| Action Date |
Action |
Description |
DEC Staff |
| 5/8/1990 |
Document, Report, or Work plan Review - other |
ADEC sent Col. Edwin Ruff letter re: USTs at Fort Richardson. Staff reviewed the draft SOPs for Site Investigation of UST removals dated April 11, 1990.
Screening Method: Soil samples collected when HNU [photoionization analyzer] readings are consistently less than 50 ppm. Recommend excavating until the readings with Hnu are non-detectable (or equal to the background readings) and then collecting soil samples for laboratory analysis.
Sample location: The department has not been accepting composite sampling from within excavation as a means of determining adequacy of cleanup. Composite sampling has been approved as a method of characterizing spoils piles after excavation.
Sample collection procedure: Sample collection jars should be obtained from the laboratory that will perform the analyses. Samples must be stored at 4 degrees celsius from the time of collection until analyzed (within 14 days of collection).
Analysis: All soil samples should be analyzed for Total Petroleum Hydrocarbons (EPA Method 418.1) and BTEX (EPA Method 8020) unless a hydrocarbon identification test (EPA Method 8015) clearly shows that the contamination is ONLY diesel or another non-gasoline fraction hydrocarbon such as heating fuel. Under these conditions, samples need only be analyzed for TPH.
If the tank was used for waste oil, soil samples should be analyzed for PCBs (EPA 8080), total arsenic, cadmium, chromium, and lead as proposed in your SOPs. If the total lead content is above allowable limit, additional sampling and analysis should be conducted following the toxic characteristic leaching procedure (TCLP). Rather than testing the soils for total organic halides by EPA Method 9020, the department is requesting analysis of total organic halides by EPA Method 8010.
If a site cannot be cleaned up adequately through the tank removal and initial excavation efforts, a site assessment may be requested including individual work plans and QA/QC plans. For the initial tank removals this letter and your SOP for tank removals, dated April 11, 1990, will suffice as a generic work plan. |
Ron Klein |
| 5/14/1990 |
Update or Other Action |
APVR-DE-PSE (200-1A) May 14, 1990: Memorandum for Record - Sampling at Antenna Field
1. On 25 Apr 90. the Environmental Reaources Branch sampled
seven underground storage tanks (USTs) at the antenna field.
All tanks had previously been sampled and only the sludge
remained. Three of the tanks did not have enough sludge to draw
a sample (< l"). We have attached the analysis for the remaining
(Samples 90041, 90042, 90043, 90044).
2. The analysis indicates no PCBs were detected in any of the
samples. Additionally, samples 9941 and 90042 were water with
only trace amounts of fuel.
3. The remaining compounds are not toxic unless they are
ingested. It is unlikely the contents of these tanks will cause
any adverse effects if proper work practices are used.
Lori T. Lay Environmental Engineer
. |
Jennifer Roberts |
| 5/21/1990 |
Site Added to Database |
|
Louis Howard |
| 5/31/1990 |
Notice of Violation |
Excavate until field screening indicates contamination removed to levels at or near background levels. Written report within ten (10) days of receipt of letter. |
Louis Howard |
| 7/5/1990 |
Leaking Underground Storage Tank Corrective Action Underway |
Letter from Colonel Ruff states that 840 cubic yards of petroleum contaminated soil were excavated and stockpiled. Petroleum contamination remains at the site. 21 soil and 2 water samples were collected. Of these, results for 14 soil samples and 2 water samples were submitted. Water samples were collected in improper sample containers. Subsequent sampling of the stockpiled soil (which was moved to the landfill) indicated PCB contamination was present. No data had been submitted to the department for six soil samples from the tank area that were to have been analyzed for PCBs, metals and halogenated compounds. |
Louis Howard |
| 2/11/1991 |
Update or Other Action |
Army sent John Halverson (ADEC) a letter regarding the test results for Fort Richardson's UST Project. These USTs were removed permanently or replaced in 1990. Site assessments have already been submitted for USTs 31, 58, and 50. Site Investigations for Ammo Area "A" (UST 74) and the Antenna Field (USTs 51, 51, 53, 54, 86, 87, and 88) are expected from the CORPS within the next month. Laboratory soil test results and drawings for the remainder of the USTs have been included. Tank#'s 58, 31, and 50 indicated as "clean" rest are "contaminated" per laboratory results. UST#74 is a heating oil UST which was repaired due to leaking piping-Ammo Area "A" tank. |
John Halverson |
| 4/8/1991 |
Update or Other Action |
The name P-D-680 is actually a form of military "slang" & is derived from the Federal Specification designation that governs its procurement. Throughout industry, it is more commonly referred to as: stoddard solvent, dry cleaning safety solvent, naphtha safety solvent, or mineral spirits. PD-680 is very efficient at dissolving and removing most greases & oils from metal & plastic parts.
Federal Specification P-D-680B, "Dry Cleaning and Degreasing Solvent," identifies 3 general types of the solvent classified according to their flash point: Type I > 100°F Type II > 140°F Type III > 200°F There are also Types IA and IIA which are low residue derivations of Types I and II respectively. NOTE: Each item the Government orders must have a National Stock Number, (N.S.N) unless the federal agency gets special permission to local purchase the item. Each N.S.N. item goes out for bid and has an associated minimum specification. Former Defense Reutilization and Marketing Service (DRMO) staff member (now with EPA) researched this at length when he was with DRMO Headquarters to determine which items would be hazardous waste when they received them for disposal.
He reviewed hundreds of microfiche files on all NSNs for chemicals with the specifications for PD680, a.k.a. Stoddard Solvent, back in the 1980's and before it was for a petroleum based degreaser with a specified flashpoint. No requirement for non-halogenated existed for PD680. Besides that, because Alaska was so far from venders that supplied the government, many federal agencies in Alaska with locally purchased solvents, and there were no qualifications on those solvents and most often halogenated solvents worked with less elbow grease than pure petroleum distillates, so they were preferred.
He also checked NSNs ordered through the PD680 specs normally and some batches contained: TCE, Methylene chloride, etc; it depended on who the supplier to the government was at the time. So as a result of his survey between 1980 and 1983, some PD680 batches were in fact halogenated solvents. He researched PD680/Stoddard Solvent/Petroleum Distillate/Degreasing Solvent, while at DRMO in Battle Creek Michigan., Ogden, Utah and when he arrived in Alaska at Fort Richardson. This research included sampling of hundreds of new and used drums of product, as well as NSN specifications, in nearly all western military installations, including Alaska.
MIL-PRF-680 This specification is approved for use by all Departments and Agencies of the Department of Defense. Type I, II, III, and IV are allowed to have maximum concentrations of: 0.7 mg/L or 700 ug/L of Tetrachloroethylene, Trichloroethylene at 0.5 mg/L or 500 ug/L, Benzene 0.5 mg/L or 500 ug/L and up to 100 ppm total chlorine content. |
Louis Howard |
| 5/15/1991 |
Update or Other Action |
CENPA-EN-G-M (200-1c) May 15, 1991, MEMORANDUM FOR CENPA-EN-MB-A SUBJECT: Sampling Report, Underground Storage Tank Remediation, Fort Richardson, AK recieved. The objective of the project was to obtain data for closure of the UST sites in accordance with the requirements of Alaska Department of Environmental Conservation (~EC). To close the sites, the ADEC has required soil borings to check for POL contamination and to determine if further excavation is. required for clean up where underground storage tanks (UST) were removed.
Although there are no regulatory cleanup levels for metals in soils, the presence of high lead levels could indicate the presence of leaded motor fuel. In addition, there are restrictions on soils that are to be placed in landfills. TCLP MCLs are included in Table I for comparison with landfill restrictions. Because of test methodology and reporting parameters, TCLP metal
results cannot exceed limits unless total metals exceed 10 times TCLP limits. Enclosure 1 demonstrates the mathematical logic.
Six holes. BH-12 (AP-2982) to BH-17 (AP-2987). were drilled and monitor wells were installed. Diesel fuel and BTEX contamination was found. at the 10 foot level of borehole AP-2986. Levels of soil contamination greater than 30 mg/Kg diesel fuel and BTEX 9.4 mg/Kg are marginal relative to cleanup levels cited in reference lb.
Groundwater at the site indicates that aromatics and fuel components are present. Kerosene was also present but at less than quantifiable levels. Weathering could cause misidentification of fuels.
BH-12 (AP-2982) sample ID 266 wa-benzene: 620 ug/L. BH-16 (AP-2986) 10-11.5 ft. bgs: diesel fuel #2 730 mg/kg (lab estimate). BH-17 (AP-2987): 420 ug/L. |
Louis Howard |
| 7/2/1991 |
Update or Other Action |
US Army Environmental Hygiene Agency GW Quality Survey No. 38-26-K986-91 Evaluation of Solid Waste Management Units Fort Richardson AK 24 June to 2 July 1991. This survey was performed to evaluate and update the Solid Waste Management Unit (SWMU) information contained in Fort Richardson's RCRA Facility Assessment (RFA); to determine which SWMU's require further sampling, investigation, or corrective action; and to identify and evaluate any SWMU's not previously documented.
SWMU's Not Previouslv Identified in the RFA. The following SWMU was not in existence or were not discovered during the RFA. This site should be formally added to the SWMU list, and supporting documentation regarding ongoing work or justification for no further action should be provided to the regulator prior to issuance of the permit. TABLE 2. SWMU'S NOT PREVIOUSLY IDENTIFIED IN THE RFA:
Antennae Site (SWMU 125). This site consists of several USTs formerly containing oil and slop fuels. Investigations in 1990 included sampling/analysis of ground water and soils, and additional work will be accomplished if necessary. |
Jennifer Roberts |
| 7/8/1991 |
Update or Other Action |
7/8/92 Fort Richardson submitted a memorandum from the ACOE for site assessment work conducted in 1990. Six (6) soil borings were drilled and monitoring wells were installed in each. Soil samples for PCBs or halogenated compounds or metals. Report does not contain the information required under 18 AAC 78. |
Louis Howard |
| 4/9/1992 |
Update or Other Action |
EPA Memorandum April 9, 1992 Reply to the ATTN of ES-098. Subject Toxicity of Fuels. From Carol Sweeney, Toxicologist Health and Environmental Assessment Section. To Wayne Pierre Federal Facilities Superfuend Branch (HW-124). A response has been provided to the frequently-asked question of whether a reference dose or other toxicity information can be provided for fuel mixtures so that these mixtures can be addressed quantitatively in Superfund risk assessments. The memo from ECAO Cincinnati is attached (last attachment). They have developed reference doses for gasoline, JP-5/kerosene, and JP-4, and a cancer potency factor for gasoline. The memo emphasizes that these are provisional numbers and that considerable uncertainty is involved in this quantitative assessment, because of data limitations, and because inhalation studies were used to calculate oral reference doses.
I typed up a summary table showing the numbers (first attachment) and calculated some risk-based concentrations (second attachment). On the risk-based concentration table, I also
included ordnance compounds, because I hadn't made a table of those before that I can remember. The risk-based concentrations were calculated the same way as table II-1 and II-2 of the Region
10 Supplemental guidance; for soil, the same limitations apply, that the numbers presented do not consider pathways other than soil ingestion.
Toxicity Reference Vaules for Fuel Mixtures EPA Region 10 4/9/1992 Non-cancer effects-Gasoline (unleaded) RfD (mg/kg-day) Oral: 2.0E-1, Uncertainty Factor-Oral:1000, Level of Confidence-Oral: Low. Toxicity Data Source-Oral RfD: Memo 3/92. Carcinogenicity-Cancer Potency/(mg/kg/day): Oral 1.7E-3, Unit Risk (/ug/m3) 4.8E-7, Cancer Weight Of Evidence-C, Toxicity Data Source-Oral SF and Inhal. SF: Memo 3/1992.
Kerosene/JP-5 RfD2.0E-2, UF Oral: 10,000, LOC Oral: low, TDS Oral RfD: Memo 3/92
JP-4 RfD 8.0E-2, UF Oral: 10,000, LOC Oral: low, TDS Oral RfD: memo 3/92.
Screening Values for Water RBCs based on Ingestion, Residential
Gasoline-Risk = 10-6 (ug/L) 50, 10-4=5000 HI=1 (ug/L) 7000
JP-5 Kerosene Risk 10-6 10-4=NA HI = 1 (ug/L) 700
JP-4 Risk 10-6 10-4 = NA, HI = 1 (ug/L) = 3,000
Screening Values for Soils- RBCs Based on Soil Ingestion Residential
Gasoline-Risk = 10-6 (mg/kg) 400, 10-4 (mg/kg) 40,000, HQ = 1 (mg/kg) 50,000
JP-5 Kerosene Risk 10-6 10-4 NA, HQ =1 5,000
JP-4 Risk 10-6 10-4 NA, HQ = 20,000
USEPA Office of Research and Development, Environmental Criteria and Assessment Office Cincinnati, OH Subj: Oral Reference Doses and Oral Slope Factors for JP-4, JP-5; similar to Kerosene (CAS no. 8008-20-6), Diesel Fuel (CAS No. 68334-30-5), and Gasoline (CAS No. 8006-61-9) (AVGAS) [McChord AFB (Wash Rack/Treatment)/Tacoma, WA]. From Joan S. Dollarhide Associate Director, Superfund Health Risk Techncial Support Center, Chemical Mixtures Assessment Branch TO Carol Sweeney USEPA Region X.
This memorandum is in response to your request for oral systemic and carcinogenic toxicity values for JP-4, JP-5, diesel fuel, and gasoline (AVGAS) found to contaminate soil and
groundwater at McChord AFB (Wash Rack/Treatment), Tacoma, WA. We have attempted to derive RfDs and slope factors for the above fuel mixtures. We have derived provisional RfDs for
gasoline, JP-4, JP-5 and diesel fuel; provisional cancer weight-of-evidence classifications of C for gasoline and D for JP-4, JP- 5 and diesel fuel; and a provisional slope factor (adapted from an interim Agency value) for gasoline
Based on the available evidence, unleaded gasoline can be assigned to U.S. EPA (1986) weight-of-evidence Group C: possible human carcinogen. An earlier U.S. EPA document assigned unleaded
gasoline to Group B2 as a probable human carcinogen (u.s. EPA, 1987a), but that document predates the U.S. EPA (1991d) conclusion that the male rat kidney tumors produced by gasoline
are not predictive for humans, and therefore should not contribute to the weight-of-evidence or dose-response assessment of carcinogenicity. IARC concluded that marine diesel fuel is possibly carcinogenic to humans (Group 2B), but light diesel fuels and jet fuels are not classifiable as to their carcinogenicity in humans (Group 3). |
Jennifer Roberts |
| 9/21/1993 |
Update or Other Action |
A.G. letter (Breck Tostevin) to Tamela J. Tobia OS Judge Advocate for the Army. Letter states that a separate petroleum site compliance agreement should be separate from the CERCLA federal facility agreement. The petroleum site restoration agreement would function as a "two-party agreement" under the FFA. It would track the basic provisions of the UST Agreement but be tailored to the State's contaminated site regulations and would interface with the FFA. All petroleum sites addressed under the Two Party agreement would be reviewed in the final operable unit of the FFA and actions taken would be memorialized in a Record of Decision (ROD) under the FFA. |
Louis Howard |
| 2/22/1994 |
Document, Report, or Work plan Review - other |
Staff reviewed & commented on the January 1994 Draft Remedial Investigation/Corrective Action Plan HLA Project No. 24212 Building 35752 Fort Richardson, Alaska.
The Alaska Department of Environmental Conservation-Defense Facilities Oversight group (ADEC) has received, on January 28, 1994, a copy of the Draft Remedial Investigation & Corrective Action Plan (RI/CAP) Site 4, building 35752 High Frequency Transmitter Site, HLA Project No. 24212 dated January 18, 1994. Here are ADEC's comments regarding this document.
3.1.1 Deviations from the Release Investigation Plan page 13
The text states that the two inch standpipe near monitoring well AP-3232 was investigated through geophysics by Harding Lawson Associates. A conclusion was reached that an underground storage tank was not associated with this standpipe. Although the standpipe was not considered for further investigation by HLA, ADEC requests that the Army further investigate &/or remove it. Any further investigation or proposed removal will have to follow CERCLA protocols & requirements since the garrison is proposed to be listed on the National Priorities List & this site is included as a part of Operable Unit (OU) B.
5.2.2 Soil Boring Sampling Results page 39
The text states that Diesel Range Organics (ORO) & Gasoline Range Organics (GRO) concentrations were in excess of ADEC Level "A" cleanup levels mainly in borings AP-3227 & AP-3228. The cleanup levels referenced ADEC's soil matrix score sheet are to ensure that groundwater does not become impacted due to contaminant migration from the zone of contamination. Since the groundwater at the site is impacted from petroleum contamination above MCLs the use of Level "A" cleanup levels is inappropriate. Alternative cleanup levels will have to be developed through a risk assessment that follows CERCLA protocols.
ADEC is concerned that the presence of petroleum contaminants & PCBs in the subsurface soils at the fifteen foot depth interval poses a risk to the environment through increased mobilization. ADEC requests that any corrective action plans or interim removal actions for this site incorporate an appropriate method of dealing with PCB contaminated soils (Le. TSD facility) that will satisfy CERCLA requirements.
The document also states that a qualitative risk assessment for risk based concentrations (RBCs) & potential receptors at the site be conducted to determine actions levels for PCBs. ADEC requests that the risk assessment follow CERCLA protocols & methodology. The methodology in developing a baseline risk assessment is described in the Risk Assessment Guidance For Superfund, Volume I: Human Health Evaluation Manual, Part A, (EPA 1989d) (RAGS HHEM & Volume II, Environmental Evaluation Manual (EPA 1989c).
5.2.3 Groundwater Sample Results page 41
The text states that the significant decrease of contaminant concentrations in wells AP-2982 & AP-2987 & lack of detected contaminants in other nearby downgradient wells suggests that the contaminants detected during the 1990 US ACE investigation are dissipating. This assumption cannot be substantiated with the current data set given the qualifications listed in 4.2.1 on page 25. The text states that no duplicates or MS recoveries for Volatile Organic Compounds (VOCs) were submitted for several of the aqueous samples so the data precision & accuracy could not be assessed. Subsequently, the data is suspect & should be viewed with caution. ADEC requests that any additional sampling be conducted with CERCLA protocols in mind since this site is proposed to be included in OU B.
5.2.4 Surface-Water & Sediment Sampling Results Page 42
The text states that cleanup levels are not established for sediment, however there are sediment quality criteria (SQC) available that the U.S. EPA recommends be considered in establishing remediation goals for contaminated sediments. The SQC were designed to be protective of aquatic life & animals that consume aquatic life. The PCB SQC is not a fixed value; rather, it is dependent on the total organic carbon (TOC) concentration in the sediment. In order for the appropriate SQC level to be determined, the TOC will have to be calculated from another round of sediment sampling. ADEC requests that a sampling plan be submitted, using applicable CERCLA protocols, outlining specifically what sediment sampling will be dune & exactly how tile sample will be collected.
See site file for additional information. |
Louis Howard |
| 8/22/1994 |
Document, Report, or Work plan Review - other |
Staff reviewed and commented on the Draft July 1994 Operable Unit D Preliminary Source -Evaluation 2 Work Plans Document# 9000-036-220.
2.3.3.1 Objectives page 2.3-S
Objectives need to include assessing the potential groundwater contamination from any releases that may have occurred on site from the past activities in the drum accumulation area.
2.3.3.2 Field Investigation/Rationale page 2.3-S
The text states two soil borings will either be mstalled in areas that have been identified after analysis of the hand auger boring samples or in areas visually identifiable at the surface within the drum storage area. ADEC requests one of the soil borings be advanced and converted into a groundwater monitoring well to assess present groundwater quality and potential contamination from releases at the site.
2.4.3.2 Field Investigation/Rationale page 2.4-S
See comments under 2.3.3.2 above regarding additional monitoring we11 installation.
2.6.3.2 Field Investigation/Rationale page 2.6-10
The text states if groundwater monitoring wells (from previous investigations) with known elevations and locations are identified, then depth to groundwater measurements will be taken to evaluate the flow direction of groundwater. These previously installed wells must be comparable to any new wells installed, i.e. completed at the same depth and have comparable well screening intervals.
If there are not enough wells in the immediate area to determine the flow and gradient, then
ADEC requests additional wells be installed to obtain this information. ADEC also requests that any groundwater information generated from the previous UST investigations applicable to this OU be incorporated in the PSE 2 report. If the groundwater data is insufficient in detail to evaluate the former USTs as a potential source of GW contamination, then additional investigation must be performed to fully assess the source of contamination.
Table 2.8-2 Substantiated Groundwater Constituents page 2.8-5
The table refers to maximum detected concentrations as being above secondary or primary MCLs, but the table does not give a maximum concentration detected. Please make this consistent with information given in Table 2-l-3 where detected concentrations were listed as maximum detected amounts (i.e. “up to X ppb”)/.
Table 2.8-3 Proposed Sample Summary for Fire Training Pit page 2.8-11
ADEC requests the proposed sampling summary include analysis for dioxins and furans (method SWSZSO) for a minimum of twenty-five of the soil/sediment samples.
Table 2.9-l Substantiated Groundwater Constituents page 2.9-4
See comments above in Table 2.X-2 regarding maximum detected concentrations.
2.10-l Site Background page 2.10-l
The text states the primary objective of the basewide background sampling investigation is to determine the naturally occurring or “background” concentrations of the analytes being tested for at the OU D sites. ADEC is not aware of any naturally occurring- “background” concentrations of PCBs, VOCs, pesticides, herbicides, GRO, DRO, TRPH, SVOCs other than non-detect.
Usually analysis for background concentrations is limited to inorganics naturally occurring such as metals. Be aware that Elmendorf Air Force Base has done a basewide background sampling investigation for metals and data gathered during this effort must be compatible for comparison purposes.
2.10.4.2 Field Investigation page 2.10-3
The text states hand auger borings will be advanced in four sampling locations and samples collected at six inches and at two feet below grade. Please provide the rationale for choosing the amount and depths of hand auger borings.
Additional background data may be needed to define background values for use in risk evaluations. It is unclear from the text how many hand auger borings will be advanced at each sampling location. Please provide additional information on exactly how many borings will be advanced at each location
The text further states a soil boring will be drilled and sampled to a depth of twenty feet bgs. It is unclear what sampling frequency (i.e. every five feet or change in lithology) will be
implemented for each location. Please provide this information in the revised workplan. |
Louis Howard |
| 6/1/1995 |
Document, Report, or Work plan Review - other |
Staff reviewed and commented on the Operable Unit D Draft Preliminary Source Evaluation 2 doc# 9000-036-420 dated April 1995.
General Comments
The tables summarizing the soil, groundwater and sediment samples would be more helpful if
they included comparisions of the 1O-6 to lO-4 RBC or HI of 1 or more and highlighted the levels
that exceededth is amount. This would aid in determiningw here to proceed with future
investigative efforts. Where groundwater was not investigated at a specific site, a description of how this decision was reached should be included in the text.
5.1.5 Findings and Conclusions page 5.1-32
ADEC concursw ith the recommendations that bldg. 35-752 be investigated further under
CERCLA. Please elaborate on what would be addressedu nder the additional investigation being
recommended. Without any specifics, ADEC cannot determine the extent or scope of work being considered would address areas of concern. (This comment applies to all other sites currently being considered for additional investigation.)
5.2.5 Findings and Conclusions page 5.2-6
ADEC concurs with the recommendations that the stormwater outfall site be considered for no
further action under CERCLA. However, the comparision must be made between the risk based screening concentrations and the detection limits (i.e. MRLs). Additionally, the Army will
be required to take action to obtain compliance with the federal and state wastewater regulations concerning stormwater discharges to surface water bodies (i.e. Ship Creek).
5.3.5 Findings and Conclusions page 53-13
ADEC concurs with the recommendations that bldg. 700/718 requires further investigation under
CERCLA. Further elaboration is needed justifying lack of migration pathways and extent of
contamination at the site. Reference ADEC NON-UST soil cleanup levels mentioned in text.
5.4.5 Findings and Conclusions page 5.4-13
ADEC concurs with the recommendations that bldg. 704 requires further investigation under
CERCLA (see comment under 5.1 S). Please reference ADEC NON-UST DRO cleanup levels in text.
5.5.5 Findings and Conclusions page 5.5-16
ADEC concurs that further investigation for bldg. 796 under CERCLA is required (see comment
under 5.1S).
5.6.5 Findings and Conclusions page 5.6-13
ADEC concurs that further investigation for bldg. 955 under CERCLA is required (see comment
under 5.1.5).
5.7.5 Findings and Conchsions page 5.6-11
ADEC concurs that further investigation for the Dust Palliative site under CERCLA is required
(see comment under 5.1.5).
5.8.5 Findings and Conclusions page 5.8-20
ADEC concurs that further investigation for the Fire Training Area under CERCLA is required
(see comment under 5.1.5). Add to the table 5.8.2 that burning of pressurized-treated wood and
burning of chlorinated organics as another possible source of dioxins and furans.
5.9.5 Findings and Conclusions page 5.9-18
ADEC concurs that further investigation for the Grease Pits under CERCLA is required (see
comment under 5.1.5). |
Louis Howard |
| 6/16/1995 |
Site Ranked Using the AHRM |
Initial ranking. Action code added because it wasn't when the site was originally ranked. |
Louis Howard |
| 6/16/1995 |
Update or Other Action |
Site switched from UST Agreement to the FFA/CERCLA Agreement under OU D due to non POL contaminants found. |
Louis Howard |
| 8/31/1995 |
Update or Other Action |
Building 35-752 is secured and a fence with a locked gate is constructed around the facility. |
Louis Howard |
| 1/5/1996 |
Document, Report, or Work plan Review - other |
Staff reviewed and commented on the Draft CSMs, DQOs, ARARs OU D December 1995, Fort Richardson, Alaska.
3.1.2 Past Practices page 3.13 fourth and fifth paragraphs
The text states the cooling ponds currently receive discharge water from building 35-750. Please
provide information on whether or not the discharge is currently covered by a wastewater discharge permit from DEC. The text states that it was hooked up to the post sewer system by 1972 and thus that would negate the need for a cooling pond for discharge if it is still being used for this purpose. A clarification is needed whether or not the bld. is on the sewer system with the rest of the Post. 3.1.3.2 Remediation Sampling page 3.1-5 1st paragraph Note that rotating biological factors should reference: Risk Based Concentrations (RBCs).
3.1.7 Summary of Data Gaps and Proposed Actions page 3.1-14 and 3.1-15
Cooling Ponds
The text states there will be an evaluation of ecological toxicity of the sediments present. DEC
requests the Army, in consultation with EPA and DEC project managers, consider not using the
cooling pond for discharge purposes and filling in the manmade cooling pond in with material
(gravel, clean fill, asphalt) to eliminate a pathway to potential ecological receptors. -This action would save time and money that would not be spent on evaluating ecological risk from the sediments in the pond (hut not the drainpipe from the pond), or effects from contaminants in the surface water in the pond.
Groundwater
The text references the most likely remedial action for the groundwater at the site as natural
attenuation. Please elaborate on how PCBs will naturally attenuate in the groundwater at this site (i.e. at MW AP-2986). As a pat-t of any proposed intrinsic remediation scenarios that the Army wishes to consider, there must be a description of what type of: institutional controls, deed restrictions and land use controls placed on groundwater use.
Buidling 45590
3.2.7 Summary of Data Gaps and Propose Actions page 3.2-9
The text states there are no risk values for DRO and thus the extent of DRO does not need to be
further evaluated. DEC does not concur. Secticn 3.2.3 on page 3.2-5 states that the “DRO was
consistently detected in the groundwater from two of the wells and exceeded ADEC Water Quality
Criteria in one well.” If the groundwater contamination is not to be pursued by the FFA, then it
should be addressed by either the USTMP or the SFRERA. Regardless of which agreement it is
covered by, analysis of total PAHs in the groundwater will have to be conducted to determine if the PAHs have leached from the soils into the groundwater and what levels &e being detected.
Building 726
See comment above regarding DRO detected in the groundwater. |
Louis Howard |
| 3/22/1996 |
Document, Report, or Work plan Review - other |
Staff reviewed and commented on the Drafi Management Plan OU D February 1996, Fort Richardson, Alaska.
4.3 Potential Remedial Technologies Applicable to Soil and Water page 4-13
The text references a remedial alternative for the groundwater at OU D as natural attenuation
(intrinsic remediation.) As a part of any proposed intrinsic remediation scenarios that the Army
wishes to consider, there must be a description of what type of institutional controls the Army is considering, deed restrictions for the OU and land use controls placed on groundwater use until the groundwater meets drinking water standards.
7.0 References
Please note the DEC has new Underground Storage Tank (UST) regulations (18 AAC 75 November
3, 1995) and an accompanying UST Procedures Manual (September 22, 1995) that supersedes the
1993 reference listed on page 7-l.
Appendix C ARARS
DEC has included many of the same comments that were made on the December draft in a previous
letter to the Army:
1) The chemical specific analysis does not appear to address PCBs in sediments or PCBs in soil.
The ARARs should mention TSCA standards and EPA PCB cleanup guidance and new proposed PCB cleanup regulations.
2) Table 3-l should have a footnote acknowledging that DEC has adopted EPA RCRA standards
by reference in 18 AAC 62.
3) Section 4.0, proposed location-specific ARARs, does not note the parallel state statutes involving wetlands, historic preservation or endangered species (although the notification list does not some of these state agencies involvement). The section should incorporate the Alaska Coastal Management Program standards in 6 AAC 80.
DEC has also noted an incorrect citation form in table 3-l on pages 3-11 and 3-13. 46 AS 14 should be cited as AS 46.14. greatly expanded in the future. Identification of ARARs is an iterative process and additional analysis will be needed when remedial alternatives are proposed and analyzed. |
Louis Howard |
| 5/29/1997 |
Update or Other Action |
Staff sent letter to Kevin Gardner re: Field Sampling Plan addendum 1. Section 1.2.3 Fish Hatchery Page 1-3: The text states that only a review of the existing data for the site will be done. There was a report of a diesel range organics being detected in monitoring well near the site. It is DEC's understanding that the site will be investigated this field season under one of the two POL agreements the Army has with the State (USTMP or SFRERA). If that is not the case, then the site will need to be included for investigation under the OU D sampling plan. |
Louis Howard |
| 10/1/1997 |
Update or Other Action |
In order to construct a more permanent asphalt surface, approximately 1,500 cubic yards of soil were excavated from the gravel parking lot at the site in 1997. Soil removed during excavation activities was found to contain PCBs at higher concentrations than samples collected at other locations evaluated during the RI. A definitive source of the PCBs was never determined. |
Louis Howard |
| 10/7/1997 |
Document, Report, or Work plan Review - other |
Staff reviewed and commented on the OU D Draft Remedial Investigation, Fort Richardson, Alaska dated August 26, 1997.
General Comments
Add a list of acronyms to table of contents to help the reader quickly find the meaning of each
acronym as needed.
Specific Comments
4.1.4 page 4-20
The text references contaminants of potential concern (COPCs) in table 4.1-2, but offers no
reasoning on why they should be retained as COPCs. DEC requests a footnote be added either in
the text or table 4.1-2 referring the reader to Appendix G “Analytical Data”. DEC also requests that language be explaining the raticnaie why a ccntaminant is not considered a CQPC if the REC falls within the range of non-detects or when the range of non-detects exceed the RFK for that
contaminant. This comment mainly applies to the semivolatile organic compounds and in some cases
volatile organic compounds.
4.1.4.5 Groundwater page 4-44 4th para.
The text refers the reader to the DAR (data assessment report) for a more detailed explanation of this section. Please spell out DAR and add text which will aid the reader to Appendix F of the RI where the Data Assessment Report is located.
The tables presented in this appendix list COPC determinations for bldg. 35752. DEC requests
adding the remaining sites to this section list the determination of chemicals of potential concern. |
Louis Howard |
| 10/30/1997 |
Update or Other Action |
Staff sent letter to Kevin Gardner re: draft operable unit D risk assessment dated September 23, 1997. General comments: Bldg. 35-752 has had some recent activity with regards to a new paved parking lot and removal of 1,500 cubic yards of soil off-site. DEC requests the Army indicate on a map the extent of the pavement added and what the horizontal and vertical extent of the excavation was performed at the site.
Bldg. 796: The text states that EDB (1,2-dibromoethane) detected is unlikely to have originated from unleaded gasoline sinc ealkylated monoaromatics (toluene, ethylbenzene, and xylenes) were not detected at elevated levels in identical samples. ADEC agrees with the statement, however, it should be noted that a 1994 HLA release investigation report showed that residual contamination was left in place at 8-12 ft. below ground surface because of concerns of comprimising foundation integrity and the two existing USTs. Previous sampling efforts by contractors did not access the contaminated soils beneath the building, thus leaving question as to how much contamination is present. This may or may not have any bearing on the overall "risk" to receptors since it is at depth, but needs to be noted that the site has not been completely charaterized. |
Louis Howard |
| 1/14/1998 |
Update or Other Action |
Staff sent letter to Kevin Gardner re: Remedial action objectives Tech. memo for OU D. The first page states that tech. memo includes: proposed applicable, relevant, or apprpriate, requirements (ARARs) based on the status of the remedial investigation and risk assessment documents for OU D. The document does not mention many ARARs other than referring to the fact that the risk based PRGs refer to the EPA Region 3 RBCs (Nov. 1997) and Region 9 PRGs for lead. Please include the reference noted for the Remedial Action Objective (RAO) in Table 1 "restore soil concentrations to ADEC required levels for fuel contaminants...". The footnote does not mention any State regulation or guidance document, for example 18 AAC 78 Underground storage tanks, Alaska Soil Cleanup Matrix, or 18 AAC 75 Oil and Hazardous Substances Pollution Control Regulations cleanup standards. |
Louis Howard |
| 3/24/1998 |
Update or Other Action |
Staff sent letter to Kevin Gardner RE: Draft Final RI/FS Volumes I, II, and III for OU D. The draft feasibility study doe not clearly indicate whether remedial action objectives (RAOs) and remedial alternatives will be protective of future residents or only industrial workers. ADEC requests RAOs and preliminary remediation goals (PRGs) be based upon the protection of future residents and ecological receptors where present and not just for the protection of industrial workers. This document should not be establishing land use restrictions other than a cursory mention as part of institutional controls since that issue is more appropriately formalized in the Record of Decision. Contaminants in the groundwater detected above State and Federal maximum contaminant levels (MCLs) wil require some type of action be it institutional controls and regular monitoring or some other type of remedial effort.
Results from the "fireman" receptor risk characterization should be included characterizing the risk from PCBs in floor dust at Bldg. 35-752. Remedial alternatives that address these risks should be developed and included in the FS. Alternative 2 should be eliminated from this section at the initial screening step. ADEC is not aware of any remedies that will naturally attenuate PCBs of a realistic timeframe.
DEC requests more informaiton be included regarding the significant quantities of PCB contaminated soils that was remeoved from the site during an unplanned paving project at the building. This information will include, at a minimum: an estimate of the volume of the soil excavated, the known levels of PCBs in the soil, and status of the excavated soil. |
Louis Howard |
| 6/1/1998 |
Update or Other Action |
The Army has completed its characterization of the soil that the Air Force dug up at Bldg 35-762 and transported from Ft. Rich. to their property on the base.
29 of 30 samples came back under 50 ppm. One of the analytical results is 79 ppm PCB. |
Louis Howard |
| 6/5/1998 |
Update or Other Action |
Staff letter to Kevin Gardner re: Draft Postwide Risk Assessment. Normally, if there is no risk based concentrations available when a contaminant is detected, it would be addressed as an uncertainty during the risk estimates. On page 2-3, regional data was used at times instead of site-specific background data. This may be appropriate if it can be shown that the regional data is comparable to site specific values. Please explain or justify the use of regional values in screening of contaminants of potential concern (COPC).
The conceptual site model shows that the construction worker would not be expected to be exposed to via dust inhalation. This is counterintuitive since construction workers are subject to exposure from some dust via their activities such as trenching, excavating, or other intrusive work. Please correct this discrepancy in the text. |
Louis Howard |
| 7/16/1998 |
Update or Other Action |
Staff sent letter to Kevin Gardner RE: Draft Proposed Plan for Operable Unit D. The text states the surface soils are exposed in the gravel parking area around the building. This is partially true; however, there is a paved parking lot that covers the surface soils in front of the building and between 35-752 and 35-750. Please correct the text to reflect the paved parking lot. The excavated soils fromt he parking lot were previosly not investigated nor thought to contain PCBs. However, subsequent analysis found PCBs above residential and, in some cases, industrial scenario cleanup levels for surface soils. This will need to be addressed in this document.
The text states PCBs were detected in soils excavated during the 1996 waste oil tank removal. The amount of PCBs found in the soils was not stated in the document. This is inconsistent with the previous 1990 tank removal where the amounts of PCBs in the excavated soils was listed. Please address this disparity by including the levels of PCBs found in soils stockpiled during the 1996 tank removal. |
Louis Howard |
| 10/8/1998 |
Update or Other Action |
Staff sent letter to Kevin Gardner RE: OU D RI/FS Draft Final. The text states groundwater at bldg. 35-752 cannot legally be developed as a water resource (Anchorage Municipal Code 15.55). Please elaborate on what AMC 15.55 is called, i.e. Groundwater Well Development Regulations, Drinking Water Well Code For Domestic Use, etc.. Add a reference in the Appendix for the Anchorage Municipal Code.
The text refers to groundwater at OU D sites on Fort Richardson is not currently being used as a public drinking water source. This may or may not be true, since it has been revealed that three deep backup wells directly across from (OU D site) Bldg. 35-752 have been used (and are being used) to supplement drinking water supplies on a regular basis. Until a pumping test can be performed on these wells which shows that the aquifers (shallow and deep) are not connected, it cannot be ruled out that groundwater at the OU D sites is not used for drinking water.
Under implementability the text states it may be impossible to implement natural attenuation (NA) in conjuction with instititutional controls (ICs) and long term monitoring (LTM). Please elaborate on what circumstances this would occur, more often than not, DEC has seen ICs and LTM work well with natural attenuation.
Alternative 2 lists ICs and NA without references to LTM. As an integral component of NA, periodic monitoring of contaminant degradation rates of the contamination (borings, monitoring wells, etec..) will be necessary to determine if attenuation is occurring. DEC requests that the text for this type of alternative include language such as: Monitored Natural Attenuation. It is implied in this section, but not explicitly referenced in the text. |
Louis Howard |
| 11/23/1998 |
Update or Other Action |
Staff sent letter to Kevin Gardner re: Draft Proposed Plan OU D. DEC requests clarification on the timeframe to meet cleanup goals for contaminated soils if the contaminant of concern is PCBs and breakdown through natural attenuation is not likely to occur. For example, state whether the estimate for attaining cleanup is from modeling, other sites with like contaminants or other reasons not explicitly stated in this section. |
Louis Howard |
| 3/29/1999 |
Proposed Plan |
Preferred alternative for contaminated groundwater at buildings 35-752, 796 and 45-590 is monitored natural attenuation combined with natural attenuation. Soil and sediment PCB contamination preferred alternative is phytoremediation and if not effective after two seasons-thermal desorption will be implemented. Additionally, windows and doors of Building 35-752 will be sealed with plywood and 8 foot security fence to prohibit access to PCB contaminated dust inside the building. Cooling pond and trench will be filled in and the source of water rerouted to sanitary sewer. COCs in GW include benzene, trichloroethene, iron, manganese, aluminum. |
Louis Howard |
| 12/27/1999 |
Update or Other Action |
ADEC sent Kevin Gardner letter re: Draft remedial design/remedial action OUD GW Monitoring Program. ADEC requests the Army present data using a graphical representation (e.g. line graphs) for portraying trends in contaminants over time for the available data in each well and a maximum contaminant level for each contaminant. Absent from the document are analyses for natural attentuation parameters generally accepted as being performed at contaminated sites. The burden of proof for natural attenuation is upon the Army to demonstrate through adequate site characterization/monitoring that it is an achievable goal and viable remediation option.
The Air Force Center for Environmental Excellence has developed an analytical protocol to be used to include parameters necessary to document that natural attenuation is occurring. This includes the effects of sorption, aerobic, anaerobic biodegradation. Please include the parameters for monitoring natural attenuation in the groundwater at bldgs.: 35-752 and 45-590. |
Louis Howard |
| 9/28/2000 |
Update or Other Action |
ROD for OUD signed memorializing transfer to OUE. Interviews with former Post employees revealed that PCB transformer oil was dumped into a trench from the transformers used at the nearby building 35-750. With the new additional information, it has been determined that this site has not been adequately characterized. As a result, additional RI work needs to be performed in the pit, trench, parking lot and around 35-750 where the transformers were located in order to determine the extent of contamination in this area and select an appropriate remedy. For these reasons, this site is being transferred to OUE. Another Proposed Plan and ROD will be developed for this site under OUE. |
Louis Howard |
| 2/22/2001 |
Update or Other Action |
The U.S. Environmental Protection Agency (EPA) has performed a review of response actions taken by the U.S. Army, Alaska (USARAK) under the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA) at eight Resource Conservation and Recovery Act (RCRA) units identified by the above-referenced FFCA in order to determine whether those response actions have met the closure requirements of 40 C.F.R. § 265, Subpart G.
The eight RCRA units include; (1) Circle Road Drum Storage Area, (2) Building 755 - Auto Hobby and Crafts Center, (3) Building 704, (4) Building 955 - DEH Preventative Maintenance oil/water separator sludge bin, (5) Building 986 tanks and containers, (6) Building 35752, (7) Building 45-590 - Former Auto Shop, and (8) the open burning/open detonation (OB/OD) pad at Eagle River Flats.
The FFCA required USARAK to determine whether hazardous waste was stored or released at Building 35-752. Should it be determined that hazardous waste were stored or released from this unit, USARAK was required to develop closure/post closure plans in accordance with 40 CFR § 265 Subpart G.
EPA reviewed the following documents pertaining to RCRA and CERCLA-related activities at Building 35-752; (1) OU D ROD, (2) Memorandum: October 15, 1997, Preliminary Laboratory Results Building 35-752 Soil Samples, Fort Richardson, AK, (3) OU D Preliminary Source Evaluation 2, October 1996, (4) Closure Plan for Building 35-752, February 9, 1994, and (5) OU D Remedial Investigation Report, August 1997. However, EPA cannot confirm from the documentation that USARAK has met the requirements of the FFCA by obtaining a detailed chemical and physical analysis of a representative sample of waste or using knowledge of the waste to determine if the wastes stored or released from this unit are hazardous.
The 1994 Closure Plan described proposed closure activities for Building 35-752 and an adjacent outside area east of the building. An area south of the building which was the site of seven former USTs was not included in the closure plan. EPA is particularly concerned about the former drum storage area east of the building. USARAK has not provided documentation whether wastes stored in this area were hazardous. Media or debris contaminated with polychlorinated biphenyls (PCBs) as found within and outside the building does not appear to be a hazardous waste as defined under 40 CFR § 262.11.
This unit has been referred to CERCLA OU E for further investigation and remediation, if necessary. Upon completion of the OU E investigation and remediation, USARAK must present documentation to EPA that COCs remaining at the unit do not exceed concentrations above the clean-up levels established at 18 AAC 75.341, Tables A1, B1 and B2, before EPA could consider this unit to be clean-closed. |
Louis Howard |
| 9/30/2001 |
Update or Other Action |
The soil was determined to be contaminated with PCBs and stockpiled at the site until transported to a TSCA-regulated landfill in 2001. |
Louis Howard |
| 2/20/2003 |
CERCLA ROD Periodic Review |
Jennifer Roberts signed the five year review document for the Post. The objectives of the Five-Year Review are to answer the following questions:
•Are the remedies functioning as intended by the decision document?
•Are the exposure assumptions, toxicity data, cleanup levels, and remedial action objectives (RAOs) used at the time of the remedy still valid?
•Has any other information come to light that could call into question the protectiveness of the remedy?
The NFA decisions for seven of the sites identified in the ROD are intended to document that the risk to human health and the environment associated with contamination from past activities at Fort Richardson is not present at these sites. Two of these source areas, the landfill fire training area and the grease pits, are being monitored in accordance with the requirements of the Fort Richardson Landfill Closure Plan. The NFA decision under CERCLA was made in the OUD ROD for the following source areas:Building 726 Laundry Facility, Storm water Outfall to Ship Creek,
Dust Palliative Locations (four separate areas),
Landfill Fire Training Area, Grease Pits,
Building 45-590, and Circle Road Drum Site.
The next Fort Richardson Five-Review will be conducted in 2008, five years from the date of this review. The next Five-Year Review will be the first full-term review for the OUC ROD. |
Jennifer Roberts |
| 9/22/2004 |
Update or Other Action |
Operable Unit E consists of two sites, the Building 35-752 Area and the Armored Vehicle Maintenance Area (AVMA), Site investigations and risk evaluations conducted for the Building 35-752 Area indicate that the contaminants found at the site do not pose a threat to human health or the environment and do not require cleanup action. Therefore, no further action is recommended for the Building 35-752 site. However, PCBs were detected in the soil at the site. The Army has decided to proceed with removal of soil contaminated with PCBs exceeding levels established by regulation (State Regulations and Toxic Substances Control Act) set at 1.0 mg/kg. The soil removal will be conducted under the TSCA self-implementation rule. |
Louis Howard |
| 10/2/2006 |
Update or Other Action |
Environmental Protection Agency issues a Preliminary Close Out Report (PCOR) which documents that US Army Garrison, Alaska (USAG-AK) has completed all construction activities for the Fort Richardson Superfund Site (“the site”), in accordance with the U.S. Environmental Protection Agency (EPA) guidance, Close Out Procedures for National Priorities List Sites (OSWER Directive 9320.2-09A-P, January 2000). EPA and the Alaska Department of Environmental Conservation (ADEC) have determined that USAGAK constructed and/or implemented the remedies in accordance with remedial design (RD) plans and specifications. USAGAK has initiated activities necessary to achieve performance standards and site completion.
Remedy Selection: The remedy for Operable Unit (OU)D was selected in a record of decision (ROD) signed on June 30, 2000. The OUD ROD was a No Action ROD. Nine of the sites listed in the ROD (Building 45-590, Building 726, Storm Water Outfall to Ship Creek, Dust Palliative Locations, Landfill Fire Training Area, Grease Pits, Circle Road Drum Site, Building 700/718, and Building 704) were considered to require No Further Action at the time the ROD was signed. The ROD required the Army to conduct sampling at two sites (Building 955 and Building 796) to confirm whether or not contaminants were present at concentrations exceeding cleanup levels. One site, Building 35-752, was transferred to OUE for additional investigation.
Remedial Action: Remedial actions were not required at any of these sites. |
Louis Howard |
| 2/23/2007 |
Exposure Tracking Model Ranking |
|
Louis Howard |
| 1/16/2008 |
Site Closure Approved |
DUPLICATE SITE-In the FUTURE, this site's actions will be merged with OUE Bldg. 35752. |
Louis Howard |
| 9/2/2014 |
Exposure Tracking Model Ranking |
Initial ranking with ETM completed for source area id: 71909 name: Underground tank |
Louis Howard |
