivalent to the contract lab program (CLP) level 4 data quality. Additionally, response to several comments from EPA on the Draft PA were incompletely responded to in the final PA. |
Laura Noland |
| 5/13/1994 |
Document, Report, or Work plan Review - other |
Staff reviewed and approved the Draft Final Community Relations Plan. Minor comment was to change the Department point of contact name and address in Appendix C. |
Laura Noland |
| 5/16/1994 |
Document, Report, or Work plan Review - other |
Staff reviewed and approved the Draft Final Work Plan and Draft Field Sampling Plan
Remedial Investigation/Feasibility Study Kotzebue Long Range Radar Station, Alaska dated April 1994.
The Department of Environmental Conservation has received and reviewed the above named documents which describe Remedial Investigation/Feasibility Study (RI/FS)
activities planned for the summer of 1994 at Kotzebue Long Range Radar Station. The RI/FS will address six known contaminated sites and investigate ten areas of concern which were identified during 1993 site reconnaissance.
Air Force personnel and their contractor have previously met with Department staff and explained their work plan. This type of presentation greatly facilitates Department review. The Department approves of the work plans as written and looks forward to working further with the Air Force as the RI/FS proceeds at Kotzebue LRRS.
NOTE: Six Sites include: 1) Site SS02-Waste Accumulation Area No.2/Landfill; 2) Site ST05-Beach Tanks; 3) Site SS07-Lake; 4) Site SS08-Barracks Pad; 5) Site SSll-Fuel Spill; and 6) Site SS12-Spills No. 2 and 3.
Areas of concern include: AOC-1 Landfarm Landfarm Seeps, AOC-2 POL Lines, AOC-3 East Tanks, AOC-4 Power Plant Garage, AOC-5 Small Day Tanks, AOC-6 Nav Aid Bldg., AOC-7 Steel Pilings, AOC-8 White Alice Garage, AOC-9 White Alice Tanks, AOC-10 Septic Holding Tank. |
Laura Noland |
| 7/1/1994 |
Interim Removal Action Approved |
In late July 1994, Tetra Tech conducted an interim remedial action at SS02. Tar and associated soil material were excavated from a disposal trench and contained in two 55 gallon drums. However, the IRA was suspended prior to the complete removal of tar waste due to the discovery of additional buried drums containing tar product, significantly increasing the estimated volume of material requiring excavation.
A supplemental IRA was conducted between October 3 and 8, 1994 to complete the removal of tar waste and buried drums remaining at SS02.
SS02 Waste Accumulation Area Tar Trench Removal Action
6 55-gal drums, Tar & Soils (mixed) 10/27/1994
13 85-gal drums. Tar & Soils (mixed) 10/27/1994
10 85-gal drums, Tar product/drums 10/27/1994
13 110-gal drums, Tar product/drums 10/27/1994
17 55-gal drums, Empty (partially crushed) removed from excavation 10/27/1994 |
Laura Noland |
| 11/21/1994 |
Document, Report, or Work plan Review - other |
ADEC letter to Air Force Re: Northern Region Air Force Installations: Risk Assessment Work Plan. The purpose of the letter is to inform you that the Department of Environmental Conservation will require that a risk assessment work plan be submitted to the Department any time a risk assessment is planned for Air Force facilities. The risk assessment work plan must be approved by the Department before the risk assessment can proceed. This requirement is in accordance with 18 AAC 75.327 (Contaminated Sites Regulations in effect as of November 21, 1994) which states:
" (a) Immediately upon becoming aware of a discharge of a hazardous substance to the land or waters of the state, any person responsible for that discharge shall contain, clean up, and dispose of the material collected, using methods for which approval has been given by the Department. The discharge must be cleaned up to the Department's satisfaction."
The work plan must include:Present and Future Land Use: Risk assessment will need to include both present and relevant future exposure scenarios. The Department will assume that all properties will be used for residential purposes. If the Air Force determines that this is not the case, then the Air Force must present their case to the Department and request concurrence. Future land use decisions must be made based on the best available information.
The risk assessment must identify which contaminated sites at the facility are candidates for risk assessment, and why. Sources where floating product and ongoing releases are evident are candidates for interim remedial cleanup actions and risk assessment may not be the only course of action. |
Laura Noland |
| 1/30/1995 |
Update or Other Action |
Air Force letter to ADEC RE: Cleanup Levels for FY95 Interim Remedial Action (IRA) at Kotzebue Long Range Radar Station (LRRS)
An IRA at Kotzebue LRRS is planned for the summer of 1995. In order to properly plan and scope this project, negotiations on cleanup levels were undertaken between 611 CES/CEVR and Ms. Laura Noland of ADEC-NRO. This letter is to clarify understandings achieved and propose final cleanup levels for the remediation of Petroleum, Oil, and Lubricant (POL) contaminated soils at Kotzebue LRRS.
It is the understanding of 611 CES/CEVR that only POL soils contaminated in excess of 1,000 mg/kg or parts per million (ppm) will require excavation and remediation. The proposed remediation technology is Low Temperature Thermal Desorption (basically a steam stripper). This technology has been used extensively on the North Slope and has been approved by ADEC-NRO for remediation of POL contaminated soils.
The remediated soils are to be used to provide additional cover for the beach landfill, site SS02 (file #410.38.002.12). Due to the proximity of the site Kotzebue Sound, it is felt that a cleanup level of 1000 ppm is inappropriate. The 611 CES/CEVR therefore proposes the cleanup level to be 300 ppm, and that no remediated soils are to be spread west of the roadway which runs between the landfill and the Sound.
It is further understood that all areas disturbed by excavation and the spreading of remediated soil will be revegetated. Revegetative efforts will include regrading and seeding with an appropriate mix of available plant species.
The 611 CES/CEVR feels the above cleanup levels, institutional controls and revegetation efforts will be adequate to protect human health and the environment for this remedial effort. Agreement on the above will allow the 611 CES/CEVR to proceed with scoping, contracting and development of work plans, health and safety plans etc., in preparation for the FY95 field season. |
Laura Noland |
| 3/31/1995 |
Update or Other Action |
Site Characterization Summary-Informal Technical Information Report & Risk Assessment (July 1995 finalized this investigation: Final RI/FS Report). SS02 (WCC Site Designation KOT-2) Waste Accumulation Area No. 2/Landfill. The landfill is located on a triangular piece of land adjacent to & north of the former fuel storage tanks on the beach. Waste accumulation Area No.2 IS located Northeast of the former fuel storage tanks adjacent (south) to the landfill. The landfill was used until approximately 1974. Waste accumulation Area No.2 was used until approximately 1972; 1975, the site was cleaned up & the area graded.
Diesel Range TPH (AK102)-One sample SS02-SS1 revealed elevated TPH at 2,400 mg/kg. Residual Range TPH (AK102-Extended): Sample results indicated a significant TPH concentration at 31,000 mg/kg. Groundwater sample results: DRO: 5.5 mg/L (Table C 1.5 mg/L) & TCE 20 ug/L (Table C 5 ug/L).
During the 1994 field investigation, a tar disposal trench was discovered within Site SS02. Based on available field information, the USAF initiated an interim remedial action to mitigate potential hazards associated with the disposal trench.
The gradiometric survey identified 95 grid cells containing buried metallic material, & 18 cells containing significant buried metallic material. Survey results identify three main areas where buried metallic material have been detected within the former landfill boundaries, including a large area in the southern portion of the site. Survey results indicate the detection of significant buried metallic material in the cell containing the former tar disposal trench.
Similar signals detected in other areas (grid cells) of the site may or may not indicate the presence of buried drums. It is important to note that the magnetic locators are very susceptible to noise caused by some natural soil conditions. Additionally, magnetic locators are limited in providing quantitative data concerning the number & depth of identified targets. This survey should be viewed as a qualitative method of identifying potential "hotspots" that may contain buried metallic waste such as drums. However, excavation is required to distinguish buried drums from other innocuous metallic debris.
A baseline risk assessment, performed in support of the 1995 RI/FS, determined that no unacceptable risk to human health & the environment existed at the site. The primary contaminants of concern at the site consists of low levels of fuel & pesticides in near-beach groundwater. The groundwater at the site is brackish & not potable. Ponded surface water at the site was found to contain pesticides at concentrations above the interim cleanup levels. Due to the limited extent of surface water, the fact that it is not used as drinking water, & the absence of fish & shellfish, no unacceptable human or ecological risks were determined to exist at the site.
Diesel-Range TPH (Method AKI02): Diesel-range TPH was detected at relatively low concentrations in background Samples SS3 at 11 mg/kg & SS4 at 43 mg/kg. However, Sample SS2-01 revealed a TPH concentration of 1,200 mg/kg. Based on the elevated concentration observed in Sample SS2-0 I, a second sample (SS2-02) was collected from a location approximately 200 yards upgradient, & analyzed for TPH. Sample SS02-02 revealed a TPH concentration of 3,800 mg/kg (see Figure 3-8). No visual or olfactory evidence of petroleum contamination was noted during background sample collection.
The TPH soil cleanup levels developed & implemented to guide site characterization & remedial action during previous IRP RI/FS activities are not acceptable to ADEC. TPH concentrations remaining in soils at selected sites will require additional characterization to evaluate current site conditions & the extent of potential contamination relative to ADEC accepted criteria. ADEC has established a target level for diesel range TPH at 1,000 mg/kg in soils at Kotzebue LRRS. |
Louis Howard |
| 9/5/1995 |
Update or Other Action |
Kalu Kalu sent letter to Mr. Greg Smith USACE-RE: Formerly Used Defense Site. RAB brought up the presence of old barrels that are spread all over the eastern part of the Kotzebue airport. They contend the barrels were brought up by the military and are spread over one square mile. The Department requests an INPR be conducted on the drum sites in Kotzebue and the neighboring areas. |
Kalu Kalu |
| 11/12/1996 |
Update or Other Action |
Conservation Agreement for Barneby's Milkvetch entered into between the United States Fish & Wildlife Service (USFWS) and United States Air Force (USAF) authorized by the Endangered Species Act of 1973, as amended; the Fish and Wildlife Act of 1956, as amended; and the Fish and Wildlife Coordination Act, as amended, and the Sykes Act, as amended.
Barneby's Milkvetch was described by Dr. Stanley Welsh in 1968 based on collections from the Kotzebue area. In 1984, it was added to the candidate list of plants for Alaska (now called Species of Concern). The Alaska Natural Heritage Program ranks Barneby's Milkvetch as G4T1/S1. The Global rank for this species indicates secure populations on a species level, while the rank of "TI" indicates "critically imperiled" for the subspecies. The rank of "SI" indicates it is critically imperiled in the state.
A status survey for this species was completed by Mr. Rob Lipkin of the Alaska Natural Heritage Program in 1985. Mr. Lipkin visited seven populations and estimated total population size to be 1,487 plants. In 1995, for the purposes of assessing impacts from a dredging project in Kotzebue, Service Botanist, Ms. Virginia Moran, and Bureau of Land Management (BLM) Botanist, Ms. Randy Myers of the Kotzebue Field Office visited all populations outlined in Mr. Lipkin's report. The total population size had increased over 5
times from the 1985 population estimates and two new locations were found. Also during this field season, Ms. Myers discovered a new population on a tributary of the Squirrel River
estimated to be about 300 plants. During the summer, 1995, two populations on USAF property were accidentally extirpated (wiped out/destroyed) during soil remediation activities. An estimated 300 plants, or 9%
of the total population on USAF lands, were extirpated propelling the Service to more
aggressively outline protection measures for this species in the form of a Conservation
Agreement. The total population estimate is now 8,391 plants. About 36% of the total/
population occurs on USAF lands at the Kotzebue Long Range Radar Site.
The duration of this Conservation Agreement is for 5 years following the date of the last
signature (signed in 1996 expires in 2001). The parties involved will review the Conservation Agreement and its effectiveness
annually (no later than August 31) to determine whether it should be revised. The parties will
also notify one another should there be a change in the personnel that have the lead for this agreement. During the last month in which it is valid, the Conservation Agreement must be reviewed and either modified, renewed, or terminated. If some portion of this Conservation
Agreement cannot be carried out or if cancellation is desired, the party requesting such action will notify the other party(ies) within 1 month of the changed circumstances. When and if it becomes "known that there are threats to the survival of the subject species that are not or cannot be resolved through this or any Conservation Agreement, the species will be retained in or reassigned to Category I. and an appropriate listing priority assigned. |
Kalu Kalu |
| 12/31/1996 |
Update or Other Action |
If specimens are identified as OAB, this will change the rarity status of this species
significantly. It should be noted that the taxonomy of OAB should be analyzed, preferably by DNA analysis. Although anecdotal, two morphological variations were observed; one morph appeared tall and robust with few large leaflets; another morph appeared shorter, more prostrate and had more, but smaller leaflets. A few purple-flowered variants were also found.
Oxytropis arctica has a purple flower and is the only purple-flowered species of the O. campestris type native to the "American segment of the Arctic circle" (Barneby, 1952). As far as any perceived morphological differences, without further analysis, it is impossible to conclude this is genetic versus phenotypic. Polyploidy has been reported in the Oxytropis campestris complex of species which includes OAB (Dawe and Murray, 1981). Murray(1987) states polyploidy is a common characteristic of Arctic species. Polyploid taxa are adaptively superior. Murray goes on to state, "hybridization and formation of polyploids provided recombinants superior to the parental stock in the new environments."
In arctic alpine Draba species from the Nordic, ecological amplitude increased significantly with increasing ploidy levels (Broehmann et. al., 1992). OAB had a much wider 'habitat amplitude' than was expected. It was observed in the following habitat types: riparian, gravel bars and outwash areas, mixed-herb meadow, sedge-dryas tundra, cliff faces, grassy bluffs, and alpine tundra. Obviously, the more generalized a species is in its habitat preferences, the less vulnerable it is to extirpation. While speculative, perhaps polyploidy enables OAB to have a wider habitat amplitude. It serves to exemplify that variation between and within the species deserves additional genetic analyses, such as electrophoresis (allozyme) or DNA studies.
Conclusions that it is no longer necessary to take protective actions to conserve all
OAB populations owing to the discovery of many more plants in the Squirrel River drainage are incorrect. If anything, all populations (or the total known gene pool) should be conserved in order to complete needed genetic analyses. During this study, a total of 15,782 new plants were estimated for five habitat types of the No Name and North Fork Squirrel River drainages. In order to conclude this species is secure, taxonomic studies are necessary and should be made a priority. Until these studies can be conducted, all populations should be protected and the measures outlined in the Conservation Agreement and accompanying plan should be followed next year. |
Louis Howard |
| 1/3/1997 |
Update or Other Action |
USAF 611 ASG 611 CES KLRRS Remediation Report of 1995 and 1996 Field Activities-Final. SS02-Beach Landfill Site: No contaminated soil was excavated from this site. Approximately 825 yds 3 of coarse aggregate (stone), consisting of excavated and cleaned soil exceeding 3/8" diameter, was backfilled and graded in several pre-existing holes or low areas within this four acre landfill site. Because much of the site had naturally revegetated itself, care was taken to minimize its disturbance. Manual revegetation of the backfilled areas was deferred because of cold weather which would have killed the seeds.
Clean soil from the soil washing system was backfilled at source area excavations at ST14,
ST04 , SS12, and SS13. The clean gravel 3/8-inch and larger was backfilled at SS02 (the
Beach Landfill) to fill large holes remaining from previous remediation and landfill closure
activities. Possibly a planting program for the endangered Oxytropis plant will be implemented in 1997 to encourage the proliferation of the species. Additionally, the backfilled areas at SS02 were not revegetated at the end of the 1995 field effort because the weather was too cold for successful revegetation.
All stone material screened from the soil prior to treatment was washed in the large coarse
aggregate screw and stockpiled for backfilling at site SS02. This material was considered
"clean" because of its size. Contamination was not present in the large aggregate portion of
the gravel. However, to ensure that the aggregate was clean, it was washed through the large
aggregate screw.
|
Kalu Kalu |
| 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 syopsis and limited review of investigative and remedial activities at the Kotzebue LRRS, Alaska prepared by USDOI BIA contractor-Montauk Environmental Engineering June 1997. Site SS02 - Waste Accumulation Area No.2/Landfill This area is comprised of a waste accumulation area and facility landfill, formerly used to store and dispose of wastes at the LRRS Petroleum hydrocarbons (up to 5 5 mg/Kg [parts per million, or "ppm"]) and pesticides detected at relatively low concentrations in shallow near-beach groundwater are the primary contaminants identified at the site The former landfill was cleaned and graded in 1975. In 1996, tar barrels from this stte were excavated and disposed offsite.
Groundwater monitoring was recommended on a biannual basis for a duration of 4 years, to include analyses for volatile organics, semivolatile organics, pesticides and PCBs, diesel range
organics and metals from water samples collected from site monitoring wells (i.e., Monitoring wells SS02-MW1M, W2,a nd MW3)to evaluate potential contaminant migration from the site via groundwater to Kotzebue Sound. |
Louis Howard |
| 12/11/1997 |
Update or Other Action |
Management action plan: SS02 is a former waste accumulation area and landfill located at the beach area. The site was used to store and dispose of wastes generated at the facility until approximately 1972 (ES
1985). In 1975, the site was reportedly cleaned and graded by the Air Force (WCC 1990). A 1987 field reconnaissance found that the area was completely revegetated with no evidence of biological stress. However, ADEC expressed a concern regarding potentially hazardous material which may have been buried under clean fill and requested that an investigation confirm or deny the presence of potentially hazardous material buried at this site.
During field activities at the landfill in 1993, a tar disposal trench was discovered. Removal
actions were undertaken in 1994 to remove tar and mitigate the immediate environmental hazards. Removal actions included excavation, removal, and containment of approximately
1,433 gallons of tar-laden soil, 850 gallons of tar product, and 17 empty 55-gallon drums.
Subsequent confirmatory sample analysis indicated that residual hydrocarbons at this location did not exceed ADEC action levels, with the exception of DRO in groundwater which was suspected to have originated from ST05. Analytical results also indicated low levels of pesticides in the soil and groundwater and arsenic in the soil (Tetra Tech 1995).
Investigation findings and recommendations included groundwater monitoring and regrading
and revegetation of the landfill to bury any exposed debris (Tetra Tech 1995). In 1995, the
area was backfilled with approximately 825 cubic yards of coarse aggregate and graded fiat. Revegetation of the backfilled areas was deferred due to cold weather. |
Louis Howard |
| 12/31/1997 |
Update or Other Action |
Management Action plan lists a zone approach for the installation. 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 |
| 6/10/1998 |
Update or Other Action |
Memorandum for Kotzebue RAB from HQ Human Systems Center Brooks Air Force Base. Consultative Letter AL/OE-CL-1997-0194 Health Risk Assessment for Berries and Greens at Kotzebue Long Range Radar Site (LRRS). Summary: The U.S. Public Health Services' Agency for Toxic Substances and Disease Registry (ATSDR) and the 611th Civil Engineering Squadron (CES) requested the U.S. Air Force's Health Risk Assessment Branch (OEMH) evaluate potential risks due to past waste practices (e.g. spills and landfill) at the Kotzebue LRRS. The potential food chain risk is from consumption of plants grown on the facility.
A review of the Kotzebue LRRS IRP documents lead OEMH to determine that plant and not fish consumption was more appropriate to evaluate for risks from contamination, since fish can travel greater distances and the potential levels of chemicals from Kotzebue LRRS that could reach the Sound would be low. This was discussed and supported by some area residents who described that area fish do not spend much time near the Kotzebue LRRS. Mr. Walter Sampson, Kotzebue resident, took OEMH staff to the Kotzebue LRRS and identified edible plants (berries and greens) commonly gathered by local residents. He also said crop yield was below normal during the 1996 harvest season. OEMH had a difficult time collecting enough berries and greens to meet sampling analytical requirements. OEMH staff collected surface soil samples to identify if contaminants measured in berries and greens were present in the soils and at what concentrations.
The list of contaminants evaluated in the berries and greens included those contaminants detected in previous water and soil at SS12 and other LRRS IRP sites. Based on this information, berries and greens were analyzed for semi-volatile organic chemicals (including polychlorinated biphenyls (PCBs), pesticides, and petroleum products. SS12: Four samples were collected from each location-one each for salmon berries, bog blueberries, sourdock and surface soil.
A "background" location was chosen based on previous IRP sampling and availability of berries and greens not influenced by site contamination. The background location is adjacent to the "Old Water Supply Lake" (SS07 formerly KOT-7).
The results were well below health based comparison values used by ATSDR, ADEC and EPA. This indicates that the consumption of berries and greens from Kotzebue LRRS and incidental ingestion of surface soils from SS12 pose no significant risk to Kotzebue residents. The safety factors used in the toxicity assessment and conservative (maximum) exposure estimates used to calculate berry and greens consumption and incidental ingestion of surface soil supports this conclusion. No further action is required at Kotzebue LRRS. It is safe for the residents of Kotzebue to continue collecting and eating berries and greens from the Kotzebue LRRS. |
Louis Howard |
| 3/9/1999 |
Update or Other Action |
Kotzebue Drum Dump (KDD) -CERCLIS ID AK0002011385, Latitude: 69 52' 25" Longitude:162 37' 10" West legal description Section 16, Township 17 North, Range 18 West.
Site Inspection Report TDD: 97-09-0011 Contract 68-W6-0008 February 1999 (received on March 9, 1999) Region 10 Superfund Technical Assessment and Response Team (START). The KDD is located south of Ralph Wein Memorial Airport (referred to as the Kotzebue Airport), which is south of the City of Kotzebue and adjacent to the city's facilitative sewage lagoons. This site is located on a strip of land bordered by Kotzebue Sound on the west and a saltwater lagoon to the east (see also CS reckey# 1999320110401 Kotzebue Drum Dump).
The KDD is a stockpile of 150 rusted or otherwise comprised 55-gallon drums scattered over approximately one acre of land. The site is not fenced or gated. Approximately 5% of the drums are labeled with either United States Air Force or United States Navy markings. The drums labeled United States Air Force are also labeled Mona Lisa Project. The Mona Lisa Project was an Air Force effort to transport supplies of all types to rural locations throughout Alaska. The ADOT and Public Facilities (State of Alaska) is the current property owner, prior to statehood, the land remained in the public domain. The Air Force has never owned the land, and records of any improvements to the site do not exist. The former Long Range Radar Station (LRRS) is located approximately two to three miles southeast of the site.
Aerial photos from August 25, 1969 indicates more than 500 drums were stacked in two similar sized piles approximately 150 ft. apart. 1977 aerial photos indicate that all but 10 drums from the southern drum pile had been moved, the northern drum pile still contained approximately 400 drums, fish camps were present in the tent city area west of the KDD. Aerial photos from 1987, vegetation obscures the view of the Drum Dump area, making an estimate of the number of drums difficult, but apparently many of the drums had been removed since 1977.
The community of Kotzebue contends the drums were deposited by the Air Force during operations and closure of the LRRS. The Air Force contends that while the drums originally may have been Air Force property, the drums were utilized by local residents and deposited on the site after non-military use.
A total of five surface soil samples were collected from the KDD to determine potential contaminants associated with the source. Two samples were collected from the southern stockpile (7,500 sq. ft.) and three samples were taken from the northern stockpile (75,625 sq. ft.). Surface samples were collected from 0 to 6 inches below ground surface (bgs). Gasoline range organics (GRO) was found in DD02SS at 420 mg/kg and diesel range organics (DRO) ranged from 13,000 mg/kg to 71,000 mg/kg and residual range organics ranged from 38,000 to 160,000 mg/kg. These petroleum contaminants were the only contaminants of concern that were detected above any applicable cleanup level. Based on the Preliminary Assessment, EPA does not anticipate further investigation under the Federal Superfund Program. |
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 |
| 5/21/1999 |
Document, Report, or Work plan Review - other |
Kevin Oates sent the Air Force a letter regarding the proposed recycling of petroleum contaminated soils at the former Long Range Radar Station (LRRS) at Kotzebue, AK. The proposed recycling would be to use treated and non-treated stockpiled soils for scheduled road expansion and paving project in Kotzebue later this year. The soils would be used for road sub-base, aggregate, or hot asphalt mix on the road surface. The ADEC supports the beneficial re-use of the stockpiled soils and has the following guidance to offer in the evaluation of the recycling option.
For the hot asphalt mix, ADEC does not have a requirement for a range of acceptable concentration for constituents such as diesel range organics (DRO). DEC does require that asphalt plant that will be used to process the asphalt have a current air permit that allows for this use. Based on data presented in the May 7, 1999 draft soil washing post construction report (which used soils from sites:ST14, ST04, SS13, and SS12) for Kotzebue LRRS, the stockpiled soils appear to be suitable for use in the asphalt mixture.
For aggregate and sub-base components of the roadwork, residual concentrations should not exceed 18 AAC 75.341 (Soil Cleanup Levels: Tables.) Table B1 levels for BTEX and PAH compounds, or Table B2 for petroleum hydrocarbons. The reported concentrations in the above mentioned report are below soil cleanup levels for all constituents except sample K-SS15-101A-1-1.5 for DRO. That sample indicates a concentration of 19,700 mg/kg of DRO. The applicable DRO soil cleanup concentration is 12,500 mg/kg for the Arctic zone. The stockpile that contain this concentration would be most suitable for the hot asphalt mixture, but not for the sub-base or aggregate layers. |
Kevin Oates |
| 12/30/1999 |
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.
At SS02, the very low level of DDT in the surface water and metals in the surface water and groundwater do not pose an unacceptable risk to human health or ecological receptors. DDT decreased to 0.004 (cleanup level 0.039 ug/L) ug/L and all others were below cleanup levels. |
Louis Howard |
| 12/31/1999 |
Long Term Monitoring Established |
During the 1999 field effort, only one serviceable, well MW-1, was sampled. All contaminants were found to be below regulatory limits in groundwater except for aluminum, arsenic, copper, iron, manganese and nickel. A marine surface water sample was also collected in 1999 and analyzed for the same compounds as groundwater. All contaminants in the marine surface water sample were below regulatory limits except for DDT, which was measured at 0.004 micrograms per liter (ug/L). The interim cleanup level for DDT is 0.00059 ug/L. One sediment sample was collected at SS02 in 1999. No contaminant concentrations exceeded the applied regulatory limits. |
Louis Howard |
| 5/5/2000 |
Meeting or Teleconference Held |
Community Meeting- Public questioned the appropriateness of using a higher cleanup level than what was originally used for the soil washing project. The first proposed levels excavated soil greater than 1,000 mg/kg diesel range organics (DRO) for treatment, and identified 100 mg/kg as the post treatment contaminant level. Question was asked why the Air Force wasn’t planning to follow the original cleanup level.
Air Force responded: There was no formal agreement between the Air Force, ADEC, and community of Kotzebue to clean the soil to 100 mg/kg DRO. This was a voluntary goal established by the Air Force. This goal proved unattainable with the soil washing technology used to treat the soil. In the time between the start of the soil washing project and the abandonment of the technology, ADEC published Final Regulations for DRO cleanup in soil.
ADEC and the Air Force determined that 18 AAC 75 Method 2, Table B2 cleanup values were appropriate cleanup levels. The new level would be 12,500 mg/kg DRO. The soil at the facility is well below this level and requires no further remedial action. Further, the soil could be spread onsite, regraded and re-vegetated to ensure runoff and erosion control. |
Ann Farris |
| 8/23/2000 |
Update or Other Action |
The Alaska Department of Environmental Conservation (Department) has received the Draft 2000 Groundwater Monitoring Workplan, Kotzebue LRRS, Alaska for review and comment. This work plan 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. The thoroughness in the descriptions of the past sampling efforts and results at the two sites has 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 |
| 9/4/2000 |
Update or Other Action |
Final Work Plan received. This work plan outlines the field sampling activities to be performed in support of the Monitoring Program at two sites at the Kotzebue LRRS. The overall goal of the
outlined work is to monitor contaminated media in support of cleanup objectives established for Waste Accumulation Area No. 2 (SS02) and Storage Tank No. 5 (ST05). SS02 is comprised of a waste accumulation area and landfill. ST05 is a former aboveground storage tank.
As part of the data is evaluated and field Monitoring Program, existing tasks conducted to collect additional data as needed. Collected data will be validated, summarized, and evaluated in an Analytical Data Advancement Package (ADAP). Results of these previous sampling activities will also be summarized in a Long Term Monitoring Plan for the Kotzebue LRRS that will include SS02 and ST05. Waste generated at the LRRS burned and of in accumulation areas. SS02 is located on the beach area below the installation, along Kotzebue Sound. Both of these areas were abandoned in the early 1970s. In 1975, waste that had been stored at SS02 was shipped to the Defense Reutilization and Marketing Office (DRMO) at Elmendorf AFB. Since that time, all wastes generated at the facility have been shipped off-site to the DRMO.
Groundwater associated with the beach area SS02 and ST05, is restricted to a narrow zone
adjacent to Kotzebue sound that is not as persceptible to permafrost. DRO in groundwater at SS02 is suspected to originate from ST05, located immediately south of well SS02-MW3. Pesticide compounds were ubiquitously detected at relatively low concentrations during the 1994 RI, including all background soil sample locations. The pesticides 4,4'- DDE, 4,4'-DDD and 4 4'-DDT were detected at relatively low concentrations in a single groundwater sample from well SS02-MW2. These concentrations exceeded federal water quality criteria established for the State of Alaska based on the protection of human health from the consumption of contaminated water, fish, and/or shellfish.
The three groundwater monitoring wells (SS02-MW I, R-SS02-MW2, and R-SS02-MW3) at SS02 will be sampled for DRO, VOCs, SVOCs, total metals, pesticides, PCBs, total HG, and TOC. In addition, background well MW1 (located 650' N and 400' W of SS02-MW1) will be sampled for the same chemical analyses as the SS02 monitoring wells. A potentiometnc water-level survey will be performed at Site SS02. Water level measurements, including depth to groundwater depth, and total depth, will be recorded at each of the three wells prior to sampling. This survey will provide groundwater flow direction and gradient information for this site. Fleld parameters (pH, conductivity, temperature, dissolved oxygen, turbidity, and redox) will be recorded at the time of groundwater sample collection.
One surface marine water sample (SS02-SW1) and one sediment sample (SS02-SE1), will be
collected at the beach/water interface, down-gradient of SS02. This will ensure the tidal flat area is safe before proceeding to the sampling location to collect the samples.The surface water sample will be collected before the sediment sample at this location.
Potential groundwater exposure pathways for humans include ingestion of water, dermal contact with water, and Inhalation of chemicals volatilized from water. The potable waler supply for the Kotzebue LRRS comes from the City of Kotzebue. Therefore, mgestlon of groundwater is not a potential exposure pathway at the site. Because the shallow near-beach aquifer system is not a potable drinking water source (1.e., brackish), DROs and pesticides were detected at relatively low concentrations, and no risk-based criteria were exceeded. |
Ann Farris |
| 11/3/2000 |
Document, Report, or Work plan Review - other |
Staff reviewed and commented on the Proposed Plan for Cleanup, Kotzebue Long Range Radar Site, Sites SS08 and SS16, Kotzebue, Alaska, dated September 1999. The Proposed Plan summarizes the site history, previous site investigations, and a cleanup alternatives analysis for the Waste Accumulation Area No. 2/Landfill (SS02), Beach Tanks (ST05), Spills No. 2 and 3 (SS12), and the Garage and Power Plant (SS15). The Department has the following general comments on the Plan:
1. As a whole, the document is very confusing and does not adequately discuss the specific environmental issues at each of the four sites. The sections “Results of Previous Investigations” and “Summary of Interim Action” may be clearer if they were combined and each site was discussed separately. However it is presented, though, please include specific dates of the report or investigation, a list of contaminants of concern (COCs), potential or proven sources, the impacted media (soil, surface water, and/or groundwater), the estimated volume or magnitude of the contamination, and the specific interim remedial action (IRA) taken along with the estimate of the extent of contamination remaining at the site after the IRA. In order for the public to make comments, they have to be able to understand the type and extent of contamination.
2. Throughout the document indicate what type of fuel is being discussed (e.g. DRO, GRO).
3. Recommend that investigations and reports not related to the four sites be left out of this Proposed Plan. They are not necessary and confuse the relevant issues.
4. Please include a discussion of proposed soil, groundwater (if necessary), and surface water cleanup levels. This should refer to the contaminated sites regulations (18 AAC 75), the surface water regulations (18 AAC 70), and, if necessary depending on the COCs, EPA risk-based concentrations.
5. Please indicate the SS or ST numbers on Figure 1.
6. Page 3, 2nd paragraph, 6th sentence: ADEC does not define suprapermafrost as surface water. However, the water does need to be evaluated as a possible mechanism for contaminant transport to a surface water body. If the contaminant is migrating via this pathway, the cleanup criteria for the suprapermafrost water is set such that the surface water body does not exceed the water quality regulations.
7. Page 3, 2nd paragraph: The explanation of the geology in the area is confusing. It may be clearer to define the separate areas (i.e. beach, near beach, tundra) and explain the soil type, permafrost, and groundwater characteristics for each area.
8. Page 6, under Alternative 2, 5th sentence: “Natural attenuation of fuels has been demonstrated at Kotzebue LRRS.” Please include a reference for this and indicate the type of fuel.
|
Ann Farris |
| 12/31/2000 |
Update or Other Action |
In September 2000, three groundwater samples, one marine surface water sample, and one sediment sample were collected at SS02. In groundwater, DRO was measured at 0.095 mg/L, which was below the 1.5 mg/L regulatory screening criterion. No other contaminants were detected in groundwater except for arsenic, which was measured at 0.003 mg/L. The interim cleanup level for arsenic is 0.050 mg/L. This concentration, however, does not exceed naturally occurring background levels of arsenic. |
Ann Farris |
| 2/23/2001 |
Document, Report, or Work plan Review - other |
Letter to AF RE: Proposed Plan for SS02, ST05, SS12, and SS15. Recommend dividing the plan into two separate documents, handling SS02 and ST05 separately from SS12 and SS15. The sites along the beach: SS02 and ST05 are very different than the two sites on the gravel pad and tundra. The sites along the beach are physically close to Kotzebue Sound, a marine surface water body, and have groundwater issues. The other two sites are underlain by continuous permafrost, have had significant cleanup work completed, and have surface fresh water issues.
SS02 and ST05
The proposed cleanup levels for soil are not appropriate. The Arctic Zone Levels are not applicable at these sites because groundwater exists. Options for groundwater cleanup levels are: 18 AAC 75 Table C values, 10 Times the Table C values, site specific risk based cleanup values.
Pesticides surface water cleanup criteria have a quantitative cleanup values and must be monitored for in the groundwater monitoring wells.
SS02 will need to be closed out per the ADEC Solid Waste Regulations since it was operated as a landfill. The preferred remedy for SS02 is not technically natural attenuation since the groundwater and surface water are already below the cleanup levels. It would be described as long term monitoring to show the contaminants in the landfill are not migrating, institutional controls to prevent digging in the landfill and monitoring of the landfill cover for erosion and revegetation.
Excavation of 375 cubic yards at ST05 is fine. However, it is unclear why the soil at the former water tank location with DRO at 10,100 ppm is proposed for excavation but not at the soil remaining at the former location of the other tanks, which is as high as 18,000 ppm. |
Ann Farris |
| 4/30/2001 |
Update or Other Action |
United States Department of Interior (USDOI) Bureau of Land Management (BLM) Northern Field Office Kotzebue Long Range Radar Site and White Alice Communication Site Conveyance Scenario (Case serial no. F-010085 2310 (027)). Approximately 508 acres are currently withdrawn for use by the USAF (February 3, 1953 Public Land Order 883). Topfiled by the State of Alaska (F 89403). Also found under BLM Case Serial number AKF 010085 FRC Site Code ANC, Case Type 233400 Wdl-Dept of Air Force, Accession Num: 49790101. Original acreage was 1,115 acres as Kotzebue Air Force Reserve, Kotzebue LRRS, Kotzebue White Alice. The installation boundaries originally covered Sections 21 (lot 1), 22 (Lot 1), 26 (Aliquot SW), 27 (Lot 1), 28 (Lot 1), 34 and 35 (aliquot W2) T. 17 N. R. 18 W. Kateel River Meridian.
Now the installation covers Sections 21, 22, 27 and 28, T. 17 N. R. 18 W. Kateel River Meridian.
The surrounding lands have been selected by the Kikitagruk Inupiat Corporation (KIC) (F 14880-A). Under ANCSA, any lands withdrawn for national defense purposes were not available during the selection period open to NANA Regional Corporation or the KIC Village Corporation.
When the lands have been cleared of excess buildings and hazardous materials, the USAF will file a Notice of Intention to Relinquish the Land with BLM. A copy of this Notice of Intention will also be sent to General Services Administration (GSA). GSA will send a notice to all federal agencies, as a part of a preliminary screening process, to inform them that this parcel is available, should they want it.
In addition to transfer of this parcel to another federal agency, a separate option also exists. While still withdrawn, and with concurrence of the USAF, and if the State of Alaska agrees to withdraw its application, a government of non-profit entity authorized to acquire land may file a Recreation and Public Purposes application (43 CFR 2740). Recreation and public purposes include providing for services or facilities in connection with public health, safety or welfare. Common examples are: schools, hospitals and churches. |
Louis Howard |
| 5/17/2001 |
Meeting or Teleconference Held |
Staff attended restoration advisory board (RAB) meeting - issues discussed were publishing reports in the newspaper, better explanation of ecological risk assessment, proposed plans pending, need to explain cleanup levels well, historical grave on the facility, program for the school, and need to present GW results. |
Ann Farris |
| 6/12/2001 |
Document, Report, or Work plan Review - other |
ADEC letter to USAF re: review comments on the sampling and analysis plan for post thermally-treated soils from the Long Range Radar Site Location, Kotzebue, Alaska dated May 2001.
The sampling and analysis plan (SAP) describes details of the thermal treatment of contaminated soils to be completed at the Kotzebue Long Range Radar Station (LRRS) in the 2001 field season. The SAP includes the stockpile and sampling details for the pre- and post-treated soils. ADEC has the following comments on the plan:
1. Page 4, Section 4.6, 1st Sentence: The ADEC Cleanup Level A Standards apply as indicated unless site-specific cleanup levels have been approved by the ADEC and the treated soil will remain on the original site.
2. Page 5, Section 5.0 Table: The minimum lab samples are accurate, however, the minimum field screening is not. 18 AAC 78.605 refers to UST Procedures Manual for field screening. The manual indicates in Section 4.5.3 that one field screening sample must be collected every 10 cubic yards, unless otherwise approved by ADEC. Please correct the text to indicate this requirement. If on specific sites you wish to alter this requirement, you may submit a request to the appropriate ADEC Project Manager. For the Kotzebue Long Range Radar Site, this requirement is not waived.
3. Page 6, Section 5.2, 1st Sentence: The most recent version of the UST Procedures Manual is dated December 1, 1999. Please update the reference.
4. Page 6, Section 5.4: For the Kotzebue Long Range Radar Site specifically, the analyticals that will be required post-treatment will be dependent on the analysis collected prior to excavation. Residual range organics (RRO) and polynuclear aromatic hydrocarbons (PAHs) may or may not be necessary.
Please note, ADEC review and concurrence on this workplan is to ensure that the work is done in accordance with State of Alaska environmental conservation laws and regulations. While ADEC may comment on other state and federal laws and regulations, our concurrence on the plan does not relieve responsible persons from the need to comply with other applicable laws and regulations. |
Ann Farris |
| 7/31/2001 |
Update or Other Action |
2001 Soil Removal and Treatment - Approximately 300 cubic yards of fuel-contaminated soil from beneath the former 2-million-gallon water above-ground storage tank (AST) were removed and treated in 2001. Prior to the excavation, two samples of contaminated material were collected, and each was analyzed for diesel range organics (DRO)/residual range organics (RRO). DRO and RRO were detected at concentrations of 5,760 and 4,750 mg/kg, respectively, which were below ADEC Method Two cleanup levels.
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 (confirmation) samples.
Excavated soil was treated on-site 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 ADEC Method Two cleanup levels. |
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 |
ADEC sent letter with comments on the Draft 2002 Groundwater Monitoring Workplan Addendum, Kotzebue Long Range Radar Station, Alaska, October 2002.
The Alaska Department of Environmental Conservation (ADEC) has completed review of the workplan which describes the details of the proposed 2002 sampling event at the Installation Restoration Program Sites ST05 and SS02. ADEC has the following comments:
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. |
Ann Farris |
| 12/31/2002 |
Update or Other Action |
In 2002, three groundwater samples were collected from monitoring wells SS02-MW1, SS02-MW2, and SS02-MW3 (USAF, 2003a). DRO was not detected at well SS02-MW1. DRO concentrations were below the 1,500-µg/L regulatory limit (ADEC 18 AAC 75) in wells SS02-MW2 (70 µg/L) and SS02-MW3 (110 µg/L). DRO detected at site SS02 in 1994 is suspected to have originated from ST05, located immediately south (up-gradient) of well SS02-MW3 (USAF, 1995a). Aluminum, arsenic, copper, and nickel were either not detected, or were detected below cleanup levels. Only iron (105 µg/L) and manganese (358 µg/L) were detected above their respective 50-µg/L and 300-µg/L cleanup criteria. No pesticide compounds were detected. |
Louis Howard |
| 2/11/2003 |
Document, Report, or Work plan Review - other |
Staff reviewed the results of the 2002 groundwater sampling. Three wells were sampled between the site and Kotzebue Sound. Samples were analyzed for the full suite of chemicals, including pesticides, VOCs, SVOCs, DRO, metals. No exceedances were detected except slightly elevated concentrations of iron and manganese. |
Ann Farris |
| 5/22/2003 |
Meeting or Teleconference Held |
Staff attended a Restoration Advisory Board (RAB) meeting in Kotzebue regarding the Kotzebue Long Range Radar Site. The meeting focused on whether or not the community wanted to continue the RAB as meetings have been sporadic and attendance low. The radar site was demolished and the majority of active cleanup has already occurred, however, Proposed Plans and Decision Documents still need to be prepared and signed. These documents are expected to be forthcoming in the next year. The community decided they wanted to attempt to continue with the RAB in order to actively participate in the proposed plan/decision document stage. The next meeting is scheduled for July 22-23. The local community members that were in attendance agreed to contact several organizations and other community members by the July meeting in an effort to revitalize the RAB. |
Ann Farris |
| 6/24/2003 |
Document, Report, or Work plan Review - other |
Comment letter on the SS02 and ST05 Proposed Plan.
General comment: correct typographical and grammatical errors throughout the document and use milligrams per kilogram or milligrams per liter instead of parts per million throughout the document. Note there are no specific cleanup levels for sediments so the screening criteria that was used must be referenced. Please indicate why the metals are thought to be naturally occurring. Clarify why there was no estimate of health risk to humans from ST05.
Page 8, 1st Paragraph, 3rd Sentence - The cleanup level for polynuclear aromatic hydrocarbons (PAHs) is not the same as the TAqH standard. The TAqH standard is comparable to the sum of the concentrations of benzene, toluene, ethylbenzene, and total xylenes (BTEX) compounds and a specific list of PAHs.
Page 8, 1st Paragraph, 4th Sentence - The statement that the groundwater contamination is contained needs to be substantiated via a brief explanation in the text and a reference. It is not enough to say the samples in the sound did not detect contaminants. The contaminants may still migrate to the surface water body, but be quickly diluted to the extent that they cannot be detected in a surface water sample.
Page 10, 4th Paragraph, 4th Sentence - The current statement indicates the “contaminant levels do not pose a risk to human health, and this pathway was not included in the risk assessment.” The discussion should indicate that because the water is non-potable due to the high salinity, the potential risk to humans from drinking the water was not evaluated.
Page 11, Table 1 - The arctic cleanup levels are applicable for the sites on the bluff, but not on the beach because the 18 AAC 75 Arctic Zone Soil Cleanup Levels are based on the migration to groundwater not being a complete pathway. Groundwater is present at these two sites, although it is not being used as a drinking water source.
For these two sites, the ADEC would be satisfied with establishing cleanup levels only for the groundwater and surface water. The risk from the soil contamination is based on potential migration to the groundwater and Kotzebue Sound. Since the proposed remedy is to actually monitor the groundwater and surface water, there is no need to sample or establish cleanup levels for the soil. When the water meets the appropriate cleanup levels, the soil will be sufficiently clean to be protective of human health and the environment. Please note that this discussion is based on the selected remedy of long-term monitoring and institutional controls to restrict excavation of the beach sands. If a different remedy is ultimately selected, different cleanup levels may be applicable.
The cleanup levels for groundwater water and surface water should be those listed in 18 AAC 70 Water Quality Standards for Marine Water Uses. The groundwater must meet these standards due to the close connection between the groundwater and Kotzebue Sound at these sites.
Page 13, 1st Paragraph, 4th and 6th Sentences-Please clarify if there are solvents at these sites that need remediation. If not, please remove the word solvents in this sentence. If there are solvents present, the proposed plan needs to be significantly revised.
|
Ann Farris |
| 1/15/2004 |
Update or Other Action |
Remedial Investigation conducted in Fall 2003 at facility. Surface water & sediment samples showed no contaminants of concern above action levels. GW exists at Kotzebue LRRS as a supra-permafrost shallow aquifer & is present at SS02 located adjacent to Kotzebue Sound along the beach. GW was collected from each site as part of the 2003 RI/FS. At SS02, DRO & pesticides were analyzed to confirm SS02 is not a potential source for pesticide contamination. Three GW monitoring wells were sampled at SS02. None of the samples collected at SS02 exceeded GW screening criteria.
No pesticides were detected at SS02-MW2 in 2003 & none of the GW samples at SS02 in 2003 exceeded GW screening criteria. Since the analytical results are below cleanup standards, the site is recommended for closure. RI field activities in 2003 were performed to minimize any impact to the plant. Field personnel & equipment avoided areas with reported Barneby’s Milkvetch. Furthermore, no sampling occurred in areas where the rare plant was previously mapped. During the initial site inspection & during field activities, no Barneby’s Milkvetch was observed.
Values equal to 10 times (10x) the GW cleanup levels presented in Table C of 18 AAC 75.345 were used as primary GW screening criteria. In accordance with criteria listed in 18 AAC 75.341(b)(2)(A), GW that does not constitute a potential drinking water source can be considered for 10x cleanup levels. Due to the brackish character of near-beach GW at SS02 & ST05, the GW is considered to not be a likely future drinking water source. Geochemical testing of near-beach GW at ST05 during the 1994 RI reported chloride levels as high as 760 mg/L. According to surface water quality criteria set forth in 18 AAC 70.020, the reported chloride level exceeds the maximum allowable chloride level of 250 mg/L for a fresh drinking water supply.
Due to the proximity of GW to Kotzebue Sound & the shallow nature of the aquifer, Alaska surface water quality criteria (18 AAC 70) & surface water quality regulations were also used to establish GW screening criteria. The selected screening criteria were used only to evaluate the nature & extent of GW contamination & determine COPCs. The GW screening criteria were evaluated on an analyte- or chemical-specific basis.
A localized area of near-beach GW is present at SS02 & ST05. Because contaminated GW is considered the environmental media of concern at these sites, & GW monitoring is likely to continue, the migration of residual fuels in soil would be evident in future GW results. No soil samples were collected at SS02 & ST05 during the 2003 RI/FS. No soil samples were collected at SS02 & ST05 during the 2003 RI/FS.
ARARS
The drinking water regulations are not an ARAR for SS02 and ST05 because the underlying aquifer is high in salinity and not suitable as a drinking water source.
National Recommended Ambient Water Quality Criteria, 40 CFR Part 131 (November 2002). These standards were developed under Clean Water Act Section 304(a) to provide guidance to states in adopting ambient water quality criteria (AWQC). The water quality criteria are potentially relevant and appropriate to the Kotzebue LRRS sites because CERCLA 121(d)(2)(A) establishes that site cleanups must at least attain a standard of control equal to the federal AWQC. Although the federal AWQC are not enforceable, these standards may be relevant and appropriate under the circumstances of the release at non-Superfund sites.
See site file for additional information.
|
Ann Farris |
| 2/26/2004 |
Document, Report, or Work plan Review - other |
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 actions 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.
The 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 the 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.
|
Ann Farris |
| 4/23/2004 |
Risk Assessment Report Approved |
None of the groundwater samples collected at SS02 in 2003 exceeded groundwater screening criteria. Monitoring well SS02-MW3 has historically reported the highest concentration of DRO at SS02. The 1995 RI/FS reported a DRO concentration in groundwater of 5,500 ìg/L for monitoring well SS02-MW3. The 2003 DRO concentration in SS02-MW3 was significantly lower at 74 ìg/L.
Pesticides were not detected at SS02-MW2 in 2003. The highest 1994 pesticide concentrations in groundwater, detected in well SS02-MW2, were 0.074 ìg/L DDD; 0.057 ìg/L DDE; and 0.40 ìg/L DDT. The highest reported 2003 RI pesticide concentrations at SS02 (0.00023 ìg/L DDD, 0.00026 ìg/L DDE, and 0.00035 ìg/L DDT) are substantially lower in comparison to the highest 1994 RI pesticide concentrations. The ubiquitous nature of pesticides at the Kotzebue LRRS suggests that SS02 is not considered to be a point source for these compounds.
No discussion of natural attenuation is provided for SS02 because groundwater and surface water analytes that previously exceeded screening criteria in the 1995 RI/FS were substantially lower in comparison to the 2003 RI sample results; and none of the groundwater or surface water samples collected during the 2003 RI exceeded the screening criteria. Well SS02-MW3 has been incorporated in the ST05 groundwater monitoring well network.
A human health and ecological risk assessment was finalized in 2004 using data fromt he 2003 Remedial Investigation/Feasibility Study. No significant human health or ecological risk was identified for SS002. |
Ann Farris |
| 1/12/2005 |
Update or Other Action |
File number updated with subfile 410.38.002.12. |
Aggie Blandford |
| 2/6/2005 |
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 |
| 6/1/2005 |
Update or Other Action |
Final version of proposed plan received. Former Waste Accumulation Area No. 2/Landflill (SS02)
SSO2 is a former waste accumulation area and landfill that was used until 1972 to store and dispose of wastes from Kotzebue LRRS. USAF removed leaking drums of fuel-based wastes, and cleaned and graded the site in 1975. There were also localized areas of mounded landfill debris at the former landfill site comprised of crushed drums and containers and other metallic debris.
1995 RI/FS: The pesticides DDE, DDD, and DDT were found in groundwater at 0.074, 0.057, and 0.4 parts per billion (ppb), respectively. The surface water sample, collected from a temporary pond on the beach, also had the pesticides DDE, DDD, and DDT at levels of 0.065, 0.045, and 0.039 ppb, respectively. Cleanup levels for DDE,DDD, and DDT in groundwater and surface water were 0.0059, 0.0083, and .0.059 ppb, respectively. In groundwater total PAHs were also detected at 17 ppb, which slightly exceeded the cleanup level of 15 ppb.
1999 Long-Term Monitoring-USA F collected one groundwater sample, one seawater sample, and one
sediment sample. All sample results were below EPA cleanup levels with the exception of the seawater sample, which had DDT at 0.004 ppb, which is above EPA's 1999 National Recommended Water Quality Criteria of 0.00059 ppb.
DRO was found at 5.5 ppm in groundwater, which exceeded the ADEC cleanup goal of 1.5 ppm. DRO is thought to be from former fuel tanks (ST05) located upgradient and south of SS02, because it was only found in one well, located to the south of SS02.
USAF recommended long-term monitoring of groundwater to evaluatefuel contaminant levels, re-grading SS02 to prevent surface water ponds, and re-vegetation. The site was covered in 1995 with gravel and re-graded.
SS02 Proposed Action under ADEC-Landfills with undocumented contents such as SS02 may require institutional controls to restrict subsurface activities (i.e., access to potentially hazardous and non-hazardous substances). Institutional controls for SS02 will be documented in the Base General Plan and will be funded under the USAF Compliance Program. USAF’s established dig permit and construction review system will continue to be utilized to restrict activities at the landfill. Periodic visual inspections will be performed to verify the effectiveness of the institutional controls.
Institutional controls with NFA status will be noted in USAF and ADEC records for SS02. Land use at SS02 will be restricted because the site is a former landfill. USAF plans to maintain ownership of SS02 due to the necessity of institutional controls at the site. Following consideration of public comments received, USAF will prepare a ROD to document the final selected remedy for SS02. |
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.
Clarification to community member's comment that excavation at the beach area of SS002 could result in the formation of thermokarsts due to the presence of permafrost in the area. Air Force response: No permafrost exists in the SS002 area because of a thaw bulb due to the close proximity of Kotzebue Sound.
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.
Community member expressed discomfort with leaving unknown debris in the landfill at SS002.
Air Force response: It was explained that the shore line at SS002 appeared stable and no contaminates are migrating from the landfill, therefore a No further Action determination with land use controls is the appropriate course of action for that kind of site. No serious disagreement was voiced.
No formal written comments were received during the open comment period. Neither were comments received by the toll free telephone line. |
Louis Howard |
| 6/8/2006 |
Document, Report, or Work plan Review - other |
FYI entry: John Halverson (ADEC) denies 611 CES/CEVR request for waiver of the requirement that an "Impartial Third Party" conduct sampling.
We received your request for a waiver of the state requirement that a qualified, impartial third
party conduct sampling, analysis, interpretation and reporting of characterization and cleanup
data for work planned at Barter Island this summer. Specifically, the request was for the Civil
Engineering Squadron, Environmental Operations Section (CES/CEVO) staff to be approved
for collecting soil, sediment and concrete samples at Installation Restoration Program and
Clean Sweep sites.
However, ADEC has several concerns over past work conducted by the CES/CEVO, which lead to our denial on the request for a waiver. It has come to our attention that the CEVO work crew allegedly discovered releases of oil or other hazardous substances and failed to report the
releases to DEC in a timely manner as required by 18 AAC 75.300; assessment/cleanup reports
prepared by the CEVO lack detail and required information; the field crew has reportedly not
followed approved work plans. A few examples of this include:
- Point Lay where "gross petroleum contamination" was found during removal of bulk fuel tanks in 2005. We have found no record of a spill report being submitted, our contaminated sites staff working on the site was not informed, the draft report submitted this year failed to describe the release or extent of contamination clearly and instead described sampling in downgradient test pits and recommended natural attenuation for the area.
- Point Lonely, where several large fuel tanks, a pumphouse and associated piping, and petroleum contaminated soil were removed in 2005. The draft report does not adequately describe fieldwork that was conducted during the characterization and removal of the contaminated soil and lacks required information (no data quality review, lack oflaboratory data). DEC comments on the draft report have yet to be addressed and no final report has been submitted.
• North River RRS - Fieldwork was not conducted in accordance with the approved work plan (no field screening to guide excavation); the draft report lacked detail describing the field work and lacked laboratory reports and a quality assurance review, there were QA/QC problems. DEC comments on the draft report have only been partially addressed, and a final report has not been submitted. The excavation was left open with a liner placed in the bottom and rocks on it; the excavation was not properly backfilled and secured nor is it being inspected and maintained as requested by the department.
A survey of our project managers indicates there has a consistent problem with the CEVO
reporting information in a clear, understandable and complete manner.
Based on these issues, we regrettably must deny your request for a waiver ofthe impartial third
party sampler. As discussed with Mr. David Longtin of the 611 CES/CEVR, Air Force staff may conduct field screening and sampling to evaluate whether a release of oil or hazardous substances has occurred; however, a qualified impartial third party must conduct or oversee
sampling, data collection and interpretation and reporting for contaminated site characterization and cleanup work on sites where releases have been confirmed. |
Louis Howard |
| 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' 36"N, 162° 36' 26"W (NAD83/WGS84) TOPOZONE.COM USGS Kotzebue D-2 |
Louis Howard |
| 9/18/2007 |
Update or Other Action |
Workplan (WP) approval requirements & quality assurance oversight on Performance Based Contracts (PBCs) letter from John Halverson (ADEC) to Scott Hansen (611 CES). ADEC is writing to remind you of contaminated site WP approval requirements in AK’s oil & hazardous substance pollution control regulations & UST regulations. Additionally, ADEC is concerned over quality assurance on PBCs.
WP Approval-Several 611 CES environmental restoration projects were implemented this summer without obtaining prior WP approval from DEC. The site cleanup rules require ADEC approval on WPs before beginning interim removal actions (18 AAC 75.330), site characterization work (18 AAC 75.355), or cleanup operations (18 AAC 75.360). Similarly, the UST regulations specify ADEC may require a corrective action plan be submitted for approval prior to conducting corrective action at an UST release site (18 AAC 78.250).
ADEC staff strives to complete plan reviews & respond to responsible parties within thirty (30) days after receipt of plans, although this is not always possible nor is it a requirement. At times expedited plan reviews are feasible based on project manager work load, adequate up-front planning, & contractors providing complete, well written plans. However, if significant WP revisions are required, additional review & comment resolution time will be needed. To facilitate successful project implementation, I recommend DoD project managers & contracting staff:
• Coordinate schedules with DEC project managers in advance & throughout projects.
• Include DEC project managers in project planning meetings (DQO meetings, UFP QAPP development meetings, Triad & other Technical Project Planning team meetings, etc.).
• Plan & maintain project schedules that include a sixty (60) days for reviewing draft work plans, comment resolution, any necessary revisions & a final review & approval.
• Review contractor planning documents prior to submission to DEC to ensure compliance with state & federal regulations consistency with agreements made during project planning meetings.
Failure to obtain WP approval before implementing site work described above is considered a violation of AK regulations & may result in field work not being approved or additional work being required & may subject responsible parties &/or contractors to a Notice of Violation (NOV).
Independent QA oversight on PBCs-As DoD transitions more ER projects to PBC concerns have risen regarding the level of Quality Assurance (QA) oversight. The site cleanup rules require that “collection, interpretation, & reporting of data, & the required sampling & analysis is conducted or supervised by a qualified, impartial third party”.
Depending upon the specific terms in a PBC, a contractor may no longer be considered an impartial third party with respect to collecting, interpreting & reporting data. This should be taken into consideration when preparing scopes of work. DEC strongly recommends the Air Force provide an on-site Quality Assurance (QA) Representative or a third party QA oversight contractor to monitor fieldwork for consistency with approved plans & contract requirements.
DEC is beginning to conduct more frequent independent QA site inspections to evaluate conformance to approved work plans & regulatory compliance. Because we lack staff resources to conduct independent QA on all of the anticipated PBC projects, we intend to include contracting support for field QA oversight in the DSMOA Joint Execution Plans & budget. |
John Halverson |
| 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. Soild waste exists at SS002 Waster Accumulation Area No. 2/Landfill. LUCs (also known as institutional controls under 18 AAC 75.375) will be implemented and maintained as long as undocumented solid waste remains buried at SS002.
The selected remedial action under the State of Alaska regulations is - LUCs for SS002 and - Sampling/Modeling of Groundwater Migration with LUCs (institutional controls) for ST005. LUCs (also known as institutional controls under 18 AAC75.375) will be implemented and maintained as long as undocumented solid waste remains buried at SS002. Notice in Air Force land records to prohibit disturbance within SS002 of surface or sub-surface soil without ADEC concurrence to prevent possible exposure of landfill contents at SS002.
• 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. LUCs will continue until T AH and TAqH concentrations reach the cleanup criteria in this ROD.
• 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/monitoring will occur until the Air Force demonstrates through modeling, that no degradation of the adjacent surface water is occurring. The estimated duration of this sampling/monitoring is estimated to be five years or less.
The LUCs at SS002 and STOOS are designed to limit disturbance and off-site transport to control exposure and protect human health and the environment.
See site file for additional information.
|
John Halverson |
| 11/1/2007 |
Institutional Control Record Established |
Land Use Controls -LUCs (also known as institutional controls under 18 AAC 75.375) will be implemented and maintained as long as undocumented solid waste remains buried at SS002. Notice in Air Force land records to prohibit disturbance within SS002 of surface or sub-surface soil without ADEC concurrence to prevent possible exposure of landfill contents at SS002.
LUCs will be implemented and maintained as long as sampling/modeling of surface water and
near-beach groundwater total aromatic hydrocarbons (TAH) and total aqueous hydrocarbons (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 TAH and TAqH concentrations reach the cleanup criteria in this ROD.
The LUCs at SS002 and STOOS are designed to limit disturbance and off-site transport to control
exposure and protect human health and the environment. The LUCs will include the following:
• Notice in the Air Force Land Records to prohibit the disturbance of soil at S8002 and ST005
without prior approval by ADEC.
• Provide for a survey and document LUC boundaries in the Kotzebue LRRS BGP and Air Force
Land Records.
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, so that the ADEC can be involved in discussions to ensure that appropriate provisions are included in the transfer terms or conveyance documents to maintain effective LUCs.
In addition to the land transfer notice and discussion provisions above, the Air Force further agrees to provide ADEC with similar notice for federal-to-federal transfer of property accountability and administrative control. Review and comment opportunities afforded to ADEC as to federal-to-federal transfers shall be in accordance with all applicable federal laws. All notice and comment provisions above shall also apply to leases, in addition to land transfers or sales.
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.
• The Air Force shall provide notice to ADEC as soon as practicable after discovery of any activity that is inconsistent with the LUC requirements, objectives or controls, or any action that may interfere with the effectiveness of the LUCs. The Air Force shall include in such notice a list of corrective actions taken or planned to address such deficiency or failure.
• If the Air Force requires a substantial LUC modification or termination of the LUCs inconsistent with this ROD, the Air Force and ADEC will issue an addendum to this ROD. |
Louis Howard |
| 11/5/2007 |
Conditional Closure Approved |
ADEC John Halverson sent the Air Force a cover letter to accompany the Final April 4, 2007 Final Record of Decision For No Further Action received for signature. The source areas covered by the document include - SS007 (Former Water Supply Lake), SS013 (Landfarm), SS014 (East Tanks), SS015 (Former Power Plant/Garage), SS016 (Buildings 101 and 102), SS017 (PCB Spill at Building 102), SS019 (PCB Spill South Fence), SS020 (Spill Nos. 2 and 3), SS018 (Former Truck Fill Stand), SS002 (Waste Accumulation Area No. 2/Landfill) and ST005 (Former Beach Tanks).
SS002 Waste Accumulation Area No. 2/Landfill
ADEC concurs no further remedial action is warranted at the site. However, as a former dump where undocumented solid waste remains buried, land use controls (LUCs) will need to be in place. In addition to the notice in Air Force land records prohibiting disturbance without ADEC concurrence to prevent possible exposure of landfill contents at SS002, ADEC requests the Air Force provide the information to BLM for inclusion in it’s case files for the land status plats. The information provided in this ROD will suffice as information to be provided in the BLM case files. 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. |
Louis Howard |
| 11/14/2008 |
Update or Other Action |
Long Term Management Report SS012, SS018, SS002, and ST005 October 2008 received. This report presents the results of the 2008 Long Term Monitoring (LTM) efforts at
beach groundwater wells at the Former Beach Tanks (ST005) and Waste Accumulation
area No.2 (SS002); and at the diesel rang organics (DRO) impacted sites Spill No.2 & 3 (SS012), and Former Truck Fill Stand (SS018) at Kotzebue Long Range Radar Station (LRRS). This work is done by the 611th Civil Engineer Squadron (CES) of the United States Air Force Environmental Remediation Project Manager. All work was performed by qualified persons as defined by 18 AAC 75.990(100) and required by 18 AAC 75.
The purpose of the LTM effort is to meet the requirement of the groundwater monitoring at ST005 and SS002 sites; and monitored natural attenuation at SS012 and SS018 sites ROD (USAF 2007). The objective of the LTM includes the following:
? Monitoring for natural attenuation parameters and contaminant levels every five years at SS012 and SS018 until the DRO level at the soils are or below 12,500 ppm.
? Visual inspection for presence of a sheen at seasonal surface water ponds located at the down gradient edge of the sites every five years.
? Monitoring annually groundwater under the direct influence of surface water at the selected beach wells down-gradient to SS02 and ST05 for potential migration of total aromatic hydrocarbons (TAH) and total aqueous hydrocarbons (TAqH) off-site into the surface water body (Kotzebue Sound).
Groundwater under influences of surface water at the beach wells down-gradient of the Former Beach Tanks (ST005) and Waste Accumulation area No.2 (SS002) sites has been detected high level of total aromatic hydrocarbons (TAH) and total aqueous hydrocarbons (TAqH) petroleum products. The groundwater down-gradient of ST005 exceeds the State of Alaska standards set forth in 18 AAC 70.020 which is implies a threat to public health, welfare, safety, or the environment. The selected remedy in the 2007 ROD under the state laws and regulations is LTM or develop a model that shows no degradation of the adjacent surface water has occurred.
Groundwater samples were tested for TAH and TAqH at contaminated sites SS002 and ST005. The test results from monitoring wells SS02MW2 and SS02MW3, down gradient of SS002, were below the method detection level and well below the established the ADEC Water Quality Standards. This indicates that there is no threat of contamination at the site migrating into Kotzebue Sound.
See site file for additional information.
|
Louis Howard |
| 11/25/2008 |
Document, Report, or Work plan Review - other |
Staff reviewed and commented on the Draft Long Term Management Report SS012, SS018, SS002, and ST005 October 2008.
SS012 and SS018
The text states no groundwater contamination was detected at the SS002 monitoring wells and that there is no need for annual or additional monitoring on those wells. ADEC disagrees. Section 4.3 on page 4-31 reported a small amount of sheen observed at the edge of the pond down gradient of SS012 and SS018 during the visual inspection. A water sample from the ond was tested for BTEX, SVOC and DRO, but was not sampled for TAH and TAqH.
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 down gradient 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.”
Since a sheen was observed, at a minimum, the Air Force will be inspecting and re-sampling surface water at least one more time before July 28, 2013. ADEC will require the Air Force to sample soil for: DRO, SVOCs, BTEX in sediments and surface water for: total aqueous hydrocarbons (TAqH) via method 625CSIM and total aromatic hydrocarbons (TAH) via method 602/624.
Note the AK101 method can be extended for specific determination of volatile aromatics (BTEX) as specified in EPA Method 8021B or 8260B for solids utilizing methanol preservation option only. All AK101 and volatile aromatic samples must be preserved with methanol.
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. The Air Force is responsible for the actions of its contractors, subcontractors, agents, or other persons acting on its behalf, who perform work to accomplish the tasks and objectives listed in the “2008 Long Term Management Work Plan”.
|
Louis Howard |
| 2/4/2010 |
Update or Other Action |
LTM report received.
GW under influences of surface water at the beach wells down-gradient of the Former Beach Tanks (ST005) & Waste Accumulation area No. 2 (SS002) sites has been found to contain high levels of TAH & TAqH. The GW down-gradient of ST005 exceeds the State of AK standards set forth in 18 AAC 70.020 which implies a threat to public health, welfare, safety, or the environment. The selected remedy outlined in the 2007 ROD under the state laws & regulations is to conduct LTM or develop a model that shows no degradation of the adjacent surface water has occurred.
SS002 GW samples were collected from temporary piezometers installed within 10’ downgradient of the wells, except TAqH & natural attenuation parameter samples at SS02-MW3, which were collected from the existing monitoring well during the first sampling period. The test results from piezometers SS02-MW2P & SS02-MW3P, & monitoring well SS02-MW3, downgradient of SS002, were either below the method detection level or practical quantitation limit (PQL) & well below the established ADEC Water Quality Standards. This indicates that there is little threat of contamination in shallow GW from the site migrating into Kotzebue Sound, & GW itself is not significantly impacted.
DO, iron, manganese, total nitrate, chlorine, fluorine, sulfate, sulfide, ammonia, & TOC were measured at the six wells, four hyporheic sample locations, & two surface water locations at the SS002 & ST005 sites during the September 2009 monitoring event. Results were used to evaluate the processes associated with intrinsic biodegradation. Although there is not a current background well at the site (i.e. upgradient of contamination), evaluation of natural attenuation usually compares measured values within the contamination plume to background concentrations for the site.
Since a formalized background well does not currently exist at the site, wells SS02-MW2 & SS02-MW3 were treated as a proxy background wells for the purpose of this analysis, due to their non-detect to extremely low results for TAH & TAqH & distance from the grossly contaminated area.
TAH & TAqH in GW, hyporheic water, & surface water have been non-detected or at least an order of magnitude below the surface water criteria for both 2008 & 2009. These results indicate that not only is surface water not being adversely impacted by petroleum contamination, but also the hydrocarbons dissolved in GW & hyporheic water are insufficient to do so now or in the future. MNA parameters including DO, ORP, manganese, & iron are more indicative of background or upgradient conditions, & do not exhibit evidence that biodegradation has occurred or is ongoing; an observation consistent with the TAH & TAqH observed. It is recommended that the ADEC grant Closure Complete/Institutional Controls status.
Recommendations: GW, hyporheic water, & surface water monitoring should be discontinued at site SS002 since monitoring data has yielded sampling results for TAH & TAqH that are either non-detect or at least one order magnitude below the surface water cleanup standard. All SS002 monitoring wells should be removed.
See site file for additional information. |
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 received and commented on by staff.
For all documents submitted to ADEC for review and comment, please have the names and signatures of the specific “qualified person” or if more than one staff person, “qualified persons” responsible for the following:
Cover Page (of the report)
?Name and signature of qualified person responsible for collecting samples.
? Name and signature of qualified person responsible for interpreting the data.
? Name and signature of qualified person responsible for reporting the data.
This requirement and others are found in ADEC’s “Site Characterization Work Plan and Reporting Guidance for Investigation of Contaminated Sites” version 1.1 as amended through September 23, 2009. The most recent version of this guidance can be found at ADEC’s website: http://www.dec.state.ak.us/spar/guidance.htm#csp under Site Characterization and Cleanup.
The text states annual monitoring of surface water-influenced groundwater at select beach wells downgradient to SS002 and ST005 for potential off-site migration of total aromatic hydrocarbons (TAH) and total aqueous hydrocarbons (TAqH) into the surface water body (Kotzebue Sound).
Please note while the 2008 work plan and Table 3-1 (Analytical Methods) of the draft report states TAH will be analyzed via EPA 602/624 and TAqH will be analyzed via EPA 625CSIM, ADEC Contaminated Sites program has the following requirements for TAH and TAqH compliance monitoring:
18 AAC 70.020 Water Quality Standards for Designated Uses table, note 7 currently reads:
7. Samples to determine concentrations of total aromatic hydrocarbons (TAH) and total aqueous hydrocarbons (TAqH) must be collected in marine and fresh waters below the surface and away from any observable sheen; concentrations of TAqH must be determined and summed using a combination of:
(A) EPA Method 602 (plus xylenes) or EPA Method 624 to quantify monoaromatic hydrocarbons and to measure TAH; and
(B) EPA method 610 or EPA Method 625 to quantify polynuclear aromatic hydrocarbons listed in EPA Method 610;
use of an alternative method requires department approval; the EPA methods referred to in this note may be found in Appendix A of 40 CFR 136, Appendix A, as revised as of July 1, 2003 and adopted by reference.
ADEC will require the Air Force to confirm that the calculation of the reported values for TAqH were summed using Method 625CSIM to quantify PAHs listed in Method 610 and either Method 602 (plux xylenes) or Method 624 to quantify monoaromatic hydrocarbons.
3.0 2009 Long-Term Management Activities Page 12
The text states that Well SS02-MW1 could not be found and likely was destroyed or decommissioned. ADEC requests the Air Force replace the well as soon as possible if it was destroyed. If the well was decommissioned, then provide documentation in the report proper decommissioning activities took place for Well SS02-MW1 (adopted by reference 1992 Recommended Practices for Monitoring Well Design, Installation, and Decommissioning).
The 2007 Record of Decision requires an annual report be submitted to ADEC for the 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.
ADEC requests the Air Force submit the annual report for LUCs’ status, in a separate document, as stipulated in the Record of Decision. LUCs will continue to be required at SS002 because the site is a former landfill with undocumented contents.
|
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.
Groundwater Sampling – SS002 & ST005
Seven monitoring wells will be sampled; this includes the two new wells to be installed. The groundwater samples will be analyzed for:
TAH
TAqH
Nitrate/Nitrite
Total Organic Carbon (TOC)
Ammonia
Iron
Manganese
Chloride
Fluoride
Sulfate
Sulfide
The following field parameter measurements will be obtained based on the availability of water:
Temperature
pH
Conductivity
Dissolved oxygen
Oxidation/reduction potential
Turbidity
Surface Water Monitoring and Sampling – SS002 & ST005
Two locations will be sampled in the SS002 and ST005 areas annually. The samples will be collected from the surface water in the Kotzebue Sound. Sediment samples are not collected from these areas.
The samples will be analyzed for:
TAH
TAqH
Nitrate/Nitrite
TOC
Ammonia
Iron
Manganese
Chloride
Fluoride
Sulfate
Sulfide
Pore Water Sampling – SS002 & ST005
Pore water (hyporheic water) samples will be collected annually at four locations within the
SS002 and ST005 areas. The samples will be collected along the waterline where the Kotzebue Sound meets the beach, as the sea elevation is decreasing. The sampling device will be inserted about 2 ft bgs.
Samples will be analyzed for:
TAH
TAqH
Nitrate/Nitrite
TOC
Ammonia
Iron
Manganese
Chloride
Fluoride
Sulfate
Sulfide
3.3.5 Soil Sampling – SS012 & SS018
Five soil samples will be collected at approximately 1 ft below the organic layer at each location. Soil sampling locations will be based on past maximum observed concentrations. |
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 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.
TAH and TAqH concentrations in groundwater, hyporheic water, and surface water at site SS002
have been below the detection level, or approximately an order of magnitude below the surface
water criteria, for the past three annual sampling events. These results indicate that not only is surface water not being adversely impacted by petroleum contamination, but also the concentration of hydrocarbons dissolved in groundwater and hyporheic water is insufficient to cause an adverse impact now or in the future. Field parameters, including DO and ORP, are indicative of background or upgradient conditions. |
Louis Howard |
| 4/5/2011 |
Update or Other Action |
Staff received the Environmental Baseline Study work plan for review and comment. A Phase I EBS and possibly a Phase II EBS will be performed at Kotzebue LRRS. The objective of the Phase I EBS is to document conditions at each subject property and identify recognized environmental conditions in connection with each subject property. Primary tasks associated with the Phase I EBS include records review, interviews, and site reconnaissance. Asbestos-containing building materials (ACM), radon, lead-based paint, drinking water quality, polychlorinated byphenols (PCBs), and mold will also be evaluated as appropriate.
If the results of the Phase I EBS suggest that potential environmental contamination is present at an installation, the objective of the Phase II EBS will be to confirm the presence or absence of contamination through limited surface soil sampling.
Phase II EBS soil sampling will be limited to the collection of surface or shallow subsurface
(up to 1 foot deep) soil samples. No deep soil (greater than 1 foot deep) or groundwater
sampling is anticipated. Because the type or types of contamination that may be present is
unknown, a relatively broad analytical suite has been specified for the purposes of this Work
Plan.
It is estimated that about eight soil samples will be collected from each installation. Based on historical research and field observations, samples may be analyzed for gasoline range organics by Alaska Method AK101, for diesel range organics by Alaska Method AK 102, for residual range organics by Alaska Method AK 103, for volatile organic compounds by EPA Method 8260B, for semivolatile organic compounds by EPA Method 8270C, for PCBs by EPA Method 8082, and/or for metals by EPA Methods 6010B, 6020, and 7471A. |
Louis Howard |
| 7/1/2011 |
Risk Assessment Workplan Approved |
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 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 Dump Site (SS002)
TAH and TAqH concentrations in groundwater, hyporheic water, and surface water at site SS002 have been below the detection level, or approximately an order of magnitude below the surface water criteria, for the past three annual sampling events. These results indicate that not only is surface water not being adversely impacted by petroleum contamination, but also the concentration of hydrocarbons dissolved in groundwater and hyporheic water is insufficient to cause an adverse impact now or in the future. Field parameters, including DO and ORP, are indicative of background or upgradient conditions. |
Louis Howard |
| 7/27/2011 |
Update or Other Action |
Staff received the draft work plan for Environmental LTM & Maintenance at the Kotzebue Long Range Radar Station Contract: FA8903-10-D-8593, Project Number: MLGD20117701.
The environmental LTM & maintenance effort at Kotzebue LRRS consists of monitoring GW annually at SS002 & ST005, & monitoring natural attenuation at SS012 & SS018. This Work Plan details the environmental LTM & maintenance activities at SS002, ST005, SS012, & SS018.
The efforts described in this plan consist of environmental monitoring of groundwater, soil, sediments, surface water, & pore water.
The scope of the field work includes the following tasks:
- Collect groundwater, surface water & pore water (hyporheic zone) samples from areas SS002 & ST005 annually.
- Collect soil samples & visually monitor seasonal ponds on the down-gradient edge of SS012 & SS018. Collect surface water & sediment samples if a sheen is observed.
Groundwater Sampling – SS002 & ST005
Six monitoring wells will be sampled. The GW samples will be analyzed for:
- TAH by USEPA Method 624 or SW846 8260B
- TAqH by USEPA Method 625
- Nitrate/Nitrite by USEPA Method 353.2 or SM4500-NO3-E
- Total Organic Carbon (TOC) by USEPA Method SM5310B
- Ammonia by USEPA Method 350.1
- Iron by USEPA Method SW846 6010B
- Manganese by USEPA Method SW846 6010B
- Chloride by USEPA Method 300.0
- Fluoride by USEPA Method 300.0
- Sulfate by USEPA Method 300.0
- Sulfide by USEPA Method 376.2 or SM4500-S-2 D & E
The following field parameter measurements will be obtained based on the availability of water using a submersible water quality probe:
- Temperature
- pH
- Conductivity
- Dissolved oxygen
- Oxidation/reduction potential
- Turbidity
Surface Water Monitoring & Sampling – ST005
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.
The samples will be analyzed for:
- TAH by USEPA Method 624or SW846 8260B
- TAqH by USEPA Method 625
- Nitrate/Nitrite by USEPA Method 353.2 or SM4500-NO3-E
- Total Organic Carbon (TOC) by USEPA Method SM5310B
- Ammonia by USEPA Method 350.1
- Iron by USEPA Method SW846 6010B
- Manganese by USEPA Method SW846 6010B
- Chloride by USEPA Method 300.0
- Fluoride by USEPA Method 300.0
- Sulfate by USEPA Method 300.0
- Sulfide by USEPA Method 376.2 or SM4500-S-2 D & E
Pore Water Sampling – SS002 & ST005
Pore water (hyporheic water) samples will be collected annually at four locations within the SS002 & ST005 areas. The samples will be collected along the waterline where the Kotzebue Sound meets the beach, as the sea elevation is decreasing. The sampling device will be inserted about two ft bgs. Pore water sampling locations have been selected based on previous LTM sampling event locations.
Samples will be analyzed for:
- TAH by USEPA Method 624or SW846 8260B
- TAqH by USEPA Method 625
- Nitrate/Nitrite by USEPA Method 353.2 or SM4500-NO3-E
- Total Organic Carbon (TOC) by USEPA Method SM5310B
- Ammonia by USEPA Method 350.1
- Iron by USEPA Method SW846 6010B
- Manganese by USEPA Method SW846 6010B
- Chloride by USEPA Method 300.0
- Fluoride by USEPA Method 300.0
- Sulfate by USEPA Method 300.0
- Sulfide by USEPA Method 376.2 or SM4500-S-2 D & E
Soil Sampling – SS012 & SS018
A combined total of 10 soil samples will be collected from Site SS012 & SS018. Five soil
samples at each site will be collected at approximately one ft below the organic layer. Soil
sampling locations will be based on past maximum observed concentrations.
SS012 - Three sample locations will be centered at the location where elevated levels of DRO have been observed during past sampling episodes, with two of the samples being located
across-slope a distance of approximately 25 ft in either direction from the center sample. Two
additional samples will be located downslope approximately 50 ft from the center sample
location.
SS018 - Two samples will be retrieved at the location where elevated levels of DRO have been observed during past sampling episodes. One sample will be located downgradient approximately 25 ft from the highest observed DRO levels observed during the 2010 sampling event. Two additional samples will be located upgradient approximately 50 & 75 ft from the previous sample location.
The soil sample collection & screening procedures are detailed in the Field Sampling Plan. Sampling equipment will be decontaminated between sampling intervals.
The soil samples will be analyzed for:
- DRO by AK102
- Nitrate/Nitrite by USEPA Method 353.2or SM4500-NO3-E
- Benzene, toluene, ethylbenzene, & xylenes (BTEX) by USEPA Method SW846 8260B
- Polycyclic Aromatic Hydrocarbons (PAHs) by USEPA Method SW846 8270D SIM
See site file for additional information. |
Louis Howard |
| 7/28/2011 |
Document, Report, or Work plan Review - other |
Staff provided comments on the Environmental LTM and Maintenance for Kotzebue LRRS July 2011.
5-2 Table 5-2: ADEC requests the Air Force to provide sample/sample duplicate and RPD results, regardless if they were greater than the reporting limits or not.
64 Worksheet #28 QC Samples Table: ADEC requests the Air Force ensure that all field duplicate collection will follow the ADEC’s December 2010 Draft Field Sampling Guidance. Specifically: Table 3 – Minimum Quality Control Requirements: Minimum Field QC Samples: Field Duplicate (Minimum of one per every 10 field samples for each matrix sampled, for each target analyte, minimum of one) All soil and water samples Relative percent differences (RPD) less than: 30% water, 50% soil.
Field Duplicate for Grab Samples: QC Samples Table states one of 20 field samples of similar matrix will be the frequency/number collected. This conflicts with Section 4.2 Quality Control Samples Page 4-5 which states (correctly): One duplicate will be collected for every 10 samples.
67 QAPP Worksheet #30 Analytical Services Table: The text states no backup laboratory has been selected at this time. However, several other laboratories in the SGS network are ELAP certified, and if necessary, samples can be sent to alternate laboratories under the subcontract that is in place. ADEC will require the Air Force to use current ADEC certified laboratories for any backup laboratory analyses. The SGS Laboratory in Anchorage is the only “SGS” Laboratory (UST-005) certified by ADEC for the analyses proposed in this work plan.
80 QAPP Worksheet #37: The text refers to TestAmerica LODs are capable of meeting sensitivity requirements, and the compounds of potential concern can be detected below the project evaluation criteria. This is the first time TestAmerica Laboratory is being referenced. Section 4.7 Laboratory Methods Page 4-7 states the analytical laboratory planned for use is SGS North America Inc. (SGS) 200 West Potter Drive, Anchorage Alaska 99518. Please delete reference to TestAmerica since SGS is the laboratory of choice for this work plan.
143 of the PDF Table 15-1 Reference List and Evaluation Criteria for Soil/Sediment Samples: The table incorrectly references Alaska Department of Environmental Conservation (ADEC) Soil Cleanup Levels, Direct Contact, Over 40 inch Zone (2008) and Alaska Department of Environmental Conservation (ADEC) Soil Cleanup Levels, Outdoor Inhalation, Over 40 inch Zone (2008). The Method Two direct contact and outdoor inhalation cleanup levels for the Arctic Zone are the correct cleanup levels. As defined by regulation, ADEC believes the Kotzebue LRRS is in the arctic zone. 18 AAC 75.990 (4) “Arctic zone” means areas north of latitude 68° North; and area south of that latitude will be considered an “Arctic zone” on a site-specific basis, based on a demonstration that the site is underlain by continuous permafrost. Please change the values to Arctic Zone soil cleanup levels.
m- & p-Xylenes as well as o-Xylene are shown to have NS or not specified cleanup level for direct contact or inhalation. However, please note that there are cleanup levels for total Xylenes under Method Two for the Arctic Zone: Direct Contact 27,400 mg/kg and Outdoor Inhalation 63 mg/kg.
Bis(2-chloroethoxy)methane is shown to be NS or not specified cleanup level for Direct Contact, Outdoor Inhalation or Migration to Groundwater. Absent cleanup levels specified in 18 AAC 75 under Method Two for this compound, ADEC requests the Air Force reference the EPA Risk-Based Concentration screening level table available at
http://www.epa.gov/earth1r6/6pd/rcra_c/pd-n/screen.htm for compounds without a specified cleanup level (i.e. NS).
For Example:
p-Xylene
600 mg/kg for Residential Soil and a risk-based soil screening level (SSL) for protection of groundwater value of 0.2 mg/kg.
m-Xylene
590 mg/kg for Residential Soil and a risk-based soil screening level (SSL) for protection of groundwater value of 0.2 mg/kg.
o-Xylene
690 mg/kg for Residential Soil and a risk-based soil screening level (SSL) for protection of groundwater value of 0.2 mg/kg.
4-Nitroaniline
24 mg/kg for Residential Soil and a risk-based soil screening level (SSL) for protection of groundwater value of 0.0014 mg/kg.
Benzyl Alcohol
6100 mg/kg for Residential Soil and a risk-based soil screening level (SSL) for protection of groundwater value of 0.89 mg/kg
Bis(2-chloroethoxy)methane
180 mg/kg for Residential Soil and a risk-based soil screening level (SSL) for protection of groundwater value of 0.25 mg/kg.
|
Louis Howard |
| 4/6/2012 |
Update or Other Action |
Draft Technical Project Report for the 2011 Environmental Long Term Monitoring and Maintenance at Kotzebue Long Range Radar Station received. One SS002 monitoring well planned for sampling (SS002-MW3) was not sampled because the field sampling team could not access the well. The well lid required a different type of rectangular wrench that the field sampling team did not have.
There were no exceedances for TAH or TAqH from groundwater samples collected at SS002.
One SS002 hyporheic water sample (SS002-P1) was collected. Concentrations at SS002-P1 were ND for TAH and 2.06 µg/L for TAqH. There were no exceedances for TAH or TAqH from the hyporheic sample collected at Site SS002, as per Alaska Water Quality Standards.
Periodic monitoring through visual inspection and photo documentation has been completed at
SS002. Additionally, one hyporheic water sample was collected and analyzed to determine TAH
and TAqH. As part of the required Environmental Long Term Monitoring and Maintenance, this
event will occur at SS002 until deemed unnecessary by USAF and ADEC. Further remediation
at SS002 is not recommended at this time.
BEM considers the associated samples representative of the SS002, SS012, SS018, and ST005 sites. The data collected is partially consistent with the approved workplan/sampling and analysis plan. However, not all the samples identified in the QAPP on Worksheet #10 were collected. Specifically, one monitoring well was not sampled at SS002, and four monitoring wells were not sampled at ST005.
The remaining contamination is currently at concentrations below Alaska Water Quality Standards (18AAC 70.020), making negative impact toward the on the Beaufort Sea unlikely. However, if an increase in contamination is observed in future hyporheic sampling events downgradient of SS002, the USAF may decide at that time to further investigate additional remediation alternatives. |
Louis Howard |
| 4/27/2012 |
Update or Other Action |
Staff reviewed & provided comments on the Draft Technical Project Report for Kotzebue Long Range Radar Station.
3.1 ADEC requests the AF either change the well lid so that it matches the other well lids of the other GW wells & does not require a different type of rectangular wrench or ensure the next sampling team has both types of rectangular wrenches needed to access all GW monitoring wells at the site. This is a data gap for SS002 with regards to not sampling SS002-MW3.
Please ensure that GW wells are sampled regardless of sheen or hydrocarbon odor for TAH & TAqH. The footnote for 18 AAC 70 that excludes sampling surface water where sheen is present does not apply to sentinel monitoring wells being monitored for TAH & TAqH. Alternatively, the Air Force can install four additional monitoring wells between the existing wells & the surface water body to try to find GW that has no sheen present.
This may be an issue since the surface water is so close to the sentinel wells with sheen being observed & therefore, the Air Force must sample these wells in the future regardless of sheen. Ideally, the purpose of sentinel wells is to warn of contaminant migration towards a receptor.
The document states: “GW samples were also analyzed for natural attenuation parameters including ammonia, chloride, fluoride, total & dissolved iron & manganese, nitrate/nitrite (as nitrogen), sulfate, sulfide, & total organic carbon (TOC).”
Unless there is information to the contrary not present in this report, ADEC requests the AF add text to state “GW samples were not analyzed for natural attenuation parameters at the following wells, because no GW samples were collected at SS002 (S002-MW03) & at ST005 (ST005-MW2, MW6, MW8 & MW9B).” At ST05-MW10, GW samples were collected & the results of the natural attenuation parameters can be found on page ….”
5.1
GW Results
Please identify the GW wells sampled for SS002 & ST005. Also, discuss the results of the natural attenuation parameters GW samples & any interpretation that can be reached from the natural attenuation results for SS002 & ST005.
See site file for additional information.
|
Louis Howard |
| 5/29/2012 |
Document, Report, or Work plan Review - other |
Environmental Long Term Monitoring and Maintenance Final Technical Project Report, Alaska June 2012 Final Technical Project Report 10-ECOS09-13; CDRL A001C received.
ADEC has completed its review on the document concerning: SS002 (CS DB Hazard ID 850), ST005 (CS DB Hazard ID 831), SS012 (CS DB Hazard ID 826) and SS018 (CS DB Hazard ID 829. The document is approved by ADEC. In the future, ADEC will require a cover page for all submitted reports [in accordance with 18 AAC 75.335(b)(1)]:
1) Name and signature of “qualified person” responsible for collecting samples [in accordance with 18 AAC 75.355(b)].
2) Name and signature of “qualified person” responsible for interpreting the data [in accordance with 18 AAC 75.355(b)].
3) Name and signature of “qualified person” responsible for reporting the data [in accordance with 18 AAC 75.335(c)(1)}.
4) Site name(s)
5) ADEC file number(s)/CS Database hazard ID(s).
All work plans submitted to ADEC review and comment must include as the cover page the following information
1) Name and signature of the “qualified person” who prepared the work plan,
2) Site name(s)
3) ADEC file number(s) and CS Database hazard ID(s).
|
Louis Howard |
| 6/12/2012 |
Update or Other Action |
Kotzebue Long Range Radar Station Environmental Long Term Monitoring and Maintenance
Final Technical Project Report 10-ECOS09-13; CDRL A001C received.
CONCLUSIONS AND RECOMMENDATIONS
The 2011 Environmental Long Term Monitoring and Maintenance activities for Sites SS002, ST005, SS012, and SS018 at Kotzebue LRRS are complete for this year. Conclusions and recommendations specific to each site are provided below.
Waste Accumulation Area No. 2/Landfill (SS002)
Periodic monitoring through visual inspection and photo documentation has been completed at
SS002. Additionally, one hyporheic water sample was collected and analyzed to determine TAH
and TAqH. As part of the required Environmental Long Term Monitoring and Maintenance, this
event will occur at SS002 until deemed unnecessary by USAF and ADEC. Further remediation
at SS002 is not recommended at this time.
The remaining contamination is currently at concentrations below Alaska Water Quality Standards (18AAC 70.020), making negative impact toward the on the Beaufort Sea unlikely. However, if an increase in contamination is observed in future hyporheic sampling events downgradient of SS002, the USAF may decide at that time to further investigate additional remediation alternatives.
Former Beach Tanks Site (ST005)
Periodic monitoring through visual inspection and photo documentation has been completed at
ST005. Additionally, hyporheic, surface and groundwater monitoring samples were collected
and analyzed to determine TAH and TAqH. As part of the required Environmental Long Term
Monitoring and Maintenance, this event will occur at ST005 until deemed unnecessary by USAF
and ADEC. 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 evaluate site contaminant migration through the soil column, into the active layer and toward the Kotzebue Sound.
As a result of the statistical analysis performed for historic and recent hyporheic sampling events downgradient of ST005, no increasing trend in the three temporary well points (ST005-P1, ST005-P2 and ST005-P3) was observed.
Spill Sites No. 2 & 3 (SS012)
Periodic monitoring through visual inspection and photo documentation has been completed at
SS012. Additionally, five soil samples were collected and analyzed for DRO and natural
attenuation parameters. As part of the required Environmental Long Term Monitoring and
Maintenance, this event will occur at SS012 until deemed unnecessary by USAF and ADEC.
Further remediation at SS012 is not recommended at this time. However, if in the future, DRO contamination in the soil is observed to increase, or negatively affect the surrounding area, the USAF may decide at that time to further investigate additional remediation alternatives.
Former Truck Fill Stand (SS018)
Periodic monitoring through visual inspection and photo documentation has been completed at
SS018. Additionally, five soil samples were collected and analyzed for DRO and natural
attenuation parameters. As part of the required Environmental Long Term Monitoring and
Maintenance, this event will occur at SS018 until deemed unnecessary by USAF and ADEC.
Further remediation at SS018 is not recommended at this time. However, if in the future, DRO contamination in the soil is observed to increase, or negatively affect the surrounding area, the USAF may decide at that time to further investigate additional remediation alternatives. |
Louis Howard |
| 8/8/2012 |
Update or Other Action |
Draft Environmental LT Mgt. work plan Kotzebue LRRS received.
The efforts described in this plan consist of environmental monitoring of groundwater, soil,
sediments, surface water, and pore water.
The scope of the field work includes the following tasks:
- Collect groundwater, surface water and pore water (hyporheic zone) samples from Sites
SS002 and ST005 annually.
- Collect soil samples and visually monitor seasonal ponds on the down-gradient edge of
SS012 and SS018. Collect surface water and sediment samples if a sheen is observed.
Site-specific information regarding sampling and monitoring locations, the number of samples,
well locations, and the project schedule is discussed in this plan. Exact locations of samples will be subject to change, based on site conditions.
Six groundwater monitoring wells, including SS02-MW3, ST05-MW2, ST05-MW6, ST05-MW8, ST05-MW9B and ST05-MW10 will be sampled (Figure 3-1) during the 2012 annual field event and analyzed for:
- TAH by United States Environmental Protection Agency (EPA) Method 624or 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 and E
It should be noted that, per ADEC recommendation, all planned groundwater 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.
Pore water (hyporheic water) samples are collected annually at four temporary locations within
the SS002 and ST005 areas (Figure 3-1), including SS02-P1, ST05-P1, ST05-P2, and ST05-P3.
The pore water samples will be collected along the waterline where the Kotzebue Sound meets
the beach, as the sea elevation is decreasing. The field team will utilize a global positioning
system (GPS) device to navigate to the collection point for each pore water sample, based on
previous LTM sampling event locations. The sampling device will be inserted about two ft bgs
at each location and will be collected using a peristaltic pump and dedicated tubing.
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 and 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 and ST005. Sediment samples are
not collected from these areas.
|
Louis Howard |
| 4/24/2013 |
Update or Other Action |
Draft Environmental LTM report received for review & comment.
Waste Accumulation Area No. 2/Landfill (SS002)
Annual monitoring through visual inspection & photo documentation has been completed at SS002 for the 2012 calendar year. Additionally, one GW sample (SS002-MW3) was collected & analyzed to determine TAH & TAqH concentrations. One planned pore water sample location (SS002-P1) could not be sampled due to limited recharge in the temporary well after it was purged dry. The recharge problem was potentially due to frozen conditions beneath the ground surface in the active zone region. No analytical results for TAH & TAqH or natural attenuation parameters were obtained for SS002 hyporheic water sampling from the 2012 LTM event.
As part of the required LTM for this site, LTM will continue at SS002 on an annual basis until deemed no longer necessary by the USAF & ADEC. Further remediation at SS002 is not recommended at this time. Based upon several consecutive years of monitoring results, the remaining contamination is currently at concentrations below Alaska Water Quality Standards (18AAC 70.020), making negative impact toward the on the Beaufort Sea unlikely. However, if an increase in contamination is observed in future hyporheic sampling events downgradient of SS002, the USAF may decide at that time to further investigate additional remediation alternatives.
See site file for additional information. |
Louis Howard |
| 5/20/2013 |
Document, Report, or Work plan Review - other |
Staff provided comments on the draft LTM report.
For the purposes of scheduling, the Air Force should schedule and resample in early September from this point forward, instead of October 22-24, 2013 due to freezing conditions. Soil sampling was not conducted at Sites SS012 and SS018 as planned, due to frozen ground conditions. The two seasonal ponds located at the downgradient edge of SS012 and SS018 were frozen and inspecting for sheen or other evidence of contamination was difficult at best and no surface water or sediment samples were taken.
At SS002-P1, the temporary well location immediately purged dry, with no observed recharge, preventing sample collection in that particular location. This was potentially due to frozen conditions beneath the ground surface in the active zone region. Three ST005 hyporheic water samples (ST005-P1, ST005-P2, and ST005-P3) were planned for sampling, however, ST005-P3 was found to be frozen below the ground surface, to the extent that a stainless steel drive point could not be advanced beyond a few inches, preventing sample collection at that location.
|
Louis Howard |
| 6/13/2013 |
Document, Report, or Work plan Review - other |
ADEC has received the final version of the Environmental Long Term Management Technical Report for Kotzebue Long Range Radar Station on June 10, 2013. ADEC has reviewed the final document and has no further comments on it. The document is approved. |
Louis Howard |
| 6/13/2013 |
Exposure Tracking Model Ranking |
Initial ranking with ETM completed for source area id: 71829 name: SS002 Former Landfill Waste Accumulation Area |
Louis Howard |
| 2/4/2014 |
Update or Other Action |
Environmental Long-Term Management report received for review and comment. TAqH was exceeded at SS002-MW3 and SS002-P1: 32.9 ug/L (The Limit of Detection value was utilized in calculating TAH and TAqH). Due to laboratory-reported matrix interferences and required dilutions, the reported LODs for water samples were high, causing even non-detect results for TAqH to be in exceedance of criteria. 8270C was utilized by the laboratory to determine PAH values, which provides higher LOD values when matrix interference is observed. For future monitoring where TAqH is to be calculated, 8270C SIM should be utilized to provide less opportunity for exceedance sensitivities.
Although currently, there is no background well at the site (i.e. upgradient of contamination), evaluation of natural attenuation usually compares measured values within the contamination plume to background concentrations for the site. Due to the well’s non-detect (ND) results for TAH and TAqH concentrations, and distance from the contaminated area, SS002-MW3 is being treated as a proxy background well for the purpose of this analysis. Site ST005’s background well ST005-MW10, has identical TAH and TAqH concentrations as SS002-MW3, with ND results.
DO is typically the key factor affecting natural biodegradation of hydrocarbons in the saturated zone. DO measurements taken from hyporheic water sample locations are less indicative of biodegradation due to the influence of wave action; as such DO is only discussed for the SS002 and ST005 monitoring well sample locations.
The DO concentration measured at SS002-MW3 was 11.07 mg/L. Other biological activity indicators are nitrate, manganese, sulfate, sulfide, and iron. SS002-MW3 concentrations of these parameters were: 1,700 µg/L, ND, 5,100 µg/L, ND, and ND, respectively. The ORP value from SS002-MW3 was negative (-) 27.7 mV. These values, in conjunction with MNA parameter results from the 2009 LTM event (USAF 2010a), will be considered background concentrations for Site ST005 groundwater, and will be used as a baseline comparison.
As part of the required LTM for this site, LTM will continue at SS002 on an annual basis until deemed no longer necessary by the USAF and ADEC. Further remediation at SS002 is not recommended at this time. Based upon several consecutive years of monitoring results below cleanup criteria, and ND analytical results for TAH and TAqH with the 2013 LTM, despite the exceedance of TAqH criteria as explained in the paragraph above, the remaining contamination should be considered at concentrations below Alaska Water Quality Standards (18AAC 70.020), making negative impact toward the Beaufort Sea unlikely. However, if an increase in contamination is observed in future hyporheic sampling events downgradient of SS002, the USAF may decide at that time to further investigate additional remediation alternatives. |
Louis Howard |
| 2/21/2014 |
Document, Report, or Work plan Review - other |
Staff provided comments on the draft work plan.
Groundwater Sampling
Page 15
The text states: “Groundwater depths and total well depths were measured the day prior to purging and sampling to minimize disturbance of the water column. Low-flow purge and sampling techniques using peristaltic pumping were employed for all groundwater samples.
Once purge stabilization had been achieved, the laboratory-provided sample containers were filled using a low-flow peristaltic pump equipped with disposable Teflon®-lined tubing in accordance with ADEC’s Draft Field Sampling Guidance (ADEC 2010).
Groundwater samples were then submitted to the laboratory for analysis of benzene, toluene, ethylbenzene, and xylenes (BTEX) and polycyclic aromatic hydrocarbons (PAHs) to determine levels of TAH and TAqH, to measure the current contaminant concentrations at the site. BTEX results were summed to determine TAH, and BTEX and PAH results were summed to determine TAqH.”
Page 16
“Prior to collecting samples, field water quality parameters (temperature, conductivity, DO, pH, ORP, and turbidity) were measured using methods described in Section 2.1. A low-flow peristaltic pump equipped with disposable Teflon®-lined tubing was used for sample collection.”
Please be aware in the future for groundwater monitoring of BTEX, peristaltic pumps (regardless if “low flow”) are not allowed due biasing sample results of volatiles and other air sensitive parameters low. ADEC will require the Air Force to use other acceptable sampling equipment in lieu of peristaltic pumps. Please amend all future sampling work plans to incorporate these changes.
EPA and USGS have documented their concerns with the use of the peristaltic pumps to collect water sample in the below documents.
• "The agency does not recommend the use of peristaltic pumps to sample ground water particularly for volatile organic analytes" RCRA Ground-Water Monitoring Draft Technical Guidance, EPA Office of Solid Waste, November 1992.
• "The peristaltic pump is limited to shallow applications and can cause degassing resulting in alteration of pH, alkalinity, and volatiles loss", Low-flow (Minimal drawdown) Ground-Water Sampling Procedures, by Robert Puls & Michael Barcelona, April 1996, EP A/540/S-95/504.
• "Suction-lift pumps, such as peristaltic pumps, can operate at a very low pumping rate; however, using negative pressure to lift the sample can result in the loss of volatile analytes'', USGS Book 9 Techniques of Water-Resources Investigation, Chapter A4. (Version 2.0, 9/2006”
Therefore, ADEC requests the Air Force cease the use of peristaltic pumps at Kotzebue LRRS as part of the groundwater monitoring program (where BTEX and other air sensitive parameters are being sampled) and sample with one of the following: bladder pumps, positive pressure submersible pumps, gear pumps, samplers like Hydrasleeve, Snap Samplers to reduce the loss of volatiles (GRO, BTEX) during sampling. |
Louis Howard |
| 4/29/2014 |
Document, Report, or Work plan Review - other |
Staff provided comments on the Draft Kotzebue Long Range Radar Station Supplemental Work Plan 2014 Environmental Long Term Management and Remedial Action-Operations, Kotzebue LRRS, AK dated April 2014.
ADEC will approve the document as submitted. Please finalize the document.
|
Louis Howard |
| 3/18/2015 |
Institutional Control Update |
One of several sites with Land Use Controls in effect (LUCMP)in 2015 Pacific Air Forces Regional Support Center Installations, JBER, AK, March 13, 2015.
This LUCMP identifies the LUCs in place for ERP (or Defense Environmental Restoration Account [DERA]-funded) sites at PRSC installations in Alaska, JA, & WIA & documents the responsibilities & procedures for maintaining, managing, tracking, enforcing, & when appropriate, modifying or terminating the LUCs.
Note that the current version of this LUCMP covers the following sites:
• ERP sites & landfills determined to contain hazardous waste, waste assumed hazardous, or nonhazardous waste
• Sites regulated by the U.S. Environmental Protection Agency (EPA), Alaska Department of Environmental Conservation (ADEC), & the ERP
• ERP sites for which information regarding the contamination & LUC status was readily available during the development of this LUCMP
• Landfill sites managed by PRSC determined to contain hazardous waste, waste assumed hazardous, or nonhazardous waste that are not regulated by the ERP
“CZ” is the abbreviation for the Environmental Engineering Directorate of AFCEC, & “CZOP” is the abbreviation for Environmental Engineering Directorate, Operations Division, Pacific.
LUCs on active installations are not recorded in deeds. The USAF uses existing land use planning & management systems to track & manage LUCs at its installations. These systems typically involve including LUC boundaries & attributes into geographic information system (GIS) layers, incorporating LUCs into the installation master plan, & filing LUCs with the installation offices that are responsible for managing the buildings & grounds, utility systems, & construction.
Once LUCs are implemented, they must be maintained as long as site conditions exist that prevent unrestricted land use &/or unlimited exposure. LUCs can be maintained using a variety of separate & collective processes, including the site approval process, LUC boundary markers, periodic site inspections, environmental self-audits, training, internal notices, & 5-year reviews. If it appears a LUC is being violated, then appropriate installation officials should be notified immediately. Furthermore, regulatory agencies may be notified of the violation as applicable & as detailed in DDs, RODs, signed action memoranda, or ADEC letters of concurrence. The officials should take steps to ensure the integrity of the LUC is restored & the necessary corrective action & notifications are made. In addition, if the type of land use at an ERP site changes, the LUCs for the site should be reviewed to ensure that the new land use is compatible with the LUCs. If it is not, then the site remedy & DDs may need to be revised before implementing a land use change.
In addition to ICs established as part of LUCs of the ERP for landfill sites with LUCs in effect, both ERP landfill & non-ERP landfill sites in Alaska under the management of PRSC must also comply with regulations set forth by the ADEC solid waste regulations in 18 AAC 60. Furthermore, landfill sites under the management of PRSC but not categorized as an ERP site must also comply with ADEC 18 AAC 60.
Landfills are defined in 18 AAC 60 as “an area of land, or an excavation in which solid wastes are placed for permanent disposal, & that is not an application site, injection well, reserve pit, or waste pile.” This definition applies to most PRSC ERP & non-ERP sites in Alaska designated as landfills, dumps, or caches. Small PRSC ERP & non-ERP landfill sites at remote installations, such as the long-range radar stations, are regulated as Class III landfills as defined by ADEC.
General requirements to manage landfills in place are established by ADEC. However, alternative criteria can & often are adopted through negotiation with ADEC (see 18 AAC 60.900, Waivers).
Kotzebue LRRS KOT-3 Road Oiling SD003
Kotzebue LRRS KOT-4-Waste Oil No. 1 SS001
Kotzebue LRRS WAA No. 2/Landfill SS002
Kotzebue LRRS Spill/Leak No. 1 SS006
Kotzebue LRRS KOT-6 Barracks/Barracks Area SS008
Kotzebue LRRS KOT-5 PCB Spill SS009
Kotzebue LRRS KOT-5 Solvent Spill SS010
Kotzebue LRRS Fuel Spill SS011
Kotzebue LRRS Spills No. 2 and No. 3 SS012
Kotzebue LRRS Former Truck Fill Stand SS018
Kotzebue LRRS White Alice Tanks (AOC 9) ST004
Kotzebue LRRS KOT-8 Site/Beach Tanks ST005
LUC_RESTRICTION LUCs (also known as institutional controls under 18 AAC 75.375) will be
implemented and maintained as long as undocumented wastes (POL contamination) remains buried at SS002. Notice in Air Force land records to prohibit disturbance within SS002 of surface or sub-surface soil without ADEC concurrence to prevent possible exposure of landfill contents at SS002. |
Louis Howard |
| 11/3/2015 |
Update or Other Action |
Draft environmental monitoring report received for review and comment. Monitoring well SS002-MW3 was dry at time of the 2015 LTM events, and therefore no samples were collected from this well for laboratory analysis.
Annual monitoring through LUC inspection and photograph documentation has been completed
at SS002 for the 2015 calendar year. No groundwater sample was collected and analyzed, as
well SS002-MW3 was observed to be dry during the sampling event. One hyporheic water sample location (SS002-P1) was sampled. Analytical results for TAH and TAqH and natural attenuation parameters were obtained for SS002 hyporheic water sampling from the 2015 LTM event. TAH and TAqH concentrations were reported as ND and 3.89 µg/L, well below the respective Alaska Water Quality Standard of 10 µg/L and 15 µg/L.
A LUC inspection conducted at SS002 identified various debris located across the site that is
recommended for removal (Figure 5). Some evidence of vehicle traffic was also observed,
although it does not appear to be negatively site conditions. As part of the required LTM for this
site, LTM will continue at SS002 on an annual basis until deemed no longer necessary by the
USAF and ADEC. |
Louis Howard |
| 11/30/2015 |
Document, Report, or Work plan Review - other |
Staff reviewed and approved the Draft Kotzebue Long Range Radar Station Supplemental RA-O Work Plan 2015 Environmental Long Term Management, Kotzebue LRRS, AK dated November 2015. |
Louis Howard |
| 12/29/2015 |
Update or Other Action |
Staff assigned changed to Joy Whitsel |
Joy Whitsel |
| 1/21/2016 |
Institutional Control Periodic Reporting |
DEC has reviewed and approves the final report entitled Technical Project Report Environmental Long Term Management Kotzebue Long Range Radar Station. This report presents the results of the 2015 Environmental Long Term Management (LTM) program at four sites: Waste Accumulation Area No. 2/Landfill (SS002), the Former Beach Tanks Site (ST005), Spill Sites No. 2 & 3 (SS012), and Former Truck Fill Stand (SS018).
Groundwater and soil water samples were below the respective DEC Method Two Soil Cleanup levels and Groundwater Cleanup levels, and surface water samples were within Alaska Water Quality Standards at all sites except for Site ST005. Groundwater modeling results for ST005 represent an advancing contaminant plume and suggest that the existing residual contaminant plume is contributing a greater rate of dissolved concentrations of TAH and TAqH to ST005 groundwater than what is degraded through natural attenuation.
Land Use Control (LUC) inspection of SS002 identified various debris located across the site that is recommended for removal. LUC inspection of ST005 identified various debris associated with shooting range and dog kennel activities across the site that is recommended for removal.
|
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 |
| 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 |
| 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 |
| 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. |
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 |
