| Action Date |
Action |
Description |
DEC Staff |
| 9/3/1984 |
Update or Other Action |
Preliminary Assessment Nikolski.Contract No. DACA85-92-D-0007 Delivery Order 0007 U.S. Army Engineer District, Alaska. Appendix A: INVENTORY of Debris Disposal Fiscal Years 1984-1986: A record of debris removed from several USAF sites between 1984 and 1986. Although the quantifies are not representative of annual waste generation amounts, the inventories provide an indication of the types of wastes generated.
|
Louis Howard |
| 1/25/1988 |
Update or Other Action |
USEPA Assistant Administrator J. Winston Porter (OSWER) Memorandum for the record to Regional Administrators I-X Subj: Enforcement Actions under RCRA and CERCLA at Federal Facilities. Statutory language makes it clear that Federal facilities must comply both procedurally and substantively with RCRA and CERCLA in the same manner as any non-Federal entity. The purpose of this memo is to lay out the statutory authorities under RCRA and CERCLA that EPA may use at Federal facilities to achieve compliance and expeditious cleanup.
EPA (The Agency) is viewing the Section 120 Interagency agreement as a comprehensive document to address hazardous substance response activities at a Federal facility from the remedial investigation/ feasibility study (RI/FS) through the implementation of the remedial action. All such interagency agreements must comply with the public participation requirements of Section 117. The timetables and deadlines associated with the RI/FS and all terms and conditions associated with the remedial actions (including operable units or interim actions) are enforceable by citizens and the States through the citizen suit provisions of Section 310 of CERCLA. In addition, Section 122(1) of CERCLA authorizes the imposition of civil penalties against Federal agencies for failure to comply with interagency agreements under Section 120. Procedures for imposing these penalties are provided for in Section 109 of CERCLA.
Executive Order 12580 clarifies that EPA is authorized to issue Section 104 and Section 106 administrative orders to other Federal agencies, with the concurrence of the Department of Justice. Section 4(e) of the Executive Order provides that: Notwithstanding any other provision of this Order, the authority under Section 104(e)(5)(A) and Section 106(a) of the Act to seek information, entry, inspection, samples or response action from Executive Departments and agencies may be exercised only with the concurrence of the Attorney General.
States also have a variety of enforcement authorities under CERCLA, so the exercise of EPA's enforcement authorities should be closely coordinated with the States.
First, Section 121(e) (2) of CERCLA authorizes States to enforce ANY Federal or state standard, requirement, criteria or limitation to which the remedial action must conform under CERCLA.
Second, Section 310 authorizes citizen suits to require Federal agencies to comply with the standards, regulations, conditions, requirements, or orders which have become effective pursuant to CERCLA including IAGs under Section 120 of the Act.
Third, Section 120(a)(4) clarifies that State laws concerning removal and remedial action, including State laws regarding enforcement, are applicable at Federal facilities not included on the NP. In addition, Section 120(i) states that nothing in CERCLA Section 120 shall affect or impair the obligation of the Federal agency to comply with the requirements of RCRA, including corrective action requirements (see section IV.C., "Importance of the States as a Party to the IAG"). EPA enforcement actions against Federal agencies should therefore be carefully coordinated with States to avoid potentially duplicative or conflicting exercises of authority.
All RCRA Subtitle C permits issued after November 8, 1984, will contain provisions for implementing the corrective action requirements of 40 CFR Part 264 Subpart F (or authorized state requirements), and Section 3004(u) and (v) of RCRA. For facilities that have or are seeking a RCRA permit, the requirements for a "CERCLA" remedial investigation and cleanup could be met by implementing these requirements through RCRA corrective action. It is important to keep in mind, however, that the extent of coverage of the RCRA permit is generally limited to hazardous wastes/constituents (e.g., some CERCLA hazardous substances such as radionuclides are not RCRA hazardous constituents and, therefore, the permit may not be able to address all of the releases at a facility).
The corrective action authority under Section 3008(h) of RCRA can be used at RCRA interim status facilities to address releases from RCRA regulated units and other solid waste management units. At a Federal facility that has interim status, a RCRA corrective action order could address the investigation and clean-up of releases in. lieu of a "CERCLA" response action or as an interim measure. Again, the extent of coverage in the RCRA corrective action order is limited to RCRA hazardous wastes/constituents.)
CERCLA Section 106 can be used to address releases from RCRA units or CERCLA sites when an "imminent and substantial endangerment" is shown. A Section 120 IAG could be drafted to incorporate all RCRA corrective action requirements and CERCLA statutory requirements. Where some or all of a Federal installation has been listed on the NPL, the CERCLA Section 120 IAG is required for remedial action by statute. |
Louis Howard |
| 11/8/1989 |
Meeting or Teleconference Held |
Factsheet APVR-DE-PSE/Env Res Br William A. Gossweiler/863-3295
SUBJECT: Update on Eagle River Flats/Poleline Road Contaminated Site Studies.
FACTS:
The Eagle River Flats Task Force was informed at their last meeting (8 November 1989) that USATHAMA had set aside The Eagle River Flats Task Force was informed at their $500,000 for FY 90 Eagle River Flats studies. They now say that under the new circumstances, they are diverting that money toward the investigation of the recently discovered Pole Line Road contaminated site.
i. The Poleline Road contaminated site was brought to the Command's attention in fall 1989 by Mr. Floyd C. Fruik (a former soldier on Fort Richardson during the early 1950s) & later confirmed by old photographs & maps obtained from the Corps of Engineers.
k. The scope of work for the Poleline Road contaminated site study has just been completed & the estimated costs are approximately $300,000. |
Louis Howard |
| 11/13/1989 |
Update or Other Action |
Factsheet re: Poleline Road Disposal Area discoverd through search for a link to a dump site to the ERF mortalities of waterfowl.
SUBJECT: Poleline Road Chemical Disposal Area
BACKGROUND: Records on past (before the mid-1970s) landfills or "dumps" are poor with usually no documentation of material deposited into them. A dump site location, an acknowledgement that such a site existed and was properly closed, or something similar is usually the best file information available. It is unlikely that any more information on the Poleline Road Chemical Dump site will be uncovered in the files.
FACTS BEARING ON THE SUBJECT:
a. Facts. In late September of 1989, Anchorage Mayor Tom Fink informed MG Fields, Commanding General of the 6th Inf Div (L) and U.S. Army Garrison, Alaska, of an Anchorage citizen who was stationed on Fort Richardson in the 1950s and remembered chemicals being buried in an area close to Eagle River Flats Impact Area (ERFIA). The Mayor indicated this might be connected to the Eagle River Flats Waterfowl Mortality (ERFWM) problem under Army investigation in the ERFIA. This project will be handled separately from the ERFWM project unless/until a link between the two is found because it is likely that they are unrelated (they are separated by about five kilometers).
b. Action Taken. The informant spent an afternoon with 6th Inf Div (L) Directorate of Engineering and Housing (DEH) personnel locating a primary and alternate site on a map. This was followed : by site visits to confirm the possible dump locations. From this information, DEH has coordinated with EOD and the 6th Engineers to perform an electromagnetic sweep of the areas to determine what, if anything, was buried there.
Concurrent with this action, an investigation of the map archives at the Corps of Engineers revealed a 1954 map showing a chemical disposal area at the same spot as the primary location identified by the informant. The map says "Chemical Disposal Area" in the middle of a full circle. On the radius line leading from the label to the circle are the words "2400 radius contamination zone" (see attached map).
Aerial photography from a 1957 overflight showing visible trenches collaborates this dump location. Based on this data, the alternate site has been dropped from the investigation. While preparations for the electromagnetic sweep are proceeding, the 6th Inf Div (L) has issued a request through WESTCOM to USATHAIJIA asking USATHAMA assistance in investigating the Poleline Road Chemical Disposal Site.
C. Action Required. Continue investigation efforts and have the 23rd Engineers perform the initial electromagnetic sweep, have EOD perform a follow-up sweep as soon as possible and USATHAMA encourage to perform an investigation of this site and establish it as a project under the Installation Restoration Program (IRP).
4. REFERENCES.
a. AR 200-1, 15 June 1982, Environmental Quality, Environmental Protection and Enhancement. b. Memorandum, DEH, APVR-DE-PS, 13 Nov 89 Subject: Chemical Disposal Area (request for USATHAMA assistance). |
Louis Howard |
| 11/14/1989 |
Update or Other Action |
Memorandum for the record: Army interview with Mr. Paul Roseland. Originally assigned at the Post in the mid-forties, in 1948 transferred to the 266th Chemical Detachment (CD) of 11 men assigned to dispose of chemicals brought back from the Aleutians after WW II.
He was a carpenter building crates for chemical containers & labeling them for shipping. Labels on the containers varied from Mustard, phosgene & chloropicrin.
Address stenciled on crates were to Utah (Ogden UT). The 266th CD disposed of FS smoke & Japanese CLUSTER BOMBS by wrapping them in detonation (det) cord & detonating them. FS smoke in 41% chlorsulfonic acid, 54% sulfur trioxide & 5% sulfuric acid which becomes smoke when exposed to moisture. There was residual liquid in the drums after they were blown which still smoked if water was added.
The CLUSTER BOMBS were identified by EOD as the Japanese Army type 2 1/3 kg bombs in a 76 bomb container. They burned for quite a while after going off, indicating they were either incendiaries or illumination rounds.
There were some delayed action fuzes as well since the BOMBLETS kept going off 2 to 3 hours after the operation. He stated there were a lot of duds that were blown all over the place & not picked up.
NOTE: Type 2 bombs have arming vanes which would need to rotate a certain number of times to arm the bomb. Not all of the bomblets would have been subjected to enough velocity & distance to arm which would account for the high "dud" rate. The main hazards of these bombs would be spinning the vanes, which may be a fractional spin away from arming, & the hazard of picric acid, a high explosive used as a booster by the Japanese which has been known to exude, crystallize & be highly shock & friction sensitive.
Mr. Roseland stated that the really hazardous chemicals were shipped & the less hazardous chemicals (FS & the cluster bombs) were done at PRDA. He indicated that even Mustard in broken vials were shipped after repackaging.
He also indicated where trenches were dug & the electro-magnetic (EM) survey confirmed that there was a 50' x 6' x 6' trench there & the ground had even settled in a couple of places.
|
Louis Howard |
| 2/9/1990 |
Site Added to Database |
Chemical agent identification sets (CAIS) and chlorinated solvents. |
Jennifer Roberts |
| 6/1/1990 |
CERCLA PA |
Expanded site investigation received by ADEC. Conclusions reached: there has been a release of chemicals which may pose a potential threat to public health/environment based upon the existence of exposure pathways. Organic/inorganic analytes in groundwater exceeding drinking water maximum contaminant levels (MCLs): Benzene, Carbon tetrachloride, Trichloroethylene, Metals that may be a result of human activity(more work is needed).
NOTE: Trichloroethylene is a clear, heavy liquid that is easily recycled and features excellent solvency for outstanding cleaning power. Trichloroethylene is nonflammable (under most end use conditions), having no flash point as determined by standard test methods. It is highly stable and
features a low boiling point. This characteristic permits vapor degreasing with low heat input to facilitate rapid handling of work following degreasing. Trichloroethylene is used as a
cleaning solvent in the manufacture of circuit board assemblies and wafers, as an intermediate in producing fluorocarbons, as a pretreatment in the manufacture of textiles, and as an ingredient
in the formulation of adhesives.
In the past, carbon tetrachloride was widely used as a cleaning fluid (in industry and dry cleaning establishments as a degreasing agent, and in households as a spot remover for clothing, furniture, and carpeting). Carbon tetrachloride was also used in fire extinguishers and as a fumigant to kill insects in grain. Most of these uses were discontinued in the mid-1960s. Until recently, carbon tetrachloride was used as a pesticide, but this was stopped in 1986. |
Jennifer Roberts |
| 6/30/1990 |
Update or Other Action |
Fact sheet Installation Restoration Division: Summary of the current status of the Poleline Road Disposal Area (PRDA) activities. US Army Toxic and Hazardous Materials Agent (USATHAMA-which became the US Army Environmental Center USAEC in 1993) became aware of the problem when they received a memorandum dated November 13, 1989 requesting USATHAMA's assistance on how to proceed with the investigation. A scope of work was drafted by USATHAMA to use initially non-intrusive measures (ground penetrating radar and electromagnetic conductivity) followed by intrusive measures such as soil sampling, well drilling and ground water monitoring. To date, members of the 23rd Engineer Co. surveyed the area and swept it with negative results utilizing an ANPSS-11 metal detector.
Sixteen signs designating the PRDA as a "possible contaminated area authorized personnel only" were built to warn personnel to keep out. Field work began in June 25, 1990 with non intrusive geophysics and preliminary findings give the indication that trenches and buried drums may exist in the area. The Post EOD unit will provide chemical agent screening of all environmental samples taken utilizing the M-18 kit and the new chemical agent monitor (CAM). The CAMs provided by technical escort unit(TEU) will provide confirmation of a negative test by the M-18 kit. TEU provides the Department of Defense and other federal agencies with a unique, immediate response capability for chemical and biological warfare material. The CAM also will provide a real time monitoring of the air in the immediate working area. |
Louis Howard |
| 8/24/1990 |
Update or Other Action |
Surface Geophysical Investigation U.S. Army Ft. Richardson Facility by Environmental Science & Engineering, Inc. ESE No. 6901095 dated August 24, 1990. Three surface geophysical investigative methods were used to help detect the possible presence of materials and/or objects buried in the shallow subsurface of the study area.
1) Electromagnitic (EM) conductivity (using an EM-31) was used to investigate the site subsurface for areas which appear to have electrical properties altered by the possible presence of contamination in the groundwater. Secondly, EM conductivity measurements was used for the recording of the instrument responses to conductive objects in the shallow subsurface. The EM-31 conductivity equipment utilizes fixed transmitting and receiving antenna geometry, and has a fixed penetration depth that averages 18 feet.
2) Magnetometer surveys were used to record the changes in the earth's magnetic field across the site, and to determine if the presence of metallic objects in the near subsurface causes changes in the magnetic field. The magnetic survey was conducted with a GEM-19 Overhauser memory magnetic gradiometer. The data is stored in internal memory, and then downloaded to an onsite computer.
3) Ground penetrating radar (GPR) applicability at this site is dependent on the radar signal's ability to penetrate the subsurface materials and return reflected signals to the surface. For this investigation, the antenna had an apparent center frequency of 120 Mega-hertz with fixed transmitter to receiver geometry. This configuration has proved to be applicable in similar site investigations.
Based on the three geophysical methods, there is strong evidence that at least two areas of this site were excavated and materials buried. An area on the western edge of the surveyed area appears to have the most significant changes in conductivity. This area, located directly beneath the cut toe of the hill, has several conductivity anomalies that are truncated against the hill. These anomalies appear to represent point sources of increasing conductivity values.
The magnetic field data, recorded at this site, appear to indicate that buried metallic objects have caused disruptions in the magnetic field at several locations. There is very close agreement between the areas indicated on the total magnetic field measurements and for the measurements of the magnetic gradient. The two areas of significant magnetic anomalies correspond with those described for conductivity anomalies. There are several minor magnetic anomalies of less magnitude located in the northern central portion of the site.
Ground penetrating radar (GPR) data is in general agreement with the locations of conductivity and magnetic anomalies. There appear to be indications of excavations along the western portion of the site. Radar transects were not recorded over the area in the northeastern corner having magnetic and conductivity anomalies; therefore there is no information on the possibility of area excavations.
However, there are some indications that the western edge of a possible excavation may have been recorded on two GPR transects in that area. GPR reflections recorded in the central portions of the site may represent excavations; however, there were no strong conductivity or magnetic anomailes associated with these reflections. These reflections could be related to the construction of the road that passes north-south in this area. |
Louis Howard |
| 9/26/1990 |
Update or Other Action |
INTERIM GUIDANCE FOR SURFACE AND GROUNDWATER CLEANUP LEVELS SEPTEMBER 26, 1990
Interim cleanup guidance for contaminated surface and groundwater remediation is necessary to ensure that consistent cleanup levels are being applied by district and regional program staff. 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 and cleanup standards should enter into development of final site cleanup levels.
Groundwater should be cleaned up to levels not exceeding the more stringent of the final State or Federal Maximum Contaminant levels (MCLs) for Organic and Inorganic Chemicals. If final MCLs have not been adopted for a contaminant, then groundwater 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 and final Federal MCLs are specified in 40 CFR 141 and 142. Proposed Federal MCLs are specified in the May 22, 1989, Federal Register Vol. 54, No. 97, pages 22155 - 22157 and the July 25, 1990, Federal Register Vol. 55, No. 143, pages 30408 - 30448. Appendix I provides a summary listing of State and Federal Final and Proposed MCLs for selected organic and inorganic contaminants.
For organic and 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 and compounds which have toxic effects on aquatic organisms or toxic and carcinogenic effects on humans.
If groundwater is being used as a drinking water source and 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 and 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 and inorganic chemicals, as specified above. Under the authority of 18 AAC 70.020, surface waters important to the growth and 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 and 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 and other pertinent information.
The responsible party (RP) may prepare at its own expense a risk assessment which shall include an assessment of both human health and environmental risks. Specific components of the risk assessment should include an exposure assessment, toxicity assessment, risk characterization, and justification of ACLs. A general description of these risk assessment components is provided in Appendix II.
General technical requirements for risk assessments should be based on EPA risk assessment guidance for superfund sites. A site specific risk assessment procedure must be prepared by the RP and submitted to the department for review and approval prior to conducting a risk assessment. The RP, at the department's discretion, must agree to reimburse the department for expenses incurred by the department if it chooses to contract for a risk assessment review. |
Louis Howard |
| 2/27/1991 |
Update or Other Action |
US Army Corps of Engineers, Toxic and Hazardous Materials Agency Final PRDA Expanded Site Investigation by Envir. Science & Engineering Inc. received. After preliminary results from the geophysical survey were received, the soil boring and monitoring well installation program were planned and site mobilization began in July 1990. Field activities for the soil sampling and monitoring well installation were completed in August 1990.
Groundwater sampling was conducted in September 1990 and again in October 1990. Upon completion of the October sampling, the wells were all aquifer tested to determine an estimate of aquifer characteristics. This Expanded Site Investigation Report contains the results of all the field activities described above.
The general objective of the expanded site investigation at PRDA was to evaluate the site to categorize the nature of any releases and/or potential threats to human health and the environment. Specific objectives of the investigation were:
Determine if any releases have occurred from this suspected disposal area;
Determine which releases pose a potential threat to public health and the environment;
Determine if there is any immediate threat to persons living or working near the site; and
Determine and make recommendations for no further action, a remedial investigation/feasibility study (RI/&), and/or interim remedial action, as appropriate.
Soil Results: The compounds which were detected were
1,2-Dichloroethene ranging from 0.005 to 0.010 ug/g,
1,1,2,2-tetrachloroethane ranging from 0.03 to 1.4 ug/g,
tetrachloroethene ranging from 0.0010 to 0.017 ug/g, and
trichloroethene ranging from 0.008 to 0.20 ug/g.
The limitation of number and depth of samples, as well as the problem of having to choose locations outside the areas of geophysical anomalies in order to avoid potential drilling hazards, precludes drawing any conclusions other than that the presence of these compounds indicates disturbance and chemical disposal at PRDA did occur.
Groundwater Results: Organic compounds were detected in all wells except MW-2. Ranges for the organic compounds detected in shallow groundwater were
carbon tetrachloride, 49-53 /ug/L (18 AAC 75 (April 2012) Table C 5 ug/L);
1,1,2,2-tetrachloroethane 45-47,000 ug/L (Table C 4.3 ug/L);
1,2-dichloroethene 6.1-1600 ug/L (Table C cis 1,2-DCE 70 ug/L trans 1,2-DCE 100 ug/L);
trichloroethene, 28.1-l 1,200 ug/L (Table C 5 ug/L);
benzene 8.98-11.6 ug/L (Table C 5 ug/L);
1,1-dichloroethylene one detection at 5.02 ug/L (Table C 7 ug/L);
chloroform,one detection at 28.0 ug/L (Table C 140 ug/L);
1,1,2-trichloroethane, 35-230 ug/L (Table C 5 ug/L);
hexachloroethene 6.5-9.3 ug/L (Table C 40 ug/L) ; and
RDX, one detection at 2.84 ug/L (Table C 7.7 ug/L).
The bedrock aquifer (MW- I)also contained detections of organic compounds. Carbon tetrachoride was detected at 1.9 and 4.3 ug/L (Table C 5 ug/L) during the two sampling events and 1,1,2,2-tetrachloroethane was detected at 5.6 ug/L (Table C 4.3 ug/L) during October.
The shallow groundwater beneath the PRDA contains organic compounds, mainly chlorinated solvents. Well MW-4 the furthest downgradient from the site, contained the most elevated levels of VOC contamination. Well MW-5, which is situated uppgradient of the majority of the site, was also contaminated. These 2 wells apparently have been impacted by activities conducted on the western portion of the site, although actual sources cannot be delineated at this time, due to the limitations of this investigation.
It is likely that MW-4 has been contaminated by the activities conducted on the eastern portion of the site as well, since it is positioned immediately downgradient where groundwater from both areas converge. Well MW-3 also contained VOC compounds, but at lower concentrations.
This well is situated adjacent to the eastern portion of the site. Since the well lies lateral to the gradient direction, lesser concentrations of these compounds would be expected. There is also a possibility that contamination in MW-3 may be due to an unrecognized disposal area on the southteastern side of PRDA. |
Louis Howard |
| 6/12/1991 |
Update or Other Action |
June 12, 1991 Resource Conservation & Recovery Act (RCRA) HW Management Compliance Evaluation Inspection Report documents Tim Law, Daniel Hartung, Vic Vickaryous, Geoffrey Kany, of ADEC's RCRA program inspection the Post for compliance with the provisions of the compliance agreement (FFCA) on April 29, April 30, 1991
Building 45-133 - Hazardous waste Covered storage Area
All other containers outside along the north end of the interim status unit were empty or empty unservicable containers, see photos #44, 45, and 46. Most of those containers were adjacent
to the north end of Building 45-133, see photo #45.
However, the containers on the outside of Building 45-133 on the eastern side of the building do contain hazardous waste. Photo #43 shows the eastern side of Building 45-133. Hazardous wastes that were generated from the groundwater monitoring wells installed at the "Pole Line Road" [SEE Operable Unit B Poleline Road Disposal Area CS DB HAZARD ID 940] site were being stored along this eastern edge.
An inadequate hazardous waste determination has been made on these wastes to date, in violation of 40 CFR 262.11. Ms. Scott tried to displace some of the blame for Fort Richardson's failing to make a hazardous waste determination on these solid wastes that were generated on-site by complaining that she had a telephone message in for Mr. Michael Gearheardt of the U.S. EPA in Seattle, that she needs his help in making the hazardous waste determination. |
Louis Howard |
| 7/2/1991 |
Update or Other Action |
US Army Environmental Hygiene Agency GW Quality Survey No. 38-26-K986-91 Evaluation of Solid Waste Management Units Fort Richardson AK 24 June to 2 July 1991. This survey was performed to evaluate and update the Solid Waste Management Unit (SWMU) information contained in Fort Richardson's RCRA Facility Assessment (RFA); to determine which SWMU's require further sampling, investigation, or corrective action; and to identify and evaluate any SWMU's not previously documented.
SWMU's Not Previouslv Identified in the RFA. The following SWMU was not in existence or were not discovered during the RFA. This site should be formally added to the SWMU list, and supporting documentation regarding ongoing work or justification for no further action should be provided to the regulator prior to issuance of the permit. TABLE 2. SWMU'S NOT PREVIOUSLY IDENTIFIED IN THE RFA:
Poleline Road Site (SWMU 123). A contractor under
the U.S. Army Toxic and Hazardous Materials Agency (THAMA) has just completed an investigation at this former disposal site. The investigation has identified soil and groundwater contamination, and proposed additional work includes a soil gas survey, additional monitoring wells and aquifer tests, and trenching/soil sampling. |
Jennifer Roberts |
| 8/1/1991 |
Update or Other Action |
Remedial Investigation Technical Plan received 11/21/91. The purpose of the report was to outline field investigation procedures. Specific objectives are:
Determine site & contamination boundaries using soil gas survey;
Characterize the contamination occurring in, & the interrelationship between, the shallow & deep aquifers at the PRDA; & With trenching & soil sampling operations, characterize source areas identified-in ESI which have the potential of impacting media at the PRDA.
Trenching will be conducted in the two suspected source areas located on the PRDA site. The trenching will be conducted by Fort Richardson EOD utilizing a Small Enplacement Excavator (SEE) & will aid in the characterization of anomalies detected during the Es1 geophysical survey. Trenching will be conducted in the suspected disposal areas on the northeastern & northwestern portions of the site. ESE will direct EOD during the trenching activities.
GW monitoring wells will be installed in areas determined by the soil gas survey to be within the plume. A total of six Cinch I.D. monitoring wells will be installed at the PRDA. Drilling will not-exceed a total of 680 feet. These monitoring wells will consist of four deep & two shallow wells. The deep wells will be installed in conjunction with a new or existing shallow well to form a cluster. One shallow well will be installed upgradient of the anticipated GW flow direction at PRDA. All GW well locations be finalized after evaluation of the soil gas survey results.
To determine the hydraulic communication between the shallow & deep aquifers as well as the hydraulic conductivity & transmissivity of the deep aquifer, a 72-hour pump test will be conducted. The pump test will be designed after Neuman & Witherspoon, 1972 (Appendix B). Prior experience with well yield in the deep aquifer at PRDA has shown that this aquifer may not be able to produce enough water to be pumped. The pump test, therefore, will only be conducted if the deep aquifer monitoring well can produce water through pumping.
Two observation wells will be installed after determining which deep monitoring well will be used for the pumping well. The observation wells will be installed in the unsaturated zone which occurs approximately 60 to 120 feet below ground surface. The wells will be installed in a radial line from the pumping well. These observation wells will be’constructed of 2-inch PVC.
The actual construction details will be determined in the field by the project hydrogeologist according to subsurface conditions encountered during the borehole advancement. The observation wells will generally be constructed similarly to the monitoring wells.
Water levels in each well will be measured using downhole pressure transducers. The transducer, as well as all other downhole instruments, will be steam cleaned with approved water prior to use in the well. The transducer is then lowered into the well to a depth which will allow for detection of minimal water level fluctuations. The transducer readings & time will be monitored over the 72-hour period using an Tnsitu Hermitm 2ooo which stores the data as it is being recorded. The recovery rates will also be monitored for 8 hours after the pump is turned off.
See site file for additional information. |
Jennifer Roberts |
| 2/19/1992 |
Update or Other Action |
EPA MEMORANDUM
SUBJECT:Permits and Permit "Equivalency" Processes for CERCLA On-site Response Actions
FROM: Henry L. Longest II, Director, Office of Emergency and Remedial Response
TO: Director, Waste Management Division, Regions I, IV, V, VII, and VIII; Director, Emergency and Remedial Response Division, Region II; Director, Hazardous Waste Management Division, Regions III, VI, and IX; Director, Hazardous Waste Division Region X
PURPOSE: The purpose of this directive is to clarify the Environmental Protection Agency (EPA) policy with respect to attaining permits for activities at CERCLA sites. CERCLA response actions are exempted by law from the requirement to obtain Federal, State or local permits related to any activities conducted completely "on-site". It is our policy to assure all activities conducted "on site" are protective of human health and the environment. It is not Agency policy to allow surrogate or permit equivalency procedures to impact the progress or cost of CERCLA site remediation in any respect.
BACKGROUND: In implementing remedial actions, EPA has consistently taken the position that the acquisition of permits is not required for on-site remedial actions. However, this does not remove the requirement to meet (or waive) the substantive provisions of permitting regulations that are applicable or relevant and appropriate requirements (ARARs). (For definitions of "substantive" and "administrative," see 55 FR 8756-S7 and the CERCLA Compliance with Other Laws Manual, Part I, pages 1-11-12.) The proposed and final 1982 National Oil and Hazardous Substances Pollution Contingency Plan (NCP) made no mention of the permit issue. However, EPA addressed the issue in a memorandum entitled "CERCLA Compliance with Other Environmental Statutes" which was attached as an appendix to the proposed 1985 NCP (50 FR 5928, February 12, 1985). The memorandum stated: "CERCLA procedural and administrative requirements will be modified to provide safeguards similar to those provided under other laws. Application for and receipt of permits is not required for on-site response actions taken under the Fund-financed or enforcement authorities of CERCLA."
EPA determined in the final rule [1985 NCP section 300.68 (a)(3)] that "Federal, State, and local permits are not required for Fund-financed action or remedial actions taken pursuant to Federal action under section 106 of CERCLA." The 1986 amendments to CERCLA codified section 300.68(a)(3) of the 1985 NCP with a statutory provision, section 121(e) (I). CERCLA section 121(e) (1) provides that no Federal, State, or local permit shall be required for the portion of any removal or remedial action conducted entirely on-site, where such remedial action is selected and carried out in compliance with section 121.
The 1990 NCP [section 300.400(e)(1)] implements this permit exemption for "on-site" actions, defining "on-site" as "the areal extent of contamination and all suitable areas in very close proximity to the contamination necessary for implementation of the response action." The preamble to the NCP (at 55 FR 8689, March 8, 1990) explains that "areal" refers both to the surface areas and the air above the site. EPA policy further defines "on-site" to include the soil and the groundwater plume that are to be remediated. On-site remedial actions may involve limited areas of noncontaminated land; for instance, an on-site treatment plant may need to be located above the plume or simply outside of the waste area itself.
As provided in NCP section 300.400(e)(I), response actions covered by CERCLA section 121(e)(l) include those conducted pursuant to CERCLA sections 104, 106, 120, 121, and 122. Thus response actions conducted by a lead agency, or by a potentially responsible party or other person under an order or consent decree with EPA, are covered under the ambit of CERCLA section 121(e)(1). Response actions by a lead agency include those response actions implemented by EPA, the Coast Guard, or another Federal agency. They also include response actions implemented by a State or political subdivision operating pursuant to a contract or cooperative agreement executed pursuant to CERCLA section 304(d)(1), under which EPA selects (or must approve) the remedy. |
Louis Howard |
| 7/1/1993 |
Update or Other Action |
Letter sent to Doug Johnson via fax prior to actually sending it out to Colonel Robert J. Wrentmore. Per our meeting on May 21, 1993, ADEC is requesting the status report on the planned removal at the Poleline Road Disposal Area. We are concerned about this site since ADEC has not been provided with the promised schedule, nor has the draft workplan been submitted for our review and approval. As discussed in the meeting: any work, removal, site assessment or remediation, must have prior approval by the ADEC under 18 Alaska Administrative Code 75. ADEC is concerned that the work will not move forward this year. By not proceeding with the proposed removal at PRDA this year, ADEC may issue the Army a letter of non-compliance (NOV) under Alaska Statutes and Regulations. Please respond to this letter with an updated schedule and status of the removal workplan within 14 days of receipt of this letter. |
Jennifer Roberts |
| 9/3/1993 |
Interim Removal Action Approved |
Letter to Doug Johnson (6th ID Light Department of Public Works) which ADEC approved the workplan submitted to ADEC for Poleline Road disposal area contract # DACW 45-89-D-0516. The use of action limits identified on Table 1-1 for TCE and PCE (600 mg/kg and 100 mg/kg respectively) are for the removal action only (interim) and not the final action level for the site.
Note to file: "Interim Remedial Actions" or "IRA" are discussed in the Preamble to 40 CFR 300.430(a) (1), 55 Fed. Reg. 8703-8706 (March 8 , 1990), and shall mean all discrete actions
implemented under remedial authority that are taken to prevent or minimize the release of hazardous substances, pollutants, or contaminants so that they do not endanger human health or the environment. Interim actions shall neither be inconsistent with nor precludeimplementation of the final expected Site remedy and shall be undertaken in accordance with the NCP, 40 CFR Part 300, as amended, and with the requirements of CERCLA;
Identify removal and Interim Remedial Actions ("IRA")alternatives that are appropriate at the Site prior to the implementation of final remedial action(s) for the Site. IRA alternatives shall be identified and proposed to the parties as early as possible prior to formal proposal of IRA(s) to U.S. EPA and ADEC pursuant to CERCLA and applicable state law. This process is designed to promote cooperation among the Parties in identifying IRA alternatives prior to selection of final IRA(s). |
Louis Howard |
| 9/7/1993 |
Document, Report, or Work plan Review - other |
USEPA comments on workplan for Rapid Response Removal Action at PRDA. This letter is in response to your request to review the project work plan for the removal action at Poleline Road. This agency has completed it's review and finds that the document adequately address the needs of the work plan for such an action.
However, EPA has a few concerns that need some clarification based on our review of the Work Plan and the Sampling and Analysis Plan subsections of this document. The first regards
the need for a contingency plan regarding the potential for unexploded ordnance (UXO) and/or chemical weapons (CW). The work plan mentions the possibility of these substances being present at the site.
However, I did not see any further mention of these UXO or CW later in the text. Some sort of contingency for dealing with these substances should be include if it is anticipated that unexploded ordnance and/or chemical weapons will be encountered during this investigation. Based on my review, I an unclear as to how many samples of the soil collected from the trenches will be shipped off for independent quality assurance analysis.
On page 7-1, a scheme for labeling the samples is presented which involves the use of a letter to distinguish the sample type. It appears that the letter "D' is used twice; to indicate that the sample is a drum sample and a disposal sample. This may cause confusion and perhaps this scheme should be re-evaluated. In conclusion, EPA does not find any significant problems with the work plan for the Rapid Response Removal Action at Poleline Road Disposal Area. |
Louis Howard |
| 10/3/1993 |
Update or Other Action |
Rapid Response weekly report 001 received. 9/29/93 excavation of North end of Trench A closest to Hill 385 was commenced with large amounts of scrap metal and rusted drums and pails encountered. Large amounts of WW era type of respirator cartridges were discovered and stockpiled. 20 tons of soil removed. 9/30/93 sixty additional yards removed from Trench A and more scrap metal and respirator cartridges removed. 10/01/93 Trench A excavation continues and at 9:30 AM. 7 to 8 metal gas cylinders were found which were determined to be old oxygen and acetylene cylinders. At 11:30 AM small amber glass jars were discovered in south end of Trench A. Jars were empty and had no lids with legible print on outside-HD-TOXIC GAS-SET M1. EOD staff determined that the bottles were mustard gas test kit items and that the chance of finding mustard gas agents at the site has now escalated.
OHM staff also found that morning a partially deteriorated technical manual from a test kit which discussed mustard gas and other chemical warfare agents (now referred to as "chemical agent").NOTE to file: Chemical agent: means a chemical compound (to include experimental compounds) that, through its chemical properties, produces lethal or other damaging effects on human beings, is intended for use in military operations to kill, seriously injure, or incapacitate persons through its physiological effects. Excluded are research, developement, testing and evaluation (RDTE) solutions; riot control agents; chemical defoliants and herbicides; smoke and other obscuration materials; flame and incendiary materials; and industrial chemicals.
2:30 PM two "PIG" apparatus containers were found which were described in the manual that they might contain samples of several different kinds of chemical warfare agents. 10/2/93 Army sampled the PIGS for vapor release and moved the containers to an on secure bunker Building 55228-Bunker D-15 (a.k.a. Ammunition Storage Area A).
Lewisite: CAS 541-25-3 A human poison by inhalation and skin contact. A blistering type military poison. An oily colorless liquid having the odor of geraniums. Lewisite is absorbed through the skin, as little as 2 mL on the skin can cause death. Has delayed action similar to distilled mustard gas. This gas exhibits a systemic poisoning effect on humans. When heated to decomposition it emits toxic fumes of CL- and As. A specific antidote, British Anti-Lewisite, decrease systemic effects but causes some toxicity itself.
Adamsite: CAS 578-94-9 light yellow to green granules. Human poison by inhalation. A vomiting type of poison gas (non persistent). When heated to decomposition it emits very toxic fumes of As and Cl-.
Mustard (HD): CAS 505-60-2 Colorless (if pure) to light yellow oily liquid. A human poison by inhalation and subcutaneous routes. A military blistering agent. Strongly effects the skin, eyes, lungs, and gastric system. Pulmonary lesions are often fatal. It penetrates the skin deeply and injures blood vessels. Minute amounts can cause inflammation. When heated to decomposition or on contact with acid or acid fumes it emits highly toxic fumes SOx and Cl-. Despite the relative rapidity of hydrolysis reaction H has been found to persist in soil or even under water for periods of decades. The primary means of detoxification in aqueous solution is via oxidation. Hypochlorite bleaches were the earliest decontaminants used to detoxify mustard. During WW II, both common bleach (NaOCl) and superchlorinated bleaches (Ca(OCl)s) were used. More stable N-chloro compounds such as chloramine have been used in modern decontamination systems. In the 1950s a non-aqueous equipment decontamination solution "DS2" (2% NaOH, 70% diethylenetriamine, 28% ethylene glycol monomethyl ether) was developed in which the conjugate base of glycol ether reacts rapidly with mustard via double elimination. |
Louis Howard |
| 10/17/1993 |
Update or Other Action |
Rapid Response Weekly report 003 received week ending on 10/17/93. OHM mobilized an expert on gas cylinders for inspecting 10 large cylinders and 4 smaller cylinders staged at the site that were removed from Trench A. All of the larger cylinders are empty as evidenced by the ruptured relief discs on the cylinders. The 4 smaller cylinders were also inspected and X-rayed by Technical Escort and EOD. Two of the cylinders are approximately 5 inches in diameter by 18 inches long were found to contain 4-6 ounces of liquid in one and a similar quantity of solids in the second cylinder. These cylinders were found to contain methylene bromide as evidenced by the faint visible markings on the cylinders. The 2 smaller cylinders 1.5 inches by 14 inches long were found to be empty of liquid as verified by x-ray. The vapor content or vapor pressure inside was not measurable and the previous use of the cylinders is not known. |
Louis Howard |
| 10/20/1993 |
Update or Other Action |
Memorandum for Deputy Commanding Genera/Chief of Staff-Subject: Chemical Event in Alaska.
On 1 Oct 93 contractor personnel involved in site cleanup operations, as part of Fort Richardson's ongoing environment restoration program, unearthed what appears to be remnants of
chemical warfare (CW) agent training materials and chemical decontaminants. The 176th EOD Detachment, fire department, medical personnel, the military police, and subsequently, a member of the AMC Technical Escort Unit (TEU) from Aberdeeh PG, MD,responded to the event. The site has been secured.
b. The CW training materials are from 1940's era training aids called Gas Identification Sets (known simply as ID sets). The CW training policy of the times called for use of actual CW
agents to promote realism in training. To achieve the desired realism these sets contained active CW compounds in both dilute and full strength forms and, as uch, if not handled properly.
c. The ID sat contents were used in training to promote confidence in protective equipment,
agent detection, and provide practice in CW materiel decontamination, and self-aid treatment
of skin after agent exposure,
d. The site is located near the intersection of Pole Line Road and Bars Boulevard on Fort Richardson (see area maps at encls 1 and 2). The contractor's excavations have thus far
uncovered two steel cylinders (probably ID set containers, called "PIGs") , several empty glass vials with the CW agent marking "HD" (indicating the blister agent Distilled Mustard), and one vial marked "L" for Lewisite (another type of blister agent). bepending upon the actual configuration, each PIG could contain as much as 2.5 liters of chemical agent. No chemical munitions have been found and no chemical aqent has been detected, Bowever, most blister agents freeze at temperatures in the midfifties (Fahrehheit) and the average ambient temperature at the site has thus far been in the forties. To offset this problem some samples taken at the site have been heated well above freezing and monitored for agent; again no agent was detected.
e. The advance party member from TEU informed the initial EOD response team that they would require "certified" protective masks and toxic agent protective (TAP) gear to continue recovery operations on-site. Additionally, they would require "certified" Chemical Agent Monitor (CAM) operators. In 1990 HQDA told us that EOD units without an implicit chemical mission in USARPAC and USAREUR would not be require to maintain certified sets of TAP gear. (Certification must normally be accomplished on a quarterly basis and is only done in CONUS, USASCH (less masks), and at Johnston Island.) Inquiries have been made to both DA DCSLOG and DA Safety. JI is leaning forward to supply what ever is required within their capability, but we should not react with a knee-jerk reaction without a plan. The emergency, if there ever was one, is over. Next week TEU will arrive on-site with a portable X-ray machine to try to determine the contents of the PIGS.
f. Future actions involve reviewing the situation to determine the best course of action, development Of a plan of action, execution of revised restoration operations, and disposition of recovered materials, NO further excavation should be attempted until a thorough reclamatioh plan has been developed, staffed ahd approved. The United states Army Chemical Materiel Destruction Agency is the proponent for the recovery of found-on-site chemical items. However, it will ultimately be a contractor's responsibility to excavate the site and USACMDA's
responsibility to recover, containerize, and ship or destroy the items found. USACMDA will fulfill their responsibilities using TEU assets. This process is expected to require until next
summer (1994) to complete, In the interim the site will be secured and contained pending the restart of cleanup operations. Current plans are to backfill the trenches, raise the actual
level of soil with clean fill dirt, and fence and mark the area appropriately.
See site file for additional information. |
Louis Howard |
| 10/24/1993 |
Update or Other Action |
Rapid Response Weekly report 004 received week ending on 10/24/93. On Monday and Tuesday (18th and 19th) personnel decontaminated the rocks previously separated from the soils during excavation by spraying with a 10% solution of clorox and water and triple rinsing with a high pressure washer. The water was collected and placed into drums for sampling and disposal.
The site excavations were backfilled on Thursday and Friday with pit run material provided by Fort Richardson Roads and Grounds department. The material was delivered in end dump trucks and placed in the excavation by OHM’s rubber tire loader. Prior to backfilling the trenches 6 mil poly sheeting was placed in the bottom and sides to separate the backfill material from the soil underneath. 2 x 4 stakes were placed in the corner of each excavation to mark the boundaries for ease of location at a later date. After the trenches were completed approximately 6 inches of pit run was spread across the site to cover all remaining staging and work areas, The adjacent Barrs Blvd. was not covered.
The gas cylinders (14 total) were placed in a flat area north of Baars Blvd. l/2 way
between the site and Poleline Road. Received notification from MRI Laboratory on Friday that Mustard and Lewisite in the soil samples is below detection limits. Based on these results the samples stored in the Bunker for predisposal analysis by Columbia Analytical were FedExed to Columbia and samples in storage for submittal to disposal sites for acceptance were shipped to OHM’s Sanleandrov California office for holding until predisposal analytical results are received. |
Louis Howard |
| 10/26/1993 |
Update or Other Action |
US ARMY letter to DEC Commissioner John Sandor. As you know, on October 1, 1993, during our removal action at the Pole Line Road Disposal Area, our contractor excavated two items that have been identified as World War II Chemical Agents. There was prior indication that test kits might have been disposed of at Pole Line Road; however, the evidence was
cursory and problematic and led only to a conclusion to take extra safety precautions during excavation.
When the “pigs” were recovered, my staff immediately notified both the State Spill Notification Center and the National Response Center. While no spill or leak of the chemical agents were detected, I felt it prudent to make the notification process. Since that time, I have directed that approximately 260 cubic yards of excavated dirt be packaged for transportation and disposal out of state. In addition, the two items of record have been repackaged and are
currently stored in an ammunition bunker on Fort Richardson. Indications are that both containers will be transported out of state for long-term storage sometime over the next six to twelve months. Prior to transport, I will notify your offices.
The two areas excavated at the PRDA site have been backfilled with clean native gravel and the area has been surveyed and fenced to provide additional protection during the winter months. I have also requested that the
staff be prepared for the resumption of the removal action on August I, 1994. It
is my intention to complete the removal action at this site and to remove the remaining contaminated material; however, an extraordinary number of players
will undoubtedly offer advice and assistance and there can be no assurance we will receive the required blessings to complete this removal action.
For your information, our removal contractor was directed to perform additional soil and groundwater sampling to further define or detect any release of chemical agents. A preliminary report is attached for your inspection I also directed the contractor to take additional soil and groundwater samples as an extra precaution to be analyzed for the more normal analytical parameters. Signed R. J. Wrentmore Colonel US Army DPW. |
Louis Howard |
| 12/23/1993 |
Document, Report, or Work plan Review - other |
Staff reviewed and commented on the draft scope of work for OUB Preliminary source evaluation 2. The text describing the four sites does not state if any of the ground is covered with asphalt. If asphalt is being drilled through, then the soil samples collected at depths shallower than two feet may be cross contaminated with residual asphaltic organics. ADEC suggests that the soil samples for volatile organics not be collected from depths shallower than two feet when drilled through asphalt. The text states background samples will be collected at the same depths from two different locations outside the drum storage area. Four different sample locations would be more appropriate in establishing background levels of naturally occurring elements.
To select background areas to sample it is suggested to include the following criteria:
1) select areas that are a minimum of 1,000 feet from developed areas of the Garrison;
2) review of aerial photos to show no past development in the areas selected;
3) stressed vegetation is not present in the area chosen; and
4) the areas chosen are upgradient of utilities and POL lines. |
Louis Howard |
| 5/9/1994 |
Document, Report, or Work plan Review - other |
Staff reviewed and commented on the draft final workplan phase 2 continuation of the removal action at Poleline Road Disposal Area (PRDA). The site specific health and safety plan (as all plans of this nature) will not be reviewed by ADEC, but will be kept on file. After an expedited review of the document, the workplan is approved as submitted. In the future, ADEC requests document submittals allow for a thirty day review time frame. |
Louis Howard |
| 5/15/1994 |
Update or Other Action |
PRDA field operations workplan manual received. The manual describes the interim holding facility for temporarily storing chemical warfare materiel (CWM) until an approved onsite treatment system is available for treatment and disposal of the CWM. The CWM is packaged in single round containers placed on wooden pallets that will be placed in individual portable secondary containment devices. The Post's responsibilities under this manual are:
1) assume responsibility for every aspect of the PRDA removal action, 2) perform monitoring of the interim holding facility (IHF) after the PRDA remedial investigation has been completed. The IHF will be monitored monthly, in accordance with monitoring instructions. 3) Provide personnel and all necessary supplies to perform monitoring. 4) Failure of the IHF structure or major components will be corrected immediately. Should major structural repair be impractical, FTR will ensure that the IHF will be replaced and CWM transferred following procedures developed for receipt, storage, and export of CWM. 5) The Post, in close coordination with USACMDA, will exercise control of CWM after receipt from the PRDA remediation site, and until final disposition of the CWM. 6) Inspect the IHF monthly for signs of exterior deterioration or other damage that could lead to a release.
The CAIS "instructions for using gas identification sets" (USA, N.D.) ampules/jars states that they may contain:
Sulfur Mustard (H)-Either neat agent, diluted 5% H in 95% chloroform by weight, or agent adsorbed on charcoal
Nitrogen Mustard (HNI)-diluted 90% chloroform, 10% HNI
Lewisite (L)-diluted 5% L in 95% chloroform by weight or agent adsorbed on charcoal
Chloropicrin (PS)-diluted 50% PS in 50% chloroform by weight or PS adsorbed on charcoal
Phosgene (CG)
Triphosgene (solid)
Cyanogen chloride (CK)
Chloroacetophenone (CN) solid tear gas.
Summary of events table showed that during October/November 1993 sample results received during the soils and waters indicated that the primary contaminants in both are Tetrachloroethane (PCA) and Trichloroethene (TCE) as originally expected. The soils were analyzed by Midwest Research Institute (MRI) for CSM/CWM. The only positive CWM contaminant detected was 4 ppm Adamsite found in the soil to be disposed, and 14 ppm Adamsite found in the soil remaining in the unexcavated areas of Trench A. December 1993 (first week)-Soils and waters transported to be disposed by RCRA Incineration at Aptus Inc. in Utah. |
Louis Howard |
| 5/18/1994 |
Update or Other Action |
Information paper generated by the Army regarding Poleline Road Disposal Area (PRDA). Background: former corporal identified the site on the ground which coincided with a 1954 Corps of Engineers topographic map which labeled the same site as a "chemical disposal area". The soldier was responsible for building the wooden crates for shipping mustard, phosgene, and chloropicrin. The chemicals were supposedly shipped out of Alaska while the less hazardous chemicals were disposed of at PRDA. Supposedly in an area east of PRDA, an unknown amount of smoke and Japanese cluster bombs were disposed of at PRDA from the Aleutians following WWII.
April 1994 Commander of Explosive Ordnance Disposal (EOD) informed Public Works of their discovery of a Corps of Engineers historical document containing a 1944 map reference to a "Chemical Filling Plant". The map shows it approximately one-half mile east of Otter Lake in the vicinity of the intersection of Otter Lake Road and the Alaska Railroad. |
Louis Howard |
| 5/31/1994 |
Update or Other Action |
Reconnaissance Ground-Penetrating Radar and Electromagnetic Induction Surveys of The Poleline Road Site Draft Final Report May 1994. During March of 1994, researchers from CRREL conducted Ground-Penetrating Radar (GPR) and ElectroMagnetic Induction (EMI) surveys of the primary area.
NOTE To FILE: GPR is capable of identifying a wide range of subsurface conditions and/or targets. Detectable objects can range in size from around 10mm up to underground cavern proportions. All types of subsurface materials, ferrous and non-ferrous, can be detected and accurately plotted.
The results are available in real time and thus usually able to be reviewed on site at the time of investigation. Collected data can also be stored on the equipment hard drive for later analysis and report preparation. Benefits: • Cost effective, fast efficient and accurate, • Non-destructive and non-invasive, • Extremely portable and environmentally neutral., • On-site real time data color display.
There are two types of Electromagnetic Induction (EMI) techniques commonly used. These are frequency-domain (FEM) and time-domain (TEM). 1. EMI - Frequency Domain- The EMI (FEM) instrument normally operates at a fixed frequency. The generated signal creates small subsurface eddy currents beneath the instrument. Automatic accurate measurements of the components of the generated subsurface eddy currents are then used to record changes in the subsurface soil conditions.
The other type of EMI instrument in common use is time-domain EMI (TEM) or “transient EM”. A short low energy electromagnetic pulse from the transmitter coil couples with the ground by and a receiver coil measures the decaying signal induced into the ground with respect to time. This technique allows very sensitive detection of shallow and deep buried metal objects. Benefits: • Cost effective - large areas covered quickly and easily. , • Non-destructive and non-invasive, • Extremely portable and environmentally neutral., • On-site real time data allows some pre information,
Interpretive Summary-The interpretations are based on the concurrence of the EMI and GPR records, the presence of concentrated, intense EMI anomalies, the location of multiple, intense hyperbolic diffractions, and the site's terrain.
1) The marsh area contains few significant conductive anomalies and only one zone with possible debris. The distribution of very weak conductive anomalies suggests a wide dispersal of small objects. A more detailed survey by GPR and EMI would be
required to better define the location of these objects.
2. The disposal area contains four large areas of strong anomalies within which occur clear indications of metallic objects. The variability in the intensity, depth and location (clustering) of anomalies suggests that both trenches (Areas A-3 and A-4)
and single or closely spaced excavations (Areas A-2 and A-l) were used for burial.
Anomalous horizons in each area begin at a depth estimated at 1 to 1.5 m below the surface and extend to a depth of over 4 m, typically ranging from 1.0 to 3.5 m. A linear concentration of strong hyperbolic diffractions within Area A-3 is suggestive of a trench of about 50 m length containing stacked cylindrical objects. Areas A-4 and A-l both have raised surfaces suggesting each was filled above the original ground surface. A more detailed GPR survey would be required to identify precisely the number and location of trenches in each of the four areas. |
Louis Howard |
| 6/15/1994 |
Update or Other Action |
Finding of No Significant Impact and Environmental Assessment Poleline Road Removal Action USACE June 1994. In accordance with the National Environmental Policy Act (NEPA) of 1969, the U.S. Army Engineer District, Alaska, has assessed the environmental impacts of the following action:
Poleline Road Removal Action Fort Richardson, Alaska. The project will remove contaminants and contaminated soil from the Poleline Road Disposal Area (PRDA) on Fort Richardson (figure 1 of the Environmental Assasment). The project is required to remediate buried solvent-containing chemical neutralization kits, chemical warfare materials, and soils contaminated with solvents and other compounds. The project will mitigate the migration of contaminants into the ground water, which has been shown to be
contaminated with volatile organics: including 1,1,2,2-tetrachloroethane (PCA) and trichloroethene (TCE). Chemical warfare identification kits and any other chemical warfare materials found during excavation will be removed to the secured ammunitions storage bunker on Fort Richardson for future disposal. Contaminated soils will be removed from the PRDA until cleanup levels are met.
The soil, rocks, and debris from the PRDA Areas 3 and 4 (figure 2 of the Environmental Assessment) will be stockpiled in lined covered storage areas until disposition and/or treatment is approved. Contaminated soils will be transferred to a long-term storage area approximately one-half mile southeast of the PRDA (adjacent to the Anchorage Municipal Landfill) for treatment. Vacuum extraction is the preferred alternative for treatment of
solvent-contaminated soils. Non-hazardous materials uncovered during the project will be sent to the Anchorage Municipal Landfill. Clean soils extracted from the work areas will be used to bactill the excavated areas.
The proposed project was evaluated for environmental and engineering feasibility and consistency with pertinent environmental laws and regulations. Human Health Considerations. The potential risk of hazardous material leaks is considered to be low based on the work that has already been done at the PRDA. If a contaminated or hazardous material spill OCCLDX, spill response activities would begin immediately. Air will be monitored continuously during soil excavation to detect and quantify potential airborne chemical hazards. If a release of phosgene or mustard agent is detected, work will immediately stop until the soace is determined and corrxtive action taken. The entire project site will be fenced to prevent public access.
A release of phosgene gas would lx the maximum credible event (MCE) that might affect unprotected personnel off site. A U.S. Environmental Protection Agency/National Oceanic and Atmospheric Administration model shows an approximate hazardous distance of 675 yards, although this distance is considered to be well in excess of the realistic MCE.
Cultural Resource ConsideraGo! Previous surveys of Fort Richardson show that no cultural resources have been found in the project vicinity. The entire PRDA is an already disturbed area, and it has low potential to contain historic or prehistoric properties.
Therefore, there are no constraints on the project due to cultural source considerations.
The environmental assessment documents compliance with the National Historic Preservation Act, the Endangered Species Act, the Clean Water Act, and the National Environmental Policy Act. An environmental review process has shown that the project does not constitute a major Federal action significantly effecting the quality of the human environment. Therefore, an
environmental impact statement will not be prepared for the Poleline Road Removal Action, Fort Richardson, Alaska. |
Louis Howard |
| 7/30/1994 |
Update or Other Action |
Rapid Response Weekly report 002 received week ending on 7/30/94. 1 4' long by 12" diameter gas cylinder (propane or acetylene), 3 4' long x 24" diameter welded metal containers with 6" flanges on each end, 5 radiation dosimeter tactical E1R3 These units are approximately 2.5" x 4" by 1" thick and contain ampoules inside (4) with unknown liquid. The EOD checked the items and found no radiation content. 1 fire starter and numerous metal debris, respirator cartridges, military gas masks, rusted drums, pails, buckets not containing any liquid, white clumps of granular material resembling lime, pockets of heavy brown liquid. Saturday 7/30 located five CAIS (pig) units. 2 were sealed and intact and 3 were open on the flanged end and were empty. Contents are unknown. |
Louis Howard |
| 8/4/1994 |
Update or Other Action |
Rapid Response Weekly report 003 received week ending on 8/04/94. Zone 1 had significant amount of scrap metal including filter type cylinders yet to be identified. As indicated in the previous report six pigs were found in Zone 1. Zones 2,3,4 and 5 results were unremarkable: anomalies indicated in the CRREL GPR survey were most likely large (3-4 feet diameter) rocks which were unearthed as the areas were excavated. Very little scrap metal was found in these 4 areas. In zone 5 has yielded 9 ppm of volatile organics airborne on site. Large amounts of wood from decontaminating agent crates were would support the airborne release of volatile organics. Most significant finding in zone 6 area to date has been several drums containing what may be Molasses Residuum (MR) which is a tar like residue which was mixed by the military with an aerosol to simulate the consistency of Mustard for tests of flow and dispersion. Also found were drums which were labeled with the acronym GTN. This may possibly be drums which contained mixtures of CWM at one time. All drums found have been sniffed with the Minicam for Mustard and the results have been proven negative. |
Louis Howard |
| 8/13/1994 |
Update or Other Action |
Rapid Response Weekly report 004 received week ending on 8/13/94. Zone 8 of Area 3 found a white phosphorus smoke grenade and EOD detonated it up Barrs Blvd. in the designated detonation area. 8/10 2 pigs were found in zone 6 and EOD determined with an X-ray unit that one had noticeable contents and the other appeared empty.
A small cylinder was discovered about 12" x 2" in diameter. It was x-rayed and had no visible contents and was placed in the cylinder storage area with the other cylinders from last year. Thursday 11th, excavation from zone 7 found an amber bottle 8 inches by 4 inches in diameter was found. It had 2" of unknown clear liquid and its small mouth lid was intact and sealed. Several drums of black tarry material were found. They believe the material is probably "Molasses Residuum" (MR), which is a "thick syrupy residue obtained in the manufacture of ethyl alcohol from molasses to which 1.5% aerosol has been added in order to stabilize the material". The material was then diluted with water to make a 25% solution which is used in engineering tests of airplane spray tanks and thin gas bombs and chemical land mines as the material has the viscosity and surface tension sufficiently close to that of Mustard to insure comparable flow characteristics. The document for the MR substance was from the Huntsville Arsenal, and dated February 24, 1947. It goes on to say that "The material will have to be disposed of by either burying or burning, as the aerosol used for stabilization does not make the material fit for stock food". OHM has not determined with the reference to this "aerosol" may be.
Friday the 12th: Zone 6 unearthed many of the Molasses Residuum drums and other drums which were empty. Several of the drums were heavy in construction and had "I" Beam type chines which steel rings around the outside. EOD and Technical Escort Unit (TEU) pointed out that this type of drum was used to contain CWM. All I beam drums were previously punctured and burned and did not have any contents or test positive with the Minicam. The large GPR anomaly concentration in Zone 6 turned out to be this deposit of drums.
Saturday the 13th excavation continues in Zones 5 and 7. Approximately 20 cubic yards of a white unknown soft, pasty material was located. The material was in clumps and also in hundreds of small cans. The material expands in the cans from contact with moisture in the ground when the cans rust through. It is the white material is lime or the bleach part of the decontamination solution kit. Also found was an intact case of HC Smoke which is hexachloroethane smoke. Finally, several small vials with lids intact were uncovered containing a clear liquid. TEU discovered that the labels on some of them were in good condition and stated that the vials contained an eye decontamination solution which is non-hazardous. At the time of this report, Battelle has completed 9 soil stockpile analysis for CWM and associated breakdown products with all negative results. 5 more laboratory analysis results should be done by 8/16.
On Friday 8/12, during a regular work break, a WP smoke grenade ignited itself in the rockpile on the discharge end of the shaker screen. |
Louis Howard |
| 8/20/1994 |
Update or Other Action |
Rapid Response Weekly report 005 received week ending on 8/20/94. Zone 7 excavation Wednesday the 17th 9 full or partially full small amber bottles were located labeled "HD-Toxic Gas Set M-1" None of the bottles appeared to have leaked into the soils, however, when one of them was placed into a ziploc bag it began to leak inside the bag so they may have been leaking into the soil. The mini-cam result from inside the bag was positive. During the period while the bottles were being excavated, the mini-cam reading went to 0.25 of the TWA for Mustard. Also from the same area: 5 empty unmarked clear bottles, one larger 24 oz. amber bottle, 2 artillery round fuses and a pair of soldier's OG pants. The pants revealed low level positive contamination with Mustard as evidenced by placing them in a bag and testing them with the Minicam. Thursday the 18th, a white phosphorus smoke grenade was found with the pin and lever intact. The grenade was detonated at the detonation area by EOD personnel. Also from the same area: 100s of small medical septums which contained aureomycin which is the same as chlortetracycline which is a common antibiotic, rabies serum, and gangrene serum. Friday 19th an additional 300-400 medical vials were found and a small HC white smoke grenade was found and set aside for EOD disposition.
Saturday the 20th: 3 pigs, 2 of which were verified to have some contents by EOD's portable X-Ray Unit. Contents appear to be the metal lids of the original packing tubes used to hold the glass ampoules. 6 small gas cylinders which were burned had unknown content. |
Louis Howard |
| 8/27/1994 |
Update or Other Action |
Rapid Response Weekly report 006 received week ending on 8/27/94. 8/24 11 drums previously overpacked but not sampled were drum punched and no Mustard was detected during monitoring immediately after punching. It appears that the drums have the same black tarry residue as the first drums that were samples. Thursday found small kits in the excavation containing lewisite eye ointment. Friday the 26th found oil cans, debris including flame thrower canisters and parts and stropine injector kits. One intact glass ampoule approximately 7 inches in length x 1 inch in diameter. The ampoule was approximately 5/8 full of a low viscosity yellow liquid. The liquid is believed to be phosgene. Saturday the 27th zone 9 of Area 4 a small round bakelite CS (teargas) grenade, the warhead of a bazooka rocket, a fuse from an artillery round, and a fuse from a smoke grenade were found. All items were removed from site by EOD and detonated at the detonation area. After extensive effort, it has been determined that the Photovac detector on site cannot distinguish between 1,1,2,2 Tetrachloroethane, Tetrachloroethene, and Trichloroethene. This takes away OHM's ability to screen samples at the site with this device. The PhotoVac detector has been sent off site and OHM will continue to only send 20 foot grid samples off site for analysis. Field chemist has been dispatched off the project. During the week while sampling, OHM used the excavator to collect samples at 18 inches, 36 inches and 54 inches below the bottom of Area 3 excavation as it now exists. The 36" sample was 10,000 ppm 1,1,2,2 Tetrachloroethane. However, at 54" the sample was 29 ppm. |
Louis Howard |
| 9/1/1994 |
Update or Other Action |
Rapid Response Weekly report 007 received. Excavation of zones 9 and 10 of area A-4 continues. Large amounts of rusted, deteriorated ordnance found. 8/29 zone 9 of A-4 three empty drums, 4 small smoke grenade fuses and 2 HC smoke grenades were encountered. Tuesday excavation yielded 9 M51 type artillery round fuses, 1 75mm artillery round warhead and 1 small bottle labeled "CN". CN is the military symbol for Chloroacetophenone which is very similar to tear gas. The bottle was empty.
Wednesday was the largest find of ordnance to date. 1 smoke grenade, 16 rifle grenade tail booms, 4 M51 Fuses, 27 aluminum grenade bodies, 3 Nose fuses, 1 fire starter, 1 large HC smoke pot, 4 2" long x 8" diameter canisters with liquid, 8 intact rifle smoke grenades, 2 empty 75mm casings, and 2 empty 105mm casings. Thursday in the same area 22 M51 type fuses, 85 rifle smoke grenades and 1 HC smoke grenade were found. |
Louis Howard |
| 9/7/1994 |
Update or Other Action |
Staff reviewed and commented on the demonstration of the dirt burner by vendor proposal for PRDA soils. ADEC has noted at the last RPM meeting September 1, 1994, it was discussed that a demonstration by an unsolicited vendor was being considered who would use thermal treatment of contaminated soils at Poleline Road. While ADEC is not adverse to thermal treatment, per se, the Army will have to provide a workplan or scope of work for the proposed action for ADEC approval. The current stockpiling of the contaminated soil is adequate for protection of human health and the environment. Use of the thermal treatment even on a small scale is premature and requires prior ADEC approval. |
Louis Howard |
| 9/10/1994 |
Update or Other Action |
Rapid Response Weekly report 008 received. Excavation was from A-4 zone 10 and on Wednesday 9/7 items removed were as follows: 1 HC smoke pot, 2 105 mm artillery rounds, 8 M51 Smoke Pots, 1 nose fuse, 2 M18 smoke grenades, several CN ID set bottles, 1 rifle grenade fuse. Friday more scrap metal found and 3 empty 105 mm casings. Saturday 2 small lecture bottles, 1 1/2 gallon amber jar with no lid, empty, 5 empty 55 gallon drums, 5 flame thrower canisters and more metal debris was found. 1500 cubic yards soil moved to date with organic contamination. |
Louis Howard |
| 9/17/1994 |
Update or Other Action |
Rapid Response Weekly report 009 received week ending on 9/17/94. Monday 9/12 continued in zone 10 of Area A-4: six flame thrower canisters, 5 cubic yards of scrap metal, 2 lecture bottles of unknown content, and 1 small jar with unknown white powder. 2 composited samples from the 24 tarry substance drums to Columbia Analytical for predisposal analysis. 24 individual samples from the drums were sent to ERDEC for individual analysis for Lewisite. Zone 10 yielded 2 HC smoke grenades, 1 empty 75mm round, 1 empty 105mm round and 1 small jar with white material. Wednesday morning Area A-3 was excavated and a 5 gallon pail was removed from the excavation by the excavator. During removal, it produced a white vapor cloud around the front of the excavator. Work was stopped immediately and TEU checked the pail for CWM content and the Mini-cam had a positive hit of 1.89. Subsequent tests with the Mini-cams continued to yield results over 1. Tests of the M-18 kits did not confirm the presence of Mustard. TEU placed the granular material which had spilled on the ground during removal from the excavation and the pail which was 2/3 full of the material into a 17-H drum. The material was reacting with the moisture in the air and producing not only white vapor but also producing enough heat to melt the plastic bags that they had first attempted to place it in.
It was later discovered that not only was the material water reactive, it exhibited a pH of 14. They believe it is Potassium Hydroxide or "Lye". Zone 4 excavated and found: 2 M60 machine gun belts with unfired blanks, miscellaneous scrap metal, respirator cartridges, 2 tail fins for 250-500lb bombs, 24 small clear bottles marked hydrochloric acid, 1 wood crate part marked "hydride charge" packaged in 1953, 1000s of old mustard and lewisite detector tubes from detector kits which were predecessors to M18-kit and 11 additional lecture bottles of unknown contents. This particular trench was found by random chance only. It was NOT indicated on the CRREL GPR/EM survey map. It was completely outside the CRREL survey area up the hill side past survey points. Trees and brush had to be removed to access the buried debris as it was encountered. |
Louis Howard |
| 9/21/1994 |
Update or Other Action |
Staff approved the OUB Proposed schedule as submitted. |
Louis Howard |
| 9/24/1994 |
Update or Other Action |
Rapid Response Weekly report 010 received week ending on 9/24/94. Friday the 23rd, a small CAIS kit (16" x 6" diameter) was found and EOD x-rayed it and determined it was empty. |
Louis Howard |
| 9/29/1994 |
Update or Other Action |
Modification to original workplan for additional excavation at PRDA. Modification will allow project team to excavate the south area of A-3 which will remove soil from the area to the border where the landfill meets the wetland. The reason for the excavation it to remove chlorinated solvents and not GPR anomalies, CRREL (D. Lawson) performed the original GPR and EM61 survey of the site developed anomaly maps from which the project was formatted.
CRREL's visit on 9/27/94 assured that there were no significant EM61 (metal) hits in the area to be excavated and that the minimal amount of GPR hits that occurred in the area were most likely from decayed roots and foliage which formulate a layer visible at 2-3 meters in depth and the Technical Escort team and all their equipment have been demobilized from the job site. |
Louis Howard |
| 10/15/1994 |
Update or Other Action |
Rapid Response Weekly report 013 received week ending on 10/15/94. Loaded 4 twenty yard bulk roll off bins with the white solid material. Material is destined for chemical waste management's Arlington Oregon Facility. A total of 79.5 tons was transported to be stabilized and landfilled at the disposal facility on Monday. On Tuesday, 5 twenty yard bulk roll-off bins with scrap wood and metal debris. 90 yards was loaded for transport to CWMA Oregon Facility for macroencapsulation and landfilled. |
Louis Howard |
| 11/10/1994 |
Document, Report, or Work plan Review - other |
Staff reviewed and commented on the ARARs, TBCs, CSM, and DQO letter reports for OUB RI management plan. Again the document was requested by the Army to be reviewed in less than thirty days. ADEC states the normal review time scheduled for documents of this nature is 30 days, however we have conducted an expedited review of the documents. ADEC reserves its right to comment further on the documents in the future submittals (i.e. the Management Plan). On the ARARs issue, please refer to the OU A letter by ADEC and the attached universe list of ARARs.
ADEC requests the Army review these attachments and list the requirements that have a bearing on the site. ADEC requests further analysis of the inhalation pathway under sec. 4.0 Summary of Uncertainties or a more detailed explanation on why the air pathway will not be investigated or addressed. The conceptual site models and management plan rationale covering project data quality considerations (i.e. data use, data quality levels, etc.) in OU A's management plan should be followed in some form or fashion for consistency between the operable units.
ADEC requests this section be expanded on in detail on why some ARARs were adopted and the justification for adopting federal statutes over State statutes/regulations. Again, it is emphasized that the format and rationale used in OU A be followed for OU B for consistency. The text discusses potential chemical specific and location specific ARARs biased towards groundwater and soil with no discussion regarding air as a media of concern. Given the potential exposure for contaminants via the air pathway at PRDA, it is not unreasonable to include mention of the applicable federal and state air standards. |
Louis Howard |
| 1/6/1995 |
Site Characterization Workplan Approved |
Staff reviewed and commented on the draft management plan. Note that wells should not be purged dry if samples for volatiles analysis will be collected. The VOCs can be readily volatilized as water cascades from the screen to the bottom of the well. Instead of using bailers for purging and sampling as proposed in the text, it is suggested that dedicated bladder pumps be used. The bladder pump has proven to be acceptable for both purging and sampling in many cases. Advantages of using a bladder pump are:
1) highest degree of accuracy and precision of any pumping device under a wide range of field conditions; accuracy not subject to operator error; 2) can be constructed of desirable materials (as can bailers), 3) high lift capability for sampling, up to 1000 feet for squeeze type designs, though flow rate at these depths is very low; 4) flow rate can be varied for purging and sampling; 5) very reliable, long bladder life for squeeze type designs; 6) can be easily repaired in the field.
Disadvantages may preclude them from being used at Fort Richardson: 1) flow rates drop with depth and may be too low for deep well or high volume purging applications; 2) the bladder is susceptible to damage by sand if inlet screen is not used; 3) operating costs can be high if compressed air/gas cylinders are used.
While bailers are acceptable as purge devices, they are impracticable where a well has little more than a small quantity of water. Also, it should be noted the bailers may reach their practical depth limit of 100-150 feet in deep wells at PRDA which penetrate bedrock at 80-160 feet below ground surface. Furthermore, the bailers may expose the well to the surface contamination, the operator to potential contaminants, and if used improperly, can cause sample aeration/agitation and increased turbidity due to water column surging.
Location standards of RCRA are only applicable if remedial activities are located in a seismically active zone within 200 feet of a fault displaced in Holocene time. Since the nearest seismically active zone is the Border Ranges Fault zone located one mile east of PRDA, it appears this specific ARAR is not applicable at this time. Add to table 4-4 Potential Action Specific ARARs: Identification and listing of hazardous wastes 40 CFR Part 261 referenced by the text on WP 4-14. Include in the table and the text: Alaska Wastewater disposal regulations 18 AAC 72 which includes specific engineering plan requirements (18 AAC 72.600 (c) and (d). Discharge criteria are contained in 18 AAC 70. Other ARARs to include are: 18 AAC 75 Oil and Hazardous Substances Pollution Control and AS 46.03.100.
The text states decontamination fluids and well purge water will be discharged on site or sprinkled onto the contaminated soil stockpiles with prior approval by ADEC and the EPA. IDW management will need to be handled in a similar fashion on a post-wide basis for all OUs that generate IDW. A central staging area that is fenced and locked may be more appropriate instead of having drums of IDW located at each site (for each OU). It would be unacceptable to discharge the fluids/purge water onto the contaminated soil stockpiles regardless of the analyses results, since that may enhance mobilization of the contaminants possibly complicate future remediation of the stockpiled soils. |
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. While this is the only reference to the chemical filling plant, the map along with the discoveries of CAIS kits/PIGS at PRDA and other historical evidence of CWM storage offers further insight in The Post's former role as a center for stocking and possibly disposing of CWM. |
Louis Howard |
| 7/1/1995 |
Update or Other Action |
Rapid Response Weekly report 002 received. Water samples from rinsate collection pool yielded 18 ppb trichlorethene and 270 ppg 1,1,1,2 Tetrachloroethane. OHM elected to mechanically filter and carbon adsorb the water. Subsequent analysis following treatment yielded no detectable levels of organic solvents. Rinsate discharged on site. 200-300 cubic yards of soil removed from rocks. |
Louis Howard |
| 7/15/1995 |
Update or Other Action |
Draft Final Report Phases I and II PRDA contract # DACW645-94-D-005 OHM Project Number 16209 December 1994. Phase I PRDA remobilization to loadout wastes. 12/7/93 Alaska Cargo Transport moved 20 feet containers to Ammo Storage Area B at the Post. Soils, scrap metal, and PPE loaded on 12/7 and 12/8. 12/9 Alaska Cargo spotted a container at the Post hazardous waste storage area and OHM began loadout of the drums of liquids from well purging an rinsate from decontamination. Altogether there were 253 DOT boxes of soil and 10 boxes of PPE and scrap metal and 16 drums of purge water and rinsate. The DOT Triwall boxes of soil and the liquid drums were incinerated at Aptus Environmental in Arogonite UT. PPE and scrap metal were landfilled by Burlington Environmental.
Transportation and disposal summary table lists:
1) White Solid sent to Chem Waste Arlington for Stabilization
2) Scrap metal/wood 90 cubic yards to Chem Waste Arlington for Macroencapsulation,
3) PPE 33 cubic yards to Chem Waste Arlington Direct landfill,
4) Molasses 26 drums to Burlington Environmental for incineration,
5) water reactive 1 drum sent to Burlington Environmental for Incineration,
6) unused medical vials 1 drum sent to Burlington Environmental for incineration,
7) Mustard Test Kit tubes 2 drums sent to Burlington Environmental for incineration.
Excavation analysis results were found to contain adamsite in all of the samples. Other CWM products and other breakdown products were not found. Results ranged from 0.24 ppm in SP-01 to 3.7 ppm in SP-02 and 4.1 in SP-03. Confirmation samples taken from the excavation at the conclusion of the removal were taken. CWM screening was done before any other analyses was conducted. Adamsite was found in samples and VOCs analysis was conducted several months after receipt so holding times were violated. Results of analysis are to be considered estimated values and biased low or suspect. Soil confirmation results for adamsite ranged from ND to 13 ppm in SC-A-D7 and 14 ppm in SC-A-07. |
Louis Howard |
| 8/8/1995 |
Update or Other Action |
Geophysical Investigations of the Poleline Road Disposal Area-Draft Final Report August 8, 1995. CRREL conducted additional ground-penetrating radar (GPR) and Electro-Magnetic Induction (EMI) investigations in June 1995 which show that the 1994 excavations by OHM Remediation Services Corp. successfully removed all major metallic objects. The few scattered, minor EMI anomalies that remained are most likely attributable to the presence of small near-surface metallic debris. For the purpose of these investigations, the PRDA was divided into two general areas: east and west of a baseline established in 1994.
West of the CRREL baseline, GPR and EMI investigations indicate that no substantial metallic materials remain buried. EM data indicate that only minor amounts of near surface metallic debris remain. The GPR data reveal locations of excavation and backfilling in 1994 as well as other suspicious zones, with scattered anonmalies presumably resulting from the complex assortment of fill materials.
The 1995 investigations east of the baseline further define the depth to and extent of the anomalous areas T-1 and T-2. Both areas contain high-amplitude EMI anomalies. Significant amounts of buried metallic debris refuse exist within these two areas, while a
slightly smaller anomaly also indicates some buried materials between the two areas. In addition, EM data indicate scatterd near-surface material across the entire PRDA east of the baseline. GPR profiles exhibit numerous targets at depths ranging from typically 1.5 to 3 meters and subsurface horizons on the GPR records suggest a buried surface which could have been the floor of a former excavation or the former ground surface.
In addition, the EMI survey indicates scattered, small, near-surface objects across the entire site. (*Japanese cluster bombs?) The GPR profiles tell us that targets lie approximately 1.5 to 3.0 m below the surface and that some of these targets are presumably large (e.g., the size of a 55-gal. drum). A broad GPR horizon,
present on most profiles, may represent a former ground surface, buried after debris disposal. This surface may have been the floor of broad pits within which metallic materials were concentrated.
Alternatively, this surface may have been the natural ground surface onto which material was dumped and covered. An intense and continuous GPR horizon in the T-1 area suggests
trench burial techniques. There are no current plans for further removal of this buried debris from PRDA. |
Louis Howard |
| 12/21/1995 |
Document, Report, or Work plan Review - other |
Staff reviewed and commented on the Eco-Risk Assessment Approach Document. ADEC requested including a source for the information concerning site hydrology and coastal zone management reports/maps from the coastal zone managment (CZM) section at ADEC. Please elaborate as to what is considered a highly toxic contaminant in reference to ecological receptors. Add to the list of screening concentrations the most recent NOAA screening criteria for water, sediments, and soils. |
Louis Howard |
| 1/24/1996 |
Update or Other Action |
Quarter 1 Groundwater elevation report. Depth to groundwater measurements were collected on November 1, 1995, December 4, 1995, and January 3, 1996. The measurements were collected using a water level indicator which is dedicated to the site and were also made by the same field technician. Table 1 presents the groundwater elevations in each of the wells for the three dates. Figures 1 - 6 present the groundwater contour maps for
the deep and shallow aquifers for the three dates.
Review of the data presented in this report indicates that more saturated zones are screened at PRDA than just the shallow and deep aquifers. There appears to be at least one additional saturated interval between the shallow and deep aquifer, and also a perched water table above the shallow aquifer. The water levels measured in MW-3, MW-4, and W-7 suggest that these wells are screened, at least partially, in an intermediate saturated interval but are not screened in the deep aquifer. MW-14 appears to be screened in the perched interval. The water level measurements taken from these wells were not used for contouring the shallow or deep
groundwater aquifers.
The groundwater flow direction for the shallow aquifer is to the northeast. The groundwater flow direction for the deep aquifer is to the north, generally. The water level measured in MW-9 may indicate that the groundwater flow direction is shifting to the northwest north of the site. |
Louis Howard |
| 4/23/1996 |
Update or Other Action |
Quarter 2 Groundwater Elevation report. Depth to groundwater measurements were collected on February 1, 1996, March 1, 1996, and April 1, 1996. The measurements were collected by the same field technician using a water level indicator which is dedicated to the site. Table 1 presents the groundwater elevations in each of the wells for the fast and second quarters. Figures 1 - 6 present the groundwater contour maps for the deep and shallow aquifers for the second quarter.
Review of the data presented in this report confirms the conclusions documented in the
Quarter 1 Groundwater Elevation Report (January 24, 1996). There appears to be at least one additional saturated interval between the shallow and deep aquifer, and also a perched water table above the shallow aquifer. The water levels measured in MW-3, MW-4, and MW-7 suggest that these wells are screened, at least partially, in an intermediate saturated interval but are not screened in the deep aquifer. MW-14 appears to be screened in the perched interval. T’he water level measurements taken fkom these wells were not ,used for contouring the shallow or deep groundwater aquifers. The water levels in the shallow aquifer are dropping at a faster rate (2 to 3 feet since November) than the deep wells (0 to 1 foot since November). |
Louis Howard |
| 5/2/1996 |
Document, Report, or Work plan Review - other |
Staff reviewed and commented on the draft remedial investigation report and risk assessment OU B. The text states no remediation of in-situ soils is necessary for the site. ADEC disagrees with the recommendation since areas A-3 and A-4 are contaminated with high levels of solvents in close proximity to the shallow aquifer at the site and may act as a source for further groundwater contamination (refer to the Risk Assessment page 7-2, 4th bullet). ADEC requests further evaluation of the contaminated soils that are beneath A-3 and A-4 in the feasibility study to determine if the soils are a source of groundwater contamination. A limited source removal of hot spots in areas A-3 and A-4 may be warranted to eliminate the source of solvent contamination.
ADEC requests the Army identify how long it will take for the current levels of contamination in the groundwater to degrade to drinking water MCLs in conjunction with the feasibility study being prepared by the Army. ICs (i.e. deed restrictions or future land use prohibitions) is an avenue the Army may wish to consider while contamination levels are above action levels during any remedial action time frame.
The text states in Appendix XIII 1,1,2,2 tetrachloroethane from 1995 data was used for the model calibration because it was the highest level in groundwater (SB-D2 at 102,400 ug/L). A more realistic approach would have been to incorporate data from MW-14 in Layer 1 using 1,900,000 ug/L as an input parameter for the model. Please elaborate as to why this approach was not taken. The data was flagged as J which is an estimated value due to exceeding the holding times of 7 days (11 days). This should not have excluded the data from MW-14 from being incorporated into the model. |
Louis Howard |
| 5/23/1996 |
Document, Report, or Work plan Review - other |
Staff commented on the technical memorandum for remedial alternatives development. Staff requested the Army review the attached list of ARARs that potentially apply to CERCLA sites. Please note the list of ARARs is not to be used as an alternative for analysis of ARARs as required by the NCP, but to assist in the initial screening of potential ARARs to perform the required ARARs analysis.
There was no mention of ARARs in the memorandum submitted to ADEC. Analysis of ARARs is an iterative process and the State reserves its right to include other ARARs should events warrant an expansion of this list which was submitted to the Army. |
Louis Howard |
| 6/25/1996 |
Document, Report, or Work plan Review - other |
Staff reviewed and commented on the Technical Memorandum #2 for Detailed analysis of Alternatives OU B. Alternative #1 No Action is not a true no action alternative if it includes groundwater monitoring and institutional controls (ICs). A no action alternative would mean the site would remain in its present condition and therefore no costs are associated with the alternative. ADEC requests the Army include institutional controls and groundwater monitoring under a new alternative in the technical memorandum and subsequent feasibility study.
The ICs listed need further explanation on how the Army will restrict groundwater use at the site and development around the immediate disposal area. Other facilities have used their base management plan as a means of limiting development or construction activities at their installation. The text states the objective of the cleanup is not to reduce the contamination in the shallow groundwater units since they are not potential drinking water sources. Please elaborate more as to the Army's determination that the shallow groundwater units are not drinking water sources. |
Louis Howard |
| 7/29/1996 |
Update or Other Action |
Staff received the Remedial Investigation (RI) at Operable Unit B (OUB), the Poleline Road Disposal Area (PRDA) at Fort Richardson, Alaska. Previous investigations & removal actions identified 4 disposal areas that were used between 1950 & 1972 for the disposal of chemical warfare training materials & halogenated solvents. Two of the disposal areas (Areas A-3 & A-4) were excavated in 1993 & 1994 & were backfilled with soil meeting removal action levels. The other 2 areas (Areas A-I & A-2) have not been excavated & potentially contain unexploded ordnance.
Soil samples were collected from borings drilled around the former disposal areas & through the backfill at Areas A-3 & A-4. Levels of contaminants in soils are generally well below regulatory levels outside of the disposal areas. None of the samples collected from the backfilled soil in Areas A-3 & A-4 exceeded the cleanup criteria used during the excavation (1,1,2,2-tetrachloroethane, 30 mg/kg; tetrachloroethene, 100 mg/kg; & trichloroethene (TCE), 600 mg/kg). However, 2 soil samples collected beneath the previous excavation in Area A-3 had levels of 1,1,2,2-tetrachloroethane (79 mg/kg & 2,030 mg/kg) which exceeded the cleanup criteria used during the excavation. These samples were collected just below the water table while drilling MW-14. The GW sample collected from this monitoring well had higher levels of VOCs than any other GW sample collected at OUB.
A well point was placed in each of the soil borings where GW was encountered. A GW sample was collected from each well point & analyzed in an on-site lab for halogenated solvents. The results of these analyses were used to select the locations for the permanent monitoring wells. The pattern of solvent detections in the well points & monitoring wells suggests that solvents have migrated in the direction of GW flow, to the northeast from Areas A-3 & A-4.
Halogenated solvents were found in both the shallow & deep water bearing intervals. 1,1,2,2-tetrachloroethane & TCE, were found at levels significantly higher than any other VOCs detected at OUB. The Alaska MCL for TCE in water (0.005 mg/L) was exceeded in 10 of the 14 monitoring wells sampled for VOCs. There is no Alaska MCL for 1,1,2,2- tetrachloroethane. The Alaska MCLs for several other VOCs were exceeded in GW samples collected from monitoring wells. Most of these came from the well located in Area A-3 or from wells close to Areas A-3 & A-4.
One GW sample (MW-14) had thiodiglycol detected (0.48 mg/L). Thiodiglycol is a breakdown product of mustard. No other samples had any chemical warfare materials or chemical warfare material breakdown products detected. Minor detections of explosives were reported in the wetlands & in one wellpoint GW sample, but levels are below ARARs. Metals are generally within or near background.
The risk assessment concluded OUB poses no imminent threat to human health or the environment, based on a lack of complete exposure pathways. A GW model performed using MODFLOW & MT3D estimated that the solvents would take over 100 years to reach the Eagle River.
Areas A-1 & A-2: The compound 1,1,2,2-tetrachloroethane was detected in six samples. No other VOCs were detected in samples collected around Area A-I & A-2. The detection limit for the field GC was 0.05 mg/kg. Detected levels of 1,1,2,2-tetrachloroethane ranged from a low of 0.12 mg/kg in MW-13 (26-28') to a high of 1.7 mg/kg in SB-B1 (4-6'). The residential soil RBC for 1,1,2,2-tetrachloroethane (3.2 mg/kg) was not exceeded. NOTE TO FILE: 2009 18 AAC 75 Soil migration to GW cleanup level is 0.017 mg/kg (more than two orders of magnitude lower) & the outdoor inhalation level is 5.5 mg/kg.
Areas A-3 & A-4: VOCs were found in 21 of the samples screened. The following compounds were detected: trans-I,2-dichloroethene (2 samples), cis-l,2-dichloroethene (2), chloroform (3), TCE (14), 1,1,2-trichloroethane (2), tetrachloroethene (2), 1,1,2,2-tetrachloroethane (19), carbon tetrachloride (1), bromoform (2), & 1,1,1,2- tetrachloroethane (1). The sample with the highest levels of chlorinated solvents was collected from MW-14 (16-18'). The level of 1,1,2,2-tetrachloroethane was 2,030 mg/kg & TCE was 384 mg/kg. Four screened samples contained VOCs above RBCs. The RBCs for carbon tetrachloride (4.9 mg/kg), tetrachloroethene (12 mg/kg), 1,1,2,2-tetrachloroethane (3.2 mg/kg), TCE (58 mg/kg), & 1,1,2-trichloroethane (11 mg/kg) were exceeded in the sample collected from the 16- to 18-foot interval in MW-14.
NOTE TO FILE: 2009 18 AAC 75 cleanup level exceeded (except where noted) for carbon tetrachloride: 3.1 mg/kg outdoor inhalation & 0.023 mg/kg migration to GW. Tetrachloroethene (PCE): 10 mg/kg outdoor inhalation & 0.024 mg/kg migration to GW. TCE 0.57 mg/kg outdoor inhalation & 0.020 mg/kg migration to GW. 1,1,2-tricholoroethane 11 mg/kg outdoor inhalation (same) 0.018 migration to GW.
See site file for additional information. |
Louis Howard |
| 7/29/1996 |
Conceptual Site Model Submitted |
Chemical compounds have leached from the PRDA into the adjacent groundwater (GW). A conceptual model (CM) of the GW system & the on-site sources of volatile organic compounds (VOC) contamination was developed from an interpretation of the available information. From this CM, a numerical model was developed & used to estimate travel time & VOC levels in GW when it. discharges into the ER. The GW modeling study area is bounded by the ER to the north & the Anchorage LandfIll to the south. The study area extends approximately 4000 & 5400’ from the PRDA to the west & east, respectively.
Four general GW elevation zones are assumed: perched, shallow, intermediate & deep. The separation of the GW system into vertical zones is not intended to imply the zones are hydraulically separate. On the contrary, it is believed that the shallow, intermediate & deep zones are connected. This assumption is supported by the presence of VOCs in the deep GW zone at the PRDA site. The 3 zones do differ, however, in the way that they are influenced by recharge & by their average hydraulic properties.
Perched GW was encountered in the vicinity of areas A-I, A-2, & A-3, but was not encountered away from the disposal areas. Shallow GW was encountered in the surficial glacial sediments & glacial tills. The vertical component of flow is expected to be downward from the shallow zone to the deep zone. This interpretation is supported by downward vertical gradients & the presence of VOCs in the deep GW zone. A deep GW zone was encountered in the advance moraine/till complex. The bedrock underlying the advance moraine/till complex is modeled as an impermeable unit that GW does not penetrate. None of the GW monitoring wells are screened exclusively in the bedrock unit & as a result the GW potentiometric head in the bedrock is unknown. The lateral extent of the shallow, intermediate & deep GW zones beyond PRDS is unknown. To be conservative, it is assumed that all 3 GW zones extend to ER & discharge into it.
The U.S. Geological Survey (USGS) three-dimensional finite difference GW flow model (MOD FLOW) (McDonald and Harbaugh 1989) was selected for use. This model code was selected because it is applicable for simulating site flow conditions on a large scale and because it is a thoroughly documented and widely accepted modeling code.
A three-dimensional finite difference model, MT3D (Papadopulos 1992) was selected to simulate the fate and transport of dissolved organic compounds in GW. MT3D incorporates the flow field estimated by MODFLOW and simulates advection, dispersion, retardation and biodegradation in GW.
Fraction organic carbon (FOC) was estimated from lab tests performed on 4 soil samples collected at or above the water table. The FOC carbon ranged from 0.19% to 0.66% with a geometric mean of 0.39%. A FOC content of 0.39 was assumed in the model. A range of normalized organic carbon distribution coefficients (Koc) for 1,1,2,2-tetrachloroethane was assumed during model calibration. A minimum Koc of 46 ml/gm . (Montgomery and Welcom 1991) and a maximum Koc of 117.5 ml/gm (Knox et. al 1993) were assumed during model calibration.
Biodegradation is modeled using a first-order rate law. The biodegradation is assumed to equal zero for the model calibration and the estimation of future contaminant plume migration. This assumption will result in a conservative (high) estimation of concentrations.
The sensitivity analysis results indicate that the 1,1,2,2-tetrachloroethane GW level of 0.005 mg/L will reach the ER in approximately 180 or 190 yrs. for the shallow (Layer 1) and deep (Layer 3) GW zones. In comparison to the base case model simulation, the travel time from PRDA increases by approximately 10 yrs. The travel time increases because the base case plume grows faster than the plume resulting from the sensitivity analysis.
The sensitivity analyses indicate that a 100 % increase in the longitudinal dispersivity will increase the travel time in the shallow zone to the ER by 10 yrs. The model results indicate that a 1,2,2-tetrachloroethane GW level of 0.005 mg/l will reach the ER in approximately 180 yrs. (after 1995) for both the shallow (Layer 1) and deep (Layer 3) GW zones.
The model results indicate that a 1,2,2-tetrachloroethane GW level of 0.005 mg/L will reach the ER in approximately 170 yrs. or 180 yrs. (after 1995) for the shallow (Layer 1) and deep (Layer 3) GW zones. Similarly; the estimated travel time for a TCE GW level of 0.005 mg/L to reach the ER is approximately 120 or 130 yrs. for the shallow (Layer 1) and deep (Layer 3) GW zones.
The model results indicate that a 1,2, TCA GW level of 0.005 mg/L will not reach the ER for 500 yrs. in either the shallow (Layer 1) or deep GW zones. Even though the 1,1,2 TCA retardation factor is lower than 1,1,2,2- tetrachloroethane retardation factor, a 0.005 mg/L 1,1,2 TCA concentration does not reach the river for 500 yrs. |
Louis Howard |
| 8/29/1996 |
Risk Assessment Report Approved |
Staff received the Remedial Investigation (RI) at Operable Unit B (OUB), the Poleline Road Disposal Area (PRDA) at Fort Richardson, Alaska. Previous investigations & removal actions identified 4 disposal areas that were used between 1950 & 1972 for the disposal of chemical warfare training materials & halogenated solvents. Two of the disposal areas (Areas A-3 & A-4) were excavated in 1993 & 1994 & were backfilled with soil meeting removal action levels. The other 2 areas (Areas A-I & A-2) have not been excavated & potentially contain unexploded ordnance.
A risk assessment was performed and is provided as a separate document. The risk assessment concluded that the site poses no imminent threat to human health or the environment, based on a lack of complete exposure pathways. A groundwater model performed using MODFLOW and MT3D estimated that the solvents would take over 100 years to reach the Eagle River.
Future land use includes the potential for closure of Fort Richardson. A pipeline carrying
drinking water from Eklutna Lake (over 15 miles from the site) runs through the area. It is
unlikely that groundwater would be used for a drinking water supply. The area is not suitable
for agricultural purposes. The potential for future residential use of the area is remote, but was considered for screening purposes in the risk assessment.
Direct contact with contaminated soils is an unlikely transport mechanism at OUB. Surface
and near surface soils have low concentrations of halogenated solvents, and the.site is
covered by snow for most of the year. A risk assessment was completed for the ~,ite and
concluded that the risk to human health at the site is negligible. The risk assessmentgsed a
conservative residential exposure scenario. Currently, and most likely in the future, access to
the site is limited to occasional military personnel or recreational users.
A risk assessment was conducted to evaluate the risk posed to human health and the environment by the site. A groundwater model was used to predict the time needed for halogenated solvents
at the site to reach one receptor, the Eagle River. The groundwater model predicted a time of
over 100 years for groundwater with a concentration of 0.005 mg/L to reach the Eagle River.
The risk assessment concluded that the contaminants at OUB do not pose an imminent threat
to human health or the environment under current and likely future exposure scenarios.
Concentrations of contaminants are relatively low except in soils at depths greater than 15
feet bgs and in groundwater, for which there are currently no complete exposure pathways.
Solvents were released at the site over 20 years ago. During this time the solvents have
traveled a relatively short distance. The groundwater model estimated that solvents would
take over 100 years to reach the Eagle River, one mile north of the site. The regional
groundwater flow direction is toward the northwest, which carries site contaminants away
from water wells located over a mile east and northeast of the site. The Eagle River acts as a
groundwater discharge area, preventing groundwater from crossing under the river and into
the community of Eagle River.
The U.S. Army owns all of the land between the site and the Eagle River and also north of
the Eagle River, and probable future land use is most likely industrial or recreational. A risk
assessment based on a conservative residential use scenario concluded that the site poses no
imminent threat to human health or the environment, based on the lack of complete exposure
pathways.
See site file for additional information. |
Louis Howard |
| 8/29/1996 |
Site Characterization Report Approved |
Staff reviewed and commented on the draft final remedial investigation/feasibility study (RI/FS) and risk assessment received on July 29, 1996. Staff stated that the levels of halogenated solvents in the soil, particularly in areas A-3/A-4, would appear to be significant contributors to groundwater contamination. Contamination of the aquifer may continue by not removing the source material ( i.e. the hotspot associated with MW-14). Addressing contamination using a proactive remedial technology would be more protective of the groundwater than solely using natural attenuation.
ADEC requests elaboration on what modeling was used for the groundwater and where the results are found. Staff requested clarification on if a bioreactor will be evaluated as a part of the treatability study or not.
ADEC requests the Army provide the citation to Army regulation which requires inclusion of evaluating natural attenuation as a remedial action alternative for petroleum and non-petroleum contaminants. The Army would be required to monitor for all the abiotic/biotic degradation products that would be expected to be produced from the chlorinated compounds at the site. The statements on par. 3 of page 3-3: "The likelihood that biotic degradation is occurring at the site is low,… The rates of both biotic and abiotic degradation are probably low due to the slow groundwater movement and cooler than average soil and groundwater temperatures.", do not make a sound argument for exclusively counting on natural degradation to treat the chlorinated contamination at the site.
Overall Protection: ADEC does not agree with the statement that this alternative is currently protective of human health and the environment simply because there are no complete exposure pathways under the current land use scenarios. This alternative does nothing to protect the environmental resources of the State, namely groundwater, from being further degraded from contaminants at the site. The text needs further clarification on whether or not the future use of the site will include any construction at the site or have groundwater used in any matter.
ADEC requests further elaboration on where the 100 year scenario for groundwater contamination not to exceed regulatory limits at Eagle River for plume migration off site. ADEC requests further explanation on the significance of using the installation boundaries for ARARs compliance.
The potentially applicable solid waste requirements includes new 18 AAC 60.025 (1/28/96) governing disposal of "polluted soil". See definition at 18 AAC 60.990(99). Citation to 18 AAC 60.035 should be removed (it was repealed as of 1/28/96). See also 18 AAC 60.200(a)(3) (solid waste permit exception for disposal under an approved 18 AAC 75 contaminated site cleanup plan). Text of 18 AAC 75 does not support the statements made in the 2nd par. of A.1.3.8 Alaska Oil and Hazardous Substance Pollution Control Requirements. Please specify the source for this interpretation. |
Louis Howard |
| 9/13/1996 |
Document, Report, or Work plan Review - other |
Staff reviewed and commented on the Draft EE/CA for the Treatment and Disposal of Chemical Agent Identification Sets from Operable Unit B. ADEC concurs with the alternative 2 selected to treat the chemical agent identification sets (CAIS) and associated contaminated debris on site using the Rapid Response System. ADEC also concurs with the disposal at a permitted facility of the associated hazardous wastes generated as a result of the treatment of the CAIS. The Army must remain cognizant that any hazardous substance, pollutant, or contaminant transferred or otherwise managed off-site as a result of the Federal Facility Agreement must be taken to a facility acceptable under U.S. EPA's Off-Site Rule (58 Federal Regulation 49200 September 22, 1993), codified at 40 CFR 300.440 (Section 8.14 FFA Administrative Docket 1093-05-02-120). |
Louis Howard |
| 10/1/1996 |
Document, Report, or Work plan Review - other |
Staff reviewed and commented on the treatability study workplan for OU B. The text states water levels will be monitored in the pumping well, the piezometers and the existing wells on the site. If the existing wells include the deep wells at the site (e.g. MW-1), then ADEC concurs with the approach in the technical memorandum. A data logger in a deep well such as MW-1 will aid in determining if pumping the shallow aquifer will show any effects to the deep aquifer. |
Louis Howard |
| 10/3/1996 |
Update or Other Action |
Final Volume I: Report & Appendix I Remedial Investigation Report Operable Unit B Poleline Road Disposal Area, Fort Richardson, Alaska (Contract No. DACA-85-94-D-005 Delivery Order No. 013)
Table 1-2 Materials Found by OHM during excavation of Areas A-3 and A-4
Poleline Road Disposal Area OUB Fort Richardson Alaska
Quantity & Items Found
1 Radiation Dosimeter Kit
Several Empty Chemical Agent Identification Set (CAIS) Units
Several Carbon Filter Canisters
unknown Scrap Metal
3 Full CAIS Units
Several Rusted Drums and Drum Lids
Several Wood DANC Crate Parts
3 White Phosphorus Smoke Grenades
NOTE: DANC (short for "Noncorrosive Decontaminating Agents) solution is a mixture of a powder (RH-195) and a solvent (actylene tetrachloride AKA 1,1,2,2,-Tetrachloroethane CAS: 79-34-5). It is used to decontaminate weapons, instruments, vehicles, equipment, and metal surfaces that have been contaminated with vesicant chemical warfare agents. Despite its name DANC residue is corrosive if left in prolonged contact with metal surfaces.
DANC tends to soften rubber and plastic, remove paint and is very toxic. DANC also forms hydrochloric acid when acetylene tetrachloride comes into contact with moisture. DANC solution is shipped in 3 gallon dual-compartment container that weighs 59lbs and occupies 1.2 cu. ft. BH-195 & tetrachloroethene may be used to prepare DANC solution.
11 Lecture Bottles
1 8" x 3" Amber Bottle with 2" of Clear Liquid
Wood Debris
2 Rusted drums with Unknown Molasses Type Material
1 Full, Unopened Case of HC Smoke Canisters
Several Small Vials of "Eye Decon Solution"
9 Full or Partially Full Amber Bottles Labeled HD Toxic Gas Set M-l
5 Empty Unmarked Clear Bottles
1 24 oz. Amber Bottle with Small Amount of Clear Liquid
3 Artillery Round Fuses
Hundreds Small Medicine Vials Containing Aureomycin, Rabies Serum, and Gangrene Serum
3 One-Gallon Size HC Smoke Pots
7 HC Smoke Grenades
Several Oily Soil, Pails, and Funnels
Several Flame Thrower Canisters and Parts
Several Atropine Injection Kits
1 Empty Bakelite CS Grenade
1 Bazooka Rocket Warhead
1 Smoke Grenade Fuses
43 M51 Type Artillery Round Fuses
1 Small Bottle Marked CN
1 76mm Artillery Round Warhead
4 Nose Fuses
8 Rifle Grenades, Intact
6 Empty ~ 105mm Casings
16 Rifle Grenade Tail Booms
27 Aluminum Grenade Bodies
1 Fire Starter
3 Empty 75mm Casings
85 Rifle Smoke Grenades
2 M18 Smoke Grenades
1 Rifle Grenade Fuse
2 105mm Artillery Rounds with High Explosives
Several CN ID Set Bottles
1 1/2 Gallon Intact Amber Jar
1 5-Gallon Pail with Water Reactive Granular Solid that Reacts with Moisture in Air
2 M60 Machine Gun Belts with Unfired Blanks
2 Tail Fins for 250 or 500 lb Bombs
24 Small Bottles Marked HCL
1 Wood Crate Marked "Hydride Charge"
Thousands Mustard & Lewisite Detector Kit Tubes. |
Louis Howard |
| 10/28/1996 |
Update or Other Action |
Soil vapor extraction (SVE) and air sparge treatability study was conducted. |
Louis Howard |
| 1/3/1997 |
Document, Report, or Work plan Review - other |
Staff provided comments on the workplan soil stockpile remediation. Staff requested the Army substitute EPA Region 3 RBCs for RCRA 40 CFR 268 LDRs for soil cleanup levels. If the Army is contemplating post treatment cleanup levels greater than RBCs, then it will need to do a site specific risk assessment. The text states the soil will be moved to its designated storage site. If the site is an industrial one, then there will need to be appropriate enforceable institutional controls to ensure the soil remains in an industrial area.
ICs would consist of, but not be limited to, land use restrictions on the site where soils are placed to prohibit access and disturbance of the soils and administrative controls for limiting future land use which include placing written notification of these remedial actions in a Post-wide land use master plan. The notification in the MP shall prohibit any activity that disrupts aspects of the engineering controls. A copy of the notification is to be provided to any prospective transferee of the property and is not included in any transfer documents, including deeds, in the event that the Army releases control of the property where the soils were disposed. |
Louis Howard |
| 1/13/1997 |
Document, Report, or Work plan Review - other |
Staff commented on the draft final proposed plan for OU A/B. Upon incorporation of the comments, which were mostly minor in nature, the plan could go final. Sidebar text states groundwater samples would be collected over a 20 year period. ADEC requests the time period be changed to 30 year monitoring period to be consistent with the evaluation of alternatives' present worth costs. Text on last page of the plan states "...natural attenuation will most likely be ineffective in treating groundwater to attain...." ADEC requests the term natural attenuation be changed to natural processes which would make it consistent with the rest of the document which refers to natural processes. |
Louis Howard |
| 1/27/1997 |
CERCLA Proposed Plan |
Final Proposed plan for Operable Unit A/B received.
Operable Unit A: Roosevelt Road Transmitter Site Leachfield, Laboratory Dry Well, & Ruff Road Fire Training Area. The risks presented in the document are conservative because they are based on future residential land use, which is not likely at this site, thereby overestimating risk for site-specific exposure scenarios. The Army, ADEC, & EPA have elected to pursue further cleanup efforts at these sites under the Two-Party Agreement. Under the agreement, the Army & ADEC will clean up contaminated materials at each site in accordance with applicable State of Alaska regulations.
While the specific cleanup actions & the time required to remediate the sites have yet to be determined, the Army & State of Alaska will jointly consider all available information before selecting appropriate OU-A site cleanup activities. Decisions regarding OU-A site cleanup will be documented in accordance with stipulations of the Two-Party Agreement. Because the OU-A sites will be addressed through the Two-Party Agreement, they are not discussed further in this Proposed Plan.
The preferred alternative for OU-B is Alternative 6: active remediation of the chlorinated solvent-contaminated hotspot, institutional controls & long-term monitoring of the contaminated groundwater outside of the hotspot. A hotspot is defined as the area containing the highest levels of contamination. Remediation of the hotspot will consist of soil vapor extraction (SVE) to treat soil & air stripping to treat groundwater.
The objective of this alternative is also to remove the contamination from the source area (hot spot) & to monitor the remainder of the contaminated plume in the groundwater. This ensures that by controlling the source, the contamination in ground water is not increasing. Also, monitoring will track the plume to determine if contamination from this site is approaching the Eagle River. This alternative also includes enforcement of land use restrictions designed to prohibit extraction & use of the groundwater & annual groundwater monitoring to track the progress of contaminant breakdown & movement, as well as provide an early indication of unforeseen environmental or human health risk.
The high vacuum extraction process uses a strong vacuum applied to the source area through a series of wells. This vacuum will draw both soil gas vapors from the hot spot as well as some contaminated groundwater. As this air & water mixture is drawn to the surface some of the contaminants in the water will transfer to the air. An air stripping system or similar performing technology will be used to treat the extracted groundwater to meet State of Alaska & Federal water quality standards prior to being reinjected down-gradient from the site. Soil vapors extracted from the hot spot soil will be treated as necessary to meet State & federal air quality standards prior to release to the atmosphere.
The groundwater contamination outside the hotspot will be regularly monitored to ensure the effectiveness of the remediation. A thorough assessment of alternatives considered groundwater risks, cleanup times, & costs. It was determined that protection of human health & the environment & compliance with ARARs would best be attained by cleanup of soil & groundwater in the source area & long-term monitoring of the groundwater plume. Although only the hotspot is proposed for active remediation for this alternative, if it is successful, it would produce a significant reduction in risk because the source area would be remediated. This alternative ensures protection of the groundwater & provides the best balance of criteria among the alternatives evaluated.
See site file for additional information. |
Louis Howard |
| 1/29/1997 |
Document, Report, or Work plan Review - other |
Staff commented on the draft treatability study report for OU B received on January 27, 1997. 2.1 System Setup page 2-2 text states a dark liquid was recovered from MP-2 several days after it was developed. The liquid was described as a dense nonaqueous phase liquid (DNAPL). NO mention was made in the document where the DNAPL from MP-2 was sent for analyses, treatment, or disposal. ADEC requests information on whether or not the DNAPL was ever found again in the monitoring point MP-2 or other areas of OU B during the treatability study. |
Louis Howard |
| 2/15/1997 |
Update or Other Action |
A Soil Vapor Extraction (SVE) test was conducted at the Poleline Road Disposal Area (PRDA) November 1996. Although the test was considered successful, the data suggested that some type of heat enhancement could improve the SVE process. The U.S. Army Corps of Engineers (USACE) requested an analysis of heat enhancement methods and development of a new remedial alternative that incorporates heat enhanced SVE of the “hotspot”.
This paper presents a summary of the information gathered while researching heat enhanced SVE. In situ heating of contaminated soils primarily increases the vapor pressure of contaminants, allowing the contaminants to more readily volatilize. There are several different ways to heat the subsurface soils including: radio frequency (RF), electrical resistance (AC), and steam injection. The radio frequency and electrical resistance heating methods work well with moist fine grained soils. The electrical properties of fine grained soils tend to capture the RF or AC energy.
Steam injection is effective in more permeable soils. The permeability is necessary to allow the steam to move through the soil. RF heating uses electromagnetic energy to heat soil in situ. The RF energy causes radiative heating of the soil rather than convective heating. Approximately 55% of the electrical energy supplied by an electrical source is delivered to the soils by the RF heating technology. A proposal from KAI, an RF heating contractor, proposed heating the soils from 4’C to 90°C in either six or 12 months.
Electrical resistance heating has a higher efficiency than RF because the electrical energy supplied by the generator is delivered directly to the soils. Both technologies can turn groundwater in low permeability zones into steam that will strip contaminants. The contaminants then move into a more permeable zone and are removed by an HVE system.
The advantage that electrical resistance heating has over RF heating is that the process is more efficient. Both technologies require Iarge amounts of electrical power. Electrical resistance heating uses that power more efficiently, lowering remediation costs.
Early attempts at using electrical resistance heating passed AC current between only two electrodes. This heated the soils very unevenly. Battelle developed a six phase soil heating (SPSH) method that results in more even soil heating. The Battelle method converts standard 3-phase current into 6-phase current. Each electrode in a six electrode array is connected to a separate transformer, wired to provide it with a separate current phase. A neutral electrode is located in the center of the six electrode array and doubles as an SVE vent well. |
Louis Howard |
| 3/15/1997 |
Update or Other Action |
Final Treatability study report for OU B. Using data collected during the SVE test, the following parameters were calculated:
l Intrinsic Permeability = 1.6 E-07 cm2
l SVE Radius of Influence is between 25 and 35 feet
l The amount of solvents removed from the soil during the 5 day test is about 11.6 lbs
Intrinsic Permeabilitv-The calculated intrinsic permeability (K), also known as soil gas permeability, corresponds with a silty sand (10-6 to 10-11 cm2). SVE is generally considered effective in soils with K values greater than 10-8 cm2 (USEPA, 1995). The permeability calculation is shown in Appendix A.
Radius of Influence-There is more than one radius of influence to estimate for the pilot study. The radius of influence of the SVE system is the first to consider. The SVE radius of influence was at least 25 feet since the outermost soil gas sampling point had an observable vacuum. Figure 2.7 is a plot of the vacuum readings at MP-2 and -3. A line drawn through the two points intercepts the x-axis (distance) at 35 feet; this point represents an estimate of the maximum radius of influence.
A radius of influence of 25 feet was calculated using an equation from the Corps’ Engineering Manual on Soil Vapor Extraction and Bioventing (EM 1110-1-4001). The 25-foot estimate would be the most reasonable number to assume for design purposes.
The next radius of influence to consider is for air sparging. The water level and dissolved oxygen measurements from the monitoring points give an indication of how air sparging is affecting the groundwater. Groundwater mounding was noted in the three monitoring points while the air sparge blower was on. The two closest points, MP-1 and MP-2, had almost the same increase in the measured groundwater elevations. The groundwater elevation increase at MP-3 was less than half the amount measured in the other points.
Dissolved oxygen in groundwater readings from the three monitoring points increased once the air sparge blower was turned on. Dissolved oxygen readings in the groundwater started at less than 10 % and increased to 100% and greater. Based on these two measurements, the radius of influence for the air sparging is at least 10 feet and possibly 20 feet.
Amount of Solvent Removed-An estimated 11.6 lbs. of solvents were removed by the SVE system during the pilot test. This estimate is based on the average concentration of soivent in the extracted air, the volume of air removed and the amount of time that the system was running during the 5 day test.
The average concentration of total VOCs in the extracted soil gas was 40 ppm. The total volume of air extracted was 986, 580 ft’. The extracted soil gas was assumed to contain only 1,1,2:2-tetrachloroethane, to simplify, the calculations. An estimated 200 gallons of groundwater were removed from the knockout tank during the test.
CONCLUSIONS-Based on the data collected during the treatability study and previous investigations completed at the site, the following conclusions can be made: SVE is capable of removing the target analytes. TCE and 1,1,2,2-tetrachloroethane are found at high levels in the soil and in the extracted soil gas. Air sparging did increase the amount of TCE extracted from the SVE well, but made little impact on the 1,1,2,2-tetrachloroethane.
Operating the SVE system under high vacuum caused a significant amount of water to be extracted with the soil gas. The intrinsic soil gas permeability is within the range considered acceptable for SVE. |
Louis Howard |
| 4/2/1997 |
Document, Report, or Work plan Review - other |
Staff commented on the draft record of decision (ROD) for OU A and OU B. Statutory Determination: it may be appropriate to mention a phased approach for the selected remedy and alternate treatment technologies. Other points to mention in this section are how and why the selected remedy will be phased and what triggers or sets forth in motion when the Army will consider looking at another treatment technology. Descriptions of Alternatives: ADEC requests for alternatives 2, 3, 4, 5, 6 language be added describing the estimated time for achieving cleanup goals and associated monitoring.
Under the selected remedy, ADEC requests the Army include language on the estimated number of years to meet MCLs. If an exact number of years cannot be given to meet MCLs, then insert some text describing a phased approach for the selected remedy. If the selected remedy does not prove to be successful at meeting MCLs, then the Army will investigate and implement other remedial alternatives. ADEC requests inserting text such as "Monitoring data will be reviewed to assess the progress made by the selected remedy toward the cleanup levels. If problems are identified, further remedial action will need to be implemented by the Army. The public, the State of Alaska and the U.S. Environmental Protection Agency will be consulted before further remedial actions are chosen." |
Louis Howard |
| 4/7/1997 |
Document, Report, or Work plan Review - other |
Staff commented on the draft technical memorandum. Text states 6 wells will be installed with 3 wells in the intermediate aquifer and 3 wells in the shallow aquifer. ADEC requests the Army consider installing a monitoring well in the intermediate groundwater interval directly north of SB-04 and SB-05. The shallow interval in this area is not being adequately addressed by monitoring wells MW-4 or MW-03 under the current proposed monitoring plan. |
Louis Howard |
| 5/15/1997 |
Update or Other Action |
Final Engineering Evaluation/Cost Analysis (EE/CA) for the treatment and disposal of chemical agent identification test set recovered from Poleline Road Disposal Area (PRDA) received. No action memorandum was produced since the system was to be permitted and operated in Utah at Tooele and Deseret pending many months of review, testing, operation at those facilities. Specific removal action objectives:
1) Remove the containers of CAIS items in storage in building 55228 (bunker D-15),
2) Treat any hazardous substances, pollutants or contaminants in the CAIS items as necessary, in order to reduce the likelihood of human, anima, or food chain exposure,
3) appropriately treat and/or dispose of any residues resulting from such treatment. The EE/CA states an action memorandum or ROD will be prepared by the U.S. Army Alaska, EPA Region X and in consultation with ADEC.
Activity relating to this EE/CA must begin within six months of signing of the action memorandum or ROD. Response activity itself is expected to take less than 3 months once initiated. Alternative 2 is the recommended removal action for the Chemical Warfare Materiel (CWM) at Fort Richardson. It meets the preferred condition of onsite disposition by decreasing the potential risk to the public.
CAIS items are brought to the RRS, where they are identified and segregated. CAIS items containing chemical agent are transferred to the neutralization station for treatment in the reactor. Those CAIS items that do not contain chemical agent would be kept in the storage area, accumulated and repacked in lab packs for shipment offsite to an approved hazardous waste TSDF for final treatment and ultimate disposal. Alt. 2 meets the guidance in Army Regulation (AR) 200-1 that states "the preferred disposition is onsite treatment." Estimated cost for implementing Alternative 2 is $2,178,302. |
Louis Howard |
| 5/16/1997 |
Document, Report, or Work plan Review - other |
Staff commented on the draft final ROD. ADEC requests deleting footnote "b" "RBCs equivalent to ..." for tables 3-1, 3-2, and 3-7 where there are no risk based concentrations exceedances listed in the tables. ADEC also requests a global change to the tables where cancer risks of 1 x 10-7 or hazard quotients of 0.1 are referenced to a cancer risk of 1 x 10-6 and a HI of > 1. This change would reduce the number of samples exceeding the screening criteria and make it consistent with tables for OU B. This approach was discussed at the last remedial project manager (RPM) meeting at Fort Richardson and agreed to by the project managers. ADEC requests deleting BNAs from the table if there are not any samples which exceed 1 x 10-6 cancer risk or an HI > 1.0. |
Louis Howard |
| 6/25/1997 |
Document, Report, or Work plan Review - other |
Staff commented on the draft final Record of Decision (ROD) for Operable Unit (OU) A and OU B. ADEC requests placement of directional arrows for shallow interval and deep aquifer flow direction. Additionally, ADEC requests adding text describing the shallow aquifer groundwater flow direction which is notably absent from the text on page 4 sec. 1.2.2 2nd par. and on page 21 sec. 3.2.2, 3rd par. |
Louis Howard |
| 7/7/1997 |
Document, Report, or Work plan Review - other |
Staff commented on the draft long term monitoring workplan for OU B. When the final six new wells are installed at the site, ADEC requests an updated map similar to figure 2-7 be submitted displaying the exact locations of the wells. |
Louis Howard |
| 7/11/1997 |
Update or Other Action |
First six phase soil heating treatability study conducted. A Design Verification Study CDVS) was conducted by URSGWC in 1997 to evaluate an innovative heat-enhanced soil vapor extraction method called six-phase soil heating (SPSH). Data collected for the DVS indicated that SPSH was an effective technology for removing chlorinated solvents from subsurface soils in a relatively short time.
Three arrays were installed for the DVS. The three arrays were installed to heat soils from 8 to 38ft bgs. Each array was heated for a total of 6 weeks. Array 1 ran from July 11, 1997 through August 22. 1997; Array 2 ran from August 24, 1997 through October 9, 1997; and
Array 3 ran from November 6, 1997 through December 18, 1997.
Each array was comprised of six electrodes arranged in a circle and installed to depths of 38.5
bgs. Arrays 1 and 2 were 27 ft in diameter and Array 3 was 40 ft in diameter. The electrode depth was selected to ensure that the shallow aquifer, suspected of having the highest concentration of contaminants, was within the heated zone. Each electrode also served as an SVE vent well with a screened interval from 8.5 to 18.5 ft bgs. The screen allows vapors to be pulled from the soil into the electrode. Placing the screen in the upper portion of the electrode ensured that rising steam was captured by the SVE system.
Granular graphite filter material was placed between the electrode/SVE well and the soil,
permitting current to flow from the casing to the soil. The granular nature of the graphite allows soil gas to be pulled from the soil into the screened portion of the well. The graphite used in the electrodes is a more dense form of graphite and does not absorb contaminants like activated
carbon.
An 8-ft long section of 6-inch diameter chlorinated polyvinylchloride (CPVC) pipe was placed
over the upper portion of the casing to electrically isolate the upper 8 ft of soil from the
electrode. This prevents active heating of the upper 8 ft of soil in the array.
Power for Arrays 1 and 2 was supplied by a 455 kW diesel generator which supplied 3-phase,
480 volt power to the 6-phase transformer and other equipment on site. Power for the third array was supplied by a 1,200 KW generator. The 6-phase transformer is actually composed of 6
single-phase transformers. The transformers convert the 3-phase power supplied by the
generator to 6 phases. each 60 degrees out of phase with the next at the desired voltage. |
Louis Howard |
| 9/18/1997 |
Cleanup Level(s) Approved |
All groundwater remedial action objectives are based on state or federal maximum contaminant levels (MCLs) with the exception of 1,1,2,2-tetrachloroethane. The RAO for 1,1,2,2-tetrachloroethane is based on the risk based concentration for this chemical in residential drinking water. RAOs for soil are based on the protection of the groundwater from leaching of the contaminants (EPA Region 3 RBCs): 1,1,2,2-tetrachloroethane -0.1 mg/kg and PCE -4.0 mg/kg.
Groundwater cleanup levels: benzene-0.005 mg/L, carbon tetrachloride-0.005 mg/L, cis-1,2-dichloroethene-0.07 mg/L, trans-1,2-dichloroethene-0.1 mg/L, tetrachloroethene (PCE)-0.005 mg/L, trichloroethene (TCE) 0.005 mg/L, and 1,1,2,2-tetrachloroethane-0.052 mg/L. (The RAO listed in the ROD appears to be incorrect and the value should have been 0.0052 mg/L. The risk assessment and groundwater model results were all based on an RBC of 0.005 mg/l for 1,1,2,2- PCA.-Feb. 20, 2003 Five year review).
NOTE to file: 18 AAC 75 (April 11, 1997):
18 AAC 75.319. DISPOSAL OF HAZARDOUS SUBSTANCES. Prior department approval is required for the ultimate disposal of a hazardous substance and of soil, cleanup materials, or other substances con¬taminated with a hazardous substance. (Eff. 5/14/92,
Register 122)
Authority: AS 46.03.020 AS 46.04.020 AS 46.09.020
AS 46.03.745 AS 46.04.070
18 AAC 75.327. CLEANUP. (a) Immediately upon becoming aware of a discharge of a hazardous substance to land or waters of the state, any person responsible for that dis¬charge shall contain, clean up, and dispose of the material collected, using methods for which approval has been given by the department. The discharge must be cleaned up to the department's satis-faction.
(b) Upon request, the department, in consultation with federal officials, as appropri¬ate, will waive the requirements of (a) of this section if the department determines that it is technically not feasible to contain or clean up the discharge or that the containment or cleanup effort would result in greater environmental damage than the discharge itself. (Eff. 5/14/92,
Register 122)
Authority: AS 46.03.020 AS 46.04.020
AS 46.03.740 AS 46.04.070
AS 46.03.745 AS 46.09.020 |
Louis Howard |
| 9/18/1997 |
CERCLA ROD Approved |
OU-A/OU-B signed by EPA's Regional Administrator Chuck Clarke & Army staff and ADEC Director (L. Kent for K. Fredriksson on September 18, 1997). Alternative six (6) is the selected alternative for treating soil & GW at OU-B. Protection of human health & the environment & compliance with ARARs will be attained through cleanup of soil & GW in the source area, long-term monitoring of the GW plume, & enactment of institutional controls to prevent unrestricted use of the area.
NOTE TO FILE: § 300.430 RI/FS & selection of remedy.(a) General—(1) Introduction. The purpose of the remedy selection process is to implement remedies that eliminate, reduce, or control risks to human health & the environment. Remedial actions are to be implemented as soon as site data & information make it possible to do so.
Accordingly, EPA has established the following program goal, expectations, & program management principles to assist in the identification & implementation of appropriate remedial actions.
(iii) Expectations. EPA generally shall consider the following expectations in developing appropriate remedial alternatives:
(D) EPA expects to use ICs such as water use & deed restrictions to supplement engineering controls as appropriate for short- & long-term management to prevent or limit exposure to hazardous substances, pollutants, or contaminants. Institutional controls may be used during the conduct of the RI/FS & implementation of the remedial action &, where necessary, as a component of the completed remedy. The use of institutional controls shall not substitute for active response measures (e.g., treatment &/or containment of source material, restoration of ground waters to their beneficial uses) as the sole remedy unless such active measures are determined not to be practicable, based on the balancing of trade-offs among alternatives that is conducted during the selection of remedy.
The use of HVE, a variation of SVE, is EPA's primary presumptive remedy for VOC-contaminated soils. The multi-step approach adopted in Alternative 6 is part of EPA's presumptive strategy for addressing contaminated GW. If HVE alone fails to remediate the source area within a reasonable time frame & the Treatability Studies are successful, then one of the successful technologies (i.e. soil heating) for enhanced extraction will be combined with the selected alternatives.
The "hot spot" is defined by the area containing greater than 1 mg/L 1,1,2,2-tetrachlorethane in GW. This area represents the main threat at this site. Specifically, the hot-spot is the area that contains the contamination & acts as a reservoir for migration of contamination to GW. Actively remediating this hot spot addresses the main threat. Concentration of 1,1,2,2-tetrachloroethane & TCE that exceeds the 1% solubility of these chemicals area found within the hotspot. *EPA Guidance publication 9355.4-07FS January 1992 states if one or more of these conditions are present, DNAPL is likely to be at the site: DNAPL related chemicals are in GW > 1% of the pure phase solubility or effective solubility, DNAPL-related chemicals in soils are > 10,000 mg/kg (equal to 1% of soil mass), concentrations of DNAPL related chemicals in GW increase with depth OR appear in anomalous upgradient/cross-gradient locations.
These high levels indicate a need to closely monitor for denser than water nonaqueous phase liquid (DNAPL) during construction & operation of the hotspot treatment system. Concurrent with implementation of the selected remedy will be monitoring of the downgradient plume to track and assess the natural attenuation of GW contaminants. The monitoring will be conducted to determine whether the plume is expanding beyond the boundaries of Poleline Road. This alternative also includes enforcement of land use restrictions designed to prohibit extraction and use of the GW, periodic GW monitoring to track the progress of contaminant breakdown and movement, and an early indication of unforeseen environmental or human health risk.
|
Louis Howard |
| 9/18/1997 |
Long Term Monitoring Established |
ROD was signed this week, long term monitoring to begin in addition to institutional controls with high vacuum extraction. State Acceptance is contingent upon
1) RD/RA will include refining of the contaminant fate & transport modeling based on new field data, which will be reviewed & approved by ADEC/EPA & the Army. This refinement of the modeling is to verify whether the proposed RAOs are protective of the GW, & to better evaluate the anticipated attenuation of GW contaminants & time needed to achieve MCLS.
2) If the modeling results indicate that soil meeting the RAOs would continue to act as a secondary source for GW contamination, the RAOs will be re-evaluated & modified to be protective.
3) If the GW monitoring results indicate that contamination is migrating farther from the source area & Eagle River could be affected, alternative or additional remedial actions will be evaluated & if determined appropriate, implemented.
4) Based on current land ownership, ADEC will accept natural attenuation as a treatment of GW for 150 years. However, if the land use changes, & becomes available for development, then the department will re-evaluate whether the time frame is reasonable for the proposed use.
GW monitoring data will be reviewed regularly to assess the progress made by the selected remedy toward the cleanup levels, & will continue in the downgradient portion of the plume until state & federal MCLs are achieved over three consecutive quarters & until subsequent soil borings show that RAOs are met after remedy shutdown & the plume is not expanding.
Because the remedy will result in hazardous substances remaining above regulatory levels on site, a review will be conducted within five years after commencement of the remedial action to ensure that the remedy continues to provide adequate protection of human health & the environment, & will continue for five-year increments until the remedy is complete. After five years of implementation, if monitoring & performance data indicate that the selected remedy & any enhancements to the remedy are not effectively reducing & controlling contamination at the site, then remedial objectives may be re-evaluated. As part of this evaluation, a Technical Impracticability (TI) Waiver may be sought by the Army. The TI Waiver would be granted by EPA if data demonstrate that available remedial technologies cannot attain the RAOs established in this ROD, based on the complexities of the contaminants & hydrogeology at OUB.
The Superfund program remains committed to restoring groundwater to beneficial use consistent with CERCLA and the NCP, and bring human exposures under control. Technical Impracticability (TI) Waiver determinations are a recognized part of EPA’s remedial strategy, and they may be appropriate depending on-site specific conditions, as discussed in the 1993 TI guidance.
See site file for additional information. |
Louis Howard |
| 9/18/1997 |
Institutional Control Record Established |
ROD was signed this week, long term monitoring to begin in addition to institutional controls with high vacuum extraction. State Acceptance is contingent upon 1) RD/RA will include refining of the contaminant fate and transport modeling based on new field data, which will be reviewed and approved by ADEC/EPA and the Army. This refinement of the modeling is to verify whether the proposed RAOs are protective of the GW, and to better evaluate the anticipated attenuation of GW contaminants and time needed to achieve MCLs. 2) If the modeling results indicate that soil meeting the RAOs would continue to act as a secondary source for GW contamination, the RAOs will be re-evaluated and modified to be protective. 3) If the GW monitoring results indicate that contamination is migrating farther from the source area and Eagle River could be affected, alternative or additional remedial actions will be evaluated and if determined appropriate, implemented. 4) Based on current land ownership, ADEC will accept natural attenuation as a treatment of GW for 150 years. However, if the land use changes, and becomes available for development, then the department will re-evaluate whether the time frame is reasonable for the proposed use. |
Louis Howard |
| 10/1/1997 |
Document, Report, or Work plan Review - other |
FINAL long-term groundwater (GW) monitoring received for OU B. Objective of monitoring will be to collect data on GW contaminant trends (in particular towards the north and west part of the site), to devise an appropriate LTM plan for the site. 8 rounds of sampling in twenty wells will be performed initially to evaluate GW trends. First two rounds to include natural attenuation parameters. 10/06/97 fax received by ADEC outlining 7 borings to 40' to further characterize hotspot in Area A-3. Comments to Army stated that GW encountered in borings will need to be analyzed for chlorinated compounds. |
Louis Howard |
| 10/10/1997 |
Document, Report, or Work plan Review - other |
Staff commented on the proposed soil boring location for OU B "Hotspot" delineation for area A-3. ADEC requests the Army analyze any groundwater found at the site during the drilling of the seven borings at Poleline Road Disposal Area (PRDA). It is important to not only characterize the soil that is encountered during this operation, but to analyze the perched and shallow aquifers for the contaminants of concern-chlorinated solvents. |
Louis Howard |
| 10/16/1997 |
Update or Other Action |
(Old R:Base Action Code = RDRA - Remedial Design / Remedial Action). Remedial design/remedial action scope of work received for Poleline Road. Descriptions of major RD/RA tasks were included. Preliminary RD due within 60 days of ROD signatures. Draft RA workplan will be prepared by RA contractor with detailed drawings, specs., design analysis, final construction cost estimate. A separate more detailed schedule will be prepared for the long-term monitoring phase of OU B. ADEC accepts the statement of work as submitted on 10/09/1997 and looks forward to reviewing the preliminary remedial design and remedial action work plan with detailed drawings, specifications, design analysis, and final construction cost estimates. |
Louis Howard |
| 12/23/1997 |
Document, Report, or Work plan Review - other |
Staff reviewed and commented on the OU B preliminary remedial design plan. ADEC requests another cost estimate be done to show an estimate of operating and maintaining power generators for the projected length of time the high vacuum extraction system will be in use at the site (12 years). A comparison between the 2 power generating options will allow a true cost/benefit decision to be reached on what electrical supply option the Army will use. The text states no permits would be required, this is true, however, any work that would have been covered by a permit will still need to meet the substantive requirements of the permit prior to initiating remedial action. |
Louis Howard |
| 2/1/1998 |
Document, Report, or Work plan Review - other |
Staff approved plan to evaluate dual phase (air/liquid) high vacuum extraction system for remediation of groundwater and soil containing VOCs. Results later that year were more beneficial at remediation of soil vapors that SVE in 1997 treatability study. However, it was not clear whether it could be beneficial unless combined with another technology. 500,000 gallons of water removed and 230 pounds of chlorinated solvents were treated. |
Louis Howard |
| 2/13/1998 |
Document, Report, or Work plan Review - other |
Staff reviewed and commented on the workplan technical memorandum design verification study, additional soil vapor extraction tests OU B. ADEC requests the Army analyze water discharged to the surface at startup of operation prior to discharge and at the end of the study for chlorinated compounds (EPA method 8260). |
Louis Howard |
| 3/9/1998 |
Document, Report, or Work plan Review - other |
Staff commented on the draft remedial action report for soil stockpile remediation PRDA. ADEC concurs with the recommendations in the document. However, as we discussed with EPA and Army staff on March 9th, ADEC requests the Army further remediate the northerly stockpile also known as "batch treatment cell#2) during the 1998 field season. This will allow the Army to meet 1,1,2,2 PCA 6.0 mg/kg cleanup level by treating the hotspots within cell #2. |
Louis Howard |
| 7/2/1998 |
Update or Other Action |
Updated USARAK institutional control policies and procedures received. The draft USARAK Command Policy Memorandum, ICs standard operating procedure and revised excavation clearance request have been finalized. To ensure the effectiveness of institutional controls, all organizational units and tenant activities will be informed on an annual basis of the institutional controls on contaminated soils and groundwater in effect on USARAK property. Where institutional controls are applicable to any organization, tenant, or activity, land use restrictions shall be incorporated into either a lease or Memorandum of Agreement, as appropriate. Costs for any and all remedial actions and fines and/or stipulated penalties levied as a result of a violation of an established institutional control shall be funded by the violating activity or organization. |
Louis Howard |
| 7/15/1998 |
Document, Report, or Work plan Review - other |
Staff commented on the Draft destruction plan for Chemical Identification Sets (CAIS). ADEC requested some minor address corrections be conducted for Appendix B. |
Louis Howard |
| 2/17/1999 |
Document, Report, or Work plan Review - other |
Staff commented on the draft remedial action report for the soil stockpile remediation project. ADEC concurs with the recommendations. The 3,600 cubic yards of TCE, PCE and 1,1,2,2 PCA contaminated soils have been successfully treated to the 6.0 mg/kg cleanup level agreed upon by ADEC, U.S. EPA and the Army. The cleanup level is consistent with those found in 18 AAC 75 Method Two Cleanup Levels Table B1 for Under 40 Inch Zone. Pending EPA concurrence, no further remedial action will be required by ADEC for these soils. This action does not preclude ADEC from requesting further remediation or site investigation if new information causes or exceeds an unacceptable risk to human health or the environment. The soil may be used at unmanned (unoccupied) facilities in an industrial setting. |
Louis Howard |
| 3/1/1999 |
Update or Other Action |
Staff reviewed the draft high vacuum extraction treatability study. ADEC concurs with the recommendations to improve the dual phase extraction system so it could be started without raising and dropping the drop tubes. ADEC requests the Army design a post treatment system for air emissions from the air stripper prior to implementing a full scale HVE system for this site. The post treatment emissions must meet or be less than the EPA Region III RBCs for ambient air (ug/m3) prior to discharge into the atmosphere. Additionally there may be air quality requirements that have to be met (e.g. Air Quality Regulations 18 AAC 50, Air Quality Statute AS 46.14 and 40 CFR Part 61 National Emission Standards for Hazardous Air Pollutants).
A few suggested options for this "polishing" requirement is to use one or more of the following: granular activated carbon (GAC), catalytic oxidation, and thermal oxidation. GAC is simple and effective at removing volatile organic compounds. However, catalytic oxidation may have to be used if the contaminant loading rate at the site is expected to be too high to make GAC economical and when concentrations are at or below 20 % of their lower explosive limit. A thermal oxidizer may be employed when the concentrations of contaminants are expected to be sustained at levels greater than 20 % of their LELs. |
Louis Howard |
| 4/1/1999 |
Update or Other Action |
Soil Stockpile Remediation Poleline Road Disposal Area Fort Richardson, Alaska final remedial action report received. The objectives of DO No. 0007 were as follows:
-To remediate of approximately 3,600 cubic yards of stockpiled soil contaminated with 1,1,2,2-tetrachloroethane (1, 1, 2, 2-PCA), trichloroethylene (TCE), tetrachloroethylene (PCE), and diesel-range organics (DRO).
-To attain the specified cleanup criteria consistent with Title 40 of the Code of Federal
Regulations (CFR), Part 268, Land Disposal Restrictions, and Title 18 of the Alaska
Administrative Code (AAC), Chapter 78 (referred to as 18 AAC 78), Underground Storage Tanks. Specific cleanup criteria for the project have been established for l, l, 2, 2-PCA (6 milligrams per kilogram [mg/kg]), TCE (6.0 mg/kg), PCE (6.0 mg/kg), and DRO (100 mg/kg).
The treatment process, using heat-enhanced vapor extraction. was not intended to treat the soil to concentrations which would render the material nonhazardous nor was the project to operate as a treatment, storage or disposal facility (TSDF) as defined by the Resource Conservation and Recovery Act (RCRA). The scope of work for this project included the following activities:
-Preparing project-specific work plans and support documents to carry out the work
-Treating 3,600 cubic yards of contaminated soil to reduce chlorinated solvent concentrations to at-or-below land ban criteria
-Conducting sampling and testing to monitor treatment progress and to document completion of soil treatment
-Managing the off-site transportation and treatment of process residuals by an approved off-site treatment storage and disposal facility
-Documenting final conditions in the stockpile area
The scope was modified on September 17, 1997, through Amendment of Solicitation/Modification of Contract No. 0007P3. The modification consisted of remediating an additional 50 cubic yards of contaminated soil. The treatment of this soil is addressed in a separate technical letter to the USACE. The heat injection/vapor extraction system was operated for approximately 12 weeks in 1997 and 10 weeks in 1998.
Soil Action Levels-Removal/Post Treatment: DRO 100 mg/kg, 1,1,2,2-PCA 6.0 mg/kg, TCE 6.0 mg/kg and PCE 6.0 mg/kg. NOTE TO FILE: 18 AAC 75 (2009) Method Two soil cleanup levels are: DRO 250 mg/kg, and the following are more stringent than those used in 1999: 1,1,2,2-PCA 0.017 mg/kg, TCE 0.020 mg/kg, and PCE 0.024 mg/kg.
Site restoration activities required by DO No. 0007 were limited to stockpiling treated soil in
the current work area at the completion of the project. No soil removal or backfill with
imported fill or topsoil, or revegetation of the work site was required by this DO.
The objectives of this project, and the results of the work performed by OHM, are described below:
-Remediation of stockpiled soil contaminated with 1,1,2,2-PCA, TCE, PCE, and DRO - OHM successfully identified an on-site technology to reduce contaminant concentrations.
-Attainment of specified cleanup criteria (40 CFR 268, 18 AAC 78)-OHM treated approximately 3,600 cubic yards of contaminated soil to reduce the average concentrations and the 95% upper confidence intervals of TCE, PCE, and 1,1,2,2-PCA to less than 6.0 mg/kg. DRO levels met cleanup goals prior to treatment. |
Louis Howard |
| 4/22/1999 |
Document, Report, or Work plan Review - other |
Staff reviewed and commented on the System Evaluation Operable Unit B, Poleline Road Disposal Area Fort Richardson, AK, Contract # DACA-85-94-0-005 Delivery Order ##02 1 Modification 15 April 6, 1999.
3.3 Groundwater Transport Model
The text states that two models (MODFLOW/MT3D) were used to model fate and transport of
1,1,2,2 TCA in groundwater. However, the next section states that URSGWC reviewed all the
data gathered since the three models were run. DEC requests further elaboration on the third
model, which is not obvious when reading this section. Delete or complete the last sentence
fragment in this section.
3.5 Summary of Modeling
The text states that the data gaps are still valid now, as they were when the models were first run. DEC concurs with the recommendation not to rerun the models as long as the data gaps exist.
However, as more information becomes available that closes a data gap, DEC requests the Army
consider the benefits of rerunning the models or even using a newer model that best simulates
site conditions in an effort to further refine the time frame to meet MCLs.
7.3 Recommended Remediation Options
DEC concurs with the recommendations to install and operate the arrays and sample groundwater before starting array 4 and after finishing array 6.
|
Louis Howard |
| 7/31/1999 |
Update or Other Action |
Quarterly report received. Matanuska Electric Association (MEA) finished installing permanent electric power at site. Six phase soil heating system array 6 and operations of arrays 4, 5, and 6 began in July 31, 1999. |
Louis Howard |
| 9/8/1999 |
Update or Other Action |
Final Work Plan Technical Memorandum, Operable Unit B, Poleline Road, DACA85 94-0-0005, Delivery Order 21, Fort Richardson, Alaska received. Specifically, field procedures are provided for conducting a design verification study for a heat-enhanced soil vapor extraction system at Operable Unit B (OUB) at the Poleline Road Disposal Area (pRDA), Fort Richardson, Alaska. The primary objective of the design verification study is to evaluate Six-Phase Soil Heating (SPSH), an enhancement to soil vapor extraction (SVE), as an applicable in-situ technology for remediating soils contaminated by volatile organic compounds (VOCs).
CES personnel will be present at the site to connect and start the system. Specific activities will include:
• setting up the SPSH power supply and connecting the electrodes
• setting up the instrumentation and control equipment for the SPSH system
• setting up the water addition system
CES personnel will also provide guidance on the location of the safety exclusion zone and
electrical grounding requirements.
Once the exclusion zone has been evacuated, the SPSH power supply and control system will be
energized and the SPSH power system will begin the power~up programming. Electrode
voltages will be maintained at approximately 100 volts (V) while a grounding check is
completed. Water addition will be maintained at 2 gallons per hour (gph) during initial start-up.
Following the grounding check. the SPSH power supply will be ramped up to anticipated
operational power levels (400 to 500 V). Once the target condition is reached, grounding checks
will be repeated for all equipment outside the exclusion zone. If any grounding problems are
observed, the SPSH power supply will be de-energized and the grounding connections will be
modified to fix the problem.
As soil temperatures begin to rise due to heating, the individual phase resistances will be
monitored for imbalances. Imbalances may occur due to stearn generation at the electrodes. The
water drip system will be adjusted to correct these imbalances. CES personnel will monitor
heating and resistance remotely, and provide guidance to lJRSGWC personnel on-site to make
these adjustments. |
Louis Howard |
| 9/30/1999 |
Update or Other Action |
Final System Evaluation received.
SPSH uses six-phase electricity to resistively heat soils and groundwater. Each electrode in a
six-electrode circular array is connected to one of six single-phase transformers. Because each
electrode is at a different voltage phase, the electricity conducts with all the other electrodes in proportion to the voltage differences. This results in a relatively even heating pattern. Electricity will follow the path of least resistance between the electrodes. SatUrated fine-grained soils have high electrical conductivities. Electricity will initially flow through these types of soils, but as the groundwater turns to steam the soil moisture content also drops. As the soil moisture content drops so does the electrical conductivity of the soils.
Groundwater was not initially designed to be remediated using SPSH, therefore groundwater
monitoring wells were not located within the active remediation zone. Additionally, an existing
monitoring well located close to the arrays (MW-3) was destroyed by the high temperatures used
in the SPSH treatment. Currently, the closest available monitoring well that is located in the
shallow aquifer is MW-21 (AP-3983). The distance from the fonner arrays to the monitoring
well is approximately 75ft. Because of this, it is unclear how effective SPSH is in remediating
groundwater.
A viable option for the OUE site, must include the ability to treat groundwater. Operation of the HVE system for 15 years is not considered an effective remediation option for this site because groundwater will likely not be addressed within the 15 year time frame. Operation of the HVE systems alone for 30 years. is not expected to address groundwater contamination as effectively as other options.
It is recommended that the three planned arrays be installed and operated this summer. Before
starting Array 4, and after completion of Array 6, a series of groundwater samples should be
collected from the area surrounding and including the "hotspot". In the event that groundwater
monitoring wells are damaged during soil heating, installation of new monitoring wells will be
necessary.
These groundwater samples will remove the data gap concerning the effectiveness of SPSH to
treat groundwater. These results will more clearly characterize the total impact that SPSH has on the site and how SPSH can be used with other technologies.
Overall cost involved in utilizing SPHS technology is a combination of mobilization/demobilization, construction, and short-term O&M. Of these costs, the largest line-item expense is the installation of electrodes for each array (see Table 7-1 for detail system costs). Using actual cost involved in Arrays 1. 2, and 3; anticipated costs for Arrays 4. 5, and 6 operation: and cost outlined in the 1999 FRTR, following is a breakdown of the system's overall costs:
• Less than 53 per 1,000 gallons of groundwater removed
• Less than $7 per pound of soil vapor removed and treated
• Less than 5100 per ton 0 f soi I treated. |
Louis Howard |
| 10/19/1999 |
Update or Other Action |
Quarterly report received. Groundwater sampling occurred in October as a part of the long term monitoring at the site. 6 phase soil heating ceased in the first week of October for the rest of the season until next summer. |
Louis Howard |
| 10/31/1999 |
Update or Other Action |
Six phase soil heating sytem operation is discontinued. |
Louis Howard |
| 11/16/1999 |
Meeting or Teleconference Held |
Staff attended restoration advisory board meeting at Russian Jack Chalet. Army provided updates on 2 party site work and operable units (OUs) B, C, and D. Record of Decision for OUD is delayed until February 2000 when it is anticipated that signatures will be done for the final document by all 3 agencies. Range rule and munitions rule briefing done by the Army's contractor Hart Crowser Cathy Steen. |
Louis Howard |
| 11/16/1999 |
Update or Other Action |
Staff received a technical memorandum for Array 5 at PRDA. The purpose of this effort was to install a six-phase soil heating/high-vacuum extraction (SPSH/HVE) soil-remediation array and to collect samples from the borings to estimate the contaminant concentrations present within the most contaminated portions of the borings. The analytical data obtained will be compared to data from samples collected after the system has been operated to estimate the effectiveness of the system.
Seven SPSH electrodes, three HVE wells and two thermocouple wells were installed and
constructed between 18 and 27 May 1999. A total of sixteen soil samples were collected from
ten of the borings for laboratory analysis. All of the samples were tested for volatile organic
compounds (VOCs) by method 8260B.
Significant VOC contamination was encountered in all of the borings. The YOCs, cis-
1.2-Dichloroethene, trans-1,2-dichloroethene, 1,1 ,2,2-tetrachloroethane, trichloroethylene (TCE) and tetrachloroethylene (PCE) were reponed in most of the samples at up to 1.1, 0.35, 88, 7.5 and 30 mglKg, respectively. Concentrations of 1,1 ,2,2-tetrachloroethane exceeding the removal action concentration of 30 mg/Kg that was established for the work perfonned in 1994, were reported in three of the samples. No other established removal action concentrations were
exceeded.
Based on field observations and analytical results, it appears that significant levels of
contamination exist within discrete layers that appear to be randomly dispersed throughout the
vadose zone. Though there was significant variability, the highest concentrations were
consistently encountered near the water table.
AP-4041 at 17.5' was the highest with the following: 1,1,2,2-tetrachloroethane at 1800 mg/kg, tetrachloroethylene (PCE) at 34 mg/kg, and trichloroethylene (TCE) at 76 mg/kg.
TCE: AP-4031/27' bgs 5.7 mg/kg, AP-4033/27.5' bgs 2.2 mg/kg, AP-4034/27.5' bgs 1.4 mg/kg, AP-4032/35.5' bgs 0.94 mg/kg, AP-4038/37' bgs 2.0 mg/kg.
Cis-1,2-Dichloroethylene (240 ug/kg): AP-4033 & AP-4032 had 1,100 ug/kg "D" flagged, Sample result was derived from a diluted sample. Trans-1,2-dichloroethylene (370 ug/kg) had 510 ug/kg all at 17' bgs for AP-4032 and AP-4033.
AP-4031 18.8' bgs 7,500 ug/kg "D" PCE (24 ug/kg) and 39,000 ug/kg "D" 1,1,2,2-Tetrachloroethane
(17 ug/kg), TCE 30,000 ug/kg "D" (20 ug/kg).
Document states that there was consistently high concentrations encountered near the water table. Though the water table does not preclude downward migration of the contaminants, it appears to be acting as an inhibiting factor at the site.
Though significant deficiencies were noted in the analytical results of several analytes, the
quality of the data associated with the contaminants of concern is considered adequate for the
purpose of comparison to the post-remediation samples. |
Louis Howard |
| 12/17/1999 |
Update or Other Action |
Summary of the Design Verification Study at Operable Unit B, Ft. Richardson, Alaska,
Delivery Orders No. 021 and 013, Contract No. DACA85-94-D-0005 received.
Field activities for the Design Verification Study (DYS) at Operable Unit B (OUB) began in May
1999. Installation of electrodes for Array 5 commenced May 18; Array 4 installation started on June 7, and Array 6 on July 12. Array 5 was installed by the USACE, Alaska District with technical assistance by URS Greiner Woodward Clyde (URSGWC). Each array included 7 electrodes installed to a depth of 38 feet below ground surface (bgs), 2 thermocouple borings installed to 35 feet bgs, and 3 soil vapor extraction wells. Installation of the soil vapor extraction (SVE) system and Six-Phase Heating (SPH) power supply began June 14.
Electrical power was provided to the site by Matanuska Electric Association (MEA). A buried cable was installed from the Anchorage: Landfill entrance, down Barrs Boulevard to the site. The final connection included a pad-mounted 300 kW transformer, a meter base, and a junction box. The junction box provided 12.4 kV to the six-phase transfonner which was connected to the 21 electrodes. The 300 kW transfonner supplied 480-volt power to the remaining electrical equipment (condenser, blower, and office trailer). Due to delays with installation of the pennanent electrical service, the transfonner was not turned on until July 31, 1999.
The vacuum extraction blower was turned on August 2. The blower was connected to the nine new
SVE wells and the two SVE wells installed for the High Vacuum Extraction system run in 1998. An
on-site systems check was conducted daily and parameters were recorded. Data included parameters
for monitoring system perfonnance and for calculating the mass removal of contaminants via the .
condensate water and extracted soil gas.
Carbon tetrachloride was detected in sample AP-4090 (T4-1) at maximum concentration of 1.60 mg/kg. This sample was the highest for all other COCs: trans 1,2-dichloroethene (3.9 mg/kg), cis 1,2-dichloroethene (9 mg/kg), 1,1,2-trichloroethane (35 mg/kg D5-Diluted sample!), Trichloroethene (640 mg/kg D9 diluted sample!), 1,1,1,2-tetrachloroethane (5.7 mg/kg), and tetracloroethene(120 mg/kg D5 diluted sample!). |
Louis Howard |
| 2/16/2000 |
Update or Other Action |
Long term monitoring results from October 1999 sampling effort received. In MW-21 tetrachloroethene was detected at 120 ug/L, benzene was detected at 12 ug/L,15,000 ug/L for 1,1,2,2 tetrachloroethane, 120 ug/L for 1,1,2-trichloroethane, 9,100 ug/L for trichlorethene, 33 ug/L for 1,1-dichloroethene, 2,980 ug/L for 1,2-dichlroethene (total), and a degradation product for chlorinated products: vinyl chloride at 4.2 ug/L. 18 AAC 75 Table C groundwater cleanup criteria for vinyl chloride is 2 ug/L which is mirroring the federal drinking water standards enforced by EPA. |
Louis Howard |
| 5/2/2000 |
Document, Report, or Work plan Review - other |
Staff commented on the draft design verification study. Main comment centered on use of a laboratory method for chlorinated solvents which would achieve a low enough detection limit that meets or is lower than the remedial action objective in the Record of Decision. Currently the Army is using a method which does not meet the RAO and has a detection limit higher than the RAO. |
Louis Howard |
| 6/30/2000 |
Update or Other Action |
In June 2000, another pig was discovered during the demolition of the U.S. Air Force (USAF) Long-Range Radar Site in Tin City, Alaska. The USAF contacted the Army and arranged for transportation of the pig to Building 55228 (Bunker D-15) on Fort Richardson. An x-ray of the pig showed that the CAIS items appeared to be an intact K941 set. The Army requested to transport the pig to Maryland to perform research and development testing on the intact item, however, that request was denied by the State of Maryland. Thus, the pig remains in storage at Fort Richardson awaiting treatment and disposal.
The CAIS item recovered from the USAF Long-Range Radar Site in Tin City, Alaska and from the PRDA on Fort Richardson could not be shipped out of state or stored at another location due to the reasons listed below:
• Public Law 91-121, enacted in 1969, requires DoD to take specific actions prior to transportation of any chemical agent to or from any military installation in the United States. The important aspects of PL 91-121 that preclude shipment of the CAIS items to a stockpile location in another state are 1) the Secretary of Defense must determine that the proposed transportation is necessary in the interest of national security, 2) the Secretary of Defense must notify the Secretary of the Department of Health and Human Services, 3) the Secretary of Defense must notify Congress at least 10 days prior to shipment, and 4) the Secretary of Defense must notify appropriate Governors of states through which any such agents will be shipped in advance of any such shipment.
• The National Defense Authorization Act for Fiscal Year 1995 (PL 103-337) placed additional restrictions on the movement of chemical munitions and agents. These restrictions prevent moving non-stockpile RCWM out of the state where it is located unless it is being moved to the nearest CWM stockpile storage facility that has permits for receiving and storing munitions and agents. The Secretary of Defense must consider the movement necessary and can only take place if public health and safety is protected during the transportation.
• The identified receiver for any CWM transported out of Alaska would be Deseret Chemical Depot in Utah. Because of notification requirements in PL 91-121, PL 103-337, and RCRA, the receiver state must agree to accept shipment of the chemical agent. To date no States have been willing to accept non-stockpile agent materials. The State of Maryland has denied a request to transport the Tin City CAIS for research and development testing by the Non-Stockpile Chemical Materials program. The State of Utah has denied a request to transport the CAIS items recovered from the PRDA site to the stockpile location at Deseret Chemical Depot.
• There are no permitted TSDFs located within the State of Alaska. Additionally there are no TSDFs elsewhere in the continental United States permitted to treat, store, or dispose of chemical agents. Federal law would require clarification in regard to the definition of “lethal chemical agent” to allow commercial treatment and disposal of CAIS items.
Because the CAIS item recovered from Tin City could not be shipped to a stockpile location or to a TSDF, the Army agreed to accept and store the CAIS item at Fort Richardson, the storage location of seven CAIS items recovered from the PRDA site. To facilitate disposal of all CAIS items using the RRS technology, the Army, EPA, and ADEC propose to include the CAIS item from Tin City under Title 42, Chapter 103, Sec. 9604(d)(4) of the USC.
Title 42, Chapter 103, Sec. 9604(d)(4) of the USC states that “where two or more noncontiguous facilities are reasonably related on the basis of geography, or on the basis of the threat, or potential threat to the public health or welfare or the environment, the President may, in his discretion, treat these related facilities as one for purposes of this section”.
Under this provision, the Army, EPA, and ADEC agree to treat the CAIS item recovered for Tin City, Alaska as part of the CERCLA removal action outlined by the 2003 action memorandum.
|
Louis Howard |
| 9/12/2000 |
Update or Other Action |
3rd Quarterly report received. RA workplan to be written in Fall of 2000. System will not be operated in 2001 since it appears that the hot spot remediation has been successful for the shallow soil contaminants of concern (chlorinated solvents). |
Louis Howard |
| 2/12/2001 |
Document, Report, or Work plan Review - other |
Staff reviewed and commented on the Technical Memorandum updating long-term monitoring (LTM) groundwater monitoring results. The ADEC is receptive to reducing groundwater monitoring where it makes sense to do so. It is recommended the remedial project managers (RPM) discuss this matter during the next RPM meeting, or during the drafting of the remedial action report for OUB. The ADEC does not agree with the recommendation to reduce the number of wells from 20 to 6 monitoring wells at this time. This matter is more appropriate for the remedial action report for OUB or the next remedial project manager meeting. Finally, the ADEC concurs with the last two bullets in this section. |
Louis Howard |
| 4/26/2001 |
Meeting or Teleconference Held |
Restoration advisory board meeting at Russian Jack Ski Chalet. Army presented updates on Operable Units, 2 party sites and land use controls. Community was interested in specifics of federal facility land transfer issues and a FUDS site across the Cook Inlet. Specifically, why wasn't the FUDS site considered in the CERCLA Process because it was a former bombing range. |
Louis Howard |
| 8/24/2001 |
Document, Report, or Work plan Review - other |
Staff reviewed and commented on the long term groundwater monitoring report. Figure 5-5 was very helpful in viewing the overall progress of the monitoring program at OU B over time. ADEC reserves final comment on the monitoring effort by the Army in October 2001 and its recommendations for future long-term monitoring needs.
With regards to long-term monitoring requirement, ADEC wishes to refer to Section 7.2 Agency Review of the Selected Remedy OU B August 8, 1997 Record of Decision (ROD) regarding long term monitoring requirements. It states: “Groundwater monitoring data will be reviewed regularly to assess progress made by the selected remedy toward the cleanup levels, and will continue in the downgradient portion of the plume until state and federal MCLs are achieved over three consecutive quarters and until subsequent soil borings show that RAOs are met after remedy shutdown and the plume is not expanding.”(see pages 76 and 77). If one were to read the ROD and interpret it one way, it would lead one to conclude that the Army would have to conduct quarterly groundwater monitoring at some time for a length of time as stated in the ROD. The Army has not conducted quarterly monitoring for OU B and may wish to provide a written memorandum to the file (if appropriate in this case) signed by the project managers on why they believe it has not been required for the site.
The table lists 1,1,2,2-Tetrachloroethane without a maximum contaminant level (MCL) and a remedial action objective (RAO) of 0.052 mg/L. Please be aware that State regulations, 18 AAC 75.345 Table C Groundwater Cleanup Levels, lists a cleanup level of 0.004 mg/L for 1,1,2,2-Tetrachloroethane. |
Louis Howard |
| 12/12/2001 |
Update or Other Action |
1. All organizations conducting activities on United States Army Alaska (USARAK) controlled land are responsible for complying with established institutional controls (ICs). ICs are administrative, procedural, and regulatory measures to control human access to and usage of property. They are applicable to all known or suspected contaminated sites where contamination has been left in place.
2. These controls have been established to implement the selected remedial actions agreed upon by the U.S. Army (Army), the U.S. Environmental Protection Agency (USEPA), and the Alaska Department of Environmental Conservation (ADEC) in accordance with the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) as amended by the Superfund Amendment Reauthorization Act (SARA). These controls also apply to remedial actions agreed upon under Two-Party Compliance Agreements. These agreements are concluded between USARAK and ADEC and apply to petroleum/oil/lubricants- (POL) contaminated sites.
3. ICs such as limitations on access, water use, excavations, and property transfers will supplement engineering controls as appropriate for short-term and long-term management to prevent or limit human and environmental exposure to hazardous substances, pollutants, or contaminants. Specific ICs include, among other things: limitations on the depth and location of excavations, prohibition of or restrictions on well drilling and use of ground water, requirements for worker use of personal protective equipment, site monitoring, and prohibition of certain land uses, types of vehicles, etc.
4. Organizational units, tenants, and support/contractor organizations must obtain an Excavation Clearance Request (ECR) for all soil disturbing activities impacting soils six inches or more below the ground surface. The review process for approval of an ECR begins with the identification of the current status (known or suspected hazardous waste site or “clean” site) of a work location. ECR’s for work in known or suspected hazardous waste sites:
a. will include specific limitations and controls on such work;
b. will include specific IC procedures, and notification, monitoring, reporting, and stop work requirements;
c. may include procedures for management, characterization, and disposal of any soil or groundwater encountered or removed;
d. will identify “project managers” for both the unit/contractor requesting the work and DPW Environment Resources.
5. The DPW project manager will conduct on-site inspections of each work site (at which ICs apply) to determine continued compliance with the terms and conditions of the approved ECR. DPW has the authority to revoke ECR approval if the specified terms and conditions are not being met. ECR forms are available at the Customer Service Desks at: a. Building 730 at Fort Richardson; b. Building 3015 at Fort Wainwright; c. Building 605 at Fort Greely.
6. USARAK has negotiated (with USEPA and/or ADEC) decision documents and/or Records of Decision (RODs) that mandate the implementation of ICs USARAK Directorate of Public Works, Environmental Resources Department (PWE), maintains copies of all decision documents and RODs requiring ICs in its real property files. PWE provides regularly updated post maps showing all areas affected by ICs. These maps can easily be accessed by using an approved intranet mapping interface application. Copies of these maps will be available to each directorate, activity, and tenant organization. To ensure the effectiveness of ICs, all organizational units and tenant activities will be informed on an annual basis of ICs on contaminated soils and groundwater in effect near their facilities.
7. ICs are enforceable by the U.S. Environmental Protection Agency (USEPA) and the Alaska Department of Environmental Conservation (ADEC). Failure to comply with an IC mandated in a decision document or ROD will violate the USARAK Federal Facility Agreement and may result in stipulated fines and penalties. This does not include the costs of corrective actions required due to violation of an established IC.
|
Louis Howard |
| 2/12/2002 |
Update or Other Action |
Staff reviewed and commented on the Technical Memorandum Updating Long-term monitoring (LTM) Groundwater Monitoring Results Operable Unit B Fort Richardson, AK Contract Number DACA-85-94-D-0005 Delivery Order Number 021, Mod Number 20. The ADEC is receptive to reducing groundwater monitoring where it makes sense to do so. It is recommended the remedial project managers (RPM) discuss this matter during the next RPM meeting, or during the drafting of the remedial action report for OUB. The ADEC does not agree with the recommendation to reduce the number of wells from 20 to 6 monitoring wells at this time. This matter is more appropriate for the remedial action report for OUB or the next remedial project manager meeting. Finally, the ADEC concurs with the last two bullets in this section. |
Louis Howard |
| 7/2/2002 |
Document, Report, or Work plan Review - other |
Staff reviewed and commented on the First five-year review work plan dated May 2002. Staff approved the document as submitted.
Please note the Department’s review and concurrence on this document is to ensure that the work is done in accordance with State of Alaska environmental conservation laws and regulations. While the Department may comment on other state and federal laws and regulations, our concurrence does not relieve the U.S. Army or its consultants, contractors, or civilian personnel from the need to comply with other applicable laws and regulations. |
Louis Howard |
| 8/22/2002 |
Update or Other Action |
Army is looking to award a contract to decommission the SVE, HVE, themocouple probes, and soil heating probes located in the current arrays at Poleline Road Disposal Area. The contractor will also decommission several piezometers that were installed for a pilot groundwater pumping test in 1995 (these wells have been dry for several years). Since it is highly unlikely that the system would be used in its current configuration, removal of the system would not have any affect on potential future remedial action at the site. Army would like to get agency concurrence for removal of the system/wells. |
Louis Howard |
| 8/22/2002 |
Document, Report, or Work plan Review - other |
The Department concurs with the decommissioning of the SVE, HVE, themocouple probes, and soil heating probes located in the current arrays at Poleline Road Disposal Area. For decommissioning guidance of wells, borings, use the guidance we have for decommissioning procedures ADEC has available online. |
Louis Howard |
| 9/17/2002 |
Document, Report, or Work plan Review - other |
Staff reviewed and commented on the Draft Interim Remedial Action Report OUB dated August 26, 2002. The table for Array 3 shows 1,1,2,2-Tetrachloroethane’s maximum detected values in soil at 34 mg/kg before treatment to a maximum detected value of 57 mg/kg after treatment. The Department requests the Army clarify in text why the maximum detected soil sample results were higher after treatment (e.g. sampling variability) for Array 3. Otherwise the reader may draw inferences to the soil sampling data which are incorrect.
The text states that the institutional controls such as limitations on access, water use, and excavation as supplementing engineering controls for both short-term and long-term management to prevent and limit human and environmental exposure to hazardous substances. The Department requests some examples of engineering controls being implemented at OUB also be included in this section.
The text states the operation of the long-term-monitoring plan will be evaluated annually by project managers and will continue until the remedial action objectives (RAOs) are achieved. This is correct, however the August 8, 1997 ROD for OUB section 7.2 Agency Review of the Selected Remedy states:
“…the long-term goal of the remedial action is to return all groundwater within and outside of the source area (“hot spot”) to state and federal MCLs and risk-based criteria, active remediation will be considered complete when concentrations within the “hot spot” are below remediation goals for three continuous quarters after remedy shutdown and the plume is not expanding.” The Department requests discussion on whether or not groundwater contamination levels have been shown to meet or is progressing towards these two goals within the “hot spot” or outside of the “hot spot.”
The ROD also states: “Groundwater monitoring…will continue in the downgradient portion of the plume until state and federal MCLs are achieved over three consecutive quarters and until subsequent borings show that RAOs are met after remedy shutdown and the plume is not expanding.”
The text for the second paragraph states “…the project managers will further determine whether the plan is operating efficiently and cost-effectively.” The Department requests the measurement criteria be described in further detail. Specifically, discussion on what details the Army anticipates as serving as the definition of “efficient” or “cost effective” in terms of monitored natural attenuation in groundwater and long-monitoring of groundwater contamination at OUB.
For example, costs of monitoring groundwater currently would be compared to the estimates listed in the ROD which give an estimate of 29,070 dollars per year. Operation and maintenance costs were estimated to be 64,878 dollars per year. The estimates for total costs of the preferred remedy were based on 30 years of annual operation costs, but the estimate for the groundwater to meet cleanup goals was 150 years based on groundwater modeling. The Department requests clarification on whether or not the estimate for meeting cleanup goals will be refined with additional groundwater modeling at a future date or whether or not true costs for monitoring groundwater to 150 years will be discussed. |
Louis Howard |
| 12/26/2002 |
Document, Report, or Work plan Review - other |
Staff reviewed and commented on the draft five year review required under CERCLA. 5.2.3 ARARs Page 5-7: The Department wishes to state that the Federal Drinking Water maximum contaminant level (MCL) and 18 AAC 75 Table C Groundwater cleanup level for cis-1,2-Dichloroethene is 0.07 mg/L not 0.007 mg/L.
5.4.2 Page 5-13: The text states 1,1,2,2-tetrachloroethane (1,1,2,2-PCA) was the only contaminant of concern which had a new cleanup standard promulgated since the Record of Decision (ROD) was signed. The Department disagrees. Tetrachloroethene and 1,1,2,2-PCA are listed in the ROD as having a remedial cleanup goal of 4.0 mg/kg and 0.1 mg/kg, respectively. Both of these cleanup levels are based on risk based concentration. The Department has since promulgated a migration to groundwater cleanup level for sites situated in the 18 AAC 75.341 Table B1 Method Two “Under 40 inch zone” for tetrachloroethene at 0.03 mg/kg and 1,1,2,2-PCA at 0.017 mg/kg. |
Louis Howard |
| 12/27/2002 |
Document, Report, or Work plan Review - other |
Staff reviewed and commented on the Engineering Evaluation/Cost Analysis (EE/CA) for the Treatment and Disposal of Chemical Agent Identification Sets at Fort Richardson. The Department concurs with the recommended removal action alternative: Alternative 2 Onsite Treatment of Chemical Warfare Materiel (CWM) Items and Offsite Treatment/Disposal of Associated Hazardous Substances.
The Department’s review and concurrence on the EE/CA is to ensure the proposed work is in accordance with State of Alaska environmental conservation laws and regulations. While the Department may comment on other state and federal laws and regulations, our concurrence on the requested treatment does not relieve the United States Army or its consultants, contractors, subcontractors, or Army civilian personnel from the need to comply with other applicable laws and regulations. |
Louis Howard |
| 1/29/2003 |
Update or Other Action |
Staff reviewed & commented on the tech memo for long term groundwater monitoring dated Sept. 2002 Volume 1.
Section One Introduction Page 1-1: The Department requests language from the August 1997 Operable Unit (OU) B Record of Decision (ROD) regarding the remedial action objectives & components of the selected remedy pertaining to groundwater monitoring be incorporated into the document’s introductions & recommendations.
The goal of groundwater monitoring within the shallow & deep water-bearing zones at OUB is to: 1) ensure that no off-source migration of contaminants is occurring, 2) measure contaminant concentrations & compliance with state & federal maximum contaminant levels (MCLs) within & outside the area known as the “hotspot”, 3) to indicate whether remedial action is effective or needs modification, & 4) if necessary, detect & characterize dense nonaqueous phase liquids (DNAPLs).
Strictly for informational purposes, EPA states as a “rule of thumb” that DNAPL can be inferred to be present if:
•Concentrations of DNAPL chemicals in the groundwater are greater than 1% of the pure phase solubility or effective solubility (1,1,2,2-tetrachloroethane 28.6 mg/L, tetrachloroethane 1.62 mg/L, trichloroethene 11 mg/L, carbon tetrachloride 0.795 mg/L, cis-1,2-Dichloroethylene 35 mg/L, & trans-1,2-Dichloroethylene 63 mg/L)
•Concentrations of DNAPL chemicals on soils are greater than 10,000 mg/kg (equal to 1% soil mass)
•Concentrations of DNAPL chemicals in groundwater calculated from water/soil partitioning relationships & soil samples are greater than the pure phase solubility or effective solubility
•Organic vapor concentrations detected in soil gas exceeds 100-1000 ppm.
For 2001 & 2002 groundwater sampling events, there have not been any concentrations of chlorinated solvents detected in the groundwater which exceeds the 1% pure phase solubility or effective solubility. That was not the case in the past at monitoring well MW-14 prior to treatment where: 1,1,2,2-tetrachloroethane, TCE & tetrachloroethene were detected in 1995 & 1996 above the 1% solubility limits. TCE was found in MW-4 in 1995, MW-21 in 1997, 1998, 1999 & 2000 sampling at or above the 1% solubility limit.
The Department requests the Army provide information in future submittals of this type on whether the 1 mg/L of 1, 1, 2, 2-tetrachlorethane for the “hot spot” has been achieved for three continuous quarters of sampling as required by the ROD. If so, then please state that this goal of 1 mg/L has been achieved in the “hot spot” for so many quarters of sampling, if not then state continued groundwater monitoring is needed until the goal has been achieved.
See site file for additional information.
|
Louis Howard |
| 2/20/2003 |
CERCLA ROD Periodic Review |
Jennifer Roberts signed the five year review document for the Post. The objectives of the Five-Year Review are to answer the following questions:
•Are the remedies functioning as intended by the decision document?
•Are the exposure assumptions, toxicity data, cleanup levels, and remedial action objectives (RAOs) used at the time of the remedy still valid?
•Has any other information come to light that could call into question the protectiveness of the remedy?
Operable Unit B: one issue affecting current protectiveness and three issues potentially affecting future protectiveness were identified at OUB. Institutional controls at OUB that do not specifically identify the UXO hazard in Areas A-1 and A-2 affect current and future protectiveness. Future protectiveness is also affected by the fact that RAOs have not been achieved in the “hot spot” (The “hot spot” is defined in the OUB ROD as the subsurface area containing greater than 1.0 milligrams per liter of 1,1,2,2-tetrachloroethane in groundwater and/or free-phase solvents.) and information north of the source area is needed to determine contaminant migration. Recommendations and follow-up items at OUB included continuing to monitor groundwater contaminant reduction and performing groundwater modeling for trend analysis; continuing to analyze groundwater samples for VOCs using methods that include compounds not addressed in the ROD; including new wells, installed in 2002, in the long-term groundwater monitoring program; and identifying an IC specific to UXO buried in Areas A-1 and A-2.
The cleanup level of 0.052 mg/L established for 1,1,2,2-PCA in groundwater appears to have been the result of a transcription error. The RBC for 1,1,2,2-PCA at the time the ROD was written was 0.0052 mg/L. The risk assessment and groundwater fate and transport model both used the value of 0.0052 mg/L for 1,1,2,2-PCA to estimate the time to reach clean up levels. The groundwater model estimated that it would take about 150 years for groundwater concentrations to reach the cleanup levels (0.0052 mg/L for 1,1,2,2-PCA). The original model estimate was based on initial conditions where much higher levels of chlorinated solvents were present; a new model may indicate that the time to reach cleanup levels has been greatly reduced by substantial reduction of the source area contaminants in soil and groundwater.
ICs for UXO in Areas A-1 and A-2 will be included in the master plan and real estate documents, range maps, the Environmental GIS, and the IC policy. The remedy at OUB is expected to be protective of human health and the environment upon completion. Identifying institutional controls that address potential UXO hazards in Areas A-1 and A-2 is necessary to control exposure pathways that could result in unacceptable risks.
The next Fort Richardson Five-Review will be conducted in 2008, five years from the date of this review. The next Five-Year Review will be the first full-term review for the OUC ROD. |
Louis Howard |
| 5/7/2003 |
Update or Other Action |
U.S. Army Garrison, Alaska Engineering Evaluation and Cost Analysis Action Memorandum for the
Treatment and Disposal of Chemical Agent Identification Sets (CAIS) received.
The purpose of this Action Memorandum is to document the decision by the U.S. Army Garrison, Alaska (USAG-AK) to conduct a removal action for the Treatment and Disposal of Chemical Agent Identification Sets (CAIS) at Fort Richardson, Alaska. CAIS items were recovered from the Poleline Road Disposal Area (PRDA) designated as Operable Unit B on Fort Richardson, and from the Long-Range Radar Site in Tin City, Alaska. The CAIS items are located in secure storage on Fort Richardson, pending neutralization and disposal. USAG-AK is the response authority under the Defense Environmental Restoration Program (DERP) and the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA).
The selected removal action alternative is Alternative 2 - "Onsite Treatment of CWM Items and Offsite Treatment/Disposal of Associated Hazardous Substances". The selected alternative involves onsite treatment of chemical warfare materials and offsite treatment/disposal of associated hazardous substances. This alternative involves bringing a transportable treatment system, referred to as the Rapid Response System (RRS), to Fort Richardson to conduct the on-site chemical neutralization of chemical agent materials. Following onsite chemical neutralization, the resultant hazardous waste will be shipped to an off-site facility for disposal.
This action is being undertaken as a non-time-critical removal action (NTCRA) in accordance with the Federal Facility Agreement between USAG-AK, the U.S. Environmental Protection Agency (EPA) and the Alaska Department of Environmental Conservation (ADEC). Work will be conducted in accordance with the National Oil and Hazardous Substance Pollution Contingency Plan (40 CFR 300).
The Army conducted an expanded site investigation and eventually a removal action. The purpose of the initial phase (phase one) of the removal action was to locate, remove, and dispose of suspected contaminated materials buried in trenches that were identified during geophysical investigations. Phase one of the removal action took place from September through December 1993, but was interrupted when two sealed containers (known as pigs), used for packaging CAIS, were found at the site. After further evaluation, phase two of the removal action was initiated to remove and stabilize any additional chemical agent material at the site until it could be safely treated or destroyed. Phase two of the removal action took place between July and October 1994.
Seven intact pigs, and other CAIS-related items, were found during the removal action (both phases one and two). The seven CAIS items were overpacked into sealed containers and transported to Building 55228 (Bunker D-15) for storage pending their final disposition. The agent-contaminated materials were stored on Fort Richardson because there were no facilities located within the State that were permitted to store, treat, or dispose of agent-contaminated materials, and the items could not be shipped to another state without approval from the receiving State.
The materials collected and stored in Bunker D15 have not yet been fully characterized, but have been determined to be chemical agent in nature based on chemical analysis of soil samples collected during the removal action, field screening using agent detectors, and visual characterization of the materials removed from the site.
During phase one of the removal action about 20 small amber jars were found that had legible print on the outside that read “HD - TOXIC GAS SET M1”. Specification sheets for M1 pigs were also found and two pigs containing CAIS were subsequently found. Analysis of soil samples collected during phase one of the removal action confirmed the presence of adamsite at the site.
During phase two of the removal action; nine full or partially full glass bottles labeled “HD- TOXIC GAS SET M1”; one glass vial with a stopper; one amber bottle, 8-inches tall and 3-inches in diameter; one amber bottle, 24-ounce volume, with a small amount of clear liquid; five empty, unmarked, clear bottles; and various pigs were recovered from the PRDA site.
The removal action alternative selected for treatment and disposal of the CAIS items currently stored at Fort Richardson involves onsite treatment of chemical warfare materials and offsite treatment/disposal of associated hazardous substances. This alternative involves bringing a transportable treatment system, referred to as the Rapid Response System or RRS, to Fort Richardson to conduct the on-site chemical neutralization of chemical agent materials. Following onsite chemical neutralization, the resultant hazardous waste will be shipped to an off-site facility for disposal. |
Louis Howard |
| 5/21/2003 |
Update or Other Action |
Interim remedial action report signed by ADEC. The objectives of the remedial action at OUB are designed to ensure the protection of human health and the environment by: Reducing contaminant levels in the groundwater to eventually comply with drinking water standards, Prevent contaminated soil from continuing to act as a source of groundwater contamination, Prevent the contaminated groundwater from adversely affecting the Eagle River surface water and sediments; and Minimize degradation of the State of Alaska’s groundwater resources at the site as a result of past disposal practices.
The remedial action at OUB was performed through a series of successful treatability studies due to budget and contract requirements at the time of implementation. Heat Enhanced Soil Vapor Extraction Study (Arrays 1, 2, and 3) A heat enhanced soil vapor extraction study was performed from July 11 to December 18, 1997 to evaluate the effectiveness of six-phased soil heating (SPSH). SPSH was used to resistively heat the soil. The system combined the emerging technology of SPSH with SVE.
Results for arrays 1 and 2 were similar. Each array had a comparable amount of soil, same treatment time, and similar energy inputs. The only significant difference was array 2 had a lower estimated mass of contaminants before treatment. Array 3 was not as effective as arrays 1 and 2. This may be due to an increased array size and a less than optimum borehole diameter. Increasing the array diameter results in a larger area of very high temperature soils immediately around the electrode. The high temperatures make it difficult to maintain moisture near the electrode. The dry soils resist efficient flow of electricity from the electrode.
When installing electrodes, the diameter of the borehole should be at least as large as the diameter of the very high temperature soils shown by the model. In some cases the maximum after treatment concentrations for array 3 were slightly higher than the before treatment ranges. This is fundamentally due to sampling variability and site conditions rather than impact from the treatment. Overall the average concentrations are considerably lower than before treatment. Two additional confirmation sample borings were installed after treatment at array 3.
Prior to SPSH, four soil samples from thermocouple borings were collected. After SPSH was completed, soil samples were collected from six confirmation soil borings. Only 1,1,2,2-tetrachloroethane, PCE, and TCE are presented because these compounds had the highest pre-treatment concentrations. Average concentrations for each compound and calculated values for percentages removed are also included in the tables. Approximately 99.9% of the 1,1,2,2-tetrachloroethane present before treatment was removed from the soil in the treatment area. Removal of PCE ranged from 79.5 to 99.6%. Removal of TCE ranged from 68.5 to 97.2%. |
Louis Howard |
| 5/22/2003 |
Document, Report, or Work plan Review - other |
Staff reviewed and approved the draft action memorandum for the neutralization of the chemical agent identification sets into industrial solvents this summer. |
Louis Howard |
| 5/25/2003 |
Update or Other Action |
Dense non-aqueous phase liquid (DNAPL) has been physically detected in monitoring wells twice during remedial actions and longterm monitoring. The first detection occurred in November of 1996 in AP-3992 during an SVE pilot study. DNAPL was also present in AP-3746 during sampling in May 2003. DNAPL being released is believed to be a mixture of 1,1,2,2-PCA; PCE; and TCE. A sample of the DNAPL was collected and analyzed for chemical makeup. Based on these results, the DNAPL is approximately 93.76 percent 1,1,2,2-PCA; 5.86 percent TCE; and 0.38 percent PCE.
AP-3746 is screened in a perched water zone above a local confining unit that has been dry since the November 1996 sampling event. Typically, a one percent “rule-of-thumb” is used to evaluate for the presence of DNAPL near a monitoring well. For a single-constituent NAPL, this would mean that it is highly likely that DNAPL is present if the measured groundwater concentration is greater than one percent of the single component solubility. For the multicomponent DNAPL assumed to be present at the PRDA, if the sum of measured concentrations divided by the single component solubility is greater than 0.01 (assuming the one-percent rule), it is likely that DNAPL is present in the area.
DNAPL was observed in AP-3746 in May 2003. Free product was found in this well in 2003, indicating that a source is still present in the "hot spot". (the “hot spot” is defined in the ROD as the subsurface area containing greater than 1.0 milligram per liter of 1,1,2,2-tetrachloroethane in groundwater and/or free-phase solvents). The DNAPL present here will continue to act as an ongoing source to the site and regional groundwater, depending on recharge and discharge to and from the perched zone. The extent of this perched zone and the extent of DNAPL present are currently unknown. |
Louis Howard |
| 5/27/2003 |
Site Number Identifier Changed |
Changed Workplan from X1 to X2. |
Louis Howard |
| 6/3/2003 |
Update or Other Action |
Staff reviewed and approved the draft work plan, waste management plan, and site monitoring plan for the rapid response system that will be operating on Post to neutralize the chemical agent identification sets. |
Louis Howard |
| 6/10/2003 |
Update or Other Action |
DPW Mark Prieksat sent email to EPA Bill Adams and ADEC Louis Howard. RE: Poleline Road DNAPL Product Sample VOCs results. Product found in MW-14 (perched aquifer well). This product sample contained 960,000 mg/L 1,1,2,2-Tetrachloroethane and 60,000 mg/L Trichloroethene. These are the only analytes detected above the MRLs.
CAS Number 79-34-5 1,1,2,2-Tetrachloroethane also known as: MTG MSDS 160; S-TETRACHLOROETHANE; ACETYLENE TETRACHLORIDE; SYMTETRACHLOROETHANE; 1,1-DICHLORO-2,2-DICHLOROETHANE; ETHANE, 1,1,2,2-TETRACHLORO-; TETRACHLOROETHANE; SYMMETRICAL TETRACHLOROETHANE; has a water solubility = 0.28% at 25 degrees C or 2,800 ppm, so at10% it would be 280 ppm 1% of that would be 28 ppm. |
Louis Howard |
| 9/8/2003 |
Document, Report, or Work plan Review - other |
Staff reviewed and approved the groundwater monitoring report for the site. |
Louis Howard |
| 9/9/2003 |
Update or Other Action |
Staff reviewed and approved the draft areawide community involvement plan for the facility. |
Louis Howard |
| 10/1/2003 |
Update or Other Action |
Additional fence enclosure was installed around areas suspected to contain buried WWII munitions. Warning signs were placed around the enclosure. |
Louis Howard |
| 12/15/2003 |
Update or Other Action |
Staff reviewed and commented on the draft contract report for hydrogeology. Staff requested a section be added in future reports to cover conclusions and recommendations the Army is considering. An executive summary is fine, however having a section which states the Army’s official position would help the reviewer in providing comments. The text states older well screens are becoming “silted-in” thus, slowing their response to recharge. Staff requested clarification on whether the Army will be planning to do well maintenance on these older wells or replace them entirely with new wells to address this issue. |
Louis Howard |
| 1/30/2004 |
Update or Other Action |
The estimated cost for remedial action construction, and operation and maintenance through the post-record of decision (ROD) period between 1997 and 2003 was $3,199,575 and the actual cost was $3,160,981, or about a 1 percent difference. The greatest cost difference is in projected monitoring costs for the period between 2004 and 2034 (estimate was limited to 30 year projection). Projected long-term monitoring costs are 400 percent higher than estimated in the ROD.
Several factors contribute to the cost difference including that the ROD estimate did not include cost for site closure and decommissioning, nor did the estimate anticipate requirements to continue bi-annual monitoring for an indefinite period of time. |
Louis Howard |
| 4/2/2004 |
Document, Report, or Work plan Review - other |
Staff reviewed and commented on the Chemical Data Report, OUB Poleline Road Groundwater Monitoring.
Analytical Results
This section discusses the detection of DNAPL (dense non aqueous phase liquid) recovered from wells AP-3746 and AP-4014. In section 6.1 DNAPL Discovery and Recovery, the results of the analyses of the DNAPL were only listed for well AP-3746. In the Analytical Data Table section Table 2 lists product analyses for only AP-3746. The Department requests analytical results of the DNAPL from well AP-4014 be provided to the Department for review, an explanation provided as to why the Army did not analyze the DNAPL from AP-4014 or whether this was an error in reporting.
|
Louis Howard |
| 5/19/2004 |
Update or Other Action |
Installation action plan for the Post was received and approved by the Department. |
Louis Howard |
| 6/30/2004 |
Update or Other Action |
Received a report which presents the Cleanup Operations and Site Exit Strategy (CLOSES) evaluation for the Poleline Road Disposal Area (PRDA) located in Operable Unit B (OUB), Fort
Richardson, Alaska. The CLOSES process provides a framework for assessing cleanup progress and managing remedial action decisions until Remedial Action Objectives (RAOs), designed to protect human health and the environment, have been achieved. Modifications to the course of action are made based upon a series of assessment and decision points.
Non-aqueous phase liquid (NAPL) is known to exist near AP-3746. The extent of this NAPL and its impact on site groundwater in not understood. Site characterization is ongoing, with additional soil borings and wells installed in April 2004 in order to further delineate the NAPL present.
The site hydrology is not fully understood. The interaction between the wetland and the groundwater system is not adequately understood. Also, the surface hydrology of the
wetland is unknown. This question is one of how much water flows into the wetland from surface flow and groundwater flow, and how much water exits the wetland and recharges
the site groundwater system. The extent of COCs in the shallow, saturated interval is not known to the north and northeast of AP-3747. Additional characterization downgradient of AP-3747 is
recommended.
The specific degradation processes and rates are not known at the site. An evaluation of the specific chlorinated compound degradation processes and rates has not been performed at
the site. This information is important for evaluating natural attenuation as well as identifying the possibility of enhancement of degradation processes and rates.
It is recommended that a site-wide sampling event be conducted that would consist of collecting a complete round of water levels and analytical samples from all the wells in order to evaluate current site conditions. The site monitoring and investigations taking place during the 2004 field season provide a good opportunity to collect additional data regarding natural attenuation and microbial processes that may be occurring at the site. In addition, it is recommended that the surface hydrology and
geochemistry of the wetlands be characterized as part of the natural attenuation study. |
Louis Howard |
| 7/15/2004 |
Update or Other Action |
Soil vapor extraction (SVE) system was re-installed at a few wells at the site to treat residual solvent contamination in near surface soils. These systems utilized existing wells and other existing infrastructure. |
Louis Howard |
| 6/27/2005 |
Update or Other Action |
Staff reviewed and approved the draft groundwater monitoring report. |
Louis Howard |
| 7/6/2005 |
Update or Other Action |
Staff reviewed and approved the refined 3D Geologic Model for Poleline Road Disposal Area. |
Louis Howard |
| 7/11/2005 |
Update or Other Action |
Staff reviewed and commented on the draft Operation, Maintenance, and Monitoring Manual OUB SVE Treatment System. Exit Strategy Page 3-1
The text states the system is expected to operate until cleanup goals are met. Please identify which cleanup goals it is specifically referring to: target cleanup levels found in this document, Operable Unit (OU) B Record of Decision (ROD) remedial action objectives (RAOs) or 18 AAC 75 cleanup levels for soil and groundwater.
Site Closure Page 3-2
Item 1 states data will be collected and monitored to support achievement of ADEC cleanup goals. However, the target cleanup goals in section 3.4.1 do not match those found in Table B1 for soil migration to groundwater cleanup levels nor the Table C groundwater cleanup levels.
Cleanup Levels Page 3-2
ADEC has cleanup levels in groundwater for 1,1,2,2-Tetrachloroethane (TCA) at 0.004 mg/L and for tetrachloroethene (PCE) and trichloroethene (TCE) at 0.005 mg/L. The ROD states the RAO for TCA was based on the risk-based concentration (RBC) of 0.052 mg/L and for PCE and TCE it was set at the MCL of 0.005 mg/L. The target cleanup level for PCE is set higher at 0.0608 mg/L and for TCE it was set at a lower level of 0.0016 mg/L.
TCA is listed with a target soil cleanup level of 29 mg/kg and PCE at 110 mg/kg. The OUB ROD states the RAO for PCE is 4.0 mg/kg and for TCA is at 0.1 mg/kg based on RBC. 18 AAC 75 lists a cleanup level for TCA at 0.17 mg/kg, TCE at 0.27 mg/kg and for PCE at 0.03 mg/kg. Please elaborate on why this document does not refer ROD based cleanup levels or the ADEC cleanup levels for soil and groundwater.
5.2 Environmental Monitoring Page 5-1
The text states, in general, that the monitoring at OUB will consist of soil gas sampling on a monthly basis and is conducted to determine whether cleanup goals have been achieved and site closure can be pursued. Groundwater sampling and reporting will be performed by CRREL. Notably absent from the document is mention of any soil sampling from the treatment system site to confirm whether or not it is working. ADEC requests soil sampling be conducted at the treatment system site as a baseline before active treatment begins if it has not been conducted before in previous investigations. After treatment is considered complete or has reached the point of diminishing returns and not considered practicable to continue operating, soil samples would be collected to determine what impact the treatment system has had on contaminants present at OUB.
|
Louis Howard |
| 11/15/2005 |
Update or Other Action |
Annual monitoring report received for OUB groundwater monitoring. Contaminants of concern (CoCs) above the remedial action objectives (RAO) were identified during the October and August sampling events below:
Tetrachloroethene (PCE) was detected above the RAO of 5.0 ug/L in six wells in August. Of the total wells sampled, concentrations ranged from .4J ug/L at AP-4011 to 45.5 ug/L at AP-3983. Eight wells in October had detections above the RAO with concentrations ranging from 2.44 ug/L at AP-4017 to 41 ug/L at AP-4015.
Trichloroethene (TCE) was detected above the RAO of 5.0 ug/L in fifteen wells in August with concentrations ranging from .55J at AP-3982 to 5720 ug/L at AP-4525. Fourteen wells in October had detections above the RAO with concentrations ranging
from .41J at AP-4019 to 5110 ug/L at AP 4015.
Trans-1,2-Dichloroethene was detected above the RAO of 100 ug/L in one well in August with concentrations ranging from .32J at AP-4354 to 172 at AP-3983. Two wells in October had detections above the RAO with concentrations ranging from .68J ug/L at AP-4013 to 142 ug/L at AP-4017.
Cis-1,2-Dichloroethene was detected above the RAO of 70 ug/L in seven wells in August with concentrations ranging from .54J ug/L at AP-4344 to 523 ug/L at AP-3983. Seven wells in October had detections above the RAO with concentrations ranging from .36J
ug/L at AP-4019 to 485 ug/L at AP-3983.
Carbon tetrachloride was detected above the RAO of 5.0 ug/L in one well in August with concentrations ranging from .31J ug/L at AP-3745 to 13.9 ug/L at AP-4525. One well in October had detections above the RAO. Concentrations ranged from .58J at AP-4011 and AP-4344 to 8.03 ug/L at AP-4016.
1,1,2,2-Tetrachloroethane (PCA) was detected above the RAO of 5.3 ug/L in ten wells in August with concentrations ranging from .3J at AP-4518 to 1410 ug/L at AP- 3983. Eleven wells in October had detections above the RAO with concentrations ranging from 2.66 ug/L at AP-3747 to 3050 ug/L at AP-4015.
Benzene was not detected above the RAO of 5.0ug/L during August or October.
1,1,2-Trichlorethane was detected above the RAO of 5.0 ug/L in five wells in August with concentrations ranging from .32J ug/L at AP-4011 to 34.5 ug/L at AP-4525. Six wells in October had detections over the RAO with concentrations ranging from .38J
ug/L at AP-3745 to 25.7 ug/L at AP-4017. |
Louis Howard |
| 3/1/2006 |
Update or Other Action |
Staff reviewed and commented on the Draft Groundwater Monitoring Report OUB Poleline Road Disposal Area. Section 5.2 Page 18
The text states the contaminant trends in the shallow aquifer showed an overall decrease in anaerobic degradation byproducts. However, there are some wells which do show an increase in concentrations of contaminants from previous sampling events:
• well AP-4353 showed a measurable increase of trichloroethene from August and October 2004 to June 2005 (319 µg/L and 314 µg/L to 381 µg/L) and
• well AP-3745 showed a measurable increase(28.5 µg/L and 20.3 µg/L to 36 µg/L) during that same time period.
• Additionally, well AP-4519 showed a measurable increase from August and October 2004 to June 2005 for 1,1,2,2-Tetrachloroethane (PCA) (76.4 µg/L and 97.4 µg/L to 103 µg/L),
• well AP-4353 showed the same measurable increase for PCA (120 µg/L and 94.1 µg/L to 253 µg/L) and
• well AP-3989 showed the same measurable increase for PCA (342 µg/L and 297 µg/L to 521 µg/L) during that same time period.
Deep aquifer well AP-4525 showed a measurable increase for PCA from August 2004 to June 2005 (453 µg/L to 883 µg/L). While two sampling events do not equal a trend, it is an increase in contaminant concentration that should be noted in the text.
Overall, about one-fourth of all the monitoring wells at the site showed an increase in concentration of contaminants and the other wells’ concentration trends were either stable or decreasing. |
Louis Howard |
| 3/24/2006 |
Update or Other Action |
Staff reviewed and commented on the Operable Unit B Draft Summary Report Soil Vapor Extraction (SVE) Treatment System.
Performance Page 5-1
The text states that there was no hours meter installed on the system so the length of interruption cannot be determined and operational times are estimated. ADEC requests the Army have an hours meter installed so future shutdowns, interruptions will be closer monitored.
Recommendations Page 5-2
ADEC concurs with the recommendations presented in section 5.0. Pending any EPA comments and their resolution, the document can be finalized.
|
Louis Howard |
| 6/6/2006 |
Update or Other Action |
Staff reviewed and commented on the Draft Groundwater Monitoring Report OUB Poleline Road Disposal Area, Fort Richardson, AK December 2005 Contract# W911KB-04-P-0091.
Section 5.2 Page 18 - The text states the contaminant trends in the shallow aquifer showed an overall decrease in anaerobic degradation by-products. However, there are some wells which do show and increase in concentrations of contaminants from previous sampling events:
• well AP-4353 showed a measurable increase of trichloroethene from August and October 2004 to June 2005 (319 µg/L and 314 µg/L to 381 µg/L) and
• well AP-3745 showed a measurable increase(28.5 µg/L and 20.3 µg/L to 36 µg/L) during that same time period.
• Additionally, well AP-4519 showed a measurable increase from August and October 2004 to June 2005 for 1,1,2,2-Tetrachloroethane (PCA) (76.4 µg/L and 97.4 µg/L to 103 µg/L),
• well AP-4353 showed the same measurable increase for PCA (120 µg/L and 94.1 µg/L to 253 µg/L) and
• well AP-3989 showed the same measurable increase for PCA (342 µg/L and 297 µg/L to 521 µg/L) during that same time period.
Deep aquifer well AP-4525 showed a measurable increase for PCA from August 2004 to June 2005 (453 µg/L to 883 µg/L). While two sampling events do not equal a trend, it is an increase in contaminant concentration that should be noted in the text.
Overall, about one-fourth of all the monitoring wells at the site show an increase in concentration of contaminants and the other wells’ concentration trend are either stable or decreasing.
|
Louis Howard |
| 10/2/2006 |
Update or Other Action |
Environmental Protection Agency issues a Preliminary Close Out Report (PCOR) which documents that US Army Garrison, Alaska (USAG-AK) has completed all construction activities for the Fort Richardson Superfund Site (“the site”), in accordance with the U.S. Environmental Protection Agency (EPA) guidance, Close Out Procedures for National Priorities List Sites (OSWER Directive 9320.2-09A-P, January 2000). EPA and the Alaska Department of Environmental Conservation (ADEC) have determined that USAGAK constructed and/or implemented the remedies in accordance with remedial design (RD) plans and specifications. USAGAK has initiated activities necessary to achieve performance standards and site completion.
Remedial construction at Operable Unit (OU)B has been accomplished. The most current action was re-installation and operation of an existing vapor extraction system to treat residual solvent contamination in soils at the site. This action, along with others, was described in the Record of Decision (ROD) as a mechanism for site cleanup. Groundwater monitoring and modeling will continue to support the optimization of the selected remedy. No additional construction is anticipated.
As part of the IC Policy, the Army maintains a GIS database containing environmental data that have been collected at Fort Richardson. The GIS database contains a map outlining IC areas and specific descriptions of the ICs. The GIS database is an integral part of the Master Planning process. Information contained in the database (IC map and chemical data) alerts planners to areas where ICs have been established and allows planners to make accommodations when designating land use and/or planning future projects.
An additional aspect of the IC policy at Fort Richardson is the requirement that all organizations operating on Fort Richardson complete an excavation clearance request (ECR) prior to excavating to a depth of more than six inches. Each ECR is reviewed for compliance with the IC policy prior to approval.
ICs have been implemented to restrict the access to and use of groundwater at Poleline Road (OUB) and at the AVMA (OUE) until groundwater quality has been restored (contaminant concentrations are less than MCLs), thereby allowing for unrestricted use. |
Louis Howard |
| 1/12/2007 |
Document, Report, or Work plan Review - other |
Staff reviewed and commented on the Draft Groundwater Monitoring Report OUB Poleline Road Disposal Area, Fort Richardson, AK December 2006 Contract# W911KB-05-D-0010, Task Order 05.
ADEC has noted several errors on the figure regarding concentrations being not bolded when above the remedial action objective (cleanup level) for groundwater.
Figure 4-2 Well AP-4019 - Maximum historic value for groundwater elevation was not identified as 51 meters for October 2000.
Appendix C Data Quality Evaluation Report Analytical Data Pages C-2 and C-5 - In future documents submittals which reference and use the Alaska Lab Data Review Checklist, please reference the version and data of the checklist being used (i.e. version 2.2 10/06) in the text of the document. Since this report has been drafted, a newer version of the data review checklist (version 2.3 11/06) has been posted at ADEC’s web page: http://www.dec.state.ak.us/spar/guidance.htm#csp under the Analytical Methods and Quality Assurance section of the web page. For the purposes of this draft groundwater monitoring document, version 2.2 of the check list will suffice.
The text states under “Chain of Custody” section that no other discrepancies were noted. Notably absent from the text or included appendices are the chain-of-custody forms. Without these forms, ADEC nor EPA can verify whether or not any other discrepancies are present. ADEC requests the chain-of-custody forms for samples collected as part of this December 2006 report be included in this report and submitted as soon as possible to the agencies for their review.
See site file for additional information.
|
Louis Howard |
| 2/6/2007 |
Exposure Tracking Model Ranking |
|
Louis Howard |
| 8/31/2007 |
GIS Position Updated |
61.303 N latitude -149.6113 W longitude |
Louis Howard |
| 12/6/2007 |
Update or Other Action |
Staff reviewed and approved the Draft Groundwater Monitoring Report-Operable Unit B, Fort Richardson, AK dated November 2007. |
Louis Howard |
| 12/28/2007 |
Update or Other Action |
Principle Contractor: Doyon Utilities, LLC Date of Issuance: 9/28/2007 Branch of Service: Defense Logistics Agency
Contract Details: Doyon Utilities, LLC, Fairbanks, Alaska, is being awarded $939,554,520.00 regulated tariff rate, 50-year contract for assumption of ownership, operation and maintenance of the electric distribution system, natural gas distribution system, potable water distribution system, and the wastewater collection system at Fort Richardson, Alaska. Using service is Army. Contract funds will not expire at the end of the current fiscal year. There were 503 original proposals solicited, including web solicitations, with seven responses. Date of performance completion is February 2058. Contracting activity is Defense Energy Support Center, Fort Belvoir, Va. (SP0600-07-C-8262).
Total Contract Value: $939,554,520 |
Louis Howard |
| 1/18/2008 |
Document, Report, or Work plan Review - other |
Staff reviewed and commented on Draft Five-Year Review. The Alaska Department of Environmental Conservation (ADEC) has received the above document for review and comment via electronic mail from Mr. Bob Hazlett on January 14, 2008. Below are our comments on the document which are provided to your office as requested in an expedited manner (deadline given was January 28, 2008).
Be aware that the 1994 Federal Facility Agreement (FFA) Section G. Review and Comment on Draft Documents 20.13 states: “Unless the Parties mutually agree to another time period, all draft documents shall be subject to a thirty (30) day period for review and comment.” This expedited review of the document is provided as a courtesy by ADEC to the Army and should not be construed by the Army or its contractors as standard operating procedure for future agency reviews.
1.2 Statutory Review : ADEC requests a footnote or additional text explaining what “unlimited use and unrestricted exposure” means. EPA OSWER no. 9355.7-03B-P states: “Unlimited use and unrestricted exposure” (UU/UE) means that the selected remedy will place no restrictions on the potential use of land or other natural resources. In general, if the selected remedy relies on restrictions of land and/or groundwater use by humans and/or ecological populations to be protective, then the use has been limited and a five-year review should be conducted. For example, if a site is cleaned up to an industrial-use level, and/or other types of uses are restricted (e.g., residential use), then, generally, UU/UE is not met.”
1.3.1 Federal Facility Agreement: ADEC requests additional text in this section regarding the FFA requiring a review of remedial action no less than every five years to assure that human health and the environment are being protected by the remedial action being implemented.
Table 9-1 Response to Recommendations from 2003 Five-Year Review: Table 9-1 states the installation of fence with warning signs in June 2003 affects the protectiveness. ADEC agrees that the presence of a fence and signs around Areas A-1 and A-2 would prevent exposure to potential UXO buried in these areas, but has difficulty on it affecting protectiveness of human health or the environment negatively.
Table 9-1’s main purpose is to call attention to issues of potential remedy problems (affecting current or future protectiveness) to human health or the environment. ADEC does not believe that installing a fence with warning signs, negatively affects protectiveness. If the intent is to show remedial actions which positively affect protectiveness, then the remaining three recommendations/follow-up actions would require a “Yes” as well.
10.0 Protectiveness Statements: ADEC requests adding a section 10.4 for OUE – Building 35-752 to this section. The sampling results from groundwater monitoring and review of site conditions needs to be included in this five-year review as was indicated would be done in the OUE Record of Decision (ROD).
The 2003 Five-Year review states in section 7.5.1 on page 7-6: “…institutional controls will prohibit access to the groundwater as a source of drinking water and, the land use at this source area and neighboring source areas will remain industrial for the foreseeable future. Further action requirements for this site will be documented in the OUE ROD.”
The OUE ROD stated the groundwater was recommended for no-further action under CERCLA. However under Section 2.2.1 Recommendations on page 20 it also states: “Contaminant concentrations in groundwater are decreasing and the concentration of TCE (8.6 ìg/L) is only slightly greater than the MCL (5 ìg/L). Current data suggest that the contaminant is degrading. To ensure the protectiveness of the NFA decision, the Army will monitor groundwater and site conditions during the five-year reviews”. This five year review will need to address groundwater and site conditions at Building 35-752.
If the Army does not have sampling results for groundwater at Building 35-752, then it needs to state so in this review. Something can still be said about existing site conditions at Building 37-752 with regards to existing and future land use, land use controls being protective. ADEC has no comments at this time on the figures or spreadsheet accessible from the Corps FTP site. |
Louis Howard |
| 2/21/2008 |
Document, Report, or Work plan Review - other |
Staff reviewed and approved the draft October 2007 Groundwater Monitoring Report dated January 2008. |
Louis Howard |
| 2/27/2008 |
CERCLA ROD Periodic Review |
The United States Army Alaska (USARAK) conducted the second Five-Year Review of the remedial actions at the Fort Richardson National Priorities List (NPL) site, Anchorage, Alaska, from November 2007 through February 2008. This report presents the results of that review. The next Fort Richardson Five-Review will be conducted in 2013, five years from the date of this review. The next Five-Year Review will be the first full-term review for the OUE ROD.
The purpose of this review is to ensure that remedial actions selected in the Records of Decisions (RODs) for the Fort Richardson Operable Units (OUs) are being implemented and that they continue to be protective of human health and the environment. To achieve this purpose, this review evaluates the status of implementation of the selected remedies, identifies significant variances from the RODs, and makes recommendations for reconciling variances and/or for improving performance of remedial actions.
This statutory review is required by the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) since all of the RODs for this site were signed after the effective date of the Superfund Amendments and Reauthorization Act of 1986 (SARA) and some of the remedial actions result in hazardous substances, pollutants, or contaminants remaining at the site above levels that allow for unlimited use and unrestricted exposure.
Poleline Road Disposal Area (OUB)-Recommendations and follow-up items at OUB included continuing to monitor groundwater contaminant reduction and performing groundwater modeling for trend analysis; continuing to analyze groundwater samples for VOCs using methods that include compounds not addressed in the ROD; and adding 1,4 dioxane to the list of analytes for future sampling events.
The remedy at OUB is expected to be protective of human health and the environment upon attainment of groundwater cleanup goals and in the interim ICs are preventing exposure to contaminated groundwater. The initial soil removal in 1993 and 1994 and subsequent treatability studies removed the most highly contaminated soil and debris. The remedy is expected to prevent and limit human and environmental exposure to hazardous substance. ICs that address the potential UXO hazards in Areas A-1 and A-2 have been implemented since the last 5-year review. Fencing with warning signs has been placed around Areas A-1 and A-2.
Long-term protectiveness of the remedial action will be verified by obtaining groundwater samples to evaluate potential migration of the contaminant plume downgradient toward Eagle River and ensure contaminant levels in groundwater are decreasing through natural attenuation. Current monitoring data indicates that the plume is not migrating and that the remedy is functioning as required. Geologic modeling at the OUB source area continues with the intent of helping to confirm that RAOs will be achieved within the timeframe required by the ROD. |
Jennifer Roberts |
| 4/8/2008 |
Document, Report, or Work plan Review - other |
EPA provided comments on the November 2007 OUB monitoring report. Figure 1-3, Conceptual Site Model, Fort Richardson, Alaska, Page 1-7: Cross-section A-A’ shows the locations of several soil borings/monitoring wells, however, the locations of those wells are not shown on the insert figure entitled “Approximate Path of Cross Section.” Specifically, monitoring wells AP-4014 and AP-4016 are not shown on any of the figures in the report. Please provide a figure showing all of the soil borings/monitoring wells shown on the cross section or add the locations to the inserted figure on Figure 1-3.
Figure 4-1, Long-Term Groundwater Monitoring Data Shallow, Unconfined Aquifer with RAO Exceedances OUB, Poleline Road Disposal Area, Page 4-3 and Figure 4-2, Long-Term Groundwater Monitoring Data Deep, Semi-Confined Aquifer, Poleline Road Disposal Area, Page 4-7: Figure 4-1 and Figure 4-2 show the approximate local groundwater flow direction is to the northeast in the unconfined and deep, semi-confined aquifers. However, based on the analytical results, it appears that the groundwater in the deep zones flows to the northwest. It is also unclear as to why groundwater elevation contours have not been included. Please review and revise, if necessary, the groundwater flow direction in the deep zones and add groundwater elevation contours to both figures.
Section 5, Conclusions, Page 5-1: The last bullet states that valuable information for further understanding the geology and the hydrogeology was gained from the installation of the three borings AP-5243, AP-5244, AP-5245 and new monitoring well AP-5246. Please specify what was the valuable information gained from the installation of the three borings and new monitoring well was and how the information furthered the understanding of the geology and the hydrogeology. |
Louis Howard |
| 8/15/2008 |
Update or Other Action |
A regional Native corporation is preparing to take over utility services on three Army posts in Alaska. Fairbanks-based Doyon Ltd. last fall was awarded a 50-year, $3.9-billion contract to take over electricity, water, sewer and heat systems at Fort Wainwright, Fort Greely and Fort Richardson.
The privatization is expected to increase reliability and to modernize aging infrastructure. The Army projects it will save more than $800 million over 50 years. Utility privatization was authorized by Congress and mandated by the Department of Defense. A transition period ends Aug. 15.
Doyon President George Gordon said his company is ready for the takeover. "We're marching right on down the road," he said. Doyon Utilities, a joint venture between Doyon Properties and Fairbanks Water and Sewer, has spent $35 million over six months on equipment, personnel and other costs. Private investment will total around $100 million the first five years as Doyon rebuilds electrical systems, including poles, wires and substations, Gordon said.
The government will benefit from a new level of service and competitive prices, he said. The Army anticipates greater security and faster responses to problems. Fort Wainwright public works director Mike Meeks said in an e-mail that a loss of heat would be devastating if not restored quickly. "Privatization of these utilities decreases the risk of a catastrophic failure," he said.
Steve Roscovius, Fort Wainwright chief of utilities and operations support, said Doyon will not face the same constraints as the military, including annual funding uncertainty. Each post has unique needs that Doyon Utilities is working to meet, Gordon said.
• A $3 million substation being built to serve Fort Richardson should be operational by Aug. 1, Gordon said. The substation is "sorely needed," he said.
• A similar substation should become online at Fort Greely by December and would significantly expand capacity, Gordon said. During heavy winter demand, Fort Greely supplements grid power with expensive emergency generators about 10 hours per day.
• Fort Wainwright generates much of its own power with a coal-burning plant and a new substation is less urgent. However, Fort Wainwright's infrastructure is aged, creating reliability problems, Gordon said.
At all three posts, Doyon will install utility meters at individual buildings. The chance to track use of electricity, water, wastewater and steam could lead to conservation. "The Army has started to create energy conservation programs and mandates, and these meters will allow us to hit the ground running once we get marching orders," Roscovius said.
For Doyon, the transition represents an opportunity to add jobs and delve into a new field, Gordon said. The company will employ about 60 people at Fort Wainwright, 20 each at Greely and Richardson, and up to 20 at company headquarters in Fairbanks. |
Louis Howard |
| 1/5/2009 |
Document, Report, or Work plan Review - other |
Staff reviewed and commented on the Draft Sampling and Analysis Plan Technical Memorandum Groundwater Monitoring at OUB OUE, Bldg. 762 and 786 Fort Richardson, Alaska, dated November 2008 Task Order 001 of Contract No. W911KB-08-D-0005. ADEC recently updated its contaminated site regulations (18 AAC 75 revised as of October 9, 2008). The revised cleanup levels are applicable to two-party agreement sites and source areas which are not covered by an existing CERCLA Record of Decision (ROD). ADEC expects the Army will also provide several completed ADEC Laboratory Data Review Checklists (version 2.5 April 2008) as a part of the groundwater monitoring effort.
2-Butanone (CAS Registry Number 78-93-3) is shown in Table 9 as not having an ADEC Cleanup Level. The 18 AAC 75 Table C groundwater cleanup level for this contaminant is 22 mg/L. Naphthalene (CAS Registry Number 91-20-3) groundwater cleanup level has changed to 730 ug/L.
Appendix B Laboratory Accreditations-Please provide ADEC with updated ADEC Contaminated Sites Lab Approval letter for SGS (or an alternate approved laboratory) since the approval provided in the draft plan expired on December 18, 2008. Without such approval, ADEC will not review the data pertaining to those derived from AK Methods (101/102). |
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 |
| 10/15/2009 |
Meeting or Teleconference Held |
A meeting of the remedial project managers (RPMs) convened at 0900 on 15 October 2009 in the CEAN Conference Room, Building 5312, at Elmendorf Air Force Base (EAFB), Alaska. Attendees included: Mr. Jacques Gusmano (Environmental Protection Agency [EPA]), Mr. Louis Howard (Alaska Department of Environmental Conservation [ADEC]), Mr. Don Aide (CEANR), Ms. Donna Baumler (CEANR), Mr. Gary Fink (CEAN), Ms. Melissa Markell (CEANR), and Ms. Renee Wright (3 WG/PA).
Program Update. The following items were discussed:
a. Joint Base Elmendorf-Richardson (JBER) (Mr. Fink).
(1) General Atkins of the 11th Air Force has determined that joint basing will happen; this became official on 9 Oct 09 when the Memorandum of Agreement (MOA) was signed. JBER is everyone’s top priority, but our environmental responsibilities will not be neglected.
(2) MOA Annex G was distributed (Attachment 1). This annex addresses environmental responsibilities, with Restoration responsibilities detailed in the last paragraph on the second page.
(3) The JBER implementation plan for Restoration was distributed (Attachment 2). Mr. Fink pointed out Initial Operational Capability (IOC) and Final Operational Capability (FOC) dates. One date that did not appear on the plan was June 2010; this is when the new 673rd Air Base Wing command stand-up will occur.
(4) A memorandum is expected to be sent to the agencies soon regarding transfer of the Fort Richardson Federal Facilities Agreement (FFA) to the joint base. The joint base position is that the Ft. Richardson FFA does not need to be reopened because the only changes required are administrative, such as changing the name of the FFA manager. Currently, EPA’s position on who will be the EPA RPM(s) for the joint base is unknown.
(5) Mr. Gusmano explained that there are new CERCLA sites in Alaska, so EPA is scoring and evaluating site priorities, responsible parties, etc. New RPMs may be hired, and different RPMs may be assigned to existing projects. Nothing will be certain for JBER until the EPA evaluates what lands are included in, and excluded from, JBER.
(6) Mr. Gusmano explained that because JBER will have two FFAs and two NPL sites at a single installation, we need to be aware that if waste is removed from an NPL installation, it must go to a permitted Treatment, Storage, and Disposal (TSD) facility. In other words, we can’t consolidate soil from the two different bases. EPA is working to get a waiver for this technicality so efficiencies can be realized on the joint base. Mr. Gusmano added that since the waste would not cross or use a commercial thoroughfare, this may not even be a problem.
(7) Mr. Gusmano asked who is the JBER counterpart for the EPA and ADEC attorneys. Is it Jim Klasen? Mr. Fink wasn’t sure who the official attorney would be after joint basing, but Mr. Klasen is currently the attorney for environmental issues.
(8) Mr. Fink discussed resolution of the Two-Party Agreements (TPAs) between Fort Richardson and ADEC. He explained that he had discussed this issue with Therese Deardorff and it was the joint base’s intention to dissolve these TPAs and use state regulations to guide cleanup actions at the associated sites. This would occur before FOC. Mr. Howard emphasized that the FFA includes tracking and reporting requirements for the TPA sites. Mr. Fink explained that the FFA requirements would be honored, but dissolving the TPAs would reduce duplication of efforts |
Louis Howard |
| 12/7/2009 |
Update or Other Action |
The following recommendations were developed by the Army pursuant to the March 2009 Fort Richardson FFA meeting held in Seattle, WA & as a result of subsequent analysis of 11 years of groundwater (GW) monitoring. These recommendations are meant as a guide for optimizing the future GW monitoring effort at the Poleline Road Disposal Area (PRDA).
UP-GRADIENT: Sample the mixing zone well (AP-4353).
a. GW elevation data in wells screened in the deep perched aquifer show no seasonal trend & very little variation in GW elevation. This implies the GW in the deep perched aquifer is not connected to the local shallow or regional deep aquifer systems. Any contaminant migration occurring from this area would be detected by the proposed monitoring network.
b. AP-4353 is a deeper well with contaminant exceedances suggesting vertical migration of contamination does occur here. The Army recommends continued monitoring of AP-4353 & if contaminant concentration begin increasing in this well sampling other wells along the mixing zone pathway (specifically, AP-4348/AP-4349).
c. AP-3749 is significantly up-gradient of the cleared area & is historically ND. Therefore, it can safely be removed from the monitoring program.
d. AP-4011, AP-4017, AP-4525 & AP-4551 are screened in the deep perched aquifer.
i. AP-4011 is unsuitable for LTM because it has a 26-foot screen.
ii. AP-4017 was damaged in 2002 by an earthquake.
iii. AP-4525 is unsuitable because of the slow rate of recharge to this well. In January 2009, AP-4525 was dry & could not be sampled.
iv. AP-4551 is a viable well, however because its contaminant concentrations track closely with the results from AP-4550, it is possible that there is some vertical communication between these closely spaced wells possibly due to the installation of AP-4551. Therefore, AP-4551 will not be included in routine sampling but, also, will not be decommissioned. Sampling of this well could be renewed if COC concentrations in the “hot spot” change.
DOWNGRADIENT: Recent spatial evaluation suggests the shallow plume ends north of AP-3747; contamination most likely migrates vertically & mixes with the deep regional aquifer in this area. Once contaminants reach the deep regional aquifer they appear to be diluted several orders of magnitude. At this time the Army does not feel further investigation of the northern extent of the shallow plume is necessary.The recommended monitoring network is as follows:
i. AP-3747 is the most downgradient shallow wells & has consistent contaminant detections. They vary from slightly above MCL to ND. Changes in concentrations in this area are important to understanding where there is potential for downgradient contaminant migration. The Army recommends continued sampling at this location.
ii. AP-4019 should be replaced as discussed below & sampled long-term.
iii. AP-4344 is the most downgradient deep well with contamination. Changes in concentrations in this area are important to understanding where there is potential for deep downgradient contaminant migration. The Army recommends continued sampling at this location.
iv. AP-4352 is a shallow well located near AP-4344, water level data collected in this well suggest it is locally perched & not part of the shallow aquifer system, it has been dry during the last two sampling events. Contaminant concentrations were consistently ND. The Army recommends discontinuing sampling at this location.
v. AP-3748 & AP-5246 are downgradient deep wells with trace contamination. The Army recommends continued sampling of these wells.
vi. AP-4345 & AP-4350 are also downgradient but it is presumed changes in the plume in this direction would be detected by AP-5246 & AP-3748 therefore The Army recommends discontinuing sampling of these wells. If the concentrations increase in AP-5246 or AP-3748 these wells may be sampled again.
vii. AP-4347, AP-4348 & AP-4349 are located to the east of the shallow plume; they were sampled once historically & will be sampled again to confirm the conceptual site model. Assuming non-detects these wells will not be part of the recommended long-term monitoring program.
viii. If changes in contaminant trends are observed in the downgradient deep aquifer a new well (LTMW-01) may be installed to help resolve these trends.
SOURCE AREA: Sample representative well that will allow the Army to monitor changes in the dissolved contamination/local gradients.
i. AP-4550 is located in the hot spot & currently has the highest contaminant concentrations observed in the shallow aquifer. The Army recommends continuing sampling at this site.
ii. AP-4519 replaced well AP-4015 which previously contained the highest contaminant concentrations observed in the source area. AP-4519 is screened deeper then AP-4015 & has lower concentrations then were observed in AP-4015 so AP-4550 is recommended for continued sampling in this area. |
Louis Howard |
| 1/29/2010 |
Document, Report, or Work plan Review - other |
Staff reviewed and commented on the Draft LTM Recommendations for Groundwater Monitoring at OUB dated December 7, 2009 and received on December 09, 2009 via electronic mail.
Figure 1 Current Monitoring Well Network and Figure 2 Recommended Monitoring Network
ADEC requests the Army change the figures to show trichloroethylene (TCE CAS Number 79-01-6) concentrations from 5 µg/L to 100 µg/L instead of 10 µg/L to 100 µg/L. ADEC also recommends the Army provide on the figures the other contaminant of concern (COC) in the 1997 OU A and B Record of Decision (ROD): 1,1,2,2-Tetrachloroethane (CAS 79-34-5) with two additional figures since the ROD states the "*hotspot" is defined as greater than 1 mg/L of 1,1,2,2-Tetrachloroethane.
Figures 1 and 2 imply the hotspot outlined in magenta is for TCE and not 1,1,2,2-Tetrachloroethane. If additional figures are developed for this other COC, ADEC recommends the Army use the following concentration ranges when highlighting areas with exceedances: 4.3 µg/L (18 AAC 75 Table C cleanup level) to 100 µg/L, 100 µg/L to 1,000 µg/L, and > 1,000 µg/L.
*1997 ROD
7.0 Selected Remedy Fifth Paragraph Page 74: The "hot spot" is defined by the area containing greater than 1 mg/L 1,1 ,2,2-Tetrachloroethane in groundwater (see Figure 3-6). This area represents the main threat at this site. Specifically, the "hot spot" is the area that contains the contamination and acts as a reservoir for migration of contamination to groundwater. Actively remediating this "hot spot" addresses the main threat. Concentrations of 1,1,2,2-Tetrachloroethane and TCE that exceed the 1 % solubility of these chemicals are found within the "hot spot." These high concentrations indicate a need to closely monitor for a denser-than-water nonaqueous phase liquid (DNAPL) during construction and operation of the "hot spot" treatment system.
7.2 Agency Review of the Selected Remedy
Page 76: The goal of this remedial action is to restore groundwater to its beneficial use. While the long-term goal of the remedial action is to return all the groundwater within and outside of the source area ("hot spot") to state and federal MCLs and risk-based criteria, active remediation will be considered complete when concentrations within the "hot spot" are below remediation goals for three continuous quarters after remedy shutdown and the plume is not expanding.
ADEC recommends the Army explain to the reader of the plan on why the groundwater monitoring has changed since the ROD was signed. Currently, groundwater monitoring is at a sampling frequency of twice a year from the original frequency of every quarter (i.e. Memo to the Site File with the 3 agencies signatures-cite reference) and that once cleanup levels appear to be met within the “hot spot” quarterly groundwater monitoring will begin again. Alternatively, if annual or less frequent monitoring is chosen at OUB, then three consecutive years of annually monitoring may suffice. ADEC requests the Army, EPA and ADEC remedial project managers discuss this matter.
*NOTE: 1,1,2-2 Tetrachloroethane has a lower promulgated cleanup level of 0.0043 mg/L (18 AAC 75 Table C eff. October 9, 2008) adopted since the 1997 ROD was signed.
2. Downgradient Page 3
The text states: “AP-4345 and AP-4350 are also downgradient but it is presumed changes in the plume in this direction would be detected by AP-5246 and AP- 3748 therefore The Army recommends discontinuing sampling of these wells.”
ADEC requests the Army keep deep wells AP-4345 and AP-4350 in the groundwater monitoring program, but sample both wells in preparation for the five year review.
4. Source Area Alternate Wells Page 3
The text states: “AP-3983 and AP-3984 are also located in the hot spot. AP-4550 adequately represents the hot spot so the Army recommends discontinuing sampling in these wells.”
ADEC requests the Army keep AP-3983 in the hotspot and discontinue sampling AP-4550 and AP-3984. Rationale: AP-3983 had the most vinyl chloride showing up in it from past sampling events and this may be an indicator of breakdown of chlorinated solvents (e.g. PCA/TCE).
The text states: “AP-3982 is located northeast of the hot spot and has been ND for several years. The Army recommends discontinuing sampling at this location since it is presumed AP-3744 would pick up any changes in the plume dimensions in this direction.”
ADEC requests the Army keep well AP-3982 as the shallow aquifer sentinel well in addition to monitoring AP-3744 since AP-3744 is already contaminated above MCL for TCE and AP-3982 has been clean since October 2000 which is what one might expect and desire in a sentinel well for a point of compliance. |
Louis Howard |
| 6/4/2010 |
Update or Other Action |
Staff received the GW monitoring report for spring & fall 2009. MWs & analyzing them for VOCs & natural attenuation parameters. The most recent VOC results generally fell within range of the historic results & tended to fall into the historic concentration patterns of the individual wells. Mann-Kendall analysis was performed to identify trends for various contaminants of concern at individual wells; the results indicate significant declining trends exist for ten wells within & downgradient of the former disposal area. Several increasing trends of chlorinated daughter products were present for hot-spot & downgradient, shallow wells; these increases appear to be associated with natural attenuation processes.
Shallow Aquifer Summary
COCs within the hot-spot area continue to be above RAOs. Downgradient of the hot-spot, the plume appears to be bounded by AP-4352 to the north. In AP-3982, northeast of the hot spot, COC’s were detected for the first time since August 2004 perhaps indicating slight plume migration. The levels of 1,1,2,2-PCA & TCE are above RAOs in AP-3747; with 1,1,2,2-PCA & TCE holding within historical limits. The extent of the TCE plume beyond AP-3747 in the shallow aquifer to the northeast is unknown.
The 1,1,2,2-PCA concentration in downgradient well AP-3744 remains below cleanup levels.
Deep Aquifer Summary
1,1,2,2-PCA in the deep hot-spot well (AP-4017) have decreased significantly. The combination of decreasing 1,1,2,2-PCA as well as PCE, in association with the increasing daughter compounds appears to be evidence that natural attenuation is occurring. Vinyl chloride has been detected in the hotspot well, but has not been detected in wells outside the hot spot. RAOs have not been achieved in the deep hot-spot well. TCE is the primary COC present in the deep aquifer.
The furthest downgradient RAO exceedance in the deep aquifer for the spring & fall 2009 sampling events exists at AP-4344 (10.3 µg/L & 11.2 µg/L, respectively), where neither increasing nor declining trends are evident. The deep plume appears to be bounded by AP-5246, AP-4345 to the north & AP-3748 to the northeast, where COCs are detected only rarely at levels below reporting limits.
Additional parameters were analyzed to help evaluate natural attenuation at the site. The analytes included sulfate, chloride, methane, ethane, ethene, total nitrate/nitrite, iron, & manganese, as well as the field parameters dissolved oxygen & pH. Overall, natural attenuation parameters were supportive of the presence of active reductive dechlorination.
Although a number of wells at the PRDA site have contaminants remain above RAOs, overall site contaminant levels appear to be decreasing. The extent of the contamination plume has continued to remain stable & is bounded to the north & northwest by AP-5246 & AP-4350, respectively, in the deep aquifer. The contamination plume in the shallow aquifer is bounded by AP-4352 to the north; however, the boundary north-northeast of AP-3747 is not defined. The presence of daughter products in almost all wells with contaminant concentrations above the RAOs, & the positive indications observed in the levels of other monitored natural attenuations parameters, indicate that reductive dechlorination is effectively occurring at the site.
Conclusions
26 GW wells were successfully monitored & sampled at PRDA during the spring & fall 2009 monitoring events, except for AP-4352 that was dry during fall sampling event. The conclusions below are based on the results of the monitoring events & the review of past monitoring results:
Review of historical data suggests overall contaminant levels at the PRDA site are generally decreasing; however, current levels of some COCs within & near the hot-spot area remain in excess of RAOs.
1,1,2,2-PCA & TCE continue to be the most prevalent COCs within the hot spot & downgradient plume.
Based on M-K analysis of the post-remediation data, the most significant declining trends in concentrations of COCs are apparent at monitoring wells located within the hot spot.
Natural attenuation parameters continue to provide supporting evidence that reductive dechlorination is occurring at the site, especially within the hot-spot area.
Concentrations of 1,1,2,2-PCA in GW at wells monitored in spring & fall 2009 continue to remain below the criteria of a hot-spot well defined by the ROD as exceeding 1,000 ug/L.
The shallow plume appears to be bounded by AP-4352 to the north; however, the extent of the plume beyond AP-3747 (to the northeast) is not currently understood.
Concentration of 1,1,2,2-PCA in downgradient, shallow-aquifer well AP-3744 continued to be less than the cleanup during these sampling events.
The deep plume appears to be bounded by AP-4350 to the northwest, AP-5246 to the north & AP-3748 to the northeast. |
Louis Howard |
| 6/4/2010 |
Update or Other Action |
Staff received the draft PRDA OUB GW Monitoring report.
Shallow Aquifer Summary: Concentrations of COCs within the hot-spot area continue to be above RAOs; however, concentrations of 1,1,2,2-PCA decreased slightly & in general, daughter product concentrations also are declining. This trend indicates that natural attenuation may be occurring throughout the shallow aquifer hot-spot wells.
Downgradient of the hot spot, the plume appears to be bounded by AP-4352 to the north & AP-3982 to the east northeast, where COCs have not been detected since at least August 2004. The concentrations of 1,1,2,2-PCA & TCE are above RAOs in AP-3747; with 1,1,2,2-PCA exhibiting a declining trend & TCE holding within historical limits. The extent of the TCE plume beyond AP-3747 in the shallow aquifer to the northeast is unknown.
The 1,1,2,2-PCA concentration in downgradient well AP-3744 was below cleanup level for the first time.
Deep Aquifer Summary: Concentrations of 1,1,2,2-PCA in the deep hot-spot well (AP-4017) have decreased significantly. The combination of decreasing 1,1,2,2-PCA (Figure 4-4) as well as PCE, in association with the increasing concentrations of the daughter compounds appears to be evidence that natural attenuation is occurring. Vinyl chloride has been detected in the hotspot well, but has not been detected in wells outside the hot spot. RAOs have not been achieved in the deep hot-spot well. TCE is the primary COC present in the deep aquifer.
The furthest downgradient RAO exceedance in the deep aquifer for the January 2009 sampling event exists at AP-4344 (12.3 µg/L TCE), where neither increasing nor declining trends are evident. The deep plume appears to be bounded by AP-5246, AP-4345 to the north & AP-3748 to the northeast, where COCs are detected only rarely at concentrations below reporting limits.
Review of historical data suggests overall contaminant concentrations at the PRDA site are generally decreasing; however, current concentrations of some COCs within & near the hot-spot area remain in excess of RAOs.
1,1,2,2-PCA & TCE continue to be the most prevalent COCs within the hot spot & downgradient plume.
Based on M-K analysis, the most significant declining trends in concentrations of COCs are apparent at monitoring wells located within the hot spot, with the most effective reductive dechlorination taking place near AP-4017 (the lone deep well within the hot spot).
Natural attenuation parameters continue to provide supporting evidence that reductive dechlorination is occurring at the site, especially within the hot-spot area.
Concentrations of 1,1,2,2-PCA in GW at wells monitored in January 2009 continue to remain below the criteria of a hot spot well defined by the ROD as exceeding 1,000 ug/L.
The shallow plume appears to be bounded by AP-4352 to the north & by AP-3982 to the northeast; however, the extent of the plume beyond AP-3747 (to the north-northeast) is not currently understood.
Concentration of 1,1,2,2-PCA in downgradient, shallow-aquifer well AP-3744 was below cleanup level for the first time.
The deep plume appears to be bounded by AP-4350 to the northwest, AP-5246 to the north & AP-3748 to the northeast.
See site file for additional information. |
Louis Howard |
| 6/21/2010 |
Document, Report, or Work plan Review - other |
Staff reviewed and commented on the draft groundwater monitoring report (January 2009) for OUB.
Executive Summary
The text states a Mann-Kendall (M-K) analysis is used to identify whether there is a statistically significant increasing or decreasing trend in the concentration of an analyte in an individual monitoring well. The analysis uses the relative magnitudes of the values, and not the measured values, to determine a trend. This method is not adversely affected by gaps in
sampling data, and allows the assignment of values to non-detects (in this case, one-half of
the method detection limit was used.)
Typically, the Mann-Kendall method tests for the presence or absence of trends, with the null hypothesis being ‘no trend’. With sufficient data, the null hypothesis can be rejected, but using the traditional method, there is no conclusion of ‘stability’ in the trend. Datasets with a large percentage of non-detects (30% or greater) and significant data scatter are more likely to return ‘no trend’ Mann-Kendall results.
ProUCL software may also be used to evaluate a 95% upper confidence limit (UCL) on analytical data and evaluate datasets with large numbers of non-detect results for true outliers. Calculating a 95% UCL for priority constituents at the plume stability monitoring locations will indicate when a concentration is outside of the expected high range based on previous analytical data. A 95% UCL can be used to set an acceptable high rebound concentration, exceedances of which would indicate a contingent remedy should be considered.
Conclusions Page 5-1
ADEC concurs with the conclusions presented in this section.
|
Louis Howard |
| 6/21/2010 |
Document, Report, or Work plan Review - other |
Staff reviewed and commented on the Draft Operable Unit B Poleline Road Disposal Area, Groundwater Monitoring Report Spring and Fall 2009.
Section 5 Conclusions Page 5-1
ADEC concurs with the conclusions in this section. In light of the recent federal facility agreement meeting in Seattle, WA at EPA’s office, it is recommended that a revised monitoring plan with a schedule be drafted up with the wells that will be sampled (several have been removed from the sampling program as agreed on in the Seattle meeting) and frequency of sampling.
|
Louis Howard |
| 11/17/2010 |
Update or Other Action |
Draft Memo to the Site File received.
This document was compiled in response to discussions concerning possible improvements to
long-term monitoring at Operable Unit B (OUB) at the March 2009 Fort Richardson FFA meeting
held in Seattle, WA. The recommendations were developed pursuant to an analysis of (at that
time) eleven years of groundwater monitoring. These recommendations are meant as a guide
for optimizing future groundwater monitoring at Operable Unit B, Poleiine Road Disposal Area
(PRDA) at JBER East (formerly Fort Richardson), Alaska.
The pre-ROD response (1994) included excavation of approximately 3,600 yards3 of contaminated soil. After evaluation of the potential risks and the appropriate cleanup standards, the selected alternative for OU-B (from the ROD) is Alternative 6: High Vacuum Extraction (HVE) of the hot spot. site-wide institutional controls, natural attenuation, and long-term monitoring of groundwater.
In essence, the approach for 2010 and beyond is a focusing of sampling effort on the less wellknown and -characterized deep/regional aquifer. It is appropriate to do this because the shallow aquifer is stable and has been well characterized in the previous approximately 12 years of monitoring. With this stability in the shallow aquifer, it is important to know how far and in which direction deep aquifer contamination may be moving ... if at all. This re-focus will result in a reduction in the number of wells monitored annually while maintaining a sufficient number of "contingency" wells in the network to quickly increase the overall site sampling effort, if necessary.
The addition of "contingency" wells to any given year's monitoring program would occur if contaminant concentrations in either the shallow or deep aquifer dramatically increase in response, for example, to a seismic event. Lastly, a small number of wells will act as "sentinel" wells to be sampled in the year preceding each successive Five-Year Review. It will also result in the decommissioning of a number of wells which are no longer contributing to site characterization or to measuring the attainment of the RAOs.
The shallow aquifer has been sufficiently characterized to conclude that further intensive
monitoring is unlikely to result in new findings. Future emphasis will, therefore, be placed on
monitoring the contamination in the regional (deep) aquifer while continuing sampling of a few
wells in the shallow aquifer to monitor trends in the source area. Seven wells2 will be used for
routine, "annual" sampling. If, in the course of annual monitoring of the regional/deep aquifer, it is determined that contaminant concentrations are increasing significantly, up to an additional 14 monitoring wells can be added to the sampling network to verify these trends, measure changes in contaminant plume concentrations, and the spatial extent of the plume.
Sampling should occur when the water table is at its annual peak when possible (usually in the fall) to ensure the maximum concentrations are being monitored long-term. The determination to add some or all of the "contingency" wells to the next annual sampling event would be based on "weight of evidence" criteria rather than on a specific numerical criterion. The Remedial Project Managers will review each annual sampling report and decide (based on the data and information in that report and those of preceding sampling years) whether and to what extent to include "contingency" wells in the next upcoming monitoring event.
It is the intent of the LTM Plan to decommission eleven wells, inasmuch as it has been
determined that these wells no longer provide adequate or useful data for the purposes of the
LTM Plan. |
Louis Howard |
| 2/7/2011 |
Exposure Tracking Model Ranking |
Initial ranking with ETM completed for source area id: 71919 name: Chlorinated solvents |
Bianca Reece |
| 3/29/2011 |
Update or Other Action |
Memorandum to the Site File for OUB Poleline Road Disposal Area received. In essence, the approach for 2010 and beyond is a focusing of sampling effort on the less well known and characterized deep/regional aquifer. It is appropriate to do this because the shallow aquifer is stable and has been well characterized in the previous approximately 12 years of monitoring. With this stability in the shallow aquifer, it is important to know how far and in which direction deep aquifer contamination may be moving if at all. This re-focus will result in a reduction in the number of wells monitored annually while maintaining a sufficient number of "contingency" wells in the network to quickly increase the overall site sampling effort, if necessary.
The addition of "contingency" wells to any given year's monitoring program would occur if contaminant concentrations in either' the shallow or deep aquifer dramatically increase in response, for example, to a seismic event. Lastly, a small number of wells will act as "sentinel" wells to be sampled in the year preceding each successive Five-Year Review. It will also result in the decommissioning of a number of wells which are no longer contributing to site characterization or to measuring the attainment of the RAOs.
The shallow aquifer has been sufficiently characterized to conclude that further intensive monitoring is unlikely to result in new findings. Future emphasis will, therefore, be placed on monitoring the contamination in the regional (deep) aquifer while continuing sampling of a few wells in the shallow aquifer to monitor trends in the source area. Seven wells will be used for routine, "annual" sampling. If, in the course of annual monitoring of the regional/deep aquifer, it is determined that contaminant levels are increasing significantly, up to an additional 14 monitoring wells can be added to the sampling network to verify these trends, measure changes in contaminant plume concentrations, and the spatial extent of the plume.
These additional wells are referred to as "contingency" wells. Sampling should occur when the water table is at its annual peak when possible (usually in the fall) to ensure the maximum concentrations are being monitored long-term. The determination to add some or all of the "contingency" wells to the next annual sampling event would be based on "weight of evidence" criteria rather than on a specific numerical criterion. The RPMs will review each annual sampling report and decide (based on the data and information in that report and those of preceding sampling years) whether and to what extent to include "contingency" wells in the next upcoming monitoring event.
To insure that longer-term trends are not missed, six wells will be sampled in the year prior to the next Five Year Review (2012) and the year prior to each succeeding 5 Year Review. These results will be reported with the "annual" well report in those years' reports. It is the intent of the L TM Plan to decommission eleven wells, inasmuch as it has been determined that these wells no longer provide adequate or useful data for the purposes of the LTM Plan.
Consistent with the current sampling and analysis plan for QUB, groundwater samples will be
analyzed for the primary CoCs by SW-846 Method 8260B. Natural attenuation parameters will include chloride and sulfate by EPA Method 300.0, nitrate/nitrite by EPA Method 353.2, light gases (methane, ethane, and ethylene) by method RBK 175, and iron and manganese by SW-846 Method 6020.
The above-listed natural attenuation parameters will be evaluated to assess the continuation of
the previously determined reductive dechlorination. Mann-Kendall statistical analysis of current and historical well analysis data for the COCs will be used to plot data trends in specific wells. Mann-Kendall has been very informative in clearly demonstrating the effects of active treatment and natural attenuation over the course of 12 or more years of monitoring.
The long-term monitoring network will be broken down into 3 groups: annually sampled
wells, contingency wells, and "5-year review" wells. A fourth group will be those wells
scheduled for decommissioning. Well decommissioning will occur only as funding is available.
A group of monitoring wells will be considered "sentinel" wells. These wells surround
and are generally down-gradient of the source area. The plan is to sample these wells
once every 5 years one Year in advance of each 5-Year Review. Detection of or
significant increases in contaminant concentrations here will be considered important
and will induce increased sampling. |
Louis Howard |
| 7/14/2011 |
Update or Other Action |
Staff received the draft GW Fall 2010 Monitoring Report at OUB May 2011, JBER-Richardson Alaska. This report presents the results of the fall 2010 GW monitoring event. Additional parameters were analyzed to help evaluate natural attenuation at the site. Although a number of wells at the PRDA site have concentrations of contaminants that remain above remedial action objectives (RAOs), overall site contaminant levels appear to be decreasing. The extent of the contamination plume has continued to remain stable & is bounded to the north, northwest, & northeast by AP-5246, AP-4350, & AP-3748, respectively, in the deep aquifer.
The contamination plume in the shallow aquifer is bounded by AP-4352 to the north & by AP-3982 & AP-4347 to the east; HOWEVER, the boundary north-northeast of AP-3747 is not defined. The presence of daughter products in almost all wells with contaminant concentrations above the RAOs, & the positive indications observed in the levels of other monitored natural attenuations parameters, indicate that reductive dechlorination is effectively occurring at the site.
Conclusions
Twenty-eight GW monitoring wells have been part of the PRDA GW monitoring program. Twelve GW monitoring wells were monitored & sampled at PRDA during the fall 2010 monitoring event. The GW sampling frequency at the PRDA had been conducted twice yearly prior to 2010, with sampling scheduled for spring & fall season. Depending on weather conditions & site accessibility, the actual sampling dates may have been adjusted. Based on the modified sampling program in 2010, the monitoring frequency was reduced to once a year.
The conclusions below are based on the results of the monitoring events & the review of past monitoring results:
• Review of historical data suggests overall contaminant concentrations at the PRDA site are generally decreasing; however, current concentrations of some COCs within & near the hot-spot area remain in excess of RAOs.
• 1,1,2,2-PCA & TCE continue to be the most prevalent COCs within the hot spot & downgradient plume.
• Based on M-K analysis of the post-remediation data, the most significant declining trends in concentrations of COCs are apparent at monitoring wells located within the hot spot.
• Natural attenuation parameters continue to provide supporting evidence that reductive dechlorination is occurring at the site, especially within the hot-spot area.
• Concentrations of 1,1,2,2-PCA in GW at wells monitored in fall 2010 continue to remain below the criteria of a hot-spot well defined by the ROD as exceeding 1,000 µg/L.
• The shallow plume appears to be bounded by AP-4352 to the north & by AP-3982 & AP-4347 to the east; however, the extent of the plume beyond AP-3747 (to the northeast) is not currently understood.
• Concentration of 1,1,2,2-PCA in downgradient, shallow-aquifer well AP-3744 continued to be less than the RAO during the current sampling event.
• The deep plume appears to be bounded by AP-4350 to the northwest, AP-5246 to the north & AP-3748 to the northeast.
See site file for additional information.
|
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.
The Fort Richardson OUB Poleline Road Disposal Area & OUE AMVA are sites contaminated with chlorinated compounds. They may include petroleum compounds, & they are included in a long-term monitoring program under a three-party agreement between the U.S. Army, ADEC, & USEPA. The RAO & LTM Program at OUB includes GW sample collection & analysis, replacement of damaged wells (& associated soil sample collection), monitoring well maintenance, & installation of jersey barriers for site control.
Samples will be collected in August 2011 for both OUB & OUE. Monitoring activities at each site will include an initial GW level survey for later use in developing potentiometric maps, followed by GW sample collection. A GW level survey will be conducted prior to GW sample collection at each site. Elevations will be determined during the initial visit to the site by using a depth sounder to measure water levels at all the wells to be included in the 2011 sampling program. The depth to water measurements will later be converted to elevations based on known top-of-casing elevation information.
Once a stable drawdown is achieved, the volume of water in the well casing & the volume of water in the pump’s tubing will constitute the maximum purge volume During purging prior to sample collection, select geochemical & physical parameters (pH, temperature, specific conductivity, dissolved oxygen, oxygen reduction potential, & turbidity) will be measured using a flow-through water quality meter; parameters will be allowed to stabilize before sampling. Wells will be considered stabilized once the field parameters (pH, specific conductivity, & temperature) from three consecutive readings at least 5 minutes apart are within 10 percent variance. Measurements of the field parameters will be recorded on a GW Sample Collection Form. GW samples will be collected from the monitoring locations & analyzed.
GW samples will be collected from 11 GW monitoring wells at OUB during the annual monitoring event currently scheduled for August. These wells are representative of both the shallow & deep aquifers.
Samples collected at OUB will be analyzed for the following:
-VOCs by E8021B/E8260B
-Dissolved iron/manganese by SW6020
- Chloride/Sulfate by E300.0
-Methane/Ethane/Ethene by RSK 175
See site file for additional information.
|
Louis Howard |
| 8/1/2011 |
Document, Report, or Work plan Review - other |
Staff provided comments on the Fall 2010 Groundwater Monitoring Report JBER-Richardson Operable Unit B Poleline Road Disposal Area May 2011.
General: ADEC requests clarification on when all of the groundwater monitoring wells at Poleline Road Disposal Area were last surveyed. Please include this information in the text of the report. Table 3-1 states the elevations referenced to the U.S. Army June 2003 and August 2004, Survey of Operable Unit B Data = NAVD88, Feet, state plane, Zone 4. This latest survey is seven and eight years old.
The ADEC 2009 Monitoring Well guidance states:
“Survey monitoring wells vertically and horizontally. Survey the top of the well casing and ground surface for use as a reference point to determine water-level elevations and sampling depths. At sites with long-term detection monitoring, survey the location of each well, the elevation of the land surface, and the top of each well casing. A registered professional surveyor or registered civil engineer engaged in the practice of surveying must conduct this work.
Sites undergoing contaminant assessment monitoring with a large number of monitoring wells should have the wells surveyed as described above. Re-survey monitoring wells every five years, or more frequently, if freeze-thaw processes compromise the well.”
Appendix A1 Water Sampling Logs: Page 70 of the PDF Water Sampling Log, Well No.: AP-3747 11/19/10 Time Started 0845. The Purging Data shows that 400 ml/minute [with Grundfos Pump] was the pumping rate at 0911 and 0921. Remarks “Could not decrease flow without freezing up tubing; maybe…sampling w/bailer next time.”
Page 72 of the PDF Water Sampling Log, Well No.: AP-3748 11/16/10 Time Started 1258. The Purging Data shows initial pumping rate [with Grundfos Pump] started at 700 ml/minute at 1335 and then from 1408 to 1424 it was pumped at a rate of 800 ml/minute. Remarks: “…-needed to keep flow @ 0.7 L/min. to prevent icing in tubing; Rate appear[s] to be increasing once no drawdown…”
Page 81 of the PDF Water Sampling Log, Well No.: AP-4344 Time Started 1446. The Purging Data shows that 700 ml/minute [with Grundfos Pump] was the pumping rate used at this well.
Page 92 of the PDF Water Sampling Log, Well No. AP-5246 11/16/10 Time Started 1151. The Purging Data shows 900 ml/minute [with Grundfos Pump] was the pumping rate used at this well. Remarks: “Any slower H2O would freeze on tubing.”
Sampling Log Book Page 109 of the PDF Nov. 16, 2010: -5 degrees F 1606: very cold @ this point-
Decon water is frozen, & tubing (all throughout day) frozen, & water would freeze in tubing if not enough pressure.” Page 110 of the PDF Nov. 17, 2010 -5 degrees F 16:40 Rinsate getting really cold as sun went down-equipment becoming erratic
ADEC requests the remedial project managers discuss the validity of sampling in November versus sampling in October when water would not freeze in tubing and the pumps could be used at a much lower pumping rate than the current 400 to 900 ml/minute currently being used to prevent icing up.
The use of bailers is inappropriate for low-flow sampling and not recommended for volatile organic compound groundwater sampling. ADEC is also concerned about the rate of pumping of groundwater from wells which are not the typical rates for “low-flow” for monitoring volatile organic compounds in groundwater (i.e. less than 0.5L/Min). |
Louis Howard |
| 3/16/2012 |
Update or Other Action |
Co-Occurrence of 1,4-Dioxane with Trichloroethylene in Chlorinated Solvent Groundwater Plumes at US Air Force Installations: Fact or Fiction
Richard H Anderson,*Janet K Anderson, and Paul A Bower
Air Force Center for Engineering and the Environment, Technical Support Division (AFCEE/TDV), 2261 Hughes, Site 155, Lackland AFB, Texas 78236, USA
Contractor, Air Force Center for Engineering and the Environment, Environmental Restoration Branch (AFCEE/ERD), Lackland AFB, Texas, USA (Submitted 22 November 2011; Returned for Revision 23 January 2012; Accepted 16 March 2012)
ABSTRACT
Increasing regulatory attention to 1,4-dioxane has prompted the United States Air Force (USAF) to evaluate potential environmental liabilities, primarily associated with legacy contamination, at an enterprise scale. Although accurately quantifying environmental liability is operationally dif?cult given limited historic environmental monitoring data, 1,4-dioxane is a known constituent (i.e., stabilizer) of chlorinated solvents, in particular 1,1,1-trichloroethane (TCA). Evidence regarding the co-occurrence of 1,4-dioxane and trichloroethylene (TCE), however, has been heavily debated.
In fact, the prevailing opinion is that 1,4-dioxane was not a constituent of past TCE formulations and, therefore, these 2 contaminants would not likely co-occur in the same groundwater plume. Because historic handling, storage, and disposal practices of chlorinated solvents have resulted in widespread groundwater contamination at USAF installations, signi?cant potential exists for unidenti?ed 1,4-dioxane contamination. Therefore, the objective of this investigation is to determine the extent to which 1,4-dioxane co-occurs with TCE compared to TCA, and if these chemicals are co-contaminants, whether or not there is signi?cant correlation using available monitoring data. To accomplish these objectives, the USAF Environmental Restoration Program Information Management System (ERPIMS) was queried for all relevant records for groundwater monitoring wells (GMWs) with 1,4-dioxane, TCA, and TCE, on which both categorical and quantitative analyses were carried out.
Overall, ERPIMS contained 5788 GMWs from 49 installations with records for 1,4-dioxane, TCE, and TCA analytes. 1,4-Dioxane was observed in 17.4% of the GMWs with detections for TCE and/or TCA, which accounted for 93.7% of all 1,4-dioxane detections, verifying that 1,4-dioxane is seldom found independent of chlorinated solvent contamination. Surprisingly, 64.4% of all 1,4-dioxane detections were associated with TCE independently. Given the extensive data set, these results conclusively demonstrate for the ?rst time that 1,4-dioxane is a relatively common groundwater co-contaminant with TCE. Trend analysis demonstrated a positive log-linear relationship where median 1,4-dioxane levels increased between approximately 6% and approximately 20% of the increase in TCE levels.
In conclusion, this data mining exercise suggests that 1,4-dioxane has a probability of co-occurrence of approximately 17% with either TCE and/or TCA. Given the challenges imposed by remediation of 1,4-dioxane and the pending promulgation of a federal regulatory standard, environmental project managers should use the information presented in this article for prioritization of future characterization efforts to respond to the emerging issue. Importantly, site investigations should consider 1,4-dioxane a potential co-contaminant of TCE in groundwater plumes. Integr Environ Assess Manag 2012;8:731–737
|
Louis Howard |
| 7/25/2012 |
Update or Other Action |
Draft GW Monitoring & Borehole Sampling report received for OUB & OUE.
Seven GW MWs were sampled at PRDA during August & September 2011. Additional activities included the installation of a replacement MW AP-5683 (AP-4019R), installation of Enviroblock concrete barriers around existing MWs, & a LUC site inspection. The conclusions below are based on the results of the 2011 activities & the review of historic GW monitoring results:
- Review of historical data through 2011 suggests overall contaminant levels at the PRDA site are generally decreasing; however, some COCs within & near the hot-spot area remain above the remedial action objectives (RAOs).
- Based on Mann-Kendall (M-K) analysis of the GW wells sampled, shallow wells within the hot spot (AP-4353 & AP-4550), & downgradient of the hotspot (AP-3747) & deep wells downgradient of the hot spot (AP-4344) continued to show decreasing trends of one or more of the primary contaminants. The remaining 3 sampled wells were either located downgradient of the extent of contamination (AP-3748 & AP-5246) & continued to have ND results for VOCs (indicating the extent of contamination remains stable in the deep aquifer), or did not have enough data to establish trends (AP-5683).
- Natural attenuation parameters continue to provide supporting evidence that reductive dechlorination is occurring in the shallow aquifer within the hot-spot area. No deep wells screened within the hot spot were sampled in 2011, therefore the deep aquifer wells were not carried forward in the discussion of natural attenuation factors.
- GW data collected during the sampling event continued to follow historic trends as far as the locations & concentrations of the monitored COCs, indicating the shallow & deep plume areas are remaining relatively stable.
-Soil samples collected during the installation of AP-5683 indicated TCE is present above the cleanup level at all sample intervals down to 138 feet (samples were generally collected every 20 feet). TCE exceeded 0.02 mg/kg cleanup criteria at all depths (18'-138' bgs), ranging from 0.7J mg/kg (18-23' bgs) to 3.2 mg/kg (98-103' bgs). J = The analyte was positively identified, & the quantitation is an estimation because of discrepancies in meeting certain analyte-specific quality control criteria. Or the analyte was positively identified, but the associated level is estimated above the MDL & below the LOQ
- Based on the LUC inspection, no unauthorized soil or GW-disturbing activities are occurring; however, the site access control measures have not been completely effective in preventing unauthorized site access by recreation all-terrain vehicle (ATV) users. The installation of concrete barriers around 11 existing MWs & Trespass Trail should aid in preventing further damage to monitoring wells & help restrict site access.
The LUCs restricting soil excavation, transport of materials offsite, & use of GW, along with the Base Civil Engineer Work Clearance Request process that JBER-Richardson has in place to perform any intrusive activities at the site, appear to be protective & prevent exposure to contaminated soil & GW at the site & continue to be effectively implemented.
ADEC Laboratory Data Review Checklist for report# G11090462 TestAmerica Sacremento CA
5. Sample Results c. All soils reported on a dry weight basis? NO. No soil for percent moisture analysis provided [by CH2MHILL] to the laboratory.
ADEC requires labs to correct for the solvent volume if using a water miscible solvent for extraction. When using a water miscible solvent (e.g. methanol) to extract soil VOCs, then you need to adjust the solvent volume for soil moisture content, per Section 11.10.5 of EPA Method 8000C. You must start making this solvent volume correction by April 1, 2008.
Additionally, all VOC samples for the State of AK must be methanol preserved at the time of collection. The use of alternate, low level preservation & analysis requires CS program approval on a site-specific basis. This would be primarily for analytes where the lab is unable to meet cleanup levels with methanol.
Background
Water & methanol are miscible; therefore, if you use methanol to extract soil VOCs, then the volume needs to be adjusted for the amount of soil moisture present in the solid sample. Section 11.10.5 (Moisture Corrected Reporting) of EPA Method 8000C (Mar-03) contains details on how to adjust the solvent volume for moisture content.
Some labs have not been doing this. If you do not make this adjustment, then the calculated concentration will not be accurate. The amount of error increases as the soil becomes wetter. This correction must be made for all methanol preserved soil sample VOC results reported by the lab. Additionally, per the notes to Tables B1 & B2 of 18 AAC 75.341, all concentrations in soil must be calculated & reported on a per DRY weight basis. |
Louis Howard |
| 10/17/2012 |
Document, Report, or Work plan Review - other |
Staff provided comments on the basewide UFP-QAPP which includes this site.
Site Background Third Paragraph
The Federal Facility Agreements (FFAs) divided up the Sites (Elmendorf and Fort Richardson) into subdivision of the Sites as Operable Units (defined by 40 CFR 300.5). The division of the operable units was generally based on:
- Availability and sufficiency of previously collected data to support remedy selection
- Similarities of source areas and contaminants
- Complexity and size of source areas
- Affected media, potential for migration, exposure pathways and receptors
ADEC requests JBER include text regarding the creation and presence of operable units on JBER as a part of the FFA.
Last Paragraph
The Army still has two separate agreements with ADEC. Change the word “had” to “has” in the first sentence and the word “focused” to “focuses” as the agreements are still valid and enforceable.
WS #9 Project Planning Session Summary
Meeting minutes of each planning or scoping session shall be part of the work plan and reports (as an appendix) when regulators are involved in the sessions in addition to being included in the project file and on the Alaska Group PBR Teamlink website. This will help any member that comes to the process after the meetings occurred to see what was discussed the decisions made during such meetings.
WS #10 Conceptual Site Model
Second Sentence
A CSM is always required. Delete reference to “as needed”. Developing a CSM is a critical step in evaluating a contaminated site, and must be prepared1 during the initial stage of the cleanup process, the site characterization phase.
The CSM is used to assist project managers in properly evaluating a site. It should be continually revised as new site investigations produce updated and more accurate information. In general, a CSM can be developed with only the most basic information about the site. The less information on hand, the more the preparer needs to err on the conservative side, assuming that a person, plant or animal could be exposed to the contamination. As more information is gathered, however, the CSM can be refined.
At closure, text accompanying the CSM should describe how exposure is being managed or minimized across all complete or potentially complete pathways.
Add ADEC’s Cumulative Risk Guidance (June 9, 2008) in addition to the guidance stated in the text. The Cumulative Risk Guidance is adopted by reference by 18 AAC 75.
WS #12 Sensitivity
This paragraph should also refer to LODs or both LOD/LOQs, since the LODs must (also) be verified quarterly not just LOQ.
Text states: “Any samples are not analyzed undiluted must be supported by matrix interference documentation, such as sample viscosity, color, odor, or results from other analyses of the same sample, to show that undiluted analysis is not possible. Appropriate cleanup procedures must be followed to minimize matrix effects on DLs and LOQs.”
Recommend text be added that the project chemist(s) be notified for review/approval of diluted and/or non-cleanup samples.
Accuracy AK101 GRO and AK102 DRO
Measurement Performance Criteria
AK petroleum methods only specify accuracy and precision criteria for LCS/LCSD.
VOCs by SW8260C and VPH
Representiveness/Usability
Holding time is 14 days to analysis.
PCBs by SW8082A
Representativeness/Usability
No holding time for PCBs. |
Louis Howard |
| 11/2/2012 |
Update or Other Action |
Draft third 5 Year Review received.
The purpose of this review is to ensure that remedies selected in each of the JBER-R Records of Decision (ROD) have been implemented, are performing effectively, & continue to be protective of human health & the environment. This review evaluates the remedy & its implementation status (as selected in the RODs), identifies discrepancies, & makes recommendations for resolving the identified discrepancies & improving performance of the selected remedies.
OUB: During site inspection activities, evidence of unauthorized ATV access was identified.
Recommendation: Concrete barriers were installed in the vicinity of the monitoring wells & at Trespass Trail to limit access to the site from unauthorized ATV users. A follow-up LUC inspection should be performed to ensure the concrete barriers are having the intended effect of preventing damage to the monitoring wells & limiting unauthorized ATV access.
The contaminant plume at OUB is bounded by the downgradient Monitoring Well AP-3747, located to the north-northeast of the “hot spot”; however, the plume boundary beyond Monitoring Well AP-3747 has not been defined.
Recommendation: Installation of an additional downgradient monitoring well to assist in defining the extent of the Poleline Road Disposal Area plume in the shallow aquifer is recommended.
GW samples from sentinel wells to be monitored prior to each Five-Year Review were not collected in time for data to be reviewed at the time this report was created.
Recommendation: GW samples from sentinel wells to be monitored prior to each Five-Year Review should be collected in the year preceding the beginning of the next Five-Year Review.
A cleanup standard different than the remedial action objective listed for 1,1,2,2-PCA in the Operable Unit B Record of Decision was promulgated by the Alaska Department of Environmental Conservation.
Recommendation: A memo should be sent to file describing the newly promulgated cleanup level established by the Alaska Department of Environmental Conservation.
Protectiveness Statement: The remedy at OUB is expected to be protective of human health & the environment upon attainment of GW cleanup goals at the Poleline Road Disposal Area site through natural attenuation; in the interim, LUCs are preventing exposure to contaminated GW.
See site file for additional information. |
Louis Howard |
| 11/9/2012 |
Document, Report, or Work plan Review - other |
EPA comments on the UFP QAPP.
An absence of comment on the Uniform QAPP does not equal blanket approval of equivalent in the site-specific QAPP. Generalities & vague concepts in the Uniform QAPP do not suffice for site-specific information necessary to assess contaminants & remedies.
Page number refers to the pdf page, not the document page number
In several instances throughout the document, the Basewide QAPP condenses multiple worksheets into one worksheet. These condensed worksheets exclude a significant amount of information that is discussed in the Uniform Federal Policy for Quality Assurance Project Plans Manual (UFP-QAPP Manual), dated March 2005. The Air Force needs to ensure that no information is lost from individual worksheets when condensed with other worksheets.
As stated, the main goal of the “JBER QAPP is to present a streamlined approach to the anticipated work at the JBER sites over the next eight years & is to be used in conjunction with site-specific UFP-QAPPs to be prepared during the contract Period of Performances (POP)”. With this goal in mind, because the project objectives per site are not universally the same, the following QAPP Worksheets will still be needed in the site-specific UFP-QAPP:
Worksheets #1 & 2 – Title & Approval Page
Worksheets #3 & #5 – Project Organization & QAPP Distribution
Worksheet # 6 – Communication Pathways, roles & responsibilities
Worksheet # 9 – Project Planning Session Summary
Worksheet # 10 – Conceptual Site Model
Worksheet # 12 – Measurement Performance Criteria
Worksheet #14/16 – Project Schedule
Worksheet # 15 – Project Action Limits & Lab Specific Detection/Quantitation Limits
Worksheet # 17 – Sampling Design & Rationale
Worksheet #18 – Sampling Locations & Methods
Worksheet #19 & 20 – Sample Containers, Preservation & Holding Times
Worksheet #20- Field QC Summary
Worksheet #23 – Analytical SOPs (if lab change)
Worksheet # 28 – Analytical Quality Control & Corrective Action (if lab change)
EPA comments JBER Draft Basewide U-QAPP 2
Comment #
Document/ Page &Line
Comment/Recommendation
Response
Please revise the Basewide QAPP to list all the worksheets that need to be completed for site-specific QAPPs.
There is no list of the standard operating procedures (SOPs). Please consider providing a list of SOPs, either as part of the Table of Contents or at the beginning of Appendix B.
If approved, this QAPP shall be reviewed every year & amendments shall be fully documented & submitted to ADEC & USEPA for approval. Per CIO 2106 S1, the expiration of an USEPA approved QAPP is only up to 5 years, unless there’s a major change in the implementation contractor &/or scope of work. On the 5th year, JBER will submit a revised Generic QAPP for the site addressing the current JBER project organization, site status, results of the previous 5 year work & the activities planned for the remaining 3 years to ADEC & USEPA for review & approval. The site specific UFP-QAPP shall follow the same revision process & subject to the same review & approval.
CIO 2106 Policy, Section 1.9, p. 27
The Uniform QAPP does not outline how site-specific workplans will be grouped or how many workplans are expected to reference this Uniform QAPP. Please describe the approach to the anticipated site-specific workplans (will they be grouped geographically? by contaminant? By media to be treated?)
Worksheet 3 & 5 p. 37
Project Organization & QAPP distribution. Suggestion to include review by a senior staff member within the contracting agency with strong CERCLA background on all QAPP workplans pertaining to CERLCA-based sites.
No reference (with the exception of Vicente resume) was found to the JBER Environmental Restoration Program Atlas, Final April 2012, & how it might be used as a planning or guidance tool in the Uniform Baseline QAPP or site-specific QAPP.
Table ES-1
p. 19-21
Table ES-1. Add Operating Unit designation associated with sites. Given the detail available in the JBER Environmental Restoration Program Atlas, Final April 2012, it is suggested that the table also provide the page number(s) of the atlas where the site is located. Suggestion to mark sites with petroleum contamination & under two party (ADEC) oversight with footnotes.
QAPP
Worksheets
#1 & #2
The information provided in the combined Worksheets #1 and #2 for Worksheet #2 is insufficient. The scoping sessions, mention of a QAPP for previous site work, and a list of any excluded QAPP elements are not included. Also, the QAPP identifying information that details where each required element is located in the QAPP is not included. Please revise Worksheets #1 and #2 to include this information. |
Louis Howard |
| 12/18/2012 |
Document, Report, or Work plan Review - other |
EPA comments on the draft Third Five-Year Review (FYR) for JBER-Richardson.
The draft report deviates from the “Comprehensive Five Year Review Guidance”, EPA OSWER No. 9355.7-03 B-P (June 2001) in that for two issues & two OUs the report concludes the answer to the question about whether the issue may affect future protectiveness the answer given is “TBD”. The only options available consistent with the guidance are “yes” or “no”, & when the answer is uncertain, the appropriate response is “Yes” the issue may affect protectiveness, in this case future protectiveness. From that, the appropriate conclusion for each of those OUs in terms of protectiveness is one of the following:
1. “protectiveness deferred”, with recommendations & followup actions to be taken to resolve the uncertainty (which the Guidance calls for the lead agency to do within 1 year);
2. “currently protects, & in order to remain protective for the long term the following factions need to be taken:...” ; or
3. “Not protective” & say what will be done about the issue.
If protectiveness if deferred, the Guidance calls for issues to be resolved in 1 year if at all possible.
Monitored Natural Attenuation (MNA) is a selected remedy for both OUB & OUE, so performance monitoring of MNA is an important component of the FYR Report; however, the FYR Report does not include discussion of geochemical parameters, & it is unclear whether groundwater monitoring even includes geochemical parameters. Changes in the geochemical setting as indicated by geochemical parameters (particularly the redox parameters such as redox potential, dissolved oxygen, nitrate/nitrite, manganese (II), iron (II), sulfate, & methane) may suggest there are changes in biotic or abiotic processes affecting the rate & extent of natural attenuation, so monitoring of these parameters is key for performance monitoring of MNA. Please revise the FYR Report to include discussion of geochemical parameters at OUB & OUE & what the parameters indicate about MNA at these sites.
Table 2-1 does not appear to present a complete chronology of events for OUB. For example, Table 2-1 indicates that an Expanded Site Investigation (SI) was conducted in 1990 & 1992, but does not give the date of the initial SI. Another example is the First & Second FYR Reports, which have not been included in Table 2-1. The merging of Elmendorf Air Force Base (AFB) & Fort Richardson is also missing from the table. Lastly, the construction complete date (September 2006 according to the Summary Form on page ES-3) has not been included. Please include the dates of previous Five Year Reviews. OUB Chronology contains a reference to a new monitoring well install in 2007. Please clarify this well with a well designation number & if it correlates to the new source area from the previous line in the table.
Please revise Table 2-1 to provide a complete chronology of the significant events for OUB.
Section 3.2.4 with the history of OUB describes the potential for munitions & UXO to ‘remain” in place in Area 1 & Area 2. The report states “No measurable concentrations of chemical agents have been detected in groundwater at the site”. Please describe sampling & analysis of munition-related constituents in groundwater, including perchlorate.
Section 3.2.5 states that “the concentration of COCs detected in soils near Areas A-1 & A-2 were less than RAOs… therefore, Areas A-1 & A-2 were not considered to be source areas;” however, concentrations of COCs less than RAOs in soil adjacent to Areas A-1 & A-2 does not necessarily support the conclusion that Areas A-1 & A-2 are not potential source areas. Contaminants present in soil at A-1 & A-2 (which was never sampled due to unexploded ordnance [UXO] concerns) could have leached into groundwater with little lateral migration in soil. Please indicate whether there is additional information to support the conclusion that Areas A-1 & A-2 are not potential source areas.
Figure 3-1 does not show the boundaries of the soil excavations or the locations of the treatability studies. Please revise Figure 3-1 to display both the boundaries of the soil excavation areas & the locations of the treatability studies at OUB.
Section 3.2.1 page 3-14 lines 2-4 Suggests topographical features on Figure 3-1. Please amend map to include topographic features & contour intervals or revise narrative.
There appear to be no deep wells within the excavated area or the area to the northeast of the excavation (i.e., downgradient), so it is unclear how contaminant concentrations & migration are monitored in deep groundwater. Please discuss the groundwater monitoring well network for deep groundwater at OUB.
|
Louis Howard |
| 12/20/2012 |
Meeting or Teleconference Held |
A meeting to discuss the response to comments (RTCs) on the Draft JBER Basewide UFP-QAPP was held on 20 December 2012 at the Environmental Protection Agency’s (EPA) office in the Federal Building in Anchorage, AK. On-site & teleconference attendees included representatives from the Joint Base Elmendorf Richardson (JBER), Air Force Civil Engineer Center Technology Transfer Office (AFCEC TDV), the Alaska Department of Environmental Conservation (ADEC), the U.S. Environmental Protection Agency (EPA), Weston Solutions, Inc. (WESTON), & CH2M HILL Constructors, Inc. (CH2M HILL).
Another section of ADEC Comment #9 was discussed: the phrase “the most stringent ADEC or EPA cleanup level.” Ms. Grepo-Grove wanted to know which is the most stringent. Mr. Fink answered that the choice instead depends on whether the site is under state or CERCLA regulation.
Ms. Halstead brought up JBER’s General Comment #5, asking which worksheets are site specific. Ms. Grepo-Grove believes more could be included under the Basewide QAPP. Ms. Halstead said until the Basewide QAPP is approved with any additional worksheets, all site specific QAPPs must include them.
Mr. Blei said they are already preparing work plans with worksheets that reference the Basewide QAPP. Mr. Jurena said the site specific work plans can be approved contingent on the approval of a Basewide QAPP. Mr. Fink says he doesn’t want to review documents until he can review them to approve them. It was decided that it would be easiest to proceed with decisions about the worksheets once a timeline of the approval of the Basewide QAPP was established.
A timeline with which to move forward was established. Ms. Janukajtis and Mr. Larsen said they would resubmit the RTCs based on today’s discussions, including meeting minutes, by the end of next week (December 28th, 2012). After discussion, it was decided that the agencies would approve or provide further comment on the resubmitted RTCs by January 15th, 2013. It was then decided that this resubmittal would be in redline form. Mr. Fink mentioned in regards to the timeline that some sites require fieldwork as soon as April.
Mr. Blei suggested February 15th as a submittal of the final QAPP. After further discussion, a suggested timeline was that a draft-Final red-line Basewide QAPP be submitted for review by February 15th, 2013 and the Final by March 8th, 2013. |
Louis Howard |
| 1/14/2013 |
Document, Report, or Work plan Review - other |
EPA comments on the UFP-QAPP Responses to EPA Comments.
The meeting notes, the revisions of the RTCs are acceptable. Just a few notes: change all references to Level IV data validation to a Stage IV validation. Also, state in the QAPP that "all labs that provided laboratory services and field personnel met the USEPA Forum for Environmental Measurement (FEM) policy for laboratory and field competency". An up-to-date certification/accreditation certificate must be included in the QAPP. Attached are the two documents mentioned and should be include in the list of references. |
Louis Howard |
| 1/16/2013 |
Document, Report, or Work plan Review - other |
JBER's responses to EPA comments on the draft 5 Yr. Review received.
The text of ES-6 line 1 will be updated as follows:
“Affect Current Protectiveness – No”
“Affect Future Protectiveness – No”
The text of ES-6 line 2 will be updated as follows:
“Affect Current Protectiveness –Yes”
“Affect Future Protectiveness – Yes”
The OUB Protectiveness Statement on ES-7 line 2 will be revised as follows:
“Protectiveness Determination: Short Term Protective”
“The remedy at OUB currently protects human health & the environment because the LUCs are preventing exposure to contaminated GW, soil, & potential UXO hazards. However, in order for the remedy to be protective in the long term, the COC RAOs established in the ROD will need to be re-evaluated to consider current COC toxicity information. Changes in toxicity values for some COCs currently result in & unacceptable risk (HI >1) when the residential exposure scenario is considered.”
The Protectiveness Statement on ES-7 line 3 will be revised as follows:
“The remedy at OUC is protective of human health & the environment.”
The OUE Protectiveness Statement on ES-7 line 4 will be revised as follows:
“Protectiveness Determination: Protectiveness Deferred”
“Protectiveness determination of the remedy at OUE is deferred until the potential impacts associated with vapor intrusion at the site are evaluated. The VI assessment is expected to be performed in 2013.”
The milestone date for the VI assessment will be changed to 2013.
Note: The highest PCE detected at the AVMA site during the most recent GW monitoring event (2011) was 140 ug/L; which only slightly exceeds the EPA Target GW Level Corresponding to Target Indoor Air Level of 110 ug/L. Levels of carbon tetrachloride, chloroform, & bromodichloromethane were also detected; however, they were detected below EPA VI target levels.
Table 8-1 & 9-1 will be updated to reflect any changes made to milestone dates &/or issues & recommendations.
The discussion of changes in toxicity values presented in Section 7.0 for each OU will be expanded upon.
Changes to OUB COC chemical specific toxicity information that occurred since the 2008 FYR affect cis-1,2-dichloroethene, trans-1,2 dichloroethene, TCE, & 1,1,2,2-PCA. These updates affect the OUB ROAs for 1,1,2,2 PCA (water & soil) & TCE (soil) because they were risk based at the time of the ROD (no regulatory MCL).
The toxicity changes result in an unacceptable exposure (hazard index >1) when the residential exposure assumption, used to support the OUB ROD, & the ROD RAOs are considered.
In the short term, the remedy for the AVMA remains protective because the residential use of the site is not permitted, access to the aquifer is restricted, & the RAOs are protective for an industrial exposure scenario. It is recommended that the OUB COC ROAs be updated to provide future protectiveness of human health.
Although the 2008 Fort Richardson FYR report identifies the risk based 1,1,2,2-PCA GW RAO (0.052 mg/L) as a typographical error, it is protective compared to the current EPA tap water RSL (0.066mg/L) as listed
White Phosphorus is the only COC identified in the OUB ROD does not have any matrix specific RAOs. No changes to toxicity or other characteristics for WP have occurred since the 2008 Five Year Review.
There have been no MCL changes to the chemical specific ARARs listed in the 2005 OUE ROD (40 CFR 141, 40 CFR 143, 18 AAC 75 & 18 AAC 80) that affect site COCs. Toxicity information has been updated since the risk assessment used to support the ROD was completed. The updated toxicity information does affect the protectiveness of the remedy because the RAOs listed in the ROD do not yield an unacceptable risk (carcinogenic or non-carcinogenic) for OUE.
To preserve the integrity of the historical data, the figures & data remain consistent with the reports from which they were obtained.
The text of page 3-2 starting on line 14 & ending on line 22 will be replaced by the following:
Eagle River & Ship Creek are the main streams traversing JBER. Ship Creek is the primary water supply source for JBER-R. 3 standby water supply wells supplement the surface water system with a maximum of 2 of the wells in use at time during peak demand. The water source for the standby wells is a confined aquifer in the Knik outwash deposit. The estimated population served by the water system is 10,000-11,000.
Water storage for JBER is provided by a permanent 2.5 million gallon underground reservoir in the Elmendorf Moraine, & by the Ship Creek Dam Reservoir at the base of the Chugach Mountain Range. A water treatment plant near the dam processes the drinking water. A drinking water well with a single service connection to the Otter Lake Recreational facility, about two miles from the cantonment area, serves a transient population. |
Louis Howard |
| 2/19/2013 |
CERCLA ROD Periodic Review |
The Alaska Department of Environmental Conservation (ADEC) has received the 5-Yr Review report for review on February 12,2013. ADEC appreciates the opportunity to review the third Five Year Review report for the Fort Richardson (now JBER-R) Superfund site, in Anchorage Alaska. ADEC reviewed this report for technical adequacy, accuracy, and consistency with EPA guidance and the Fort Richardson Federal Facility Agreement.
Also included are additional recommendations and follow-up actions necessary to address issues raised in the Five Year Review that affect or could affect protectiveness. In general, ADEC agrees with the protectiveness determinations in this report.
OUB Poleline Road ADEC concurs that the remedy for OUB Poleline Road Disposal Area is currently protective through implementation of Land-Use Controls (LUCs) However, to be protective in the long-term, JBER must conduct additional monitoring to augment the monitoring well network in the shallow aquifer to defme the downgradient limit of the plume. Additionally, the remedial action objectives for OUB COCs need to be updated based on changes in the toxicity factors (e.g. 1,1,2,2-tetrachloroethane for groundwater and soil and tetrachloroethylene for soil). The 1997 Record of Decision RAOs were based on 10-4 risk-based concentrations and a residential exposure scenario.
ADEC appreciates the Air Force's efforts in completing the Third Five Year Review and your project team on addressing ADEC's comments to fInalize the document. ADEC, EPA and JBER project managers have an excellent working relationship and ADEC looks forward to continuing this spirit of cooperation into the future.
See site file for additional information.
|
John Halverson |
| 2/22/2013 |
Document, Report, or Work plan Review - other |
EPA Program Mgr Remedial Cleanup Program (Cami Grandinetti) sent a comment & concurrence letter for the Third CERCLA Five-Year Review (FYR) for OUs B, C, & E, associated with Fort Richardson on JBER-R, AK. The conclusions in this letter are based on the unsigned final report which was received by the EPA on February 12, 2013. The EPA reviewed this report for technical adequacy, accuracy, & consistency with the NCP & EPA guidance.
The following are the EPA's protectiveness determinations for these Sites & the overall Site protectiveness that will be reported to Congress in the EPA's annual report. Also included are additional recommendations & follow-up actions necessary to address issues raised in the FYR that affect or could affect protectiveness. In general, the EPA concurs with the protectiveness determinations in this report. Each OU is discussed individually below.
The EPA concurs that the remedy for OU B - PRDA is currently protective through implementation of LUCs. Short term protectiveness is appropriate for this remedy where monitoring data indicate the remedy will not achieve the RAO goals for GW in the 150 year time frame, residential use of the site is not permitted, & access to GW is restricted. However, to be protective in the long term, additional monitoring is required to evaluate plume stability. The downgradient well AP-3747 monitoring data shows an increase in contaminant levels suggesting the plume stability cannot be evaluated & plume boundary is undefined.
Additionally, the ROD OU B RAOs for 1,1,2,2-tetrachloroethane at 0.1 mg/kg for soils & 0.052 mg/L for GW were adopted based on 10-4 RBCs & a residential exposure scenario. Changes to the toxicity factors for 1,1,2,2-tetrachloroethane result in unacceptable exposures under the residential exposure assumption. To ensure long term protectiveness of human health, the RAOs for COCs at OU B require updating.
The EPA concurs that the remedy for OU C - Eagle River Flats currently protects human health & the environment because pond draining to sublimate & oxidize white phosphorus has adequately addressed the wildlife exposure pathway that could result in unacceptable risk in this area. ERF is an active military range which inherently poses some human health & ecological risk.
The EPA concurs with the deferred protectiveness determination for OU E- AVMA pending additional sampling to address the potential for vapor intrusion at buildings above the contaminated AVMA GW plume. The VI evaluation is expected to be completed by 2014. An addendum to determine the protectiveness of OU E will be prepared by December 31, 2014. In addition, Land Use Controls for OUE-A VMA prohibit access to contaminated GW as a source of drinking water & the land use at this source area will remain industrial for the foreseeable future.
The remedial actions at OU B & OU C have been implemented & currently protect human health & the environment but require follow-up actions as documented in the report & this letter to ensure they remain protective into the future. The remedial action at OU E is deferred for protectiveness due to the potential for VI at buildings above the GW plume. Overall the site is currently protective but the follow-up actions need to be performed to ensure they remain protective in the long term.
Consistent with EPA's August 1, 2011 memorandum "Program Priorities for Federal Facility Five-Year Reviews", the FYR Guidance Section 1.3.3 has been superseded & the future FYR dates will be based on the completion date for this review to assure that the due dates will not change if the reports are early or late. The due dates for the subsequent FYR are February 22, 2018 & February 22, 2023. Finally, the August 1 Program policies memorandum also calls for a summary of the EPA Superfund Sitewide Environmental Indicator Status for Sites undergoing FYR. The Environmental Indicators for Fort Richardson are posted on the EPA website at SF Site Progress Profile Fort Richardson (USARMY).
The SF Sitewide Human Health Exposure Indicator status will be changed to "Insufficient data to determine human exposure control status." Due to uncertainty regarding exposures to vapor intrusion from OU E, the EPA cannot draw conclusions as to whether human exposures to tetrachloroethylene vapors are controlled in the manned facilities in the vicinity of the AVMA site in OU E.
The SF Sitewide Contaminated GW Migration indicator status will be changed to "Insufficient data to determine migration control status." As the downgradient well in OU B has recently increased in concentration, the EPA cannot draw conclusions as to whether the contaminated GW plume has stabilized.
Thank you for the Army's hard work in completing the Third FYR. I want to commend your staff on addressing EPA comments on earlier drafts & the efforts your project team demonstrated in finalizing the document. |
Louis Howard |
| 5/30/2013 |
Update or Other Action |
Draft Annual Field Activities report received for review & comment.
This report summarizes the 2012 annual long-term management activities, including remedial action-operation (RA-O) & Record of Decision (ROD) requirements conducted at Joint Base Elmendorf-Richardson (JBER) CERCLA sites. The United States Air Force (USAF) has mandated a reduction of long-term environmental liabilities & life-cycle costs through accelerated cleanup of contaminated sites.
Acceptance criteria for this project are specified in the Draft Basewide UFP-QAPP, criteria specified in the analytical lab standard operating procedures (SOPs), & accepted analytical methods. Overall, the data have met the quality control acceptance criteria specified for this project. Nonconformances of data are identified, discussed, & qualified in this report. When possible, direction of potential bias is assigned.
In September 2012, samples were collected from 13 groundwater monitoring wells at CG039 and analyzed for VOCs and natural attenuation parameters (including chloride/sulfate, nitrate/nitrite, dissolved iron and manganese, methane, ethane, and ethene). In addition to the seven wells that are sampled annually, 5-year wells that are sampled every 5 years were also sampled (USAF, 2012b). LUC inspections were conducted in September 2012.
As shown in Table 2-1 and Figures 2-1 and 2-2, cis-1,2-DCE, PCE, TCE, 1,1,2,2-PCA, and 1,1,2-TCA exceeded cleanup criteria in one or more wells. Carbon tetrachloride, trans-1,2-DCE, and 1,1-DCE were detected in groundwater but at concentrations below their respective cleanup levels. Geochemical results (including laboratory and field measured parameters) were evaluated to assess the effectiveness of reductive dechlorination (biodegradation of chlorinated compounds) at CG039. Laboratory measured parameters include VOCs and natural attenuation parameters (including chloride/sulfate, nitrate/nitrite, dissolved iron and manganese, methane, ethane, and ethene). Field measured parameters (using a YSI 556) include pH, conductivity, turbidity, DO, temperature, and ORP.
Site Summary
An OES Performance Plan for CG039 was finalized in February 2013 under the current PBR contract. The OES at CG039 includes performing an in situ treatment treatability study and continuing long-term monitoring as outlined in the 2011 Memorandum to the Site File. The treatability study will be conducted to assess the viability of enhanced reductive dechlorination (or other appropriate substrates) and in situ chemical oxidation. |
Louis Howard |
| 6/12/2013 |
Update or Other Action |
Draft UFP-QAPP for a treatability study received for review and comment.
The objective of the treatability study is to assess the effectiveness of in situ treatment for
reducing TCE concentration in groundwater at the site through: (1) ERD using emulsified
vegetable oil (EVO), (2) BiRD using EVO with ferrous sulfate solution addition, and (3) ISCO
using sodium permanganate injections. Additionally, the treatability study will determine
injection hydraulics and radius of influence (ROI) of the injections.
The effectiveness of the injections will be evaluated by calculating reductions in the geometric mean concentration of TCE in the treatment area as compared to the baseline concentrations.
Three target treatment zones have been identified as part of this treatability study. The zones
targeted for treatment are zones in which the TCE concentration exceeds approximately
1,000 µg/L in groundwater. Two target treatment zones surrounding shallow monitoring wells
AP-3983 and AP-4550 are located within the shallow aquifer hot spot. One target treatment zone surrounding deep monitoring well AP-4551 is located within the deep perched aquifer hot spot.
The substrates will be delivered to the subsurface using two injection wells in each target
treatment zone generally perpendicular to groundwater flow and upgradient of each selected
performance well within each target treatment zone.
Various treatment technologies will be evaluated to meet the objective of optimizing the existing remedy (natural attenuation and long-term monitoring). It is anticipated that the optimization will reduce contaminant mass in areas of high concentrations, thereby reducing the restoration timeframe and life-cycle costs.
Based on the results of this treatability study, the decision to implement full-scale in situ treatment will consider the technical feasibility of implementation, including the ability to implement the technology within the constraints of the site settings, in addition to the overall cost to implement the technology. Based on these considerations, ERD, BiRD, and ISCO have been selected for evaluation during a treatability study within the TCE hot spots in both the shallow and deep aquifers. |
Louis Howard |
| 6/28/2013 |
Document, Report, or Work plan Review - other |
Staff provided comments on draft annual field activities CERCLA report.
Comment#1
ADEC is requesting that 1,4-dioxane be sampled for in groundwater where trichloroethylene (TCE) or 1,1,1- trichloroethane (TCA) contamination exists or was previously above cleanup levels at any site (CERCLA or State restoration or compliance). Please incorporate these comments into any basewide sampling plans (current/future).
AFCEE research has found 1,4-dioxane at Air Force sites contaminated with TCE. The study, titled "Co-Occurrence of 1,4-Dioxane with Trichloroethylene in Chlorinated Solvent Groundwater Plumes at US Air Force Installations: Fact or Fiction," found detections of 1,4-dioxane at sites with TCE, independent of TCA.
"Surprisingly, 64.4% of all 1,4-dioxane detections were associated with TCE independently," the researchers say in the abstract. "Given the extensive data set, these results conclusively demonstrate for the first time that 1,4-dioxane is a relatively common groundwater co-contaminant with TCE."
The study authors recommend site investigations consider 1,4-dioxane as a potential co-contaminant of TCE at groundwater plume sites. The study, which was published in the Integrated Environmental Assessment and Management journal last year, explicitly warns that new discoveries of 1,4-dioxane contamination could delay cleanup completions and require more costly revisions to existing remedies, noting that there is strong evidence suggesting that 1,4-dioxane "will migrate much further than chlorinated solvents."
ADEC has promulgated enforceable cleanup levels (not advisories) for 1,4-Dioxane in soil and groundwater (latest version 18 AAC 75 April 2012 Table B1 and Table C) effective since 2008 which has remained unchanged in 2012 revised regulations.
Soil Under 40 inch Zone
540 mg/kg direct contact
0.21 mg/kg migration to groundwater
0.077 mg/L (77 µg/L) Table C groundwater cleanup level
This comment regarding monitoring requirements for 1,4-Dioxane applies to JBER-Elmendorf and JBER-Richardson sites with current or past TCE or TCA contamination. The monitoring requirement is also applicable to the “Early Warning and Sentry Wells” which were established to provide early detection of contaminant plumes that may impact Ship Creek or other downgradient environmental receptors.
1,4-Dioxane readily leaches to groundwater, is not expected to adsorb significantly to soil particles, and is difficult to biodegrade. Due to these properties, a 1,4-Dioxane plume typically proceeds ahead of the chlorinated solvent plume, and will tend to impact an aquifer system to a much larger extent.
Suggested laboratory methods: SW-846 Method 5030C, SW-846 Method 5021, SW-846 Method 8261A, SW-846 Method 5031, SW-846 8270C SIM, LVI and isotope dilution (1.0 µg/L or 2.0 µg/kg reporting limits). Dioxane can be detected using EPA 8260; however, its high water solubility causes relatively high reporting limits.
Routine organic extraction procedures like those traditionally used for EPA 8270 analyses produce low recoveries (approximately 50% or less). Whatever laboratory method is proposed for 1,4-Dioxane by JBER, the laboratory method must be able to detect at or below the ADEC promulgated groundwater cleanup level in Table C and migration to groundwater cleanup level in soil.
Be aware that with ADEC’s regulatory revisions in 2014, the level for 1,4-Dioxane (as well as many other compounds) will go down substantially from its current promulgated levels for soil and groundwater. These changes in regulations will be available for public comment sometime this year.
Finally, the EPA May 2013 Regional Screening Levels for tapwater lists a lower screening level of 0.67 ug/L which equates to a 1x10-6 total risk as well as a noncarcinogenic screening level of 47 µg/L which equates to a HI of 0.1.
15.4 [CG039] Site Summary
Add “CG039” to Site Summary heading. See comment #1 regarding 1,4-dioxane analysis in groundwater. This comment applies to JBER-E and JBER-E sites with current or past TCE or TCA contamination.
|
Louis Howard |
| 7/18/2013 |
Document, Report, or Work plan Review - other |
EPA provided comments on the TS WP.
Please explain why the geometric mean will be used to evaluate reductions & how the calculations will be performed.
Site-Specific Proposed Work
The decision to implement full-scale in situ treatment at CG039, & the design of that full-scale remedy, will be based on the results of the TS performance monitoring & regulator concurrence.
WS #5
Is the EVO or ISCO injection subcontracted? If so, please include. In either case, if injections are performed by CH2 or a subcontractor, SOPs for these activities will need to be developed & included.
WS #9
Add scoping meeting minutes from 4/30/13 meeting with the regulators. See the comments for W#9 on the DA085 (AVMA) treatability for the participant list & items discussed.
Page 22
Nature & Extent of Contamination
GW
The statement that shallow & deep aquifer areas of contamination are well defined & stable is not supported in the recent Fort Richardson 5 Year Review (Feb 2013). The plume boundary was determined to be undefined & a conclusion was made that there was insufficient data on plume stability to make a protectiveness determination. Much of the concern stems from the TCE at wells AP-5683 (deep with TCE in boring samples to depth) & AP-3747 (shallow 'down-gradient' well with 88 ug/L TCE).
Page 25
The comparisons of the hot spots would be best made to wells outside the contaminated area. The comparisons provided here are to 'less contaminated' well parameters, which in some cases are >15x the MCL for TCE.
Page 28
Data Quality Objectives
The DQOs presented here are logical, but do not correspond to any of the four DQOs outlined in Worksheet #11 of the JBER Basewide UFP-QAPP (2013). It is suggested to develop a DQO for evaluation of treatment effectiveness.
GW Sampling & Analysis (Performance Monitoring)
Please clarify when the 1/4ly performance monitoring will begin. If it is soon after injection, be aware that the presence of injected chemicals in the sample can bias the results low, effectively by continuing to destroy contaminants in the sample between collection & analysis. It can also cause serious analytical interferences. There’s an EPA issue paper by Scott Huling about this:
www.epa.gov/superfund/remedytech/tsp/issue.htm (see the first issue paper listed under the Ground Water Forum)
|
Louis Howard |
| 7/29/2013 |
Document, Report, or Work plan Review - other |
Staff reviewed and commented on the Draft UFP-QAPP Treatability Study Work Plan.
WS #10 Conceptual Site Model
Existing Natural Attenuation Conditions
The text states: “Additionally, the lack of vinyl chloride downgradient of the hot spots may indicate that the aerobic conditions outside the hot spot are capable of oxidizing this daughter product of chlorinated hydrocarbon degradation.”
Alternatively, the lack of vinyl chloride downgradient of the hotspots may indicate that degradation process is stuck at DCE and no further dechlorination is occurring.
WS #17 Sampling Design and Rationale
Page 45
Well Installation
Last Paragraph
The text states: “Prior to drilling, utility locates will be performed in accordance with SOP-04 to identify potential underground hazards. In the event underground utilities or structures cannot be definitively identified, an air knife and vacuum truck may be used to clear the upper 6 feet of the proposed drilling location prior to drilling or conducting other invasive activities. Once clearance activities have been completed in the upper 6 feet of the soil column, soil removed during utility clearance will be placed back into the hole from which it was removed.”
This 6 ft. interval shall not be excluded from field screening and sampling requirements due to it being previously removed and replaced during utility investigation activities.
While ADEC does not have a RCRA program nor is it a RCRA authorized State, it is providing the following comments (subject to EPA Region 10 official comments regarding RCRA):
In addition, there may be RCRA implications for the soil removed in this six foot interval that will not allow it to be replaced back in the “excavation” once removed from the ground. Chlorinated solvents are likely present at this site in the soil.
The purposes of the Federal Facility Agreement list RCRA (among other purposes):
Assure compliance, through this Agreement, with RCRA and other federal and state hazardous waste laws and regulations for matters covered herein.
RCRA/CERCLA Integration
Therefore, the Parties intend that activities covered by this Agreement will achieve compliance with CERCLA, 42 U.S.C. 5 9601 & seq.; satisfy the corrective action requirements of Sections 3004(u) and (v) of RCRA, 42 U.S.C. § 6924(u) and (v), for a RCRA permit, and section 3008(h), 42 U.S.C. 5 6928 (h) , for interim status facilities; and meet or exceed all applicable or relevant and appropriate federal and state laws and regulations, to the extent required by section 121 of CERCLA, 42 U.S.C. § 9621, and applicable state law.
The Parties agree that with respect to releases of hazardous waste or hazardous constituents covered by this Agreement, RCRA shall be considered an ARAR pursuant to Section 121 of CERCLA, 42 U.S.C. § 9621. Releases or other hazardous waste activities not covered by this Agreement remain subject to all applicable state and federal environmental requirements.
Subject to EPA comments on the matter, it appears that any drill cuttings or soil from the air knife operations shall need to be contained and characterized to determine whether or not they are a waste under RCRA that requires proper disposal/treatment. Clean fill will need to be stockpiled or available for placement should any of the soil removed be found to exceed applicable cleanup levels.
WS #20 Field QC Summary
Add VOCs (SW8260 preserved with methanol for ADEC requirements and one set of samples without methanol-low level e.g. sodium bisulfate to satisfy EPA requirements) to soil for any drill cuttings and soil removed during air knifing or drilling operations for waste characterization and disposal requirements.
In this case, it is ADEC’s expectation that when both analyses are performed; the methanol is the primary analysis for all COCs and the low level as the secondary line of evidence for those compounds not meeting required detection levels.
|
Louis Howard |
| 9/3/2013 |
Document, Report, or Work plan Review - other |
EPA Comments on SOP-28 Remedial Substrate Injection
SOP 28 for Remedial Substrate Injection was received for review on 8/19/13. Comments had been submitted on the draft Treatbility Workplans for both DA085 and CG039 on July 18 in which additional information on the substrate injection process was required. This SOP satisfies that requirement, as amended considering the following comments.
The verb “should” is used throughout the document (sections Pre-injection Activities, Injection Monitoring, etc…). As these are SOPs, a more definitive term such as “will” or ‘must’ is appropriate. Please revise the SOP to define the required actions. Actions to be completed at the field technician’s discretion can remain in the advisory verb of ‘should’.
The SOP contains no contingency plans for directions for system shutdown in the event of an emergency or unplanned interruption (adverse weather, military maneuvers, system failure). Please add a section to the SOP on system shutdown processes if done mid-stream in an injection.
p. D-1 SCOPE
The scope of this SOP-28 Remedial Substrate Injection refers only to JBER-R. Will a separate SOP be developed for JBER-E?
p. D-4 Injection System Setup
Please add the required pre-inection baseline monitoring measurement activities to the protocol at the appropriate point in the protocol. At this time, the Radious of Influence (ROI) and Performance Well Monitoring baseline measures are suggested to be made prior to injection (“a baseline reading should be made prior to injections….”) in the Injection Monitoring section. It is highly suggested the ROI and Performance Well baseline measures be added under the Pre-Injection Activities section (preferred) or in the Injection System Setup section but prior to the addition of water during the water-only injection tests. Please see comment #2 regarding the use of the word ‘should’ and change to ‘will’ or ‘must’.
p. D-7 Documentation First Bullet
Please add the Baseline measures to the Documentation section for the ROI and performance monitoring wells. The sentence currently addresses periodic water quality measures. Please change the sentence to require “Baseline and periodic water quality ….”
|
Louis Howard |
| 2/26/2014 |
Update or Other Action |
Treatability study implementation report received for review & comment.
Treatment Substrate Selection: The results of soil NOD & foc analyses show a substantial variability in subsurface soils. Overall, the results suggest that NOD is heterogeneous in the subsurface across the site, with some zones of low NOD & some zones of high NOD. Since NOD heterogeneity is not a desired condition for use of sodium permanganate, it was decided that sodium permanganate would not be used for the treatability study. As a result, the selected treatment alternatives were EVO & EVO with ferrous sulfate.
TCE Variability within a Target Treatment Zone: The lack of variability in TCE within each target treatment zone suggests that the effects of ERD treatment caused by EVO substrate injection within the aquifer should be relatively uniform within each target treatment zone.
Substrate Injection Hydraulics
Shallow Aquifer: The shallow subsurface lithology consists largely of sands & gravels with some silt & easily accepts the injection of EVO. Because of lack of crossgradient monitoring locations, observations of lateral distribution of EVO are limited to the 15’ between the injection wells at each target treatment zone. Lateral distribution of EVO was at least 15’.
The differences in maximum injection rate & pressure are likely related to well construction &/or well development. The ability of the shallow aquifer to accept the injection of EVO suggests that a possible future full-scale implementation of EVO injections could deploy a lateral injection well spacing greater than the 15’ spacing used in the treatability study. Additionally, because of the downgradient distribution (130’ from the injection of approximately 11,000 gallons of EVO solution), it is possible that a line of injection wells could be set at the upgradient edge of the hot spot, & if enough EVO solution were injected, it could be distributed to treat the entire hot spot.
Deep Perched Aquifer: The lithology of the deep perched aquifer consists of partially interconnected silty sand & gravel lenses within a basal till/weathered bedrock. Visual EVO breakthrough did not occur at AP-4551 until 2 hrs following completion of the injection of 1,380 gallons at MW02-4551, at which point the second batch of EVO had been injected at MW01-4551. Based on the time lag in the breakthrough of EVO downgradient as compared to laterally, it is possible that preferential flow pathways partially control the distribution of GW flow within the deep perched aquifer. This is consistent with the interpretation that the deep perched aquifer is composed of partially interconnected sand & gravel lenses within a larger till body, overlying weathered bedrock.
The difficulty of EVO injection at MW01-4551 is most likely related to the nature of the deep perched aquifer, which consists of partially interconnected sand & gravel lenses within a larger till body, overlying weathered bedrock. The non-uniform ability of the aquifer to accept the injection of EVO & the observed ROI suggest that any possible future full-scale implementation of EVO injections within the deep perched aquifer should deploy an injection well spacing of not more than 15’.
See site file for additional information. |
Louis Howard |
| 3/18/2014 |
Document, Report, or Work plan Review - other |
Staff provided comments on the draft treatability study.
Executive Summary
1st Paragraph
ADEC requests the text state: “The Air Force Civil Engineer Center (AFCEC) has implemented a treatability study at CG039 - Poleline Road Disposal Area pursuant to the process established in the Fort Richardson Federal Facility Agreement (1994) & the Comprehensive Environmental Response, Compensation, & Liability Act of 1980 (CERCLA), as amended by the Superfund Amendments & Reauthorization Act of 1986 (SARA). The purpose of the treatability study was to assess the effectiveness of enhanced reductive dechlorination (ERD) & biogeochemical reductive dechlorination (BiRD) for treating contaminated GW at the site as part of a pilot scale study.”
Please state whether the AF considers enhanced reductive dechlorination (ERD) & biogeochemical reductive dechlorination (BiRD) as innovative treatment technologies for treating contaminated GW. The EPA’s Guidance for Increasing the Application of Innovative Treatment Technologies for Contaminated Soil & Ground Water (EPA 1991) & its cover memorandum indicate the Agency’s willingness to adjust program goals & commitments, when appropriate, to achieve better cleanup solutions through innovative treatment technology development.
2nd Paragraph
Remedial cleanup goals for OUB included more than just TCE in GW: benzene, carbon tetrachloride, cis-1,2-Dichloroethene, trans-1,2-Dichloroethene, Tetrachloroethene (PCE), 1,1,2,2-Tetrachloroethane. (Table 5-1 OUB ROD).
Additionally, the 1997 OUB ROD states in the Description of the Selected Remedy:
“Long-term monitoring to assess whether GW contamination is approaching the Eagle River & to ensure that contamination levels in the GW are decreasing through natural attenuation. The plume outside the "hot spot" will be monitored to track plume migration & the progress of natural degradation processes.”
See also Section 7.1 Major Components of the Selected Remedy which states:
“Allow natural attenuation of GW contamination in areas outside the "hot spot";” Monitored natural attenuation means that not only the primary chemicals of concern will be monitored as identified in the ROD, but their daughter (or breakdown) products will be monitored for as well as part of the remedy for OUB.
5th Paragraph
ADEC requests the text state: “This treatability study report provides an overview of the implementation activities & initial results for the site. This document includes injection well installation details, baseline soil & GW sampling results, & EVO injection data.”
Page ES-3
EVO Injection
3rd Paragraph
ADEC requests the text state: “The ability of the shallow aquifer to easily accept the injection of EVO suggests that a possible future full-scale implementation, under the process established by the Fort Richardson Federal Facility Agreement & CERCLA for a fundamental Post-ROD change (ROD amendment ), of EVO injections could deploy a lateral injection well spacing greater than the 15-foot spacing used in the treatability study.”
Any selection of a remedial action (i.e. full-scale treatment) shall be in accordance with the process listed in the Fort Federal Facility Agreement (i.e. Part VIII. Scope of Agreement, F. Remedial Actions paragraph 8.10
Introduction
1st Paragraph
ADEC requests the text state: “This treatability study provides the details & documentation of the field & construction activities associated with the enhanced reductive dechlorination (BiRD) substrate injections at CG039...”
2nd Paragraph
ADEC requests the AF elaborate here & in the executive summary on assessment used to predict the time to achieve remedial action objectives listed in the OUB ROD for GW (i.e. GW contaminant levels are below federal & state MCLs throughout the site.). Be aware that there are RAOs for soil at OUB as well that must be confirmed through soil borings & sampling in addition to any GW contamination present at this source area.
The 1997 ROD states:“…150 years for natural attenuation of remaining GW to meet state & federal MCLs & risk-based criteria;” which is quite different than the 59 years mentioned in this treatability study. The 150 year timeframe appears to be based on TCE & 1,1,2,2-Tetrachloroethane fate & transport modeling, assuming no biodegradation, detectable concentrations (0.005 mg/L) reaching Eagle River in 120 & 170 years using two numerical models.
The 1997 ROD states:“…150 years for natural attenuation of remaining GW to meet state & federal MCLs & risk-based criteria;” which is quite different than the 59 years mentioned in this treatability study. |
Louis Howard |
| 5/14/2014 |
Update or Other Action |
Draft 2013 Annual Field Activities Report received. This report summarizes the 2013 annual long-term management activities, including remedial action-operation (RA-O) and Record of Decision (ROD) requirements, conducted at Joint Base Elmendorf-Richardson (JBER) Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) sites. The United States Air Force (USAF) has mandated a reduction of long-term environmental liabilities and life-cycle costs through accelerated cleanup of contaminated sites. As such, the Performance-Based Remediation (PBR) initiative has been developed to protect human health and the environment in a cost-effective manner, while at the same time reducing life-cycle costs.
In April 2012, Weston Solutions, Inc. (WESTON) was awarded a PBR contract from the Air Force Civil Engineer Center (AFCEC) (Contract Number FA8903-09-D-8589, Task Order No. 0016). The contract includes performing RA-O and ROD requirements at several JBER sites. The WESTON team performing the activities summarized in this report consists of WESTON and CH2M HILL Constructors, Inc. (CH2M HILL). WESTON executed project work on sites located within JBER-Elmendorf, while CH2M HILL executed project work on sites located within JBER-Richardson.
An Optimized Exit Strategy Performance Plan for CG039 was finalized in February 2013 under
the current PBR contract. The Optimized Exit Strategy at CG039 includes performing an enhanced reductive dechlorination treatability study and continuing LTM as outlined in the 2011 Memorandum to the Site File. Implementation of the treatability study occurred in July and September of 2013, when injection wells were installed and a combination of emulsified vegetable oil and ferrous sulfate were injected into two locations in the shallow aquifer and one location in the deep aquifer. The performance of those injections is currently being monitored; preliminary results will be available following the 2014 sampling round. |
Louis Howard |
| 6/9/2014 |
Document, Report, or Work plan Review - other |
ADEC has reviewed the Air Force's responses to ADEC's comments on the 2014 CG039 TS Implementation Report (draft). ADEC finds the responses acceptable. Pending incorporation of any EPA comments on the document, the document may be finalized. |
Louis Howard |
| 11/5/2014 |
Document, Report, or Work plan Review - other |
EPA provided comments on the draft CERCLA Report.
Comment: It would be good to clarify that soil source contamination was removed from two of the four source areas; two areas were not excavated due to potential UXO.
Comment: Change to 2013.
Comment: MK analysis for deep well AP-4344 is not included on Table 15-2.
Comment: These contours say PCE on the lines; TCE in the legend. Please correct the discrepancy.
Suggested changes to future Annual CERCLA reports.
Draft Annual Report
Sec 1.0
p. 1-2
The CERCLA sites Annual Field Activities Report clearly reports on long term monitoring activities at these JBER sites. It would be great to include a section in the annual report which lists the titles of approved/final site specific documents associated with sites in this report as a mechanism to track the ‘new’ work occurring under the PBR (ie...CG039 OUB PRDA Treatability workplan, SS044 GW Monitoring report and decommissioning workplan ). It is assumed the PBR activities will be summarized in final reports, but their influence on the long term monitoring will need to be accounted for in future CERCLA activity annual reports in the appropriate site section. The documents listed in this introductory section refer back to the 2011 reports and there is no similar index of more current workplans or reports applicable to the sites.
A specific example would be for the upcoming 2014 report, the DP98 site summary as found in the 2013 report on sec 2.4, page 2-4 would provide information on new work conducted at the site. “In Jan 2014, a DP098 DNAPL workplan was approved by regulators for field work to commence in summer 2014.”
Another example is the FT023 Site Characterization workplan that was approved by the regulators in Jan 2014.
The reference section or a relevant document table would list out the current site activities beyond the Long Term monitoring. |
Louis Howard |
| 2/19/2015 |
Update or Other Action |
Draft treatability study received for comment.
This study evaluated whether the injection of an emulsified vegetable oil (EVO) substrate, with & without ferrous sulfate, into a TCE-contaminated aquifer is able to enhance the natural degradation of TCE, speed up the cleanup process, & reduce overall life-cycle costs.
Conclusions
All 3 target treatment zones have shown generation of reducing conditions & substantial reductions in TCE in GW. The following are the conclusions from implementation through the 1st year of monitoring:
• The use of sodium permanganate was not a viable treatment option because of the heterogeneous natural oxidant demand results from across the site.
• GW samples collected from injection wells prior to substrate injections indicated that TCE within each target treatment zone were similar to each other & to historical TCE (approximately 2,000 µg/L).
• The design of the treatability study was sufficient to distribute substrate over the majority of the TCE “hotspot” as follows:
The shallow aquifer readily accepted the injection of EVO substrate at rates of 15 to 35 gpm with an observed distribution (in the downgradient direction) of between 90 & 130’. Because of lack of crossgradient monitoring locations, observations of lateral distribution of EVO substrate were limited to the 15’ between the injection wells at each target treatment zone. Lateral distribution of EVO substrate was at least 15’.
The deep perched aquifer consists of partially interconnected silty sand & gravel lenses within a basal till/weathered bedrock; & based on the variability of the achievable injection rates into the deep perched aquifer (1 to 28 gpm), it is likely that preferential flow pathways significantly control the distribution substrate. Because of the lack of monitoring locations within the deep perched aquifer, observations of lateral distribution of EVO substrate were limited to the 15’ between the injection wells at each target treatment zone. Lateral distribution of EVO substrate was at least 15’.
Based on the results of this study, the following actions are recommended:
• 2 years of annual GW monitoring (2015 & 2016) to assess potential rebound of TCE, degradation of TCE daughter products, & persistence of reducing GW conditions. The annual GW monitoring will be modified to better monitor the progress of the treatability study, as follows:
AP-3748, AP-4344, AP-4353, AP-5246, & AP-5683 (AP-4019R) will be sampled annually as prescribed by the 2011 Memorandum to the Site File for OUB/Poleline Road Disposal Area (Memo to Site File).
AP-3747 & AP-4550 identified for annual sampling in the Memo to Site File will still be sampled, although for the treatability study parameters listed in the Work Plan.
AP-3744 & AP-3989 identified as Sentinel Wells to be sampled in the year preceding the Five-Year Review (2017) will also be sampled in 2015 & 2016 for the treatability study parameters listed in the Work Plan. AP-3983R, AP-4525, & AP-4551 that were not identified to be sampled in the Memo to Site File, either annually or every 5 years, will be sampled in 2015 & 2016 for the treatability study parameters listed in the WP.
• The 2015 & 2016 GW monitoring WPs will formally outline this plan.
• The monitoring results from AP-3744, AP-3747, AP-3983R, AP-3989, AP-4525, AP-4550, & AP-4551 to be sampled for the treatability study parameters will be reported in a distinct section of the annual GW monitoring report.
See site file for additional information. |
Louis Howard |
| 4/13/2015 |
Document, Report, or Work plan Review - other |
Staff provided comments on the Draft Treatability Study for Poleline Road Disposal Area-Operable Unit B (CG039) JBER-Richardson. Main comments were regarding reporting the full suite of volatile organic compounds via Method 8260 instead of limiting it to the contaminants listed in the Record of Decision. Additional comments were made requesting statistical analysis of the monitoring results be conducted to demonstrate whether or not a particular groundwater plume is increasing, decreasing, or stable. |
Louis Howard |
| 4/20/2015 |
Document, Report, or Work plan Review - other |
The Alaska Department of Environmental Conservation (ADEC) has received the final version of the Final Treatability Study for Poleline Road Disposal Area-Operable Unit B (CG039) JBER-Richardson dated April 2015, on April 20, 2015. ADEC has no further comments and will approve the final document as submitted. |
Louis Howard |
| 4/20/2015 |
Update or Other Action |
Monitoring well installation work plan received.
The objectives of the work proposed in this work plan are twofold: (1) confirm the presence or absence of the shallow aquifer in the vicinity of monitoring well AP-3748, & (2) if the shallow aquifer is present, further define the downgradient extent of trichloroethene (TCE) contamination within the shallow aquifer.
Installation of this monitoring well will help to refine the conceptual site model, specifically the understanding of the hydrogeology/hydrostratigraphy at the site, & will address the recommendations & follow-up actions identified in the Third CERCLA Five-Year Review Report for JBER-Richardson, AK. The site-specific recommendations for Operable Unit B – Poleline Road in the Five-Year Review were as follows: “The downgradient contaminant plume boundary in the shallow aquifer has yet to be defined at OU B; therefore, it is recommended that the monitoring well network at OUB be augmented to assist in defining the downgradient extent of the plume.”
The current conceptual site model at CG039 suggests that the aquitard between the shallow & deep aquifers pinches out (&, therefore, the shallow aquifer is not present) downgradient of shallow aquifer monitoring well AP-3747. This interpretation is based on the confirmed absence of a shallow aquifer at the locations of deep monitoring wells AP-4345 & AP-5246, located north of AP-3747. Because the CSM indicates that the shallow aquifer doesn’t exist past AP-3747, it is currently the farthest downgradient well within the shallow aquifer, & only the deep aquifer is monitored downgradient of that location.
However, there is conflicting information as to the presence or absence of the shallow aquifer to the northeast of AP-3747 at deep monitoring well AP-3748. The boring log for AP-3748 indicates the presence of a water bearing unit from approximately 30 to 50 feet below ground surface (bgs). However, a more recent report indicates that the shallow aquifer was not encountered at AP-3748; it is unclear whether that interpretation was made in error or is based on information that is currently unavailable. Boring logs of existing monitoring wells AP-3747 & AP-3748 are included as an attachment to this work plan.
See site file for additional information. |
Louis Howard |
| 4/23/2015 |
Document, Report, or Work plan Review - other |
Staff provided comments on the monitoring well installation work plan. Main comment centered on requiring all VOCs be reported when analyzing groundwater and to include 1,4-Dioxane analysis since TCE is a known contaminant in groundwater at OU-B. |
Louis Howard |
| 6/2/2015 |
Document, Report, or Work plan Review - other |
Staff reviewed the responses to ADEC comments on the monitoring well installation letter work plan. ADEC agrees with the delayed sampling for 1,4-Dioxane in groundwater at a later date (TBD). ADEC requests JBER provide opportunity for ADEC and EPA to participate in the scoping of the "enterprise-wide strategy" to develop a work plan for agency review to sample groundwater on JBER-E/JBER-R for 1,4-Dioxane at all sites (State and CERCLA) where TCE/TCA was detected in groundwater. Be aware that 1,4-Dioxane has a tendency to be found to be present in an area of distribution greater (i.e. much further downgradient) than the host solvent.
Use of EPA 8260 without modifications typically leads to detection limits in the range of 100 to 150 ug/L due to the water solubility of dioxane, i.e., purging efficiency is poor. The State of Alaska's promulgated cleanup level for 1,4-Dioxane as found in 18 AAC 75 Table C Groundwater Cleanup Levels is 0.077 mg/L or 77 ug/L.
EPA's Intergrated Risk Information System has revised carcinogenicity assessment (9/20/2013) for 1,4-Dioxane. In drinking water, the 10-4 risk level is 35 ug/L, 10-5 risk level is 3.5 ug/L and 10-6 risk level is 0.35 ug/L. The unit risk and concentration estimates assume water consumption of 2 liters per day by a 70 kg human. http://www.epa.gov/iris/subst/0326.htm
Use of EPA Method 8260 as outlined in the work plan for CG039 will not meet the EPA 10-6 risk level for 1,4-Dioxane at 0.35 ug/L in drinking water. The final approved UFP-QAPP lists TestAmerica's Sacremento Laboratory Method 8260 reporting limit is listed as 50 ug/L (Appendix A Page 235) and listed as 200 ug/L for TestAmerica's Denver Laboratory Primary List Reporting Limits for 8260B (Appendix A Page 2285).
High-temperature sample preparation techniques improve the recovery of dioxane. These include purging at elevated temperature (SW-846 Method 5030C); equilibrium headspace analysis (SW-846 Method 5021); vacuum distillation (SW-846 Method 8261A); and azeotrophic distillation (SW-846 Method 5031).
Please finalize the MW Installation Letter Work Plan for CG039.
|
Louis Howard |
| 7/23/2015 |
Update or Other Action |
Draft Field Activities Report received for review & comment.
Site CG039 has been identified as a Yellow priority because TCE concentrations are generally decreasing at the site & the treatability study has substantially reduced contaminant concentrations in the target treatment zones; however, there is uncertainty regarding the downgradient extent of TCE contamination in the shallow aquifer. Annual monitoring will continue to assess plume-wide & treatability target treatment zones concentration trends, as described below. A monitoring well will be installed in summer 2015 to address the uncertainty regarding the downgradient extent of the shallow TCE plume.
Specific recommendations for ongoing GW monitoring are as follows:
Annual GW monitoring will continue in accordance with the 2011 Memorandum to the Site File for OUB/Poleline Road Disposal Area (Memo to Site File).
For the treatability study, two years of annual GW monitoring (2015 & 2016) will be performed to assess potential rebound of TCE, degradation of TCE daughter products, & persistence of reducing GW conditions.
All requirements of the Memo to Site File will continue to be monitored, but analytical & field parameters will be added as necessary so that the treatability study wells (AP-3744, AP-3747, AP-3983R, AP-3989, AP-4550, & AP-4551) continue to be monitored as outlined in Table 18-1 of the Final CG039 – Poleline Road Disposal Area Treatability Study Work Plan (USAF, 2013c) (Work Plan). The annual sampling will be modified as follows:
Five wells will be sampled annually as prescribed by the Memo to Site File: AP-3748, AP-4344, AP-4353, AP-5246, & AP-5683 (AP-4019 replacement well).
Two wells identified for annual sampling in the Memo to Site File will still be sampled as prescribed, with the addition of the treatability study parameters listed in Table 18-1 of the Work Plan: AP-3747 & AP-4550.
Two wells identified as Sentinel Wells to be sampled in the year preceding the Five-Year Review (2017) will also be sampled in 2015 & 2016 for the treatability study parameters listed in Table 18-1 of the Work Plan: AP-3744 & AP-3989.
Future Five-Year Reviews for OUs B, C, and E are necessary because COC concentrations
remain above levels that allow for unlimited use of the site and unrestricted exposure to the air,
soil, and water. The next JBER-R Five-Year Review will be in April 2018.
See site file for additional information. |
Louis Howard |
| 8/12/2015 |
Document, Report, or Work plan Review - other |
Staff provided comments on the Annual CERCLA Report. Staff commented on the need to conduct groundwater sampling for 1,4-dioxane associated with TCE contamination. |
Louis Howard |
| 1/13/2016 |
Document, Report, or Work plan Review - other |
. ADEC agrees the report documents that there is no shallow aquifer near existing “deep” monitoring well AP-3748 to the northeast of “shallow” monitoring well AP-3747. ADEC has no comments on the report and requests it be finalized pending incorporation of any EPA comments.
|
Louis Howard |
| 9/13/2016 |
Document, Report, or Work plan Review - other |
Staff commented on the UFP-QAPP – Addendum CG039 – Poleline Road Disposal Area OUB Treatability Study Work Plan – Bioaugmentation.
Staff requested the document refer to specific lab and field applications where biodegradtion have been successful and what conditions they were conducted since they may not be similar to site conditions at PRDS CG039. Staff requested that a full in-depth discussion of the treatability study results, full laboratory data packages, ADEC QA checklists, data verification be included in the annual CERCLA Monitoring Report or as a standalone document.
See site file for additional information. |
Louis Howard |
| 11/7/2017 |
Update or Other Action |
Letter report received for CY2016 [January 1, 2016 - December 31, 2016] Annual Land Use Control (LUC) and Institutional Control (IC) Monitoring at Joint Base Elmendorf-Richardson (JBER). This letter serves as the annual monitoring report on the status of LUCs/ICs in place on JBER-Elmendorf (JBER-E) and JBER-Richardson (JBER-R). The Air Force ensures compliance with LU Cs by conducting periodic monitoring and site inspections. Formal LUC/IC inspections occur annually on JBER during late spring through early fall and are typically conducted by contract. A total of 55 sites were formally inspected. Random site inspections are also conducted throughout the year by JBER Restoration staff.
Discrepancies: Large information sign providing details about SVE system & contamination at
the site is in disrepair. Thou2h it has been re-hung, much of the sign is fading.
See site file for additional information. |
Louis Howard |
| 1/23/2018 |
Document, Report, or Work plan Review - other |
Draft Fourth Five-Year Review report received for review and comment.
Main comments were to request a notice of environmental contamination be placed in ADNR's land records prior to the next (Fifth) Five-Year Review. Other comments were regarding generating a task list for when the decision will be made to amend the Record of Decision to implement full scale treatment based on the results of the treatability study for contaminated groundwater.
See site file for additional information. |
Louis Howard |
| 1/29/2018 |
Document, Report, or Work plan Review - other |
EPA sent comments on the 5YR. Triggering date for the Five Year Review (FYR). EPA will sign our concurrence letter on February 22, 2018 & will base the letter on the version of the Fourth FYR report available the week prior. In FY2011, EPA released the memo “Program Priorities for Federal Facility Five-Year Review”, August 1, 2011 which clarified the due dates for EPA concurrence on Federal Facility FYRs. The due date is based on the date of EPA concurrence of FYRs starting in FY2011. The purpose is to ensure FYRs are completed in a timely manner every 5 years.
These changes supersede section 1.3.3 of the 2001 Comprehensive FYR Guidance for Federal Facilities. The 2nd Fort Richardson FYR was signed by EPA on 2/22/2008 & the Army signed on 2/26/2008. EPA’s concurrence letter on the 3rd FYR was signed on 2/22/2013 & the Army signed on 4/1/2013. Please globally delete the reference to the triggering date for review as the date of the Air Force Signature of April 1, 2013 throughout the document & replace with February 22, 2013.
Protectiveness Statement changes: Suggested revision: The remedy at OU B CG-039 currently protects human health & the environment because ICs are implemented & effective, & no exposures to contaminated groundwater (GW), soil, & potential unexploded ordnance hazards are occurring from contaminated materials remaining at the site. However, in order for the remedy to be protective in the future, the following actions need to be taken to ensure protectiveness: COC cleanup levels should be changed to reflect revised cleanup standards, .& TCE (in soil), 1,1,2,2-PCA, 1,1,2-TCA, 1,2,3-trichlopropane, arsenic, TCE, & vinyl chloride (in GW) should be added as COCs in a decision document.
Include a table showing all sites within each OU & rationale for why they are/are not included (e.g., ongoing RI/FS; petroleum-only - transferred to the state). Appendix F of the Fort Richardson 3rd FYR (2013) contains a table that would satisfy this comment but would need to be updated to reflect changes in site status.
PFAS (including PFOS/PFOA) contamination should be included in the issues & recommendations for the appropriate sites where recent sampling detected PFOA /PFOS in soil & GW above ADEC cleanup levels & GW contamination above EPA Health Advisory levels.
See site file for additional information. |
Louis Howard |
| 2/13/2018 |
Document, Report, or Work plan Review - other |
Staff commented on the draft RA-O & M Report for select CERCLA Sites. Main comments were on contaminants which list a higher cleanup goal than what is promulgated in current November 7, 2017 18 AAC 75 regulations for soil. The matter should have been addressed in the 2018 Five-Year Review for 1,1,2,2-PCA (soil), benzene, carbon tetrachloride, cis-1,2-DCE, TCE, 1,1,2,2-PCA in groundwater. PCE & TCE were listed in the 3rd FYR as a carcinogen, but 18 AAC 75 lists them as being non-carcinogenic.
See site file for additional information. |
Louis Howard |
| 2/26/2018 |
CERCLA ROD Periodic Review |
Staff reviewed and concurred with the protectiveness statements, in general, for the Fourth Five-Year Review report at JBER-Richardson. Staff requested a notice of environmental contamination (NEC) be filed with Alaska Department of Natural Resources for all source areas mentioned in the report. Staff requested the daughter products of PCE and PCA be added with current cleanup levels in soil and groundwater to be protective in the long-term for groundwater at the site.
See site file for additional information. |
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 |
| 5/28/2021 |
Document, Report, or Work plan Review - other |
DEC Approved of Final LTM and LUC Inspection Work Plan for select CERCLA sites dated May 2021. |
William Schmaltz |
| 8/9/2021 |
Document, Report, or Work plan Review - other |
DEC staff reviewed and provided comments on Draft 2020 Land Use Control report for Select CERCLA sites dated June 2021. Report summarized LUC inspections performed in December 2020. Most sites were covered in snow and a full inspection could not be performed until spring 2021. DEC requested that the spring 2021 inspections are included in the 2020 report or as a separate cover because they are a continuation of the 2020 inspections and separate of the 2021 inspections. |
William Schmaltz |
| 2/16/2023 |
Document, Report, or Work plan Review - other |
DEC reviewed and provided comments regarding 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 |
| 4/20/2023 |
Document, Report, or Work plan Review - other |
DEC reviewed and provided comments for the 2021 Annual Remedial Action-Operations and Long-Term Management Report for Select CERCLA Sites, Draft, dated December 2023. 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 and sampling were recommended to continue for all applicable sites to ensure that conditions remain protective of human health and the environment. |
Ginna Quesada |
| 1/29/2024 |
Document, Report, or Work plan Review - other |
DEC reviewed the 2022 Annual Remedial Action-Operations and Long-Term Management Report for Select CERCLA Sites, Draft, dated October 2023. 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 and sampling were recommended to continue for all applicable sites to ensure that conditions remain protective of human health and the environment. |
Ginna Quesada |
