AR No. IR No. EIELSON AFB ALASKA. Administrative Record Cover Sheet

Transcription

1 AR No. IR No. EIELSON AFB ALASKA Administrative Record Cover Sheet

2 ...,.- ~ DEPARTMENT OF ENVIRONMENTAL CONSERVATION DIVISION OF SPILL PREVENTION AND RESPONSE CONTAMINATED SITES PROGRAM Ifb- -t::t-3 B SEAN PARNELLE OR. ~ 610 University A v Fairbanks, AK PHONE: (907) MAAA~~././o FAX: (907) p--'r- 0 January 13, 2011 File: Mr. David Beistel 354 CES / CEAN 2310 Central Avenue Suite 100 Eielson AFB, AK Re: Comments on the Draft Phase 1 Source Evaluation Report, SEROOl-2011 Taxiway Golf Dear Mr. Beistel: Petroleum-impacted soil, likely from aircraft refueling activities, was discovered during a runway upgrade project at Taxiway Golf, now known as SEROO , in July The initial response was managed by the Alaska Department of Environmental Conservation - Prevention and Emergency Response Program (PERP). PERP transferred this site on September 21, 2011, which initiated the Source Evaluation process outlined in Section 24 of the Eielson Federal Facility Agreement. The Phase 1 Source Evaluation Report was due December 20, 2011, which was 90 days from the transfer date. The draft report was received on December 21, Please see the attached table for specific comments. Using a photoionization detector (PID), a contractor collected a combination of direct and headspace readings every 10 to 20 linear feet along Taxiway Golf. Field screening occurred from 0 to 5 feet below ground surface. PID readings above 50 parts per million (ppm) were used to denote potentially impacted areas. Five potentially impacted areas were excavated, but the excavations stopped five feet from the edge of the existing pavement to prevent damage of the taxiway surface. No analytical samples were taken, and the area has been re-paved. The draft report recommends transfer to the Compliance Restoration Program, assessment of potential remedial alternatives in light of the fact that this is an active runway, and disposal of the stockpiled soil at a permitted facility. This would be acceptable if analytical samples had been collected, but because the extent of soil and groundwater contamination is undefined and there could be a vapor intrusion concern at nearby buildings, a sampling and analysis plan for a Phase II SER must be submitted within 120 days of approval of this Phase I SER. EPA and DEC are disappointed that directions from PERP to collect analytical samples before re-paving and to use 20 ppm instead of 50 ppm to determine

3 Mr. Onvid Betstel 2 January potentially impacted soils were not followed. Because no analytical samples were collected. the stockpiled soil must be sampled for gasoline range organics. diesel range organics. benzene. toluene. ethylbenzene. xylenes. polycyclic aromatic hydrocarbons and lead prior to disposal. Better oversight of contractors is needed to ensure that all environmental work conducted on base complies with regulatory requirements. Sincerely. -I/n7 G/(w)tl Kim DeRuyter Environmental Program SpeCialist Aaron Lambert Environmental Protection SpeCialist Enclosure: Comment table CC: Bob Shirley. AFCEE, via John Halverson. DEC, via Deb Yamamoto. EPA, via \ \ FA-SVRFILE\grollps\SPAR\CS\Com."lllllnult>d Site FIt<'S (38)\ to? Ell'lson AFB\ EAFB Gellernl Slte-\lllde\SER\SEROO Ta.:dwny Goll'.DEC EPA COIl Itr draft SERO()I-2011.J;ln 2012.<lo('lC

4 Alaska Department of Environmental Conservation United States Environmental Protection Agency Comments on: Draft Phase I Source Evaluation Report, SEROO Taxiway Golf at Eielson Air Force Base, Alaska Comment No. Page Section Commen tf Recommendation l. ES-1 Exec. Sum. Please change "Facilities" to "Facility" in the second line. 2. ES-1 ES.3 There is no Section ES.2. ES.3 should be changed to ES.2, and so forth DEC-PERP instructed Eielson AFB to use PID readings exceeding 20 ppm, ES-1 & ES.3& not 50 ppm, to indicate potential contamination during this investigation. throughout throughout Please clearly explain both what actually occurred as well as the screening level that should have been used. ES-2 & Please note that, in addition to funding, transport approval from DEC is ES.3 & required prior to disposal of the stockpiled soil. 5. ES-2 ES.4 "The absence of analytical data means it is unknown is contaminated soil is present at the site." While this is a true statement, Section 6.2 notes that the excavation was constrained by the taxiway surface and thus it is likely that contaminated soil remains. 6. ES-2 & 8-1 ES.5 & 8.1 The "conclusions" are mostly summary statements, not conclusions. 7. ES-3 & 8-2 ES.6 & 8.2 Also recommend sampling the stockpiled soil (one sample plus a duplicate) for GRO, DRO, VOCs and PAHs before transport The recommendation to "assess potential remedial alternatives in the context of site restrictions" seems to imply that this assessment will occur in a future report. Suggest replacing that statement and the two subbullet points below it with the following. Further site characterization under the active taxiway probably is 8. ES-3 & 8-2 ES.6 & 8.2 not warranted because remediation in this area is not practicable at this time. Institutional controls will be applied to prevent disturbance of potential contamination that remains in place. This will be accomplished by adding this site to the Eielson GeoBase, which is used to verify that construction projects do not disturb contaminated areas. Page 1 of3 January 13, 2012 \ \FA-SVRFILE\groups\SPAR\CS\Contaminated Site Files (38)\107 Eielson AFB\ EAFB General- Sitewide\SER\SEROOI-2011 Taxiway Golf\DEC EPA emt table - draft SEROO 1-20 II TGoif Jan 2012.doex

5 Because there are no analytical data to define the limits of the soil contamination or to prove that there is no groundwater plume emanating from this area, additional characterization sampling is necessary. A Sampling and Analysis Plan for a Phase II SER will be submitted within 120 days of approval of this Phase I SER. The sampling conducted under the SAP should define the extent of contamination off the eastern side of the runway. This site will remain on the list of open Compliance Restoration Program sites. Potential site characterization and remedial action will be assessed prior to any changes in site use. 1 8t paragraph: "Remedial investigations... have to fully comply with CERCLA requirements..." Please also note that remedial investigations and response activities must comply with state regulations. (This is noted in the second paragraph, but, since the CERCLA requirement is noted here, the state requirement should also be noted here.) Suggest replacing "Upon identification... USAF must decide whether to conduct a Phase I or a Phase II SER" with the following text: When a new petroleum, oil or lubricant release occurs, it is initially managed by DEC-PERF. If long-term management is required, PERF will transfer the site to DEC-CSP. At this time USAF, EPA and DEC must decide whether a SER is required or if the site should be managed under state regulations. II When an historic release is discovered, Eielson AFB is required to notify EPA and DEC within 30 days. The notification must identify the selected path forward. The path forward must be a Phase 1 SER or an SAP for a Phase II SER. The source evaluation process, including deadlines is described in Section 24 qfthe Eielson FFA. Change "and" to "or" in the third and second bullet points, respectively, of the two bulleted lists. "The FFA for Eielson AFB requires preparation of either a Phase I or Phase II SER for any potential source area identified." Suggest omitting this sentence to avoid confusion. New POL spills can proceed directly to the state without a SER. Page 2 of3 January 13,2012 \ \FA-SVRFILE\groups\SPAR\CS\Contaminated Site Files (38)\107 Eielson AFB\ EAFB General- Sitewide\SER\SEROOl-2011 Taxiway Golf\DEC EPA cmttable - draft SEROOl-2011 TGolfJan 2012.docx

6 In the paragraph that summarizes the requirements of a Phase II SER, suggest changing "completed" to "conducted" in the first bullet. "Note: the SER process does not require full site characterization to assign disposition." Suggest also explaining that the recommendation can be a combination of the state/federal. The Phase II report for SER recommends a combination of referral to state and federal programs. The last sentence states, "As there were no analytical data collected from source area SER Taxiway Golf, the SER process for this site will proceed with a Phase 1 SER." This is misleading, as it appears to imply that USAF must have data prior to initiating a Phase 2 SER, when in fact the AF could identify a new site and decide to go directly to Phase 2 SAP and SER without having any pre-ser data. This section states that groundwater flow on base is generally to the north. Groundwater flow may be more accurately described as northnorthwest Remove the word "either" from the if-then statement /20 This section notes that the "appropriate notifications" for spill reporting were made. Please specify who was notified. Please note in the legend that the orange source area boundaries are 19. Figure 2 approximate. Compliance Restoration Program sites as well as Installation Restoration Program sites should be included on this map. CSM 20. Figure 5 Please explain how future subsistence users were eliminated. Please explain why current construction workers but not current site employees are included in the soil and groundwater pathways. 2l. Figures It might be helpful to include a figure that shows the five excavated areas on a GIS map (i.e., sort of a combination of Figures 2 and 4). Page 3 of3 January 13, 2012 \ \FA-SVRFILE\groups\SPAR\CS\ContanUnated Site Files (38)\107 Eielson AFB\ EAFB General- Sitewide\SER\SEROOI-2011 Taxiway Golf\DEC EPA cmt table - draft SEROO 1-20 II TGolf Jan 2012.docx