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

Transcription

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

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3 Aaron Lambert :20:30-08'00'

4 DEC/EPA Comments Dated 14 December 2012 on Draft QAPP, Phase 2 Source Evaluation at SS085 (SER , Building 3386 UIC Well), Dated August 2012 Comment Page Section Comment/Recommendation Response Incorporated? Location GENERAL COMMENTS It is unclear which metals will be analyzed by Method 6010B and which will be analyzed by Please revise the Draft Quality Assurance Project Plan for Phase 2 Source Evaluation at SS085 (the QAPP) to clarify this information. 1. General Comment - incorporated. The method that will be used to analyze each metal is included in #15, which was not included in the draft but will be submitted in the draft final. Additionally, the information is provided in the footnotes of Table #11, Table 11-1 #15, Tables General Comment General Comment General Comment SPECIFIC COMMENTS The criteria for blanks are inconsistent between s #12 and #28. #12 describes the criteria in relation to one-half the quantitation limit whereas #28 presents a criterion at the quantitation limit. In addition, #12 indicates that the result should be greater than one-half the quantitation limit, which appears to be an error. The result should be less than the criterion. Please revise the blank criteria in s #12 and 28 to be consistent and ensure the correct symbol (i.e., < ) is used. There are inconsistencies between s #12, #19, and #36 regarding the concentration levels for certain matrix and analyte groups. For example, #36 indicates that the concentration level for all matrices and analytes is low; however, #12 indicates the concentration level for volatile organic compounds (VOCs) and semi-volatile organic compounds (SVOCs) in groundwater and soil matrices is medium/high and/or low/medium. In addition, several concentration levels presented in #12 do not match the levels in #19 (e.g., toxicity characteristic leaching procedure [TCLP] analytes). Please revise the QAPP to resolve these discrepancies. The contact information (i.e., phone numbers) for Kyle Waldron and Tina Green is inconsistent in s #3, #4, and #6. Please revise these worksheets to consistently present the correct contact information. Laboratory analysis method modification suffixes (A, B, C) in Table 11-1 notes were updated to reflect current laboratory methods. Suggested changes have been incorporated. #12 text has been changed to communicate that the result should be less than or equal to one-half the quantitation limit ( ½ LOQ), or less than or equal to the quantitation limit for common lab contaminants ( LOQ). #28 was modified to be consistent with #12. Also, several missing QC elements were added to #28. Suggested changes have been incorporated. s #12 and #19 have been modified to be consistent with #36. Concentrations are all listed as low. incorporated. #4 has been corrected. Partially Complete. Changes are not consistent between page 6-1 and 4-1, 3-1. #12, pgs to #28, pgs to 28-3 #12, pgs. 12-5, 12-6, 12-7, and 12-9 #19, pgs to 19-5 #4, pg. 4-1 Page 1 of 11

5 #3, pg #3 Eric Breitenberger s telephone number is incorrectly listed as The correct number is The correction should also be applied on Page 6-1. incorporated. s #3 and #6 have been corrected. #6 pg According to the last paragraph under Project Background, abandoned diesel and motor gasoline pipelines are located approximately 30 ft [feet] to the south of the dry well; however, it is not clear from the text whether these features are considered part of the SS085 site or if they just features adjacent to the site that could impact the sample results. Please clarify whether the abandoned diesel and motor gasoline pipelines are included as part of the SS085 site. If these features are not part of the SS085 site, please indicate whether they are being investigated under another project. The abandoned pipelines are not considered part of the SS085 site; they are features adjacent to the site that could impact the sample results. This has been clarified in the text. Although the pipelines have been investigated near the Power Plant as the source of contamination for Source Area ST48, there is no documentation of investigation of the pipelines near SS085. The sampling plan was designed to account for the possibility of a release from the abandoned lines., pg. 10-2, Fig #11, Fig The legend was changed in Figures 10-2 and 11-1 to communicate that the location of the lines are approximate. Page 2 of 11

6 The first bullet under The Environmental Questions Being Asked states that subsurface soil is most likely to be contaminated in the vicinity of the connection of drain piping within the vertical For the purpose of the Phase 2 SER, only a limited number of samples were proposed to be collected from environmental media (soil and groundwater) at places most likely to be concrete culvert that constitutes the dry well; contaminated to confirm the presence however, other possible features, such as cracks in or absence of contamination at the the concrete culvert or joints and/or cracks in the site. If the presence of a release to drain piping, are other possible likely areas of subsurface soil contamination. The text does not indicate whether the integrity of the piping and concrete culvert have been assessed, nor does the text indicate whether sampling will be completed soil is confirmed at the site, then recommendations for future sampling efforts will be made to accomplish site closure or provide a basis for remedy selection. along the drain piping and directly beneath the dry well. Please state whether the integrity of the Sampling around concrete culvert: The, concrete culvert and the drain piping have been visual inspection of the concrete culvert pgs and assessed. If no sort of integrity assessment has (as documented in photographs) 10-10, Fig been completed, then please indicate whether indicates the concrete is in good there are any plans to conduct this type of condition. The quantity of liquid #17, assessment. Lastly, please clarify whether any discharged was never expected to have Pg filled the concrete culvert to a high level, samples will be collected from the area along the so fluids discharged into the well were drain piping running from the nearby buildings to more likely to have contaminated the the concrete culvert or from directly beneath the soil and groundwater at the location of dry well (a technique such as slant drilling could be used). the culvert. If a substantial release of contaminants occurred from this dry well, impacts to groundwater will be evident. As a result, additional subsurface samples will not be added. A description of the condition of the concrete culvert has been added to the text. Page 3 of 11

7 7. (continued) 10-2 (See above) Sampling along drain piping: Samples will not be collected from along the drain piping. The pipe leading from the floor drain to the concrete culvert is metal and the portion of the pipe that is visible inside of the culvert is in good condition (as documented in photographs); there are no cracks in the pipe and only surficial rust has been observed. However, the condition of piping between Building 3386 and the dry well is unknown, and as a result, could be included in a future investigation of the nature and extent of contamination. The CSM (Figure 10-5) has been reworded so that waste associated with the dry well is considered the source, rather than just the sludge at the bottom of the dry well. 10 was revised so that it no longer states that no edits were made to the CSM. A description of the condition of the effluent pipe has been added to the text. Sampling beneath dry well: Samples will not be collected from directly beneath the dry well. Sampling downgradient of the dry well in the seasonal zone should provide adequate data to assess if the integrity of the bottom of the dry well is compromised. Of note, samples of the liquid in the culvert as well as sediment at the bottom of the culvert were collected during a previous event indicating the presence of contamination; however, both these samples are representative of the waste in the well, not of environmental media (soil and groundwater). (See above) and 10-4 According to the last paragraph on page 10-3, the limit of quantitation (LOQ) of many of the compounds exceeded the cleanup levels for the 2011 sediment samples; however, the text does not identify how many compounds or the class(es) of compounds for which this was an issue. In addition, the discussion of the liquid sampling on page 10-4 does not indicate whether LOQ values exceeding cleanup levels were an issue for any compounds in the liquid analyses. Please revise pages 10-3 and 10-4 to identify for how many compounds the LOQ values exceeded the cleanup levels and for which classes of compounds this primarily occurred. incorporated. LOQs for compounds analyzed in sediment samples exceeded soil cleanup levels for migration to groundwater for approximately half (16 of 31) of VOC compounds, three-quarters (31 of 41) of SVOC compounds, and all eight (8) pesticide compounds. The final work plan does not report that LOQs for groundwater exceeded cleanup levels, though the laboratory report is not included in the report s appendix. As a result we are unable to confirm that LOQs for the liquid sample did not exceed cleanup levels., pg Page 4 of 11

8 Page 10-5 states records indicate an 11,000 gallon tank was present at Building 3386 and stored oil and deicing fluids however a 1999 Additional information on this tank could not be located during the review of site history. Although a inventory of the facility indicated the tank was no geophysical survey to determine the longer at the building. Please describe how the tank s presence is outside the absence of the tank was confirmed. Is there a scope of this Phase 2 investigation, NA possibility that it was abandoned in place? Should a geophysical survey to determine the tank s a recommendation for the survey will be made in the Phase 2 report. presence be conducted? According to page 10-6, a draft work plan submitted in September 2012 included the closure of the dry well at Building 3386, which consisted of excavating the dry well and contaminated soil beneath the dry well; however, it is not clear if excavation and removal were conducted, or are still planned for the future. Please clarify whether the dry well and any contaminated soil beneath it have been removed. No groundwater elevation contour data has been included in the QAPP, so it is unclear how the groundwater flow direction is known. A groundwater elevation contour map for nearby areas should be provided to show that the groundwater flow direction is to the north-northwest (as stated in the text) and to validate the proposed well locations. Please revise the QAPP to include a groundwater elevation contour map for nearby areas. Page 10-8 states that the possible affected matrices include soil, groundwater, and air, but it is not clear if air refers to soil gas, indoor air, or both. Please revise page 10-8 to clarify what is the intended matrix represented by the term air. According to the first bullet at the top of page 10-9, contaminant migration pathways include vapor transport; however, since vapor transport will not be investigated at this time, the bullet should state that the vapor pathway will be evaluated in the future. Please revise the first bullet point to state that vapor transport will not be part of this investigation and will be evaluated in the future. incorporated. Upon receipt of analysis results (September 2011), EPA and ADEC ordered for all work described in the work plan to be stopped, with the exception of filling drains and other well inlets to prevent further disposal from occurring at the well. This has been clarified in the text. incorporated. As noted in the figures, the 2002 Sitewide Monitoring Program Report is the source of the groundwater flow direction used in the draft. However, since the draft document s submittal, updated groundwater elevation data collected for the IWMP has become available. A groundwater elevation contour map for nearby areas was added as Figure Direction of groundwater flow calculated from IWMP data is consistent with the 2002 SWMP report. incorporated. Text was revised to clarify that air refers to both soil gas and indoor air. incorporated., pg TOC, pg. 10-8, Fig. 10-4, pg. 10-8, pg Page 5 of 11

9 Project Decision Condition #1 indicates that metal concentrations will be compared to the higher of the background concentration or the screening incorporated. Concentrations from an in-progress background study level, but the QAPP does not discuss how will be used as a comparison. Data, background concentrations will be established and collection for the background study pg no reference is made to a background study. was completed in the 2012 field Please revise the QAPP to discuss how background metal concentrations will be determined. season. The draft background studies are scheduled for submittal in February n/a Figure #11 #11 10 should be expanded to include a figure showing, in plan and elevation, the dry well and associated plumbing. The overview provided in Figure 10-2 does not provide sufficient detail. Figure 10-2 does not show the drain piping running from the buildings to the dry well. Please revise Figure 10-2 to display the drain piping between the buildings and the dry well. SS085 has apparently never been sampled for polychlorinated biphenyls. Given the uncontrolled nature of the discharges into the UIC, and the large number of contaminants already confirmed, DEC and EPA feel that some sampling for PCBs is justified. DEC and EPA recommend that a single soil sample from the bottom of the dry well be sampled for PCBs. The bullet points under How Much Data Are Needed? do not provide the number of borings or the number of subsurface soil samples to be collected. It is understood that this information is detailed in Table 11-1, but the number of groundwater sample locations is specified in the bullet points, so for consistency the number of borings and the number of subsurface soil samples to be collected from each boring should be summarized here as well. Please revise the bullet points under How Much Data Are Needed? to provide the number of borings and the number of subsurface soil samples to be collected. As-built drawings, photos, or other documentation that indicate the location of the piping are not available. As a result, this information cannot be displayed on figures. A diagram of the dry well (in elevation) has been added as Figure The depth at which the effluent pipe enters the injection well has also been added to the well description in. As-built drawings, photos, or other documentation that indicate the location of the piping are not available. As a result, this information cannot be displayed on figures. Soil samples collected from boring SS085-SB03 will be analyzed for PCBs. incorporated. TOC, pg. 10-2, Fig NA Abbreviations and Acronyms, pg. AA- 2,, pg. 10-8, #11, Table 11-1, # #11, pg Page 6 of 11

10 Figure 11-1 does not show the drain piping running As-built drawings, photos, or other Figure 11-1 from the buildings to the dry well. Please revise Figure 11-1 to display the drain piping running from the buildings to the dry well. In addition, please consider collecting subsurface soil samples where the drain piping leaves the buildings, as these are other potentially likely points of subsurface soil contamination. documentation that indicate the location of the piping are not available. As a result, this information cannot be displayed on figures. Samples will not be collected from along the drain piping. The pipe leading from the floor drain to the concrete culvert is metal and the portion of the pipe that is visible inside of the culvert is in good condition (as documented in photographs); there are no cracks in the pipe and only surficial rust has been observed. However, the condition of piping between Building 3386 and the dry well is unknown, and as a result, is a potential source of contamination that could be investigated under a separate characterization effort. NA and 11-8 Table 11-1 According to Table 11-1, no subsurface soil samples are to be collected from Borings 1 and 2 (the locations of the temporary monitoring wells). It is not understood why subsurface soil samples will not be collected from these boreholes. Please explain why no samples are proposed for collection from borings 1 and 2. Additionally, please explain why the single soil boring will not include sampling from the smear zone in addition to the two samples to be collected above the capillary fringe. Borings 1 and 2 will not be analyzed for COPCs because Boring 3 is considered to be at the highest risk for contamination and will be adequate to determine the presence or absence of contamination in subsurface soil. If the presence of a release to soil is confirmed at the site, then recommendations for future sampling efforts will be made to accomplish site closure or provide a basis for remedy selection. A sample from the smear zone at Boring 3 has been added to the sampling plan. #11, Table #14 Headspace screening is described on page 14-3; however, if field work is conducted during cold temperatures, it may be necessary to allow the sample to warm in the bag (in order to produce vapors). Please clarify whether samples will be allowed to warm in the bag prior to conducting headspace screening in the event of cold temperatures during field work. incorporated. A statement regarding minimum headspace temperature based on ADEC Field Sampling guidance has been added to #14. #14, pgs and 14-4 Page 7 of 11

11 Temporary wells are proposed for installation, but if contamination is detected it will likely be necessary to sample the wells several times (as well as collect water level measurements). Please explain why temporary wells have been selected for The presence or absence of contamination in groundwater is unknown at this time. If groundwater sampling verifies the presence of contamination at the installation rather than permanent monitoring wells. site, permanent monitoring well, Additionally, if any IWMP monitoring wells are locations will be recommended in Figure located in the vicinity, please add them to Figure the Phase 2 SER report. # if appropriate #15 The text indicates that the content and approach for #15 is being reviewed by the regulators. It is recommended that action levels and laboratory quantitation limits for this investigation be provided and reviewed before the QAPP is approved. Proposed IWMP monitoring wells are displayed on Figure 10-2 in the document draft. In the draft final version of Figures 10-2 and 11-1, IWMP proposed well locations were replaced with surveyed well locations. incorporated. #11, Figure 11-1 #15, Tables Page 8 of 11

12 #17 does not explain why the number The soil boring location on the side of of soil samples is sufficient to address the the dry well where the concrete culvert questions being asked, nor does the worksheet is penetrated by the metal pipe was explain why two well locations are sufficient. chosen to capture the area with the Please revise #17 to explain why the highest likelihood of soil contamination. number of soil samples and two well locations are The downgradient well location is north sufficient to address the questions being asked for of the dry well, which is directly this investigation. downgradient according to groundwater elevations measured in October As a result, the well will be situated in the area with the highest probability of groundwater contamination. The upgradient well location will provide information on baseline water quality. Analytical results from the downgradient samples can be compared to those of the upgradient samples to determine whether the dry well is a contamination source #17 Characterization of groundwater and soil at the proposed locations will meet the objective of this investigation, which is to determine the presence or absence of COPCs in the areas and media most likely to be impacted by a past release. If the presence of COPCs is confirmed at the site, recommendations for future sampling efforts will be made to accomplish site closure or provide a basis for remedy selection. To reduce redundancy, only general information on how decisions are to be made is presented in #17. #11, Table 11-1 provides additional sampling design and rational. Table 11-1 was modified to clarify the sampling rationale for the selection of monitoring well locations. #11, Table #21 The revision date for Standard Operating Procedure (SOP) Number (No.) 043: Multi-probe Water Quality Monitoring Instruments is not included. The copy of SOP No. 043 in Appendix B indicates the revision date is April Please revise #21 to include the April 2011 revision date for SOP No incorporated. #21, pg Page 9 of 11

13 Several of the SOP references for the field SOP references for several pieces equipment used for data collection/analysis of equipment were updated so that reference state see equipment manual. These both an SOP and an equipment have not been included. Please revise the QAPP manual are referenced. to include copies of the user manuals for the field equipment #22 Equipment manuals were not included in the QAPP. Equipment for the purpose of field data collection is rented during the field season. The specific model of equipment used in the field is dependent upon availability at the time of rental. As a result, equipment manuals cannot be provided in advance. It is standard practice for the field crew to follow the instruction manuals provided with the equipment. #22, pg and #37 #37 #37 #37 does not indicate that post digestion spike (PDS), interference check samples, and second column confirmations will be evaluated during data validation for applicable methods. Please revise #37 to indicate that these items will be evaluated during data validation. The text discusses Method 8265 but this method is not discussed elsewhere in the QAPP. Please remove the reference to this method or revise other appropriate worksheets in the QAPP to discuss how it will be used. The description of the calculation for completeness is confusing and does not appear to be appropriate. The text states that for any instances of samples that could not be analyzed the numerator of this calculation becomes the number of possible results minus the number of possible results not reported. However, in addition to adjusting the numerator for the missed sample, any rejected data should also be subtracted. In addition, please ensure that the denominator includes the analytes associated with any proposed samples that were not collected or were not analyzed. Please revise the text to clarify the calculation for completeness. incorporated. Data validation will be performed according to DoD QSM v4.2 and USEPA National Functional Guidelines (USEPA 2008 for organics; 2010 for Inorganic analyses). incorporated. The reference to Method 8265 has been omitted. incorporated. Text will be revised to clarify the calculation for completeness. #37, pg #37, pg #37, pgs and 37-8 Page 10 of 11

14 No. incorporated. #14, It is unclear as to whether or not which discusses the use of SOP the SOP has No. 10, has been edited to discuss been revised as the issues raised in Comment #13. requested. 30. Appendix B SOP No. 10 Wells should be opened and allowed to equilibrate to atmospheric pressure before water level measurements are collected, but this step has not been included in SOP No. 10. Also, water level measurements should be collected at least three times in succession, or until two measurements are the same to ensure usable data. Please revise SOP No. 10 to state that wells should be opened and allowed to equilibrate to atmospheric pressure before water level measurements are collected and that water level measurements should be collected at least three times in succession, or until two measurements are the same to ensure usable data. Additional Changes Global References were updated to account for new references included in #15 Introduction, TOC The Appendix containing Responses to Comments has been added #16 Update to schedule. #14, pg Page 11 of 11