| Action Date |
Action |
Description |
DEC Staff |
| 5/26/1950 |
Update or Other Action |
HQ US Army AK & HW Alaskan Air Command: Joint Agreement on division of Responsibilities in the Operation of Separate Army and Air Force Installations at Fort Richardson and Elmendorf Air Force Base Alaska. This agreement includes the following: a. The extent of joint utilization of existing services and facilities and the responsibility for their operation.
b. The extent and method of budgeting for cross-servicing of jointly-utilized facilities.
c. The definition of boundaries dividing the present Fort Richardson Military Reservation into two separate installations -Fort Richardson and Elmendorf Air Force Base.
Armed Forces Food Service School: Bldgs T-312 and T-310. Various terminal bulk fuel str1rage facilities pertaining to the Quartermaster Section, Alaska General Depot. The buildings listed above, will be vacated as soon as suitable facilities become available at Fort Richardson. These are expected to be included in the FY 1950-FY 1952 construction programs.
The use of the terminal bulk fuel storage and distribution facilities operated by the Alaska General Depot will be authorized by an Agreement.
Toxic Chemical Storage Area
The area known as the AC Inert Storage Area, near junction of Flight? Road & Hill Road and approximately 9,000 feet north of Whitney Station, will continue to be used jointly by the Army and Air Force for storage of Army and Air Force chemicals and chemical munitions.
AFM 66-12 |
Louis Howard |
| 12/30/1988 |
Update or Other Action |
UST Database shows a 300 gallon UST # 45 installed in 1952 at Bldg. 987 Pump Station to be leaking and tank is in service. |
Ron Klein |
| 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 |
| 6/1/1990 |
Update or Other Action |
A 300 gallon underground storage tank (UST) was excavated on the north side of building 987 in
1990. This tank was used to catch fuel overflow. It was replaced by a 1000 gallon UST placed
on the south side of the building.
Although no written reports of the excavation exist, a site visit with Doreen Coates of Fort Richardson Retail Petroleum Branch revealed that a critical fitting had failed on this UST causing a large amount of spillage over the years. As the UST was removed from the excavation, she clearly remembered smelling petroleum. Records of sampling results at the time of excavation do not exist. |
Louis Howard |
| 6/5/1990 |
Site Added to Database |
|
Louis Howard |
| 9/26/1990 |
Update or Other Action |
INTERIM GUIDANCE FOR SURFACE & GW CLEANUP LEVELS SEPTEMBER 26, 1990: The following guidelines should be implemented under 18 AAC 75.140 which specifies that a "discharge must be cleaned up to the satisfaction of the Regional Supervisor or his designee. Final cleanup levels shall be determined by the Regional Supervisor or his designee based on site-specific conditions. Staff should be aware that if a facility is regulated under RCRA, that RCRA corrective action & cleanup standards should enter into development of final site cleanup levels.
GW should be cleaned up to levels not exceeding the more stringent of the final State or Federal Maximum Contaminant levels (MCLs) for Organic & Inorganic Chemicals. If final MCLs have not been adopted for a contaminant, then GW should be cleaned up to levels not exceeding proposed Federal MCLs. The group of compounds collectively identified as total petroleum hydrocarbons (TPH) should be cleaned, up to non-detectable levels as measured by EPA Method 418.1.
Final State MCLs are specified in 18 AAC 80.050 & final Federal MCLs are specified in 40 CFR 141 & 142. Proposed Federal MCLs are specified in the May 22, 1989, Federal Register Vol. 54, No. 97, pages 22155 - 22157 & the July 25, 1990, Federal Register Vol. 55, No. 143, pages 30408 - 30448. Appendix I provides a summary listing of State & Federal Final & Proposed MCLs for selected organic & inorganic contaminants.
For organic & in organic contaminants that have not been assigned a final or proposed MCL, cleanup levels should be based on criteria cited in EPA's Water Quality Criteria. 1986 using a health risk factor of 10-6. EPA's water quality criteria identify concentrations of elements & compounds which have toxic effects on aquatic organisms or toxic & carcinogenic effects on humans.
If GW is being used as a drinking water source & alternative water supplies or point of use water treatment cannot be provided, then final or proposed secondary maximum contaminant levels (SMCLs) may be used as cleanup target levels. SMCLs are based on aesthetic properties such as taste & odor, whereas MCLs are based on human health risks. For compounds such as xylenes, the SMCL maybe several hundred times lower than the MCL.
Surface waters used for drinking water should also be cleaned up to levels not exceeding the final or proposed MCLs for organic & inorganic chemicals, as specified above. Under the authority of 18 AAC 70.020, surface waters important to the growth & propagation of aquatic life should be cleaned up to the listed criteria which includes EPA's Water Quality Criteria. 1986. These criteria identify concentrations of specific elements or compounds which have toxic effects on aquatic organisms. The group of compounds collectively identified as total petroleum hydrocarbons (TPH) should be cleaned up to non-detectable levels as measured by EPA Method 418.1.
Alternative Cleanup Levels (ACLs) may be adopted for a site if a risk assessment approved by the department is performed & cleanup to levels identified above is technically infeasible. Risk assessments will not by themselves establish ACLs. Determination of cleanup levels is a risk management decision that the department must make based on results of a quantitative risk assessment & other pertinent information.
See site file for additional information.
|
Louis Howard |
| 9/30/1991 |
Update or Other Action |
Chemical Data Report, Building 987, Ft. Richardson, Alaska by U.S. Army Corps of Engineers dated September 30, 1991. A 300 gallon slop/overfill fuel tank was removed in June 1990 with 200 cubic yards of petroleum impacted soil was excavated and stockpiled. A records search was conducted to find other sources of leaks in the area. The results of that search revealed that building 987 was built approximately forty years ago. As-Built diawings of renovations showed that the overflow tank was not installed until the mid-1970s.
A series of soil samples were collected from four (4) borings placed north of bldg. 987. The borings were located in and around the location of the former underground storage tank (UST) which is also the location of a former dry well. Drawings found in the records at DPW show that a dry well may have existed at the site prior to the installation of the overflow tank in the mid 1970s (poff, 1994).
Three (3) of the borings reached a depth of approximately 30 ft. while the fourth boring extended 60 ft. bgs. None of the borings during this sampling effort extended to groundwater. The samples collected from this sampling effort showed that soil in the area of the former UST at bldg. 987 was contaminated with diesel, kerosene, and bunker oil. The soil samples also showed benzene, toluene, ethylbenzene, and xylene (BTEX) contamination.
Residual contamination remains-5,200 mg/kg TPH, 9,200 mg/kg DRO, 726 mg/kg Total BTEX, 11 mg/kg benzene (Sample #1 Lab# A101327). May be other unknown contaminants present. Report lacks detail on what was done. Limits of excavation not defined. Contamination identified on the opposite side of the building also. |
Louis Howard |
| 4/9/1992 |
Update or Other Action |
EPA Memorandum April 9, 1992 Reply to the ATTN of ES-098. Subject Toxicity of Fuels. From Carol Sweeney Toxicologist Health and Environmental Assessment Section. To Wayne Pierre Federal Facilities Superfuend Branch (HW-124). A response has been provided to the frequently-asked question of whether a reference dose or other toxicity information can be provided for fuel mixtures so that these mixtures can be addressed quantitatively in Superfund risk assessments. The memo from ECAO Cincinnati is attached (last attachment). They have developed reference doses for gasoline, JP-5/kerosene, and JP-4, and a cancer potency factor for gasoline. The memo emphasizes that these are provisional numbers and that considerable uncertainty is involved in this quantitative assessment, because of data limitations, and because inhalation studies were used to calculate oral reference doses.
I typed up a summary table showing the numbers (first attachment) and calculated some risk-based concentrations (second attachment). On the risk-based concentration table, I also
included ordnance compounds, because I hadn't made a table of those before that I can remember. The risk-based concentrations were calculated the same way as table II-1 and II-2 of the Region
10 Supplemental guidance; for soil, the same limitations apply, that the numbers presented do not consider pathways other than soil ingestion.
Toxicity Reference Vaules for Fuel Mixtures EPA Region 10 4/9/1992 Non-cancer effects-Gasoline (unleaded) RfD (mg/kg-day) Oral: 2.0E-1, Uncertainty Factor-Oral:1000, Level of Confidence-Oral: Low. Toxicity Data Source-Oral RfD: Memo 3/92. Carcinogenicity-Cancer Potency/(mg/kg/day): Oral 1.7E-3, Unit Risk (/ug/m3) 4.8E-7, Cancer Weight Of Evidence-C, Toxicity Data Source-Oral SF and Inhal. SF: Memo 3/1992.
Kerosene/JP-5 RfD2.0E-2, UF Oral: 10,000, LOC Oral: low, TDS Oral RfD: Memo 3/92
JP-4 RfD 8.0E-2, UF Oral: 10,000, LOC Oral: low, TDS Oral RfD: memo 3/92.
Screening Values for Water RBCs based on Ingestion, Residential
Gasoline-Risk = 10-6 (ug/L) 50, 10-4=5000 HI=1 (ug/L) 7000
JP-5 Kerosene Risk 10-6 10-4=NA HI = 1 (ug/L) 700
JP-4 Risk 10-6 10-4 = NA, HI = 1 (ug/L) = 3,000
Screening Values for Soils- RBCs Based on Soil Ingestion Residential
Gasoline-Risk = 10-6 (mg/kg) 400, 10-4 (mg/kg) 40,000, HQ = 1 (mg/kg) 50,000
JP-5 Kerosene Risk 10-6 10-4 NA, HQ =1 5,000
JP-4 Risk 10-6 10-4 NA, HQ = 20,000
IARC concluded that gasoline is possibly carcinogenic to humans (Group 2B). IARC concluded that marine diesel fuel is possibly carcinogenic to humans (Group 2B), but light diesel fuels and jet fuels are not classifiable as to their carcinogenicity in humans (Group 3). |
Louis Howard |
| 6/15/1992 |
Update or Other Action |
Northwest Environmental (under contract to Defense Reutilization and Material Service DLA200-91-D-0070). Tanker truck ~100 to 150 gallons spilled from leak originating from the area of two overfill drain pipes that run through the rear compartment. Release of petroleum mixture occurred onto the ground adjacent to railroad track and north of building 955 and adjacent to building 987. Spill # associated with event is 92-2-1-1-167-2. Leak occurred during transfer of fuel oil, oil and water mixture pumped from a railroad tank into a tractor-trailer tank type trailer supplied by Carlisle Enterprises. Size of spill is approximately 80 ft. long by 3 ft. wide at the widest point. |
Scott Bailey |
| 6/25/1992 |
Update or Other Action |
Memo from US ARMY Sam Swearingen to Tom Poliquin with lab results attached from 6/23/1992 sampling event. Preliminary results from Chemical & Geological Laboratories for Total Petroleum Hydrocarbons. It should be noted that no spills have been "reported" to the Dept. of Environmental Conservation nor to Fort Richardson Environmental Dept. by military personnel according to conversations with Catherine Scott of the Department of Public Works, Environmental Dept. for the rail yard.
US Army (S. Swearingen) and DLA (Tom Poloquin) staff took background samples and regular samples at the DLA Spill site on June 23, 1992. Samples 1, 2, and 3 that came back below ADEC non-UST spill cleanup levels for extractable petroleum hydrocarbons, but were elevated and TPH present in an area "supposedly" where no spills have occurred and no other source is readily recognizable.
Sample no. 4 came back at 18, 800 ppm TPH on the south side of USAX 6068 approximately 10 ft. from the excavation. Samples from stockpile were found to be a maximum TPH level of 8,790 ppm, approximately half of the level seen in background sample 4. The Army does not know the amount or the type of product that produced these results (18,800 ppm) or how long the material has been in the ground. Therefore, the amount of any migration that might have occurred is not known, but it suggest that an incident or incidents of some magnitude has/have occurred in the past. |
Louis Howard |
| 7/9/1992 |
Update or Other Action |
Memorandum from Army Col. Robert J. Wrentmore to DRMO James Whitaker Elmendorf AFB re: June 1992 OIl Spill. This memo is to document the activities to close out the site of 15 June 1992 spill adjacent to the railroad tracks at the Bulk Fuel Facility Building 989. To meet the Army's requirement for closing out the site: A. The hole will be lined with visqueen (8 mil or greater) and backfilled with clean fill. b. The soil must be compacted suitably to provide support to the tracks. c. The soil which has been removed from the hole must be disposed of by the contractor before the site will be considered closed. |
Louis Howard |
| 7/27/1992 |
Update or Other Action |
225,000 gallon above-ground tank being emptied into rail cars, diesel fuel arctic and a valve malfunctioned causing a spill from this tank (tank# 991). Approximately 500 gallons were estimated to be releases associated with spill# 92-2-1-1-209-2. |
John Halverson |
| 7/30/1992 |
Update or Other Action |
Scott Bailey sent Notice of Release letter (NORL) to Catherine Scott DPW US ARMY re: File# CS76.31 SPILL# 92-2-1-1-167-2. Spill from tanker truck in vicinity of Building 987. 18 AAC 75.300/AS 46.03.755/AS 46.04.01.03 require notification to this Department occur within varying time frames dependent upon the specific nature of the discharge. Immediate containment and cleanup actions, approved by the Department are required by 18 AAC 75.327-75.347 and AS 46.04.020. Additional information as required by the Department, including, but not limited to, disposal receipts for the contaminated soil, water and cleanup materials, copies of sample analyses, if required.
The following listing outlines the primary steps needed to be accomplished to fully address any residual contamination following initial cleanup activities:
1) Initial corrective action plan: usually required within five working days of the event. Includes: collection of any field data, soil excavation and sampling plans, quality assurance project plan, use of a qualified third party for sampling, sample analysis, cleanup, and site closure.
Interim Report: (daily or hourly during a major discharge, written reports within one week or receipt of the sample analyses, no later than two weeks following site assessment).
Final Report: within two weeks of completing cleanup. |
Scott Bailey |
| 3/3/1993 |
Document, Report, or Work plan Review - other |
ADEC sent Dave Fosbrook (US ARMY) letter re: Chemical Data Report for UST Closure Bldg. 987 #45 Spill# 90-2-1-0-156-3. ADEC received it on February 16, 1993. The report indicates significant petroleum contamination is present at the site. A release investigation and corrective action report in accordance with 18 AAC 78.230-350 is necessary.
ADEC recommends the site be addressed in the compliance order, under negotiation, along with other sites which need release investigations and corrective actions. Based on information in the report, a complete release investigation and corrective action at the site be conducted as soon as possible. |
John Halverson |
| 8/26/1993 |
Document, Report, or Work plan Review - other |
Letter to Army (D. Fosbrook) re: work plan building 987 Portion of mini-sites July 15, 1993. ADEC received the plan referenced in this letter on July 27, 1993. The Corps of Engineers transmittal memo to DPW requested comments by July 29, 1993 (two days after we received the plan). The transmittal letter from DPW to ADEC requested comments by August 26, 1993. As we have discussed with the Army on several occasions, work plans must be submitted at least thirty (30) days prior to the planned start date for work in order to allow time for ADEC review and comments.
During our meeting on August 5, when we visited Ammo Area A, there was discussion about the ongoing site investigation work at building 987 and the fact that field work had been initiated. During our phone conversation yesterday, you informed me that the field work may be complete (for this phase of the project). In the future, please ensure that plans and reports are submitted in a timely manner. A quick review of the July 15, 1993 work plan raised several questions. However, since the work has already been conducted, the Department will not provide a detailed review and comment on the plan. We will review and comment on the report detailing work that has been done. |
John Halverson |
| 8/30/1993 |
Update or Other Action |
A second investigation by the USACE in August 1993 found that contamination reached the groundwater. The sampling effort was undertaken to try and identify the extent of soil and groundwater contamination. Biovent wells were also installed for use at a later date. During this sampling event, six (6) borings were drilled. Soil containing BTEX was present at 30 to 40' bgs. Two (2) borings were converted to biovent wells and two were converted into monitoring wells. The sampling showed that the groundwater [115' bgs] in the area is contaminated with diesel and gasoline range organics and contain aromatic volatile organic compounds [benzene 110 ug/L > MCL of 5 ug/L]. Both of the wells showed concentrations of benzene in the groundwater.
One well was installed down gradient of the UST and the other well was located up gradient. The fact that the well up gradient showed signs of contamination led to speculation that the contamination on site may be from the site piping or offsite contamination. The wells installed during this sampling effort were incorporated into the Groundwater Study at Fort Richardson. |
Louis Howard |
| 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 |
| 4/8/1994 |
Update or Other Action |
Army CORPS of Engineers' Sampling & Analysis Plan GW Monitoring received.
3.3.5 Building 987 Monitoring Wells: These two wells were installed in September-October 1993,
as part of an investigation of POL contamination from a former overflow UST at the Building
987 fuel pump station. No known suitable alternate wells.
AP-3233
Installed: 29 Sep 93, as a flush-mounted well.
Screened depth: 104.5 to 124.5 ft bgs.
Groundwater depth: 114.62 ft bgs on 14 Jan 94.
Sampling History: Oct 93.
Notable Contamination: 120 ppb benzene, DRO 2.0 ppm
AP-3235
Installed: 4-6 Oct 93, as a flush-mounted well.
Screened depth: 108.3 to 128.3 ft bgs.
Groundwater depth: 115.85 ft bgs.
Sampling History: Oct 93.
Notable Contamination: 97 ppb benzene, DRO-4.2 ppm
Water samples from wells not associated with the landfill will be analyzed by the following analyses:
- Volatile Organic Compounds; Method 8260
- Gasoline Range Organics; modified Method 8015, ADEC version
- Diesel Range Organics; modified Method 8100, ADEC version
- 23 Target Analyte List Metals, total and dissolved
Measurements of pH, conductivity, temperature, oxidation/reduction potential and/or dissolved oxygen will be performed in the field at each well. |
Louis Howard |
| 4/8/1994 |
Update or Other Action |
Army CORPS of Engineers' Sampling & Analysis Plan GW Monitoring received.
3.3.5 Building 987 Monitoring Wells: These two wells were installed in September-October 1993,
as part of an investigation of POL contamination from a former overflow UST at the Building
987 fuel pump station. No known suitable alternate wells.
AP-3233
Installed: 29 Sep 93, as a flush-mounted well.
Screened depth: 104.5 to 124.5 ft bgs.
Groundwater depth: 114.62 ft bgs on 14 Jan 94.
Sampling History: Oct 93.
Notable Contamination: 120 ppb benzene (2011 18 AAC 75 5 ug/L), DRO 2.0 ppm (2011 18 AAC 75 1.5 mg/L)
AP-3235
Installed: 4-6 Oct 93, as a flush-mounted well.
Screened depth: 108.3 to 128.3 ft bgs.
Groundwater depth: 115.85 ft bgs.
Sampling History: Oct 93.
Notable Contamination: 97 ppb benzene (2011 18 AAC 75 5 ug/L), DRO-4.2 ppm (2011 18 AAC 75 1.5 mg/L)
Water samples from wells not associated with the landfill will be analyzed by the following analyses:
- Volatile Organic Compounds; Method 8260
- Gasoline Range Organics; modified Method 8015, ADEC version
- Diesel Range Organics; modified Method 8100, ADEC version
- 23 Target Analyte List Metals, total and dissolved
Measurements of pH, conductivity, temperature, oxidation/reduction potential and/or dissolved oxygen will be performed in the field at each well. |
Louis Howard |
| 7/19/1994 |
Update or Other Action |
USACE Chemical Data Report GW Study (Spring 1994) received. Reusable bailers were used to collect volatile organic compounds, gasoline range organics samples. The results for these contaminants should be biased low due to sampling method and loss of volatiles with bailers.
These two monitoring wells were installed in September-October 1993, as part of an Investigation of POL contamination from a former overflow UST at the Building 987 fuel pump station.
AP-3233
Sample No: 94FRGW44WA
Date Sampled: 1 April 1994
Notable Chemical Results:
2.28 mg/L GRO (2011 18 AAC 75 2.2 mg/L)
13.6 mg/L DRO (2011 18 AAC 75 1.5 mg/L)
22 ug/L benzene (2011 18 AAC 75 5 ug/L)
3.8 ug/L 1,2-dichloroethane (2011 18 AAC 75 5 ug/L)
61 ug/L 1,3,5-trimethylbenzene (2011 18 AAC 75 2.2 mg/L)
84 ug/L 1,2,4-trimethylbenzene (2011 18 AAC 75 1,800 mg/L)
17 ug/L total lead (no dissolved lead detected) (2011 18 AAC 75 15 ug/L)
19,700 ug/L total iron (1,060 ug/L dissolved iron) (2011 18 AAC 75 N/A)
2,030 ug/L total manganses (1,620 ug/L dissolved Mn). (2011 18 AAC 75 N/A)
AP-3235
Sampie No: 34FRGW20TWA, 2lWA (QC dup), 22WA (QA dup)
Date Sampled: 24 March 1994
Notable Chemicai Results:
0.496 - 0.64 mg/L GRO (2011 18 AAC 75 2.2 mg/L) decreased
4.25-8.39 mg/L DRO (2011 18 AAC 75 1.5 mg/L) decreased
4.0-5.4 ug/L benzene (2011 18 AAC 75 5 ug/L) decreased
<0.9-2.4 ug/L 1,2-dichloroethane (2011 18 AAC 75 5 ug/L) decreased
28-32 ug/L total Lead (<2-6 ug/L dissolved Lead) (2011 18 AAC 75 15 ug/L) increased
65,000-74,700 ug/L Total iron (500 ug/L diss. iron) (2011 18 AAC 75 n/a)
93-109 ug/L total chromium (no diss. Cr detected) (2011 18 AAC 75 100 ug/L)
121-150 ug/L total nickel (no diss. Ni detected) (2011 18 AAC 75 100 ug/L) |
Louis Howard |
| 8/4/1994 |
Document, Report, or Work plan Review - other |
ADEC staff sent letter to US Army (S. Swearingen) re: site assessment/release investigation report and corrective action plan July 9, 1994 for pumphouse at building 987.
3.2.2.1 DRO (8100M) Soil Page 14: For boring AP3234, the text refers to low levels of DRO until 26 ft. and declines with depth. The text must also mention contamination found at 37 ft. (820 mg/kg DRO) which is above level "A".
3.2.2.3 Volatile Aromatic Compounds (VACs) (Method 8020) Soil pages 16 and 17: The text needs to describe the amount of "significant" levels of contamination encountered in boring 3362 including depths and concentrations. The text states the total depth of contamination of VACs was down to 40 ft. This may not be true since VACs were not analyzed at the 45 ft. level.
6.6.3 Recommended Corrective Action Page 40: The text states a combination of bioventing and air sparging as the most appropriate solution for treating the groundwater and soil contamination. ADEC concurs. The next step for the Army is to submit a separate draft corrective action plan with schedules as outlined in the Underground Storage Management Plan, Attachment C UST timeline.
The corrective action plan shall include, at a minimum, the following information: a schedule for implementation, rationale for choosing a remedial technology, engineered system plans, equipment, and skilled personnel, efficiency, reliability, and compatibility of proposed actions with foreseeable requirements, the need for an on-site pilot study, qualified third party supervision of remedial actions according to 18 AAC 78.995(70), procedures for equipment monitoring during remediation, contaminant media analysis to ensure remediation is progressing and provisions for work documentation. The plan shall reference the QAPP that will be followed and address any site specific modifications necessary to conduct field work. |
Louis Howard |
| 2/5/1995 |
Update or Other Action |
Letter from Army to ADEC. On January 13, 1995, you met with Mr. Samuel P. Swearingen, and Major Kevin Gardener of the Environmental Compliance Branch. At this time you requested an explanation for the lack of spill protection on a number of underground storage tanks(UST) located at Fort Richardson. Below you will find a listing of those regulated tanks that were in question and an explanation of how the spill control requirement is met:
Tank#45A-This tank is currently out of service pending removal and replacement. |
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 |
| 8/30/1995 |
Update or Other Action |
Army letter to ADEC re: Extension on the temporary closure of UST 45A at Bldg. 987. Public Works is requesting an extension on the 12 month temporary closure period allowed for USTs in 18 AAC 78, for UST 45A at bldg. 987. This UST was temporarily taken out of service in August/September of 1994, awaiting a determination on the future usage of the three (3) on-half million gallon aboveground storage tanks (ASTs) located nearby. There are currently no plans to repair/upgrade these ASTs, and is therefore no longer required. It is currenlty scheduled for removal during the 1995 work season, but the removal may not take place within the allotted 12 month period. |
Louis Howard |
| 9/7/1995 |
Update or Other Action |
ARMY letter to ADEC RE: Extension of USTMP/2 Party POL Timelines for the release investigation at Bldg. 987. Public Works is requesting an extension in the timelines for a release investigation at bldg. 987, as agreed to in the UST mgt. plan and the 2 party POL agreement.
In July 1994, the Corps of Engineers (COE) submitted a Draft release investigation/site assessment report for bldg. 987. However, the report identified the 300 gallon underground storage tank (UST) at the site as the primary source for all contamination at the site. In August 1994, PW requested the COE address the contamination at the site based upon possible releases from the three (3) 625,000 gallon aboveground storage tanks (ASTs) located at the site. COE has finished the field work for the new investigation in July 1995, and is expecting the draft report in October (1995). PW would like the timeline for submittal of the release investigation be extended until 30 October 1995. |
Louis Howard |
| 9/18/1995 |
Update or Other Action |
In 1995, five new monitoring wells were installed to again try and determine the extent and nature of the groundwater contamination. Results of this sampling effort led to a better understanding of the contamination found on the site. The investigation revealed that soil containing DRO and GRO at lower concentrations is common throughout the site at depths up to 17' bgs.
Two of the five borings had elevated levels of DRO, GRO, and TRPH in the soil samples and one of the wells developed from the boring had low level readings for GRO (54 ug/L) and DRO (68 ug/L) in the water. The contaminated well was located downgradient of the former UST site (approx. 300-350 ft.). Three of the five wells were tested for BTEX by method 8020 and the remaining two wells were tested for volatile organics by method 8260. No levels of BTEX were found in any of the wells.
This round of sampling indicates that the groundwater is not being contaminated from an off-site source. The soil contamination found upgradient of the UST may be from a source other than the UST (surface spills, piping leaks, etc), but the groundwater contamination appears to be localized on site in the immediate vicinity of the pumphouse. |
Louis Howard |
| 9/26/1995 |
Update or Other Action |
Status of Corrective Action Plan addendum for bldg. 987 UST received from the ARMY. The orginal plan for the contaminated soil and groundwater at bldg. 987 called for air sparging the contaminated aquifer and bioventing the contaminated soils. Since the groundwater contamination appears to be localized onsite, the next step in evaluating the site was to look at the potential targets of the contamination if groundwater migrated off-site. A groundwater gradient was developed from the monitoring wells installed in 1995.
From those wells, it can be seen that the groundwater is moving in a northwesterly direction. A search was performed to identify any supply wells that may be in the path of the contaminated groundwater. Groundwater supply wells located downgradient of the contamination were found at Otter Lake. Supply wells were also located outside of the pathway for the contaminated groundwater so they are unlikely targets of contamination.
Based on the "new" well information, the proposed corrective action for this project is to conduct vadose zone and groundwater modeling in conjuction with a human health and ecological risk evaluation. It is expected that natural attenuation and verification monitoring will be the recommeded corrective action. |
Louis Howard |
| 10/24/1995 |
Update or Other Action |
ADEC letter to ARMY re: extension temporary closure for UST 45A associated with bldg. 987. State UST regulation 18 AAC 78.080(e) allows the department to grant an extension to the temporary closure period provided the UST meets the performance standards of a new UST system under 18 AAC 78.025 or the upgrade requirements of 18 AAC 78.030, and a site assessemnt has been completed.
Our records indicate that tank 45A is a double walled, cathodically protected, steel tank with spill and over-fill protection and interstitial monitoring is used as the leak detection method. The department confirmed this information during an inspection of the tank on August 25, 1995. A site assessment of the general area was conducted on July 9, 1994. The site assessment findings indicated contamination was present. However, the contamination is thought to have originated from a Non-UST source.
The Department grants the temporary closure extension for a period not to exceed June 1, 1996, provided the compliance with the following: 1) no product is added to the tank, 2) continued operation and maintenance of cathodic protection, 3) continued operation and monitoring of your leak detection method, 4) vent lines shall remain opened, 5) all other lines and manways shall be capped and secure, 6) if a release is suspected or confirmed during the extension period, the applicable requirements of 18 AAC 78.200-280 must be met. |
Tim Stevens |
| 11/24/1995 |
Document, Report, or Work plan Review - other |
ADEC letter to Sam Swearingen (US ARMY) re: Site Assessment/Release Investigation and Corrective Action Plan received on November 22, 1995. 2.1 Site Modeling-Table 3 listes BTEX in the groundwater above MCLs for all contaminants of concern (COC) at 121 ft. increasing over time from 5 to 95 years. COC increase from 1 order of magnitude to 4 orders of magnitude without any biodegradation occurring. Allowing for the biodegradation in the modeling still has benzene increasing in concentration over time to over 500 times the MCL of 5 ug/L and xylenes increasing to 24,100 ug/L or double the MCL.
3.2.1 Review of Alternatives: The text states the preferred alternative by the Army is natural attenuation. Based on the modeling result in Table 3 of the document, ADEC disagrees with the selected alternative and requests the Army immediately begin working on a corrective action plan to address the contamination at the site.
Workplans and designs submittals will cover remediation of the contaminated groundwater and soils in-situ which are still impacting the groundwater. Bioventing and air sparging as presented in the July 1994 SA/RI/CAP still appear to be the most appropriate, viable and cost effective treatment, given the depths, amounts, and types of contamination at the site. Well locations for air-sparging, based on contaminant levels, appear to be appropriate in the vicinity of AP-3233 and AP-3235. Boring locations for bioventing, based on levels found in soils, appear to be appropriate in the vicinity of AP-3362 and AP-3336.
3.3 Proposed Action: The text states the groundwater be monitored for biofeasibilty parameters on a biannual basis. ADEC will require monitoring of the groundwater for COCs: GRO, DRO, BTEX, Total PAHs. Existing monitoring wells AP-3474, 3463, 3460, and 3462 are good candidates for twice yearly monitoring to establish trend analysis and possible plume migration to the northwest. A data gap needs to be addressed by installing a groundwater well between AP-3474 and 3463 which would detect contamination moving to the northwest from the site. |
Louis Howard |
| 11/30/1995 |
Update or Other Action |
US ARMY CORPS of Engineers Chemical Data Report received for Groundwater Study Fall 1994 and Spring 1995
Well-3233
Notable Chemical Results Fall 1994 (bailed):
1.7 - 3.0 mg/L GRO (2011 18 AAC 75 2.2 mg/L) decreased
6.0 - 9.2 mg/L DRO (2011 18 AAC 75 1.5 mg/L) increased
50-55J ug/L benzene (2011 18 AAC 75 5 ug/L) increased
116 - 130J ug/L 1,2,4-Trimethylbenzene (2011 18 AAC 75 1,800 ug/L) increased
N.D. - 5J ug/L 1,2-dichloroethane (2011 18 AAC 75 5 ug/L) increased
ND (2) - 3 ug/L total Lead ( N.D. 2 ug/L dissolved Lead) (2011 18 AAC 75 15 ug/L) decreased
1,490-1600 ug/L manganese (diss. Mn 1,400 - 1,590 ug/L) decreased
Notable Chemical Results Spring 1995 (pumped):
1.8 - 1.9 mg/L GRO (2011 18 AAC 75 2.2 mg/L) decreased
1.4 - 2.0 mg/L DRO (2011 18 AAC 75 1.5 mg/L) decreased
20-22J ug/L benzene (2011 18 AAC 75 5 ug/L) decreased
120 - 130J ug/L 1,2,4-Trimethylbenzene (2011 18 AAC 75 1,800 ug/L) same
N.D. - 2.3J ug/L 1,2-dichloroethane (2011 18 AAC 75 5 ug/L) decreased
ND (2) - 2 ug/L total Lead ( N.D. 2 ug/L dissolved Lead) (2011 18 AAC 75 15 ug/L) same
1,490-1600 ug/L manganese (diss. Mn 1,400 - 1,700 ug/L) increased
AP-3235
Notable Chemical Results Fall 1994 (pumped):
0.35 mg/L GRO (2011 18 AAC 75 2.2 mg/L) decreased
0.4 mg/L DRO (2011 18 AAC 75 1.5 mg/L) decreased
N.D. (2) ug/L benzene (2011 18 AAC 75 5 ug/L) decreased
N.D. (2) ug/L 1,2,4-Trimethylbenzene (2011 18 AAC 75 1,800 ug/L) same
N.D. (2) ug/L 1,2-dichloroethane (2011 18 AAC 75 5 ug/L) increased
ND (2) - 2 ug/L total Lead ( N.D. 2 ug/L dissolved Lead) (2011 18 AAC 75 15 ug/L) decreased
426 - 419 ug/L manganese decreased
Notable Chemical Results Spring 1995 (pumped):
0.45 mg/L GRO (2011 18 AAC 75 2.2 mg/L) increased
0.7 mg/L DRO (2011 18 AAC 75 1.5 mg/L) increased
N.D. (0.7) ug/L benzene (2011 18 AAC 75 5 ug/L) decreased
N.D. (1) ug/L 1,2,4-Trimethylbenzene (2011 18 AAC 75 1,800 ug/L) decreased
N.D. (0.5) ug/L 1,2-dichloroethane (2011 18 AAC 75 5 ug/L) decreased
ND (2) - 2 ug/L total Lead ( N.D. 2 ug/L dissolved Lead) (2011 18 AAC 75 15 ug/L) same
378 (dissolved - 377) ug/L manganese decreased
The relatively high concentrations of dissolved manganese in both wells are notable.
It is thought rhat this may be related to the presence of petroleum hydrocarbons in the
groundwater and associated microbiological processes; speculation on this possibiIity lies
outside the scope of this report. |
Louis Howard |
| 2/8/1996 |
Update or Other Action |
MEMORANDUM FOR Tim Berg, Chief, Business Management Department SUBJECT: Land Usage Restriction on FRA Buildings 762 and 987, and Locality.
1. Alaska Department of Environmental Conservation (ADEC) has requested certain land usage restrictions be placed on FRA property around Bldg 987 and the site of former Bldg 762. Public Works Environmental has agreed to these restrictions as part ofa "No Further Remedial Action" under the Fort Richardson-State of Alaska, Underground Storage Tank Compliance Agreement.
2. The proposed restrictions include:
a) Permanently zone both pieces of property as industrial;
b) Water supply wells are not to be installed on either property;
c) Any soil that may be excavated from either site must be checked for possible petroleum, oil and lubricant (POL) contamination, and if contamination is found, must be dealt with according to 18 AAC 78 contaminated soil standards;
d) The asphaltic tarmac currently in place around the site of fonner Bldg 762 must remain in place indefinitely, and any portion of the tannac that is removed for maintenance of utilities, etc., that might be in the area, must be replaced.
e) Any worker conducting excavations, or other operations on site that might expose him/her to contaminated soils, must be informed of the possibility of encountering contaminated soils, and the appropriate personal protection equipment and measures.
3. Point of contact is Mr. Samuel P. Swearingen, (907) 384-2711, if you should have any
questions. |
Louis Howard |
| 9/26/1996 |
Update or Other Action |
UST Remediation Bldg. 987 Site Assessment/Release Investigation Report & Corrective Action Plan (US ACE AK District) received.
Initially, all contamination was attributed to the leaking fittings of the 300 gallon overflow UST removed in 1990. It is possible that other sources have contributed to the contamination at this site. Other possible sources include dry wells, spills inside building 987, spills outside building 987, leaking underground pipes, & the railhead. Generally, the highest levels of contamination have been found in the area of the former UST. While other spills may have contributed to the contamination onsite, it appears that the area of the greatest contamination is located in the vicinity of the over flow tank.
Regulatory levels for benzene contamination in well AP-3233 were exceeded in GW samples from the 1993 testing. Recent tests indicate that the levels appear to be dropping. While the concentration levels appear to fluctuate seasonally, the overall trend, based on the limited number of samples available, appears to be downward.
The toluene levels observed in the well samples AP-3233 & AP-3235 are below the EPA MCL of 1,000 ug/L. This is also true for ethylbenzene (EPA MCL = 700 ug/L) & total xylenes (EPA MCL = 10,000 ug/L). The GRO & DRO concentration in well AP-3235 appears to be trending downwards. It is difficult to determine if the GRO & DRO contaminant levels are dropping for well AP-3233. There are no published acceptable levels of GRO & DRO in drinking water. NOTE TO FILE 2011 18 AAC 75: GRO 2.2 mg/L DRO 1.5 mg/L RRO 1.1 mg/L.
1993 Soil Sampling: Benzene at 130 mg/kg, Ethylbenzene at 270 mg/kg, Toluene at 920 mg/kg & total Xylenes at 1,570 mg/kg from 30' bgs in 1991 sampling are the highest levels of these COCs.
1993 Soil Sampling: Gasoline Range Organics at 1,900 mg/kg from 25' bgs was the highest detected level.
1996 Soil Sampling: Diesel Range Organics at 6,600 mg/kg from 35' bgs is the highest level detected. It appears DRO is not attenuating.
Floating product was not found in any of the wells sampled for this project. Air contamination was not a consideration in this project since all significant levels of fuel were found below 15 feet bgs.
The site leaching assessment indicates that the GW at the site will continue to show an increase in the levels of benzene & that the levels of toluene, ethylbenzene, & xylenes will exceed the state & federal MCLs. This indicates that the contaminated soil at the site could continue to act as a secondary source of contamination to the GW. The proposed action at the site is a two part action designed to remove the source of continued leaching at the site.
Part one would clean up of the volatile, more mobile constituents of the soil contamination using soil vapor extraction. This would stop the vadose zone soils from acting as a secondary source of GW contamination. The heavier end components of the fuel will remain in place since the leaching assessment indicates that if these components leach into the GW, the levels will be insignificant.
The second part of the proposed action is continued monitoring of the GW in wells AP-3235, AP-3233, & AP-3699 (figure 10) to insure that the contaminant levels continue to decrease. The data collected to date indicates that the contaminant levels are trending downwards without any human involvement. With the secondary source of the GW contamination removed, the levels are anticipated to continue to decline, possibly at a faster rate.
See site file for additional information.
|
Louis Howard |
| 11/19/1996 |
Cleanup Plan Approved |
ADEC letter to ARMY (S. Swearingen) RE: Draft work plan bldg. 987 October 1996 delivery order DACA85-95-D-008. ADEC approves the workplan as submitted for implementing soil vapor extraction at the site. Please submit information on the sampling protocols, frequency of sampling, methods and any other information related to the groundwater monitoring portion of the corrective action plan submitted on October 31, 1996. |
Louis Howard |
| 11/19/1996 |
Document, Report, or Work plan Review - other |
Comment letter for Site Assessment/Release Investigation and Corrective Action Plan Bldg. 987 September 26, 1996. This letter is a continuation of issues raised by ADEC in a November 24, 1995 letter to the ARMY.
3.3 Proposed Corrective Action Page 30. - The text states the remedial action will be a two part design with soils being treated by soil vapor extraction and continued monitoring of the groundwater in MW 3235, 3233, and 3699. Groundwater monitoring shall be for the bioremediation indicators, total polynuclear aromatic hydrocarbons, and BTEX only.
Methods for anlyses will either be 602 or 624 for BTEX and methods 610 or 625 for PAHs. Site monitoring of the groundwater is suggested to continue to occure twice yearly for the first two years, then reduce sampling to once a year IF there is a decrease in contaminants in the groundwater. A five (5) year review will be required to assess the appropriateness of the selected remedy. DRO and GRO will not be required analyses for groundwater since they do not have MCLs (at this time). |
Louis Howard |
| 3/13/1997 |
Update or Other Action |
UPD added on 3/13/97, based on Army Risk Data Report dated 11/8/96.Pathways: No contaminant movement in groundwater has been observed. Area is secured with limited access. However, soil is source of continued groundwater contamination. Receptors: No wells within 1 mile. Site workers potentially exposed; potential impact to downgradient receptors in event of contamination to deep aquifer. |
Louis Howard |
| 10/23/1997 |
Document, Report, or Work plan Review - other |
ADEC letter to ARMY RE: Progress reports 6/24/97-7/24/97, 7/24/97-9/2/97 W.O. D55882 Bldg. 987 Sept. 25 and October 2, 1997. ADEC concurs with the recommendations suggested in the reports to continue operation of the system and monitoring according to the project work plan. |
Louis Howard |
| 8/10/1998 |
Update or Other Action |
Soil vapor extraction (SVE) system ran for one year and removed 2,250 pounds of petroleum hydrocarbons. Monitoring results demonstrate diminishing removal rates after one year and system was shut down. |
Louis Howard |
| 3/1/1999 |
Update or Other Action |
Post Remedial Investigation July 98/December 1998. Executive summary states several soil samples exceeded level B cleanup levels and the sample from the 30' depth was the most contaminated. Even with the newly promulgated 18 AAC 75 regulations, it appears remedial action is still warranted for the petroleum contamination in the soil and continued groundwater monitoring.
Results are as follows: 792 mg/kg BTEX, 3,700 mg/kg GRO are in excess of maximum allowable for GRO and BTEX. 3,300 mg/kg DRO exceeds the 250 mg/kg migration to groundwater cleanup level. Values for benzene in soil sample from AP-3924 were possibly higher than the level "B" criteria of 0.5 mg/kg and table B2 values of 0.02 mg/kg since the method detection limit was much higher than these cleanup levels at 5.2 mg/kg.
Groundwater has 7.7 ug/L benzene and DRO levels in AP-3235 are at 24 mg/L [NOTE TO FILE: LNAPL is considered present where analytical data shows DRO concentrations above the theoretical solubility limit for diesel of 3.9 mg/L] which are in increase of sixfold from 3 to 5 years ago. |
Louis Howard |
| 5/28/1999 |
Site Characterization Workplan Approved |
ADEC received documents on May 27, 1999 and reviewed and provided approval of the documents on May 28, 1999. Pleae be aware that this expedited review is a courtesy granted by ADEC to the ARMY and not the normal way of conducting business. Normal review times for scopes of work, work plans, sampling plans is thirty (30) days and it is generally not acceptable to send these types of documents for review turnaround times of less than THREE (3) days.
Sampling and analysis plan approved for removal of ASTs, pipeline, pumphouse, and oil sands beneath the ASTs at Building 987. |
Louis Howard |
| 8/31/1999 |
Offsite Soil or Groundwater Disposal Approved |
Staff approved transport of approximately 60 tons of oil impregnated sands to Alaska Soil Recycling (ASR) for thermal remediation. DRO is the main contaminant of concern at 11,700 and RRO at 5,810 mg/kg. |
Louis Howard |
| 10/5/1999 |
Document, Report, or Work plan Review - other |
Staff provided comment letter to ARMY re: Environmental Monitoring Report Aboveground Storage Tanks and Pipeline Demolition (August 27, 1999).
7.0 Conclusions and Recommendations Page 12. -The sampling results are as follows: ASTs 10, 500 mg/kg DRO, Fuel Pump house, truck stand and valve station: 16,300 mg/kg DRO and Fuel Pipeline trench 9,950 mg/kg DRO, 7,280 mg/kg GRO, 2,998 mg/kg total BTEX (114 mg/kg benzene). Staff requested the Army propose which method it intends to pursue site cleanup under 18 AAC 75. Additionally, ADEC requests the Army provide the justification for basing those cleanup levels upon an estimate of the reasonable maximum exposure expected to occur under current and future site conditions.
ADEC requests the Army submit a work plan to ADEC for review and comment detailing how it plans to implement a corrective action to address contamination associated with the site. State regulations 18 AAC 75.310 requires the Army after becoming aware of a discharge or release, and, after obtaining approval (by ADEC), shall treat or dispose of the contaminated equipment, materials, soil and water collected.
(c) For containment and cleanup, ADEC will determine the lowest practicable level of contamination based on
(1) protection of human health, safety, and welfare, and of the environment;
(2) the nature and toxicity of the hazardous substance, including amount and concentration;
(3) hydrogeological and climatological factors;
(4) the extent to which the hazardous substance has migrated, or is likely to migrate, from the area of original contamination if the hazardous substance remains onsite;
(5) the natural dispersion, attenuation, or degradation of the contamination;
(6) the extent to which residual soil contamination exceeds the cleanup levels in
18 AAC 75.340 and 18 AAC 75.341;
(7) the extent to which groundwater contamination exceeds the groundwater cleanup levels in 18 AAC 75.345;
(8) the current and future use of the groundwater under 18 AAC 75.350; and
(9) the need for an interim removal action under 18 AAC 75.330.
|
Louis Howard |
| 11/8/1999 |
Document, Report, or Work plan Review - other |
ADEC letter to ARMY re: 2nd letter requesting clarification and a corrective action workplan for petroleum contamination at bldg. 987. The ADEC has requested in an October 5, 1999 letter to the Army requesting clarification of certain issues raised during its review of the Environmental Monitoring Report it received on September 20, 1999. ADEC is again requesting clarification from the Army on the petroleum contamination found during the demolition project of the ASTs, piping, pipeline and pumphouse near Building 987.
General Comments: Currently long-term groundwater monitoring and an asphalt cap is all that is planned for the site. Prior to the demolition project there was a soil vapor extraction system in place that was used to address soil contamination that was lower in concentration than those currently found at the site. Based on the data at that time, it was determined that the system had reached its limit of cost effectiveness and was discontinued. Since there are higher levels of petroleum contamination at the site that were previously unknown, ADEC is requesting a work plan for corrective action at the site, which may or may not include a soil vapor extraction system.
ADEC requests the ARMY clarify which method (1, 2, 3, or 4 under 18 AAC 75.340. Soil Cleanup Levels; General Requirements) it intends to use at this site for cleanup. 18 AAC 75.325 (f) requires that the Army shall, to the maximum extent practicable,
(A) use permanent remedies;
(B) recover free product in a manner that
(i) minimizes the spread of contamination into an uncontaminated area by using containment, recovery, and disposal techniques appropriate to site conditions;
(ii) avoids additional discharge; and
(iii) disposes of the recovered free product in compliance with applicable local, state, and federal requirements;
(C) complete cleanup in a period of time that ADEC determines to be protective of human health, safety, and welfare, and of the environment;
(D) prevent, eliminate, or minimize potential adverse impacts to human health, safety, and welfare, and to the environment, onsite and offsite, from any hazardous substance remaining at the site; and
(E) evaluate and perform a cleanup of surface soil staining attributable to a hazardous substance;
(2) meet the applicable cleanup levels determined under 18 AAC 75.340 - 18 AAC 75.350; and
(3) provide for long-term care and management of a site as required under the site cleanup rules, including proper operation and maintenance of
(A) cleanup techniques and equipment;
(B) monitoring wells and equipment, if required; and
(C) institutional controls, if required under 18 AAC 75.375.
ADEC again requests the Army submit a workplan for ADEC to review and comment on detailing how it plans to implement a corrective action to address the contamination associated with the site. ADEC requests a written response to the issues raised in this letter within thirty (30) calendar days of receipt of this letter. |
Louis Howard |
| 11/16/1999 |
Update or Other Action |
Staff received a technical memorandum for the status of soil vapor extraction at Building 987.Well AP-3235 continues to exceed MCL for DRO at 8.4 mg/L DRO down from 1998 levels of 24 mg/L.SESOIL modeling of benzene, ethylbenzene, toluene, and xylenes shows that contamination in the soils will continue to leach into the groundwater and increase the groundwater contamination levels. The predictions made by SESOIL model are directly opposed to the contaminant trends observed in groundwater sampling. Ground water samples collected at the site since 1993 indicated that the contamination levels have decreased and according to the most recent data (June 1999) collected at the site, only one well exceeds the ADEC's groundwaer critiria for DRO and RRO.
Since it was not the intent of the soil vapor extraction system to remove the heavy end of the RRO, DRO and GRO contamination, RRO, DRO and GRO contamination was not modeled.
Since the intended future use of the Building 987 site is a parking/storage area and there are no plans to excavate the site for construction or drill the site for drinking water, it is the recommended (by the US Army Corps of Engineers Alaska DIstrict) that no further remedial action be pursued for the soil at this time. If the future use plans for the building 987 site change, then the soil contamination at the site will be reevaluated. It is also recommended that the groundwater be continued to be monitored seasonally so contaminant trends may be monitored. |
Louis Howard |
| 12/6/1999 |
Update or Other Action |
ARMY letter to ADEC RE: 2nd letter requesting clarification and a corrective action work plan for petroleum contamination at bldg. 987. This letter is in response to the issues raised in ADEC's letter on November 8, 1999 regarding the soil contamination discovered during the demolition of the facilities at the former building 987 bulk fuel storage facility at Fort Richardson. USARAK agrees that the previously unknown higher soil contamination levels warrant further investigation and corrective action. Based on the availability of funding and overall Fort Richardson cleanup priorities, planning and execution of this additional work will commence as soon as possible. We will provide the detailed information as it becomes available during the site cleanup planning process. Signed by Cristal Fosbrook for Mark C. Nelson Colonel US ARMY Director Public Works. |
Louis Howard |
| 12/17/1999 |
Update or Other Action |
Environmental Monitoring Report-Above Ground Storage Tank & Pipeline Demolition received.
This report documents the results of environmental monitoring conducted during the closure of three above ground storage tanks (ASTs) and approximately 1,000 lineal feet of pipeline trenching at Fort Richardson, Alaska. As part of the trench activities a total of 1,560 feet of mostly below grade 4-inch fuel piping were removed along with one fuel truck stand, and one pump house.
The 4-inch diameter fuel pipelines extended east from the tanks and the truck stand to the pump house and fenced enclosure where the tanks could be re-fueled by a nearby rail in this area. The pipelines, often lying side by side in the excavation trenches, consisted entirely of 4-inch welded steel piping. The AST and pipeline demolition was completed by Weldin
Construction, Inc. of Eagle River, Alaska, with Shannon & Wilson, Inc., providing
environmental assessment services.
The AST and pipeline demolition was conducted in accordance with the 18 AAC 78 Underground Storage Tank regulations as amended through January 22, 1999. Sampling was performed in accordance with the Standard Sampling Procedures in the December 10, 1998 ADEC UST Procedures Manual. The demolition work was authorized by Mr. Richard Weldin on May 24, 1999, in the form of a signed contract.
The tank site is situated in the northwest 1/4 of Section 31, T14N, R2W, of the Anchorage (B-8 SE) Quadrangle. The Above Ground Storage Tanks (ASTs), formerly filled with diesel (2 tanks) and gasoline (1 tank), were installed in the early 1950's and were refueled by rail cars from the track spurs that run north and south along the eastern edge of the site. Each upright tank had a 225,000 gallon capacity and measured 25 feet high and 40 feet across. Abandonment included demolition and removing the three ASTs, and 1,560 feet of 4-inch fuel piping, as well as demolition and removal of the pump house and fuel truck stand/valve station. The ASTs were taken out of service in the early 1990's and were emptied and cleaned by Kane, Inc., of Eagle River, Alaska, in October 1993.
Above Ground Storage Tanks
Sample 027S0, and a companion duplicate sample, Sample 030S0, were collected underneath AST No. 56 at a depth of 1.5 feet. A maximum concentration of 496 ppm RRO, 4,710 ppm DRO, 73.9 ppm GRO, 0.0381 ppm benzene, 0.432 ppm toluene, 0.219 ppm ethylbenzene, 1.304 ppm xylene, and 14.1 ppm lead remain in place underneath the former location of AST No. 56.
Sample 033S0 was collected at a depth of 1.5 feet underneath the former AST No. 57. Sample 033S0 had 471 ppm RRO, 10,500 ppm DRO, non-detectable levels ofGRO and BTEX, 2.79 ppm arsenic, 0.0848 ppm cadmium, 22.0 ppm chromium, and 6.23 ppm lead.
Sample 036S0 was collected at a depth of 1.5 feet underneath the former AST No. 58. Sample 036S0 had 214 ppm RRO, 608 ppm DRO, 344 ppnl GRO, 0.304 ppm benzene, 1.28 ppm toluene, 3.17 ppm ethylbenzene, and 3.58 ppm xylene. |
Louis Howard |
| 1/26/2000 |
Update or Other Action |
Staff received first quarter FY00 report for Post. Building 987 to have a task order implemented for additional remediation for petroleum contaminated soils. SVE system installation is expected to be in late summer 2000. |
Louis Howard |
| 8/31/2001 |
Update or Other Action |
Building 987 Site Investigation Chemical Report Summer 2001 dated August 2001 by the USACE Engineering Services Branch, Materials Section received. Soil samples were collected during May 24 through May 30, 2001 from 11 bore holes located at the Building 987 site. Samples were analyzed for benzene, toluene, ethylbenzene, xylenes (BTEX), gasoline range organics (GRO), diesel range organics (DRO) and polyaromatic hydrocarbons (PAHs). Two additional release sites were discovered during the course of this investigation. One site is located at the former truck stand/valve station (AP-4167) and the other is located at the fence line and in close proximity to the former railway (AP-4171). The vertical and horizontal extent of contamination at these locations is unknown.
GRO and DRO exceed regulatory limits from 15 ft. bgs to the vertical extent of drilling at two boreholes closest to the former UST. Contamination at the other locations did not exceed regulatory limits until 20 ft. bgs with the exception of the newly discovered release sites in which GRO and DRO were detected at 10 ft. bgs. The highest BTEX levels were measured in soils closest to the former Bldg. 987.
AP-4165 had the highest level of benzene at 15' bgs (7.2 mg/kg) and 20' bgs (6.9 mg/kg) and highest level of ethylbenzene at 15' bgs (26 mg/kg). AP-4165 had the highest level of toluene at 15' bgs (88 mg/kg) and 20' bgs (76 mg/kg) and the highest level of xylenes at 15' bgs (163 mg/kg). Benzene continued to be above cleanup levels at 35' bgs in AP 4162, 4165, 4167, and 4171. GRO was highest in AP-4165 (2,500 mg/kg) and AP-4164 (1,500 mg/kg). GRO continued to be above cleanup levels at 35' bgs in AP-4162, 4165, and 4171. DRO was highest at 35'bgs in AP-4171 (2,600 mg/kg), AP-4162 at 35' bgs and AP-4171 at 10' bgs (2,400 mg/kg). DRO continued to be above cleanup levels at 35' in AP-4165 and AP-4167.
Significant concentrations of fuel related hydrocarbons remain at this site. Most of the contamination can be attributed to the 300 gallon UST used as a slop tank and for arctic diesel fuel storage. Fuel compounds measured at AP-4167 are probably due to leaks or spills at the valve station valve and not part of the UST leak. |
Louis Howard |
| 8/16/2004 |
Update or Other Action |
Staff provided comments to the Army on: CLOSES Evaluation Interim Final, Fort Richardson, AK dated June 2003 Contract No. DAPC49-01-F-0165. The Alaska Department of Environmental Conservation (the Department) has received the above document August 11, 2004.
General Comments
The Department requests including additional text where “non-dissolved phase hydrocarbons” is referred to in several places in the document. Specifically, “non-dissolved phase hydrocarbons” meets the regulatory definition of “free product”. “Free product” is defined in regulation in 18 AAC 78 (67) and 18 AAC 75 (43): "free product" means a concentration of petroleum that is present as a nonaqueous phase liquid; for purposes of this paragraph, a “nonaqueous phase liquid” is a liquid that is not dissolved in water.
The effect of temperature on the volatility and solubility of the hydrocarbons present in the soil shall be addressed and the vapor pressure and solubility values used in the four phase calculator shall be representative of the average soil temperatures at Fort Richardson or the next closest observation station (i.e. Anchorage).
Executive Summary Page E5-1
The text states a new monitoring well be installed at the site (see source area at the location shown in figure 600-1). The new well will be sampled quarterly for four events and the five existing wells (AP-3699, AP-3649, AP4342, AP-4343) will only sampled during the first event. The Department concurs.
|
Louis Howard |
| 1/6/2005 |
Document, Report, or Work plan Review - other |
Staff sent Army comment letter on: Draft Spring 2004 Sampling Report Groundwater Monitoring Buildings 987, 59000, and the Seward Recreation Camp, Fort Richardson, AK dated September 2004 Contract No. W911KB-04-T-0036. The Department concurs with the recommendations to continue annual groundwater monitoring of DRO and BTEX at this site. |
Louis Howard |
| 6/20/2006 |
Document, Report, or Work plan Review - other |
Staff reviewed and commented on the draft fall 2005 sampling report for three sites: Bldg. 59000, former bldg. 987, and Seward Army Resort.
Former Bldg. 987 - ADEC does not concur with the recommendations to discontinue groundwater monitoring at wells AP-3460 and AP-3462. Instead ADEC requests the Army monitor these two wells every other year. Before the site will be considered for site closure or even conditional closure, ADEC will require a minimum of four soil borings be installed in the areas where historic high petroleum contamination was detected in the soil from the AST demolition and pipeline removal in 1999. A minimum of three soil samples per boring will be required and each sample analyzed for: DRO, GRO, PAHs, BTEX. Previous sampling results, before the area was subsequently paved over for vehicle storage, are as follows:
1. ASTs area 10,500 mg/kg DRO,
2. Fuel Pump house, truck stand and valve station area: 16,300 mg/kg DRO and
3. Fuel Pipeline trench area 9,950 mg/kg DRO, 7,280 mg/kg GRO, 2,998 mg/kg total BTEX (114 mg/kg which was benzene).
|
Louis Howard |
| 2/23/2007 |
Exposure Tracking Model Ranking |
|
Louis Howard |
| 8/30/2007 |
GIS Position Updated |
61.2668 N latitude -149.7162 W longitude |
Louis Howard |
| 2/6/2008 |
Document, Report, or Work plan Review - other |
Staff reviewed and commented on the Draft Former Building 987, July 2007 Groundwater Monitoring Report.
Section 5 Conclusions Page 5-1: ADEC does not concur with the recommendations to have Bldg. 987 be considered for conditional closure. Before conditional closure will be considered, ADEC will require a minimum of three (3) soil borings be installed in the areas where historic high petroleum contamination was detected in the soil from the aboveground storage tank (AST) demolition and pipeline removal in 1999.
A minimum of three (3) soil samples per boring will be required and each sample analyzed for: diesel range organics (DRO), gasoline range organics (GRO), polynuclear aromatic hydrocarbons (PAHs), benzene, toluene, ethylbenzene, xylenes (BTEX). Previous sampling results, before the area was subsequently paved over for vehicle storage, are as follows: 1. ASTs area 10,500 mg/kg DRO, 2. Fuel Pump house, truck stand and valve station area: 16,300 mg/kg DRO and 3. Fuel Pipeline trench area 9,950 mg/kg DRO, 7,280 mg/kg GRO, 2,998 mg/kg total BTEX (114 mg/kg which was benzene). Samples will be taken at the soil/groundwater interface, area of highest historical contamination and area of highest field screening results during boring installation. |
Louis Howard |
| 10/9/2009 |
Update or Other Action |
Memorandum of Agreement between US Air Force & US Army for Joint Base Elmendorf-Richardson. The purpose of this MOA is to define the installation support relationship between the supporting Component – the United States Air Force (USAF), hereafter referred to as the “supporting Component”, & the supported Component(s) – the United States Army (USA), hereafter referred to as the “supported Component(s)” for fully implementing Base Realignment & Closure (BRAC) 2005 Joint Base decisions per references (a), (b), (c), & (d) at Joint Base Elmendorf-Richardson. For the purposes of this MOA, the terms “party” & “parties” shall be understood to refer exclusively to the supporting Component & the supported Component(s), either collectively or individually.
This MOA establishes a comprehensive framework for Joint Base Elmendorf-Richardson implementation, & captures the most practical methods for transferring Installation Support functions while meeting mission requirements. The MOA represents Full Operational Capability (FOC). Initial Operational Capability (IOC) requirements, to include reimbursement arrangements, will be addressed in the Implementation Plan. PERIOD OF PERFORMANCE a. IOC: 31 January 2010 to 30 September 2010. b. FOC: 1 October 2010 until terminated by the signatories of this MOA. Major milestones & transfer date for each annex to successfully achieve FOC which area applicable to environmental issues.
#15 Annex G: Review existing environmental contracts/determine optimum methods to complete the JB mission Activation or completion date: 01/31/2010, #16: Develop JB Environmental Quality organizational structure 01/31/2010 #17: Merge JB tank inventories into a single, common data base (DB) 03/01/2010 #18: Work with external regulatory agencies to optimize the merger of all air permits 06/01/2010 #19: Begin Merger of JB air emission inventories into a single, common DB 09/01/2010 #20: Determine additional air regulatory requirements due to JB merger 06/01/2010 #21: Begin Merger of JB drinking water (DW) programs 06/01/2010 #22: Determine DW regulatory requirements due to JB merger 06/01/2010 #23: Merge JB environmental management system (EMS) programs 08/01/2010
#25: Complete new JB compliance inventory & risk analysis 08/01/2010 #27: Establish JB Environmental, Safety, & Occupational Health Council (ESOHC) 08/01/2010 #33: Merge JB hazardous waste (HW) programs 10/01/2010 #34: Work with external regulatory agencies to optimize incorporating Fort Richardson into Elmendorf Air Force Base Part B permit 03/01/2010 #35: Develop JB OPLAN for HW/toxic waste operations 06/01/2010 #36: Merge JB HW inventories/accumulation points into common DBs 10/01/2010 #37: Merge JB Land Use Controls (LUC) programs 10/01/2010 #42: Merge JB contaminated sites (CS) program 10/01/2010
#43: Merge JB CS inventories into a single, common DB 10/01/2010 #44: Convert Fort Richardson CS to meet Air Force protocols 10/01/2010 #45: Begin Merger of JB spill prevention & reporting programs 01/31/2010 #46: Develop JB spill contingency plan 03/01/2011 Note: this is when current plans expire. EPA says we can use existing plans until then. #58: Review existing Agreements & Plans 09/01/2010 #88: Transfer all environmental files from Fort Richardson to JBER 09/01/2010 #90: Merge Fort Richardson & Elmendorf Air Force Base Geographic Information System (GIS) into AF-approved GIS 09/01/2010 #96: Review Comprehensive Environmental Response, Compensation, & Liability Act (CERCLA) activities to ensure compliance with the Federal Facility Agreement (FFA) 03/01/2010 #97: Draft notification of responsibility change for FFA 09/01/2010 #98: Negotiate revisions/amendment to Two party Agreement 10/01/2010 #99: Prepare annual update of the status of all two-party sites 09/01/2010 #103: Prepare/update JB instruction for management of LUCs 09/01/2010 #104: Update maps/GEOBASE depicting LUC boundaries 10/01/2010
#105: Prepare/submit annual LUC report to EPA & ADEC 10/01/2010 #106: Update Air Force base general plan 10/01/2010 #107: Merge JB CERCLA administrative record 09/01/2010 #108: Merge project & contract files into common formats & DBs, libraries 10/01/2010 #109: Prepare & update the Community Relations Plan 10/01/2010 #110: Develop 1- & 2- year work plans for the (Defense-State Memorandum Of Agreement) DSMOA cooperative agreement 10/01/2010 #111: Merge JB CS programs 09/01/2010 #112: Merge JB CS inventories into a single, common DB 10/01/2010 #113: Convert Fort Richardson CS to meet Air Force protocols 10/01/2010
#114: Merge JB Military Munitions Response Program (MMRP) sites programs 10/01/2010 #115: Merge JB MMRP site inventories into a single, common DB 10/01/2010 #116: Convert Fort Richardson MMRP sites to meet AF protocols 10/01/2010 #120 I-1.3 Transfer Records Mgt. Functions to the Joint Base 06/30/2010 |
Louis Howard |
| 1/26/2010 |
Update or Other Action |
For releases where leaded gasoline and aviation gasoline are suspected contaminants of concern, ADEC requires analysis for EDB and 1,2-DCA. EPA 8260 is required for the analysis of 1,2-Dichloroethane (1,2-DCA). EPA 8011 or EPA 504.1 should be used when evaluating ethylene dibromide (EDB). EDB soil samples should be field preserved in hexane. EPA 8260 will quantify EDB in ground water; however, the detection limits do not meet the Table C cleanup level of 0.00005 mg/L. |
Louis Howard |
| 5/13/2011 |
Update or Other Action |
Staff recieved the draft work plan for corrective action at heating oil tanks for several sites. This Work Plan, in conjunction with the addenda presented herein, will guide corrective actions to be performed at the Army Reserve Center (ARC) Tank E1, ARC Tank E2, ARC Tank E5, ARC Tank E7, Building 57-428 Tank, Building 987, Biathlon Range, & Fort Richardson Landfill sites in accordance with the requirements of the U.S. Environmental Protection Agency & Alaska Department of Environmental Conservation (ADEC) guidance documents.
Monitoring well (AP-3462) at Building 987 will be replaced due to damage to the existing well. The new monitoring well will be located approximately 15 feet from the original well. The boring will be drilled to a depth of 10 feet into groundwater (approximately 140 feet bgs). Figure 4 shows the Building 987 site location. USACE & Bristol personnel will identify the monitoring well AP-3462 location prior to replacement.
The monitoring well will be constructed of Schedule 40 PVC casing & have a 15-foot section of screened casing across the water table (5 feet above groundwater to 10 feet below groundwater). The screened section of casing will have a No. 10-slot slot intake with a No. 20-40 silica sand pack. The sand will be added to the annular space surrounding the screened section using a tremie pipe, & will extend from the bottom of the screen to approximately two feet above the top of the screened section. The annular seal above the sand pack will be composed bentonite pellets that will be poured using a tremie pipe, & will extend from the top of the sand to approximately five feet above the sand pack. The upper seal will be a concrete grout that will be pumped into the annular space. The well monument boxes will be stick-ups, extending approximately three feet above the ground surface.
Three soil samples from the boring (excluding QC samples) will be collected & submitted
for laboratory analysis of GRO/BTEX, DRO, RRO, 1,2-dibromoethane (EDB), & 1,2- dichloroethane (1,2-DCA). If it appears that the fuel hydrocarbons may have migrated to the water table, soil samples will be collected at & below the water table to assess if the source extends into the zone of seasonal water table fluctuation. In addition, a total of two soil samples from the locations having the highest indication of contamination will be analyzed for EPH, VPH, & PAH. An additional two samples will be collected from locations with no indication of contamination but representative of the soil conditions in the contaminated zones, & will be analyzed for TOC. Up to 2 samples, including at least 1 from the saturated zone, will be collected & analyzed to assess the PSD, moisture content, & bulk density. Equipment blank samples will not be collected as part of the sampling program.
A groundwater sample will be collected using a low-flow sampling technique after well development. Groundwater collection methods are detailed in the SAP, located in Appendix A. The groundwater sample will be submitted to the project laboratory & analyzed for GRO/BTEX, EDB, 1,2-DCA, DRO, RRO, PAH, EPH, & VPH. QC & MS/MSD samples may be collected on a per sample delivery group basis & not necessarily on a per site basis. It is expected that all groundwater sampling will be conducted after all groundwater monitoring wells have been installed at all of the sites.
Three additional soil borings will be advanced & sampled at Building 987. Soil boring
locations will be determined in the field by USACE & Bristol personnel. The borings will
be drilled to a depth of 100 feet bgs. The soil borings will be advanced at each of the
following locations:
- Area of the ASTs;
- Fuel pump house, truck stand, & valve station area;
- Fuel pipeline trench.
Three soil samples from each boring (excluding QC samples) will be collected & submitted
for laboratory analysis of GRO/BTEX, EDB, 1,2-DCA, DRO, & RRO (total of 9 samples). In addition, a total of 3 soil samples from any location within the 3 borings having the highest
indication of contamination will be analyzed for EPH, VPH, & PAH. An additional 3 samples from any location within the 3 borings, with no indication of contamination but representative of the soil conditions in the contaminated zones, will be collected & analyzed for TOC. Up to 3 samples, including at least 1 from the saturated zone, will be collected & analyzed to assess the PSD, moisture content, & bulk density. |
Louis Howard |
| 5/19/2011 |
Update or Other Action |
Wing Instruction 32-7003 dated May 19, 2011 Land Use Control Management. OPR: 673 CES/CEANR Certified by: 673 CEG/CC (Col Russell R. Hula). This instruction implements AFPD 32-70, Environmental Quality, & is used in conjunction with AFIs 32-7020, The ERP, 32-7066, Environmental Baseline Surveys in Real Estate Transactions, & 673ABWI 32-1007, Safeguarding Utilities From Damage. It prescribes the processes & responsibilities for the management of & compliance with land use controls on Joint Base Elmendorf-Richardson (JBER) & applies to all military & civilian organizations that occupy facilities, or conduct business, on the installation. This publication does not apply to the USAF Reserve or Air NG units & members. The current land use control areas can be found on the Environmental Restoration map located on the GeoBase webpage.
General:
1.1. Land use controls (LUC), such as limitations on access, water use, excavations, & property transfers, will supplement engineering controls as appropriate for short-term & long-term mgt to prevent or limit human & environmental exposure to hazardous substances, pollutants, or contaminants.
Examples include limitations on the depth & location of excavations, prohibition of or restrictions on well drilling & use of GW, mgt. of excavated soils, & prohibition of certain land uses. LUCs, often used interchangeably with (ICs), are administrative, procedural, engineering, & regulatory measures to control human access to & use of property.
1.2. LUCs were established at JBER to prevent exposure to contaminated soil & water, based on agreements between the military services & the EPA & the ADEC. LUCs are used to reduce the potential for exposure to hazardous substances or to enhance the protectiveness of a soil &/or water cleanup remedy. They include restrictions on the use of portions of the shallow aquifer south of the Elmendorf Moraine, limitations on the types of buildings allowed in certain areas – primarily occupancy limitations, & land use designations for certain areas as recreational use only.
The LUCs have been implemented at several sites & operable units (OU) as part of the ERP. LUCs were established for DP98 & OUs 1, 2, 4, 5, & 6 on former Elmendorf AFB property in their respective records of decision (ROD), as a component of the selected cleanup remedy. LUCs were also established for restoration & compliance sites formerly part of Fort Richardson in their respective RODs or Decision Documents. LUCs must be in place as long as a property is not available for UU or UE & may include temporary or permanent restrictions or requirements. When all cleanup goals have been achieved for a given site, temporary controls, such as GW use restrictions, may be removed.
2. Responsibilities:
2.1. JBER personnel, tenants, or contractors whose projects or activities require excavation in areas where site-specific LUCs are in effect will comply with all LUCs, 673ABWI 32-1007, & applicable AF instructions. Base contractors & tenant organizations will have LUC compliance requirements incorporated into their contracts & interagency agreements, as will be necessary. Failure to comply with LUCs will be grounds for penalty, in accordance with provisions specified in applicable contract documents. At project completion, the JBER organization or contractor will sign a certification of LUC compliance & return the compliance statement to 673 CES/CEANR.
2.2. The 673d Civil Engineer Squadron (673 CES):
2.2.1. Asset Management Flight (673 CES/CEA):
2.2.1.1. Natural Resources Management (673 CES/CEAN):
2.2.1.1.1. Environmental Restoration (673 CES/CEANR):
2.2.1.1.1.1. Will provide GW & site-specific LUC requirements throughout the installation & identify any known soil contaminated sites & monitoring wells for the area of the proposed project.
2.2.1.1.1.2. Will conduct annual site visits to ensure compliance with LUCs during project implementation.
2.2.1.1.1.3. Will conduct 5-year reviews, at 5-year intervals, or as required by any subsequent RODs.
2.2.1.1.1.4. Will prepare annual LUC compliance reports & submit reports to ADEC & USEPA by 1 February each year.
2.2.1.1.1.5. Will disseminate LUC information to personnel involved in LUC mgt, including real property & 673 CES/CEPT for inclusion into GeoBase.
2.2.1.1.1.6. Will operate an active educational program that includes disseminating updated fact sheets & LUC information, providing notices through the installation intranet & the Arctic Warrior newspaper, & by briefing LUC mgt at project kick-off meetings; Environmental, Safety & Occupational Health Council meetings, & CEB meetings.
2.2.1.1.1.7. Will coordinate any changes in the base general plan (BGP), or real estate transactions, with USEPA & ADEC.
2.2.1.1.1.8. Will maintain copies of signed certificates of compliance, indicating requestor’s adherence to LUCs during project execution.
See site file for additional information.
|
Louis Howard |
| 5/20/2011 |
Document, Report, or Work plan Review - other |
The text states If it appears that the fuel hydrocarbons may have migrated to the water table, some of the soil samples will be collected at and below the water table to assess if the source extends into the zone of seasonal water table fluctuation. ADEC requests the Army collect soil samples from within the first six inches of the vadose zone above the zone of seasonal water table fluctuation. There is no regulatory requirement to collect soil samples from below the water table.
If there are not any indications from field screening for areas with the highest contamination, then ADEC recommends the Army take the five samples from areas based on visual observation, best professional judgment by the field sampler for analysis of GRO, DRO, RRO, BTEX and PAH. There are no ADEC regulatory cleanup levels for EPH or VPH.
The text states In addition, within the 4 site borings, a total of 5 samples from any location with no indication of contamination but representative of the soil conditions in the contaminated zones, will be collected and analyzed for total organic carbon (TOC). ADEC requests clarification on what the purpose of collect TOC data if the excavated soil will be sent off site for thermal treatment. TOC data cannot be taken from the contaminated site (i.e. the former excavation of the UST) using the same site borings for obtaining samples from contaminated soil. ADEC has specific guidelines for TOC collection (see ADEC Technical Memorandum 08-002 dated September 30, 2008). Please refer to and comply with all the requirements of the memorandum if TOC data collection is still something the Army wishes to pursue for this project.
|
Louis Howard |
| 5/20/2011 |
Document, Report, or Work plan Review - other |
Staff reviewed and commented on the UST CORRECTIVE ACTIONS HOT TANKS Fort Richardson, Alaska Contract No. W911KB-10-C-0029 WORK PLAN DRAFT MARCH 2011 JBER-Ft. Richardson.
The text states If it appears that the fuel hydrocarbons may have migrated to the water table, some of the soil samples will be collected at and below the water table to assess if the source extends into the zone of seasonal water table fluctuation. ADEC requests the Army collect soil samples from within the first six inches of the vadose zone above the zone of seasonal water table fluctuation. There is no regulatory requirement to collect soil samples from below the water table.
If there are not any indications from field screening for areas with the highest contamination, then ADEC recommends the Army take the five samples from areas based on visual observation, best professional judgment by the field sampler for analysis of GRO, DRO, RRO, BTEX and PAH. There are no ADEC regulatory cleanup levels for EPH or VPH.
The text states In addition, within the 4 site borings, a total of 5 samples from any location with no indication of contamination but representative of the soil conditions in the contaminated zones, will be collected and analyzed for total organic carbon (TOC). ADEC requests clarification on what the purpose of collect TOC data if the excavated soil will be sent off site for thermal treatment. TOC data cannot be taken from the contaminated site (i.e. the former excavation of the UST) using the same site borings for obtaining samples from contaminated soil. ADEC has specific guidelines for TOC collection (see ADEC Technical Memorandum 08-002 dated September 30, 2008). Please refer to and comply with all the requirements of the memorandum if TOC data collection is still something the Army wishes to pursue for this project.
A-4 2.3 ADEC will require the Army to collect and preserve AK101 and VOC soil samples as follows:
• Collect a minimum of 25 grams of soil with minimum disturbance directly into tared 4-oz or larger jar with a Teflon® -lined septum fused to the lid. Interim storage/containers (e.g. re-sealable polyethylene bags) are not allowed.
• Immediately after collection, carefully add 25-mL aliquot of methanol (methanol must include a surrogate for method AK101) until the sample is submerged.
This step must be completed as quickly as possible, within approximately10 seconds of placing the soil in the sample jar. If an extended time period between soil collection and preservation is necessary due to site conditions or safety concerns, this must be specified in an approved work plan, recorded in the field notes and documented in the final report.
• Do not place tape, including evidence tape, on the sample container directly.
• Cool and retain samples at 4o C + or - 2o C.
• Collect a sample of the same material from the same location in an unpreserved
jar for percent moisture determination.
See comment #5 regarding complying with ADEC Technical Memorandum 08-002 for TOC data collection.
A-5 Table 1 all sites with TOC data collection Each [TOC] sample will need to be analyzed in triplicate using SW-846 Method 9060. All analytical results must be reported to the department. See comment #5 regarding additional requirements for complying with ADEC Technical Memorandum 08-002 on TOC data collection.
A-7 Table 1 all sites with DCA and EDB analysis EDB soil samples should be field preserved in hexane. EPA 8260 will quantify EDB in ground water; however, the detection limits do not meet the Table C cleanup level of 0.00005 mg/L (ADEC Draft Field Sampling Guidance May 2010).
|
Louis Howard |
| 7/15/2011 |
Update or Other Action |
Staff received the Draft Work Plan Environmental RA-O & LTM & Maintenance Joint Base Elmendorf-Richardson, Alaska. The JBER-Richardson Installation Restoration Program (IRP) sites include Building 28008, Former Building 987, Building 59000, the Biathlon Range, Former Building 762, & Building 786. These are petroleum-contaminated sites within a long-term monitoring program under a two-party agreement between the U.S. Army & ADEC. The & LTM for the JBER Richardson Multiple IRP sites includes GW sample collection & analysis at six sites, replacement of damaged wells at three sites (& associated soil sample collection), installation of new wells at one site, maintenance of existing monitoring wells, & monitoring & maintenance of product collection devices at two sites.
GW monitoring at the Former Building 987 site is conducted on an annual basis to document current GW conditions & evaluate trends in fuel-related constituents. Soil contamination at Former Building 987 has been under investigation since 1990, when a 300-gallon UST was removed from the north side of the building.
The UST had functioned as a “slop tank” for three 250,000-gallon aboveground storage tanks (ASTs). One of the ASTs contained automotive gasoline, while the other two contained diesel fuel. Contaminated soil encountered during the 1990 excavation, during removal of the UST, indicated that the tank had been leaking. After the removal, the excavation was backfilled with clean soil. In 1991, a site investigation determined that petroleum hydrocarbons were present in site soils, & a follow-up investigation in 1993 indicated that GW had also been contaminated by the release.
After the discovery of fuel in the GW at Former Building 987, several other investigations & active remediation followed. In 1996, a soil vapor extraction (SVE) system was installed to remove volatile components from vadose zone soil at the site. The system consisted of two SVE wells, a blower, & piping; & it ran for 1 year, removing more than 2,250 pounds of petroleum hydrocarbons. After 1 year of operation, removal rates diminished, & the system was shut down in August 1998.
In 1999, the ASTs, pump house, truck fill stand, & 1,560 feet of associated underground pipeline were removed from the site, & the entire fenced area was paved & converted to a parking lot/vehicle storage area. All the original monitoring wells located in the vicinity of the Former Building 987 source area were decommissioned during these paving activities.
Field activities for the six JBER-Richardson sites include passive free product skimmer monitoring & maintenance (Building 59000 & Building 28008), GW sampling (all sites), soil sampling (during well installation at Building 987, Building 59000, the Biathlon Range, & Building 786), well installation & decommissioning (installation only at the Biathlon Range, installation & decommissioning at Building 987, Building 59000, & Building 786), & monitoring well maintenance (all sites).
With the exception of the monthly maintenance of product skimmers at Building 59000 & Building 28008, all field activities for these sites are currently scheduled to be conducted in the fall (August–September) timeframe. The contractor will coordinate with Base Operations for access to the Building 28008, Building 59000, & Biathlon Range sites (which require special clearance) to eliminate unnecessary delays or interruptions to military operations.
GW monitoring wells will be sampled for the following analyses & methods:
-GRO by AK101 (AP-3462, AP-4343, AP-4372)
-DRO by AK102 (AP-3460, AP-3462 [replacement], AP-4343, AP-4372)
-BTEX by SW8260B(AP-3460, AP-3462 [replacement], AP-4343, AP-4372)
-SVOCs by SW8270C (AP-3462 replacement)
-1,2-DCA by EPA 8260C (AP-3462 replacement)
Soil samples will be collected from borings during installation of replacement wells at Former Buildings 786 & 987; Building 59000; & installation of new wells at the Biathlon Range. Samples will be collected with a split spoon sampler & sample intervals will be based on professional judgment or other determining factors such as changes in soil conditions, high PID readings or target GW zones. Sample collection will be conducted using decontaminated or disposable sampling equipment.
Wells will be replaced (including the decommissioning of the existing well & installation of a new well in close proximity) at Former buildings 786 & 987 & Building 59000. The wells to be replaced include AP-5009 at Building 786, AP-3462 at Building 987, & AP-4526 at Building 59000. Replacement wells will be installed a minimum of 16 feet from the decommissioned well to avoid impacts from grouting. |
Louis Howard |
| 7/21/2011 |
Update or Other Action |
Draft Fall 2010 GW Monitoring Report received.
Groundwater at the Former Building 987 site at Joint Base Elmendorf-Richardson (JBER)-
Richardson (Formerly Fort Richardson), Alaska, is being monitored to verify that fuelrelated
dissolved-phase constituents remain below Alaska Department of Environmental
Conservation (ADEC) cleanup levels specified in Table C of Title 18, Chapter 75, Section 345
(Oil and Hazardous Substances Control) of the Alaska Administrative Code (18 AAC 75.345).
Groundwater contamination at the site is a result of leaks in former fuel tanks associated
with Former Building 987.
Monitoring during in December 2010 involved sampling of two wells (AP-3460 and AP-
4372) for diesel-range organics (DRO) and benzene, toluene, ethylbenzene, and xylenes
(BTEX). Well AP-4343 could not be sampled during this event because the well casing was
broken, and Well AP-3462 was not sampled because a bent overcasing and a frozen bag of
feces in the well casing prevented access to the well.
Results of the December 2010 monitoring indicate that DRO and BTEX constituents remain
below ADEC cleanup levels at all sampled locations. Neither DRO nor BTEX constituents
were detected in the 2010 samples. Available historic data indicate that concentrations of
DRO and BTEX have never exceeded ADEC cleanup levels. The historic data in combination
with the site being paved, preventing potential migration of soil contaminants by infiltration
of precipitation, indicate that the Former Building 987 site should be considered for
conditional closure.
Conclusions
On the basis of available historic groundwater sampling results and the analytical data from
the December 2010 event, the following conclusions can be drawn:
• Petroleum constituents have not been detected in groundwater at the Building 987 site at
concentrations exceeding ADEC cleanup levels.
• The site is paved, reducing potential migration of contaminants through infiltration of
precipitation and meltwater.
• Two wells, AP-3462 and AP-4343, cannot be sampled due to damage. AP-3462 has not been sampled since 2005.
• Benzene has not been detected in any of the wells at the Building 987 site.
• DRO has not been detected since 2007. DRO has been present historically at low concentrations and has not exceeded the 1,500 µg/L ADEC cleanup level.
• Toluene, ethylbenzene, and xylenes have not been detected at the Building 987 site at
concentrations above ADEC cleanup levels. Although low concentrations were detected for the first time (at concentrations below 1 µg/L) in 2007, the contamination may be attributed to inadequate decontamination of equipment between wells.
• The groundwater flow direction could not be calculated because depth-to-water measurements could only be obtained in two of the monitoring wells.
• Because petroleum constituents have not been detected in groundwater at the Building 987 site at concentrations exceeding ADEC cleanup levels, and there are supporting historical data, the Building 987 site should be considered for conditional closure. |
Louis Howard |
| 8/1/2011 |
Document, Report, or Work plan Review - other |
Staff provided comments on the Fall 2010 Groundwater Monitoring Report JBER-Richardson Bldg. 987, May 2011.
ES-1 Executive Summary: ADEC disagrees with the recommendations to have the Former Building 987 site considered for conditional closure (or as it is now referred to as “Cleanup Complete with Institutional Controls”). Groundwater monitoring was conducted at two monitoring wells with no indication that EDB or 1,2 DCA were sampled as required by the May 17, 2010 comment letter to the Army.
ADEC’s comments still are applicable as stated in the May 17, 2010 letter.
Before a cleanup complete with ICs will be considered, ADEC will require a minimum of three (3) soil borings be installed in the areas where historic high petroleum contamination was detected in the soil from the AST demolition and pipeline removal in 1999. A minimum of three (3) soil samples per boring will be required and each sample analyzed for: DRO, GRO, PAHs, BTEX. Previous sampling results, before the area was subsequently paved over for vehicle storage, are as follows: 1. ASTs area 10,500 mg/kg DRO, 2. Fuel Pump house, truck stand and valve station area: 16,300 mg/kg DRO and 3. Fuel Pipeline trench area 9,950 mg/kg DRO, 7,280 mg/kg GRO, 2,998 mg/kg total BTEX (114 mg/kg which was benzene). Samples will be taken at the soil/groundwater interface, area of highest historical contamination and area of highest field screening results during boring installation.
In addition to soil sampling, ADEC is also requesting JBER provide information in the closure document that it has sampled for ethylene dibromide (EDB) and 1,2-Dichloroethane (1,2 DCA) at Building 987 in the soil and groundwater. For releases where leaded gasoline (i.e. MOGAS) or aviation gasoline (i.e. AVGAS) are suspected contaminants of concern, ADEC requires analysis for EDB and 1,2-DCA. EPA 8260 is required for the analysis of 1,2-DCA. EPA 8011 or EPA 504.1 should be used when evaluating ethylene dibromide (EDB). EDB soil samples should be field preserved in hexane. EPA 8260 will quantify EDB in ground water; however, the detection limits do not meet the Table C cleanup level of 0.00005 mg/L.
Fuel was likely released via incidental spills occurring during historical system operation, and from disposal of "waste" fuel that was generated in former Building 987 during system maintenance. Waste fuel is suspected to have been placed in a former dry well that was installed when the system was built in the mid-1950s (USACE, 1994). In the mid-1970s, a 300-gallon underground "slop tank" was installed for disposal of the waste fuel. The UST functioned as a "slop tank" for three 250,000-gallon aboveground fuel storage tanks (ASTs). One of these ASTs (Tank No. 58) contained automotive gasoline (MOGAS). The slop tank is suspected to have leaked waste fuel, based on observations made during removal of the tank in 1989.
5-1 5: See comment #1 above regarding requirements for sampling and lab methods prior to consideration of a “cleanup complete with ICs” decision by ADEC.
|
Louis Howard |
| 8/12/2011 |
Update or Other Action |
FA8903-09-R-9999-R149 Draft Statemen of Objectives for Performance Based Remediation August 12, 2011
CC-FTRS-02 – Building 987 UST/AST Site
Minimum Performance Standards: Air Force approval through the COR and Regulator approval (e.g., written confirmation of acceptance of Characterization Report) of the Characterization Report.
|
Louis Howard |
| 4/26/2012 |
Update or Other Action |
Revision no. 2 for Corrective Actions HOT Tanks received.
Monitoring well (AP-3462) at Building 987 will be replaced due to damage to the existing
well. The new monitoring well will be located approximately 15 feet from the original well.
The boring will be drilled to a depth of 10 feet into groundwater (approximately 140 feet bgs).
Figure 4 shows the Building 987 site location. USACE and Bristol personnel will identify the
monitoring well AP-3462 location prior to replacement. The monitoring well will be constructed of Schedule 40 PVC casing and have a 15-foot section of screened casing across the water table (5 feet above groundwater to 10 feet below groundwater).
Three soil samples from the boring (excluding QC samples) will be collected and submitted
for laboratory analysis of GRO/BTEX, DRO, RRO, 1,2-Dibromoethane (EDB), and
1,2-Dichloroethane (1,2-DCA). Most of the soil samples submitted for hydrocarbon
concentration analysis will be from the NAPL-contaminated soil source zone—to facilitate
HRC calculations, the goal is to have a total of at least 10 soil boring samples from the
NAPL-contaminated soil source zone. In addition, a total of two soil samples with the highest
indication of contamination will be analyzed for EPH, VPH, and PAH.
If it appears that the fuel hydrocarbons have migrated to the water table, some of the soil samples will be collected at and below the water table to assess if the source extends into the zone of seasonal water table fluctuation. Soil sampling below the water table will allow the vertical extent of the source to be identified as required by the regulations. Soil samples collected below the water table that are thought to be from the NAPL source zone will be analyzed for hydrocarbon concentrations (BTEX, GRO, DRO, RRO, and potentially PAH, VPH, and EPH).
In addition, within the boring, a total of two samples from any location with no indication of
contamination, but representative of the soil conditions in the contaminated zones, will be
collected and analyzed for TOC. One of the soil samples collected in the saturated zone
below the NAPL source zone may be analyzed for TOC (DRO analysis may be used to
confirm that the TOC result is not due to hydrocarbons) to enable better retardation and half life calculations. Lastly, up to two geotechnical samples will be collected at each site,
including approximately two from the saturated zone, and analyzed to assess the PSD,
moisture content, and bulk density.
A groundwater sample will be collected using a low-flow sampling technique after well development. Groundwater collection methods are detailed in the SAP, located in Appendix B. The groundwater sample will be submitted to the project laboratory and analyzed for GRO/BTEX, EDB, 1,2-DCA, DRO, RRO, PAH, EPH, and VPH. QC and MS/MSD samples may be collected on a per sample delivery group basis and not necessarily on a per site basis. It is expected that all groundwater sampling will be conducted after all groundwater monitoring wells have been installed at all of the sites.
|
Louis Howard |
| 5/16/2012 |
Document, Report, or Work plan Review - other |
Draft Work Plan UST Corrective Actions HOT TANKS JBER-Richardson, AK dated March 2012 Revision 2 Contract No. W911KB-10-C-0029
The Alaska Department of Environmental Conservation (ADEC) Contaminated Sites Program staff has received the above document for review and comment on May 13, 2011. ADEC approves the work plan revisions for the Army Reserve Center (ARC) Tanks E1, E2, E5, E7, Building 57-428 Tank, Building 987, Biathlon Range. Any work at the Fort Richardson Landfill site will need to be coordinated with ADEC’s Solid Waste Program staff and CS Program approval of the work plan is not applicable to the Fort Richardson Landfill
|
Louis Howard |
| 5/31/2012 |
Update or Other Action |
Draft PMP received which includes work at CC-FTRS-02 Building 987 UST/AST Site (CRP). Performance Objective is response complete.
Performance Indicators:
· Continue routine annual LTM and site inspections according to existing plan
· Complete an approved Characterization/Cleanup Plan by May 2013
· Coordinate, mobilize, and execute characterization/cleanup by June 2013
· Complete an approved Characterization/Cleanup Report by December 2013
· Achieve RC in 2014
· Complete an approved OES Plan in 2014
· Complete annual site inspections, LUC reports, OES Implementation Completion Plan, and OES Confirmation Report
Date of Achieving Performance Objective: 1st Quarter FY 2013.
Planned Approach
Prepare an approved Characterization Work Plan and coordinate, mobilize, and execute
characterization by installing and sampling three soil borings and replace one existing monitoring well (AP-3462). Use HRC to evaluate SC based on risk to future residential receptors for all pathways.
Prepare an approved Site Characterization Report with an updated CSM, documented HRC risk
evaluation, and include the Cleanup Plan and prepare and submit a request for Cleanup Complete with ICs.
Prepare an approved OES Plan and implement actions.
Receive concurrence from ADEC that site has achieved Cleanup Complete with ICs and provide documentation to AFCEE.
Projected Closeout: 1st Quarter FY2013. |
Louis Howard |
| 6/22/2012 |
Document, Report, or Work plan Review - other |
Staff provided comments on the draft PMP.
2.3
Page 2-31
The text states: “The WPs will be submitted in the initial phases of the project for Air Force and regulatory review and concurrence according to the schedule outlined in the IMS. If regulatory agencies elect not to review/approve documents, approval will be sought through the Secretary of the Air Force/Installations and Environment (SAF/IE) to proceed with execution of the plan activities. The WESTON Team understands that a procedure has been established for this situation, and that the Air Force controls this process.”
Failure to obtain work plan approval before implementing site work described above is considered a violation of Alaska regulations and may result in field work not being approved or additional work being required and may subject responsible parties and/or contractors to a Notice of Violation (NOV).
7.1.2 Document Preparation and Version Control
Draft and Draft Final Versions of documents
For petroleum sites (aka Two Party sites) overseen by ADEC refer to the following:
ADEC will strive to complete plan reviews and respond to JBER within thirty (30) days after receipt of plans, although this is not always possible nor is it a requirement. At times, JBER requested expedited plan reviews are feasible based on project manager work load, adequate up-front planning, and contractors providing complete, well written plans.
However, if significant work plan revisions are required, additional review and comment resolution time will be needed. To facilitate successful project implementation, it is recommended that DoD project managers and contracting staff:
•Coordinate schedules with ADEC in advance and throughout projects.
•Include ADEC in project planning meetings (DQO meetings, UFP QAPP development meetings, Triad and other Technical Project Planning team meetings, etc.).
• Plan and maintain project schedules that include a minimum of forty-five (45) days for reviewing draft work plans, comment resolution, any necessary revisions to the draft-final version and a final review and approval.
See also the Fort Richardson 1994 Environmental Restoration Agreement “Review and Comment on Documents” which states at Section 9. “All draft final work plans for field work, site assessments or remedial actions (both interim and final) must be submitted to ADEC a minimum of 45 days prior to the start of field work or construction. Site Assessment and Remedial Action draft reports must be submitted to ADEC within 120 days after completion of field work.”
• Review contractor planning documents prior to submission to ADEC to ensure compliance with state and federal regulations consistency with agreements made during project planning meetings.
Independent QA Oversight on Performance Based Contracts
The site cleanup rules require that “collection, interpretation, and reporting of data, and the required sampling and analysis is conducted or supervised by a qualified, impartial third party”. Depending upon the specific terms in a performance based contract, a contractor may no longer be considered an impartial third party with respect to collecting, interpreting and reporting data.
This should be taken into consideration when preparing scopes of work. ADEC strongly recommends the Air Force provide an on-site Quality Assurance Representative or a third party QA oversight contractor to monitor fieldwork for consistency with approved plans and contract requirements.
7.2.1 UFP-QAPP Requirements (Planning)
Any existing approved UFP-QAPPs will be updated to reflect current regulations and guidance that have been updated since they were approved.
Page 7-6
The text states: “Our Technical Site Managers and Project Chemists will ensure that, prior to sampling activities, full service analytical laboratories to be used are, at a minimum, DoD ELAP accredited and in good standing based on standard business information sources (e.g., Dunn & Bradstreet). In addition to DoD ELAP, the Project Chemist will also ensure that the supporting laboratories are approved for work in the State of Alaska, when required. Analytical methods used will be Alaska and EPA standard methods, unless technically impractical.”
ADEC disagrees. The full service analytical laboratories have to be both DoD-ELAP accredited AND Alaska approved. Any non-EPA and/or Alaska methods must be approved by the department prior to sample collection.
|
Louis Howard |
| 7/25/2012 |
Update or Other Action |
Draft 2011 GW Monitoring & Borehole Sampling report received for TPA 28008, 59000, former blgs. 987, 762, 786 on JBER-Richardson.
The following presents deviations from the Work Plan and the reasoning behind the deviation.
- GRO results are not available for replacement well AP-5681 (AP-3462R) because the analysis was not designated on the COC, even though samples were provided to the lab and the lab was notified to add GRO analysis.
Based on the objectives of this project and review of soil and groundwater analytical data from the 2011 activities, the following conclusions can be drawn:
- Based on installation and sampling of three soil borings, AP- 5686 (SB1) Former Tank 57, AP-5687 (SB2) Former Truck/Fill Stand, and AP-5688 (SB3) Former Building 987 Pump House to support site closure with institutional controls and replacement of monitoring well AP-3462.
- GRO, DRO, and BTEX concentrations exceeding ADEC soil cleanup criteria are present at the 43 to 48 feet depth and GRO and DRO at the 118-to-119-foot-depth near the former Building 987 Pump House and DRO at the 13-to- 18-foot-depth at AP-5681 (AP-3462R).
- EDB and 1,2-DCA were not detected in any soil samples.
- Low levels of lead were detected in soil samples, but at concentrations less than the 400 mg/kg ADEC cleanup level for direct contact.
- Detected concentrations of PAHs in soil were less than ADEC soil cleanup criteria.
Historical data and the 2011 annual groundwater monitoring results from three wells show the following:
- AP-4343 was not sampled because the riser is broken off near ground surface. The damage appears to be due to soil frost heave.
- Petroleum constituents have not been detected in groundwater at the Building 987 site at concentrations exceeding ADEC cleanup levels.
- Benzene has not been detected in groundwater from any of the wells at the Building 987 site.
-DRO has not been detected in groundwater since 2007. DRO has been present historically at low concentrations and has not exceeded the 1,500 µg/L ADEC cleanup level.
- Toluene, ethylbenzene, and xylenes have not been detected in groundwater from any of the wells at the Building 987 site at concentrations above ADEC cleanup levels. Although low concentrations were detected for the first time (at concentrations below 1 µg/L) during 2007, the contamination may be attributed to inadequate decontamination of equipment between wells.
- The site is paved, reducing potential migration of contaminants to the groundwater through infiltration of precipitation and meltwater.
- The groundwater flow direction could not be calculated because depth to water measurements could only be obtained in two of the monitoring wells during the water level survey.
Based on the LUC inspection, the Building 987 site has LUCs in place restricting soil excavation and transport offsite and use of groundwater at the site is prohibited. Based on the site inspection of LUCs and the Base Civil Engineer Work Clearance Request process JBER-Richardson has in place to perform any intrusive activities at the site, the LUCs appear to be protective and prevent exposure to contaminated soil and groundwater at the site, remain effective, and are being correctly implemented. |
Louis Howard |
| 1/31/2013 |
Update or Other Action |
Draft UFP QAPP WP received.
This Work Plan describes site characterization activities that are proposed to support site closeout in accordance with the Alaska Department of Environmental Conservation (ADEC) cleanup process for petroleum hydrocarbon-contaminated sites. This site-specific Work Plan follows the Uniform Federal Policy-Quality Assurance Project Plan (UFP-QAPP) format and the work will be performed under the Basewide Uniform Federal Policy-Quality Assurance Project Plan (Basewide
UFP-QAPP) (United States Air Force.
This Work Plan proposes follow-up work to the fieldwork conducted in 2011, to address ADEC’s comments on the draft 2011 Groundwater Monitoring and Borehole Sampling, Two Party Agreement Sites: Buildings 28-008 & 5900 and Former Buildings 987, 762 & 786, JBER-Richardson (Two Party Agreement Report) (CH2M HILL, 2012). Following completion of this fieldwork, a request will be made for “cleanup complete with institutional controls [ICs]” to obtain Response Complete (RC). The following specific comments need to be addressed:
(1) Well AP-4343 needs to be either repaired or replaced,
(2) sampling for gasoline-range organics (GRO) needs to be conducted at AP-5681, and
(3) one additional monitoring well is needed to calculate a groundwater flow direction at the site used either with an existing well or an additional well installed at the site.
These three items will need to be addressed before ADEC can support a “cleanup complete with ICs” request.
The work proposed in this UFP-QAPP is intended to address ADEC’s comments to the
Two Party Agreement Report, as follows:
Sampling for GRO needs to be conducted at AP-5681. AP-5681 will be sampled and
groundwater samples will be analyzed for GRO, DRO, and volatile organic compounds
(VOCs), petroleum-related. In addition, groundwater samples will be collected from
monitoring wells AP-3460, AP-3699, and AP-4372 and analyzed for the same
constituents.
One additional monitoring well is needed to calculate a groundwater flow direction
at the site used either with an existing well or an additional well installed at the site.
To determine groundwater flow direction and gradient, water levels will be measured at
eight existing monitoring wells near the site: AP-3463, AP-3474, AP-3649, AP-3652,
AP-3699, AP-4372, AP-3460 (if logistically possible), and AP-5681.
Well AP-4343 needs to be either repaired or replaced. AP-4343 will not be replaced
for the following reasons:
- Five existing wells have been added to the monitoring network (AP-3463, AP-3474, AP-3649, AP-3652, and AP-3699) to more accurately determine the groundwater flow direction at the site
- AP-4372 is in an appropriate location to monitor groundwater downgradient of the source area, based on the current interpretation of the groundwater flow direction. If the groundwater flow direction is revised after additional data is collected, groundwater samples can be collected from well AP-3474, if deemed necessary.
- All historical sampling results at AP-4343 have been below cleanup levels. The well was last sampled in June 2009.
Groundwater samples will be collected using low-flow sampling techniques, as described in
SOP-13. Observations of odor, turbidity, and color will be recorded on the groundwater sample
collection log. Specific laboratory methods, bottle requirements, field preservation requirements, and sample volumes for these analyses are provided in Worksheet #19 of this Work Plan. Quality assurance/quality control (QA/QC) samples will be collected as specified in Worksheet #20. Sample handling will follow the procedures listed in SOP-02. |
Louis Howard |
| 2/22/2013 |
Document, Report, or Work plan Review - other |
Staff reviewed and commented on the draft UFP-QAPP.
General Comments for JBER-E and JBER-R sites
ADEC requests JBER provide the following location information for each site will be provided for in the Executive Summary text:
Please provide latitude and longitude coordinates for the site location in decimal degree format with a precision of six decimal places (dd.dddddd). Also include the following:
1. Date of collection,
2. Method of collection (i.e. GPS, hardcopy map, air photo),
3. Scale of the map used to acquire coordinates (if applicable),
4. Estimated accuracy and associated unit of measure,
5.Reference point for which the coordinates were established (i.e. center of property, entrance gate),
6.Horizontal datum (NAD 1983 is strongly preferred) and
7. Comments for additional information regarding acquistion of coordinates (if necessary).
Site Specific Proposed Work
1st Bullet
JBER shall report all VOCs, not just BTEX detected by the method 8260C. Chlorinated solvents are not expected, however, the complete list of VOC results will be included as an appendix to the draft and final reports. This comment applies to all UPF-QAPP submittals for JBER non-CERCLA (e.g. Two-Party POL) sites.
Conceptual Site Model
Potential Receptors and Exposure Pathways
Last Paragraph
ADEC requests JBER provide information (e.g. location and well construction) on the nearest (within ½ mile of TU102 site) drinking water [Base] well or standby drinking water well that may be used on a temporary, intermittent or permanent basis. This comment applies to all future UFP-QAPPs submitted by JBER for review by ADEC.
The text states: “To receive an “unrestricted use” or “cleanup complete without ICs” designation, the site must meet the ADEC risk standard (that is, the excess carcinogenic risk cannot exceed 10-5 and the excess non-carcinogenic risk cannot exceed 1 under a residential land use scenario).”
It is ADEC’s position that ICs would be applied at JBER sites when:
• The groundwater under or downgradient of a site was contaminated with POL constituents at concentrations exceeding risk criteria or MCLs; or
• POL contaminants in the soil were above the maximum allowable contaminant concentration [MAC] given in Table B2 of 18 AAC 75 or at concentrations exceeding risk criteria.
• ICs also needed if direct contact or inhalation risks exceed residential land use risk-based levels. Sites should be suitable for UU/UL for cleanup complete without ICs (June 14, 2012 meeting minutes “Use of Hydrocarbon Risk Calculator” with AFCEE, JBER, PBC and ADEC).
If soil that was above the MAC were excavated, the excavation confirmation sample concentrations could be used to replace the higher concentration in the removed soil and the statistics for the site could be rerun. The ProUCL checks for outliers and the Q-Q plot should be submitted with the 95% UCL calculations.
Vadose zone soils shall not exceed MAC for petroleum contamination for soil from 0 – 15’ bgs (i.e. direct contact for BTEX, PAHs and ingestion for DRO, GRO, RRO) regardless of HRC calculated risk levels. Treatment or excavations deeper than 15’ bgs may be warranted on a site-specific basis to prevent the soil from acting as a continuing source of GW contamination.
In addition, sites with existing GW contamination above Table C cleanup levels will require that migration to GW cleanup levels be used for soil and ICs will be required. Once GW is below Table C for a period of time (per the latest approved “Basewide Monitoring Program Well Sampling Frequency Decision Guide (Attachment 1 Memo to the Site File for OUs 4, 5, and 6 September 2003)” two rounds annual GW monitoring), the MAC may become the cleanup levels as determined by ADEC on a case by case basis.
Project Action Limits and Laboratory-Specific Detection/Quantitation Limits
ADEC requests JBER provide the analytical methods, target analyte list, the site-specific screening or cleanup levels that will be used, and the laboratory that will be used for the project. If there is a different lab (than the one referenced in the final Basewide UFP-QAPP), or new and/or modified procedures used for the specific site, appropriate lab reference limits will be provided in the site-specific UFP-QAPP. This was agreed by all parties at the February 6, 2013 EPA meeting.
See comment #3 regarding reporting of all VOCs detected and not just BTEX. |
Louis Howard |
| 4/30/2013 |
Update or Other Action |
Draft Annual Monitoring Report received for review and comment.
Historical sampling results for TU102 have indicated fuel constituents present in groundwater above State cleanup levels in 18 AAC 75 Table C and fuel constituents in soil above 18 AAC 75 Tables B1 and B2. DRO, GRO, and benzene have historically been detected at concentrations exceeding the cleanup criteria for groundwater at well AP-3235, but have not been detected above cleanup levels since 1994. Long-term biennial monitoring of the groundwater is performed at the site.
Groundwater monitoring wells at TU102 were not sampled in 2012; sampling was performed in 2011 and is next scheduled for 2013.
Fieldwork will be conducted in 2013 to address ADEC’s comments on the draft 2011 Groundwater Monitoring and Borehole Sampling, Two Party Agreement Sites: Buildings 28-008 & 5900 and Former Buildings 987, 762 & 786, JBER-Richardson (Two Party Agreement Report) (CH2M HILL, 2012). The following specific comments need to be addressed: (1) Well AP-4343 needs to be either repaired or replaced, (2) sampling for GRO needs to be conducted at AP-5681, and (3) one additional monitoring well is needed to calculate a groundwater flow direction at the site used either with an existing well or an additional well installed at the site. These three items will need to be addressed before ADEC can support a “cleanup complete with ICs” request. |
Louis Howard |
| 5/17/2013 |
Update or Other Action |
ADEC has received the final version of the UFP-QAPP SC Work Plan for TU102 Bldg. 987 (ADEC CS DB Hazard ID 931) on JBER-Richardson on May 6, 2013. ADEC has reviewed the document and has no further comments on it. The document is approved |
Louis Howard |
| 3/13/2014 |
Update or Other Action |
Draft 2013 Annual report received for review and comment. The overall project objectives included collecting sufficient data to:
• Monitor concentrations of contaminants of concern (COCs) at each site with sufficient precision and accuracy to evaluate their concentrations with respect to cleanup goals.
• Identify potentially toxic and/or mobile transformation products.
• Verify individual plume characteristics, such as downgradient, lateral, or vertical expansion or retraction.
• Evaluate groundwater flow directions and hydraulic gradients to monitor plume migration and assess contaminant sources.
• Evaluate the effectiveness of land use controls/ institutional controls (LUCs/ICs) to protect human health and the environment.
• Identify and repair damaged monitoring wells to protect groundwater.
• Identify monitoring wells that are no longer needed or are damaged beyond repair.
In August 2013, four groundwater monitoring wells at Building 987 were sampled for DRO, GRO, RRO, and petroleum-related VOCs. No detections were reported above cleanup levels.
No compounds have been detected in groundwater above Table C cleanup levels since 2004; however, 2011 data indicates that residual petroleum hydrocarbons remain in soil above ADEC’s Table B1 and B2 cleanup levels at the site. Since the 2013 groundwater monitoring event satisfied ADEC’s recent comments on the site as outlined above, it is recommended that the groundwater monitoring program at TU102 is ceased and the site is designated as having achieved “Cleanup Complete” with institutional controls. |
Louis Howard |
| 3/26/2014 |
Update or Other Action |
Staff provided comments on the draft annual report for several sites including this one.
TU102 Site Summary
The text states: “Since the 2013 groundwater monitoring event satisfied ADEC’s recent comments on the site as outlined above, it is recommended that the groundwater monitoring program at TU102 is ceased and the site is designated as having achieved “Cleanup Complete” with institutional controls.” ADEC concurs and requests a decision document be drafted for review and comment.
|
Louis Howard |
| 5/28/2014 |
Update or Other Action |
Draft Remedial Action Completion Report received for review and comment.
The purpose of this remedial action completion report (RACR) is to summarize the current status
of TU102 – Building 987 UST/AST Site (TU102) and to document concurrence with TU102 being adequately characterized and considered suitable for a “Cleanup Complete with Institutional Controls (ICs)” designation or response complete (RC). Soil vapor extraction (SVE) and an asphalt cap have been implemented as remedial actions at TU102. Diesel-range organics (DRO), gasoline-range organics (GRO), benzene, toluene, ethylbenzene, xylenes, and naphthalene (BTEXN), and polycyclic aromatic hydrocarbons (PAHs) (benzo(a)anthracene, benzo(b)fluoranthene, benzo(a)pyrene, and 2-methylnapthalene) remain in soil above Alaska Department of Environmental Conservation (ADEC) migration to groundwater cleanup levels; and PAHs remain in shallow soil above ADEC direct contact cleanup levels.
No compounds have been detected in groundwater above Table C cleanup levels since 2004, and the 2013 groundwater monitoring event satisfied ADEC’s comments on the 2011 Groundwater Monitoring and Borehole Sampling (CH2M HILL, 2012). ADEC concurs with ceasing the groundwater monitoring program at TU102. The cap and land use controls (LUCs) for soil will remain in place. The United States Air Force (USAF) is managing remediation of contamination at TU102 in accordance with ADEC’s Contaminated Sites cleanup rules (Title 18, Chapter 75 of the Alaska Administrative Code [18 AAC 75], Sections 325 to 390).
The USAF has determined that TU102 is considered suitable for a “Cleanup Complete with ICs”
designation or RC based on the following information:
• The SVE system achieved the objective of reducing contaminant concentrations to a point of
diminished returns and was shut down in August 1998.
• The asphalt cap achieved the objective of preventing dispersal of contaminated surface soil and infiltration of water through the contaminated zone and leaching/spreading of contamination to lower levels.
• Residual petroleum hydrocarbons (DRO, GRO, BTEXN, and PAHs [benzo(a)anthracene, benzo(b)fluoranthene, benzo(a)pyrene, and 2-methylnapthalene]) remain in soil above ADEC’s Table B1 and B2 cleanup levels at the site.
• No compounds have been detected in groundwater above Table C cleanup levels since 2004. It is recommended that the groundwater monitoring program at TU102 is ceased.
• LUCs and the cap will continue to limit the use and/or exposure to soil at the site. LUC inspections are conducted on a biennial basis. The 2013 inspection indicates that ICs are in
place and adequate. |
Louis Howard |
| 6/17/2014 |
Document, Report, or Work plan Review - other |
Staff provided comments on the draft remedial action completion document.
Exposure Pathway Evaluation
Inhalation – outdoor air
ADEC Vapor Intrusion Guidance for Contaminated Sites (October 2012) states for petroleum sources located less than 30' from an occupied building or where a building will be built in the future, must be considered for additional evaluation.
Since in the very next section it is states that concentrations of BTEX exceeding inhalation cleanup levels are found from 43 to 119' bgs, it would be better to state the following: “Concentrations of DRO, GRO, & BTEX in soil at depths from surface to 30' bgs are below inhalation cleanup levels; therefore, the pathway is considered incomplete for current commercial/ industrial & potential future residential land use scenarios.”
Inhalation – indoor air (vapor intrusion)
The text states: “Because concentrations of BTEX exceeding their respective inhalation cleanup levels were detected at depths greater than 15 feet bgs (43 to 119 feet bgs),…”
Restate the text as follows: “Because concentrations of BTEX exceeding their respective inhalation cleanup levels were detected at depths greater than 30 feet bgs (43 to 119 feet bgs),…”
Asphalt Cap
An asphalt cap may reduce infiltration by precipitation but the ADEC 2012 VI Guidance states: “Caps around a building, such as an asphalt driveway or frozen ground, may re-duce volatilization to outdoor air & increase the concentration of contaminants near the building foundation.” However, since the concentrations of contaminants at the site which exceed inhalation values are located below 30’ bgs (43 - 119’ bgs), this increase of contaminants (in the vapor phase) is not likely to occur.
Land Use Controls
Add the following text to the document:
“The USAF ensures compliance with LUCs by conducting periodic monitoring & completing site inspections. Separate controls are in place & enforced by the USAF to prevent inappropriate soil & groundwater exposure at these sites. The USAF currently requires all projects resulting in soil disturbance of greater than four inches below ground surface to follow 3 Wing Instruction 32-1007, Safeguarding Utilities from Damage, dated 20 Aug 10 & 673d Wing Instruction 32-7003, Land Use control Management, dated 19 May 2011.
Both instructions require the proponent to obtain an approved Base Civil Engineer Work Clearance Request (673 WG Form 3) prior to conducting work on the Base. This form is also referred to as a dig permit. If excavation occurs in a LUC area, the USAF requires the submission of a Sampling & Analysis Plan. Results of the analysis are used to determine the correct disposition of soils excavated or water removed from the site.
The Air Force is obligated to inform, monitor, enforce & bind, where appropriate, authorized lessees, tenants, contractors & other authorized occupants of LUCs impacting TU037.
The Base Master Plan will contain a map indicating site location, with restrictions on any invasive activities that could potentially result in exposure of contaminants. The LUCs will be documented in the Air Force Real Property Records, Base Master Plan, Cleanup module of the
Enterprise Environmental, Safety & Occupational Health – Management Information System (EESOH-MIS), & 673d Installation Restoration Program (IRP) Records. This will include: information about current land uses & allowed uses, geographic boundaries of the LUCs, biennial site inspection checklists with photo documentation, & LUC performance report submittals.
The Air Force will notify the ADEC of any violation of the LUCs or any other activity that is inconsistent with the LUCs or LUC objectives, as well as any obstacles to correcting violation. The Air Force must notify the ADEC as soon as practicable, but no longer than 10 days after discovery, of any activity that violates or is inconsistent with the LUC objectives or use restrictions, or any other action that may interfere with the effectiveness of the LUCs. The Air Force must take prompt measures to correct the violation or deficiency & prevent its recurrence. In this notification, the Air Force will identify any corrective measures it has taken or any corrective measures it plans to take & the estimated time frame for completing them. For corrective measures taken after the notification, the Air Force shall notify the ADEC when the measures are complete.
The Air Force will not modify or terminate LUCs or modify land uses that may impact the effectiveness of the LUCs or take any anticipated action that may disrupt the effectiveness of the LUCs or any action that may alter or negate the need for LUCs without seeking & obtaining approval &/or review & comment from the ADEC 45 days prior to the change of any required modification.”
|
Louis Howard |
| 7/14/2014 |
Cleanup Complete Determination Issued |
Staff approved the remedial action completion report for the site. An asphalt cap, groundwater monitoring and LUCs for residual petroleum contamination are in place at the site. DRO, GRO, PAHs and BTEX are the COCs. |
Louis Howard |
| 4/8/2016 |
Institutional Control Record Established |
Institutional Controls established and entered into the database. |
Louis Howard |
| 4/12/2021 |
Document, Report, or Work plan Review - other |
DEC submitted comments on Draft JBER Basewide UFP-QAPP dated February 2021. |
William Schmaltz |
| 5/19/2021 |
Document, Report, or Work plan Review - other |
DEC Reviewed and approved of Basewide Uniform Federal Policy - Quality Assurance Project Plan. QAPP summarizes general activities for a 5 year period on JBER. |
William Schmaltz |
| 2/7/2023 |
Document, Report, or Work plan Review - other |
DEC reviewed the 2023 Letter Work Plan Remedial Action Operations and Long-Term Management, Draft, dated January 2023. The work plan describes the site inspections, maintenance activities, and groundwater, seep, and surface water monitoring, at multiple sites located on Joint Base Elmendorf- Richardson (JBER), Anchorage, Alaska. The scope of work briefly summarizes the site locations, sampling/monitoring schedules, and activities such as free-product removal from monitoring wells and monitoring/maintenance activities at the Operable Unit 5 wetlands. The details regarding the procedures for the remedial action operations and long-term management activities will remain consistent with the 2021 Uniform Federal Policy Quality Assurance Project Plan (UFP-QAPP). |
Ginna Quesada |
| 4/25/2023 |
Document, Report, or Work plan Review - other |
DEC approved the 2023 Letter Work Plan Remedial Action Operations and Long-Term Management, Final, Dated April 2023. The work plan describes the site inspections, maintenance activities, and groundwater, seep, and surface water monitoring, at multiple sites located on Joint Base Elmendorf- Richardson (JBER), Anchorage, Alaska. The scope of work briefly summarizes the site locations, sampling/monitoring schedules, and activities such as free-product removal from monitoring wells and monitoring/maintenance activities at the Operable Unit 5 wetlands. The details regarding the procedures for the remedial action operations and long-term management activities will remain consistent with the 2021 Uniform Federal Policy Quality Assurance Project Plan (UFP-QAPP). |
Ginna Quesada |
| 5/18/2024 |
Document, Report, or Work plan Review - other |
DEC submitted comments regarding the 2023 Annual Remedial Action-operations And Long-term Management Report for Select State-regulated Sites Draft, Dated April 2024. The report describes the site inspections, maintenance activities, and groundwater monitoring, at multiple sites located on Joint Base Elmendorf- Richardson (JBER), Anchorage, Alaska. Site inspections were recommended to continue for all sites to ensure that conditions remain protective of human health and the environment. The report recommends updating land use controls (LUC) site boundaries at CG534, a ‘Cleanup Complete’ determination without institutional controls (ICs) for SS522, the removal of groundwater LUCs at SS041, and a ‘Cleanup Complete with ICs determination for TU101. |
Ginna Quesada |
| 6/25/2024 |
Document, Report, or Work plan Review - other |
DEC approved the 2023 Annual Remedial Action-operations And Long-term Management Report for Select State-regulated Sites Final, dated June 2024. The report describes the site inspections, maintenance activities, and groundwater monitoring, at multiple sites located on Joint Base Elmendorf- Richardson (JBER), Anchorage, Alaska. Site inspections were recommended to continue for all sites to ensure that conditions remain protective of human health and the environment. The report recommends updating land use controls (LUC) boundaries at CG534, a ‘Cleanup Complete’ determination without institutional controls (ICs) for SS522, the removal of groundwater LUCs at SS041, and a Cleanup Complete with ICs determination for TU101. |
Ginna Quesada |
| 1/30/2025 |
Document, Report, or Work plan Review - other |
DEC approved the 2025 Remedial Action–Operations and Long-term Monitoring Work Plan Addendum Final, dated January 2024.The work plan describes the site inspections, maintenance activities, and groundwater, seep, and surface water monitoring, activities that will be conducted at multiple sites located on Joint Base Elmendorf- Richardson (JBER), Anchorage, Alaska. The scope of work briefly summarizes the site locations, sampling/monitoring activities and schedules. This workplan will remain consistent with the procedures outlined in the 2023 Letter Work Plan Remedial Action-Operations and Long-Term Management. |
Ginna Quesada |
| 4/15/2025 |
Document, Report, or Work plan Review - other |
DEC provided comments for the 2024 Annual Remedial Action-Operations and Long-Term Management Report for Select State-Regulated Sites Draft, dated April 2025.The report describes the site inspections, maintenance activities, and groundwater monitoring, at multiple sites located on Joint Base Elmendorf- Richardson (JBER), Anchorage, Alaska. Site inspections were recommended to continue for the majority of the sites to ensure that conditions remain protective of human health and the environment. DEC concurs with the recommendation to close SS522 site without ICs, discontinue groundwater sampling at TU107, and reducing the sampling frequency for some wells at TU103. |
Ginna Quesada |
| 5/6/2025 |
Long Term Monitoring Workplan or Report Review |
DEC approved the 2024 Annual Remedial Action-Operations and Long-Term Management Report for Select State-Regulated Sites Final, dated May 2025. The report describes the site inspections, maintenance activities, and groundwater monitoring, at multiple sites located on Joint Base Elmendorf- Richardson (JBER), Anchorage, Alaska. Site inspections were recommended to continue for the majority of the sites to ensure that conditions remain protective of human health and the environment. DEC concurs with the recommendation to close SS522 site without ICs, discontinue groundwater sampling at TU107, and reducing the sampling frequency for some wells at TU103. |
Ginna Quesada |
