PB98-963155
EPA 541-R98-186
March 1999
EPA Superfund
Record of Decision Amendment:
USAF Eieison Air Force Base
OUs 3,4, & 5
Fairbanks North Star Borough, AK
9/29/1998
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Eielson Air Force Base
Operable Units 3, 4, and 5
Declaration of the Amended Record of Decision
Site Name and Location
Operable Units 3, 4, and 5
Eielson Air Force Base, Alaska
Statement and Basis of Purpose
This decision document presents the amended remedial action for Operable Units 3, 4, and 5
(OUs 3, 4, and 5) at Eielson Air Force Base (AFB), Alaska, developed in accordance with the
Comprehensive Environmental Response, Compensation, and Liability Act of 1980 (CERCLA),
as amended by the Superfund Amendments and Reauthorization Act of 1986 (SARA), the May
1991 Federal Facilities Agreement entered into by the Air Force, the U.S. Environmental
Protection Agency (EPA), and the State of Alaska, and to the extent practicable, the National
Contingency Plan. This decision is based on the Administrative Record for OU 3, 4, and 5,
updated in July 1998, to include new information generated since the original Record of Decision
was signed on 30 September 1995. This amendment applies to OU3 site DP44 (Battery Shop
Leach Field Building), OU4 sites SS35 (Asphalt Mixing Area) and ST58 (Old Quartermaster
Service Station), and OUS sites LF03/FT09 (Current Inactive Base Landfill / Fire Training
Area).
The State of Alaska concurs with the selected remedy.
Assessment of the Sites
Based on new information made available after signing of the Record of Decision (ROD)
document, EPA, ADEC and Eielson Air Force Base have selected alternate actions for sites
DP44, SS35, ST58, and LF03/FT09 that are more appropriate for existing site conditions than
those referenced in the original ROD document. Through new information, contaminant levels
at these sites were determined to be at lower levels than interpreted prior to signing the original
ROD document. Proper enforcement of Institutional Controls (IC's) at all sites will be effective
in controlling and restricting access to contaminated media at the sites until remediation goals are
achieved. Implementation of the amended selected alternative actions in the ROD amendment
are shown, through evaluation against the nine criteria presented in the National Contingency
Plan (NCP), to be as protective of human health and the environment as the remediation
alternatives originally selected for these sites.
Description of the Amended Selected Remedy
Site DP44: DP44 is believed to be the location of past jet engine maintenance activities near an
aircraft maintenance facility. Contaminants of concern are petroleum compounds and solvents in
soil and groundwater. Additional investigation and pilot testing at the site indicate that
contamination levels have decreased significantly through natural attenuation and biodegradation
in both the soils and groundwater; therefore, the original remedy of soil vapor extraction is
proposed to be changed as follows:
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• Residual soil contamination is not expected to act as a continuing source of groundwater
contamination. No further action of soils is proposed.
• Continued monitoring to confirm that the groundwater contamination is not migrating and
that contaminant levels are continuing to decrease.
• Implementation of institutional controls to prevent use of the contaminated groundwater in
this area.
Site SS35: SS35 was used as an Asphalt cement mixing area from the early 1950's to the late
1960's. Approximately 200 empty asphalt cement drums were reportedly disposed along the
banks of Garrison Slough in this area. The original selected remedy included installation of a
soil cover over the area to prevent direct contact and surface water runoff into Garrison Slough.
Based on re-evaluation of site conditions from new information gathered after the ROD was
signed, additional soil cover is not necessary for protection of human health or the environment
at SS35. The amended selected remedy is:
• No action under the Superfund program: and
• Continued monitoring of surface water, sediments, and aquatic organisms at the site to confirm
that concentrations remain at levels that are protective of human health and the environment.
Site ST58: ST58 was the site of a service station that was decommissioned in 1988.
Contaminants of concern are lead and petroleum compounds in the soil and groundwater.
For the lead contamination at ST58, subsequent evaluations and modeling have determined that
groundwater restoration for this confined area is technically impracticable. For the petroleum
contamination a 1993 removal of BTEX-contaminated soils from the most contaminated area of
the site removed a majority of the petroleum contaminated'soils. The level of remaining residual
soil contamination does not warrant installation of a bioventing soil treatment system.
Additional investigations have indicated that petroleum contamination is being addressed
through natural attenuation and biodegradation in both the soils and groundwater; and therefore,
the original remedy of bioventing is proposed to be changed as follows:
• Residual soil contamination does not appear to be adversely impacting the groundwater;
therefore, no further action of soils is proposed.
• Continued monitoring to confira thai the groundwater lead or petroleum contamination are
not migrating and are remaining within the currently established containment area.
• The action level would be wai\ iu for lead contamination in groundwater within this
limited containment area due to technical impracticability from an engineering perspective.
• Implementation of institutional controls to prevent exposure to contaminated groundwater in
this area to ensure protection of humin health and the environment.
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Sites LF03/FT09: LF03 occupies approximately 100 acres and was used as the main base
landfill from 1967 to 1987. FT09? which is located on top of the landfill, was used for fire-
training exercises from 1955 to 1989. No fundamental changes are proposed to the selected
remedy; however, clarification of regulatory issues is warranted. The Air Force had previously
indicated that there was documented evidence of disposal of hazardous waste in the post-1980
disposal area. A subsequent search of Air Force and Fairbanks North Star Borough records after
the signing of the original ROD could not confirm this disposal of hazardous waste. Given the
lack of documentation of hazardous waste disposal RCRA subtitle C is relevant and appropriate
as an ARAR but is not applicable. Groundwater concentrations adjacent to the landfill are below
State and federal regulatory levels, therefore an impermeable cover to prevent movement of
groundwater through the landfill is not warranted. The amended selected remedy is clarified as
follows:
• A cover to address the direct contact threat will be maintained in accordance with
relevant and appropriate requirements of the Resource Conservation and Recovery
Act Pan 264 and the Hybrid - Landfill Closure described in OSWER Directive
9234.2-04FS, "RCRA ARARS: Focus on Closure Requirements".
• Groundwater at and adjacent to the landfill will continue to be monitored to verify
that contaminant concentrations remain below acceptable regulatory levels.
• Institutional controls will be implemented to restrict land use to prevent direct exposure
to landfill waste
The major components of the amended selected remedies for sites DP44, SS35,ST58, and
LF03/FT09 include
• Monitor surface water, sediments, and aquatic organisms at Site SS35 to confirm
that contaminant concentrations remain at levels that are protective of human health and the
environment.
• Monitor groundwater at sites DP44, ST58, and LF03/FT09 to evaluate contaminant levels
and migration until remediation levels are achieved.
• Application of the Technical Impracticability Waiver to lead groundwater contamination at
site ST58.
• Implement and enforce institutional controls to prevent exposure to contaminated media at
DP44, ST58. and LF03/FT09.
In the event of base closure, any remaining contaminated sites will be addressed in accordance
with CERCLA Section 120 and State of Alaska requirements.
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Statutory Determination
The amended selected remedies are protective of human health and the environment and are cost
effective. The amended selected remedies comply with Federal and State requirements that are
legally applicable or relevant and appropriate to the remedial action with the exception of the
action level for lead established under the Safe Drinking Water Act (40 CFR 141.80). A waiver
of the lead action level is justified because compliance with the requirement is technically
impracticable from an engineering perspective. The remedies utilize permanent solutions to the
maximum extent practicable. However, because treatment of the principal threats of the sites
were found to be practicable, these remedies do not satisfy the statutory preference for treatment
as a principal element.
Because these remedies will result in hazardous substances remaining onsite above health-based
levels, reviews will be conducted at sites DP44, ST58, and LF03/FT09 each 5 years during the
five-year ROD review process to ensure that the remedies continue to provide adequate
protection of human health and the environment.
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Signature and Support Agency Acceptance of the Amended Remedy for
Operable Units 3,4, and 5, Eielson Air Force Base
CHUCK CLARKE
Regional Administrator
Region 10
U.S. Environmental Protection Agency
Date
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AMENDMENT OUTLINE
OPERABLE UNITS 3,4,5 RECORD OF DECISION
EIELSON AIR FORCE BASE
SOURCE AREAS DP44, SS35, ST58, & LF03/FT09
1.0 INTRODUCTION 4
1.1 SITE NAME AND LOCATION 4
1.2 IDENTIFICATION OF LEAD AND SUPPORT AGENCIES 4
1.3 CITATION OF CERCLA SECTION 117 AND NCP SECTION 300.435(C)(2)(II) 4
1.4 SUMMARY OF THE CIRCUMSTANCES THAT LEAD TO THE NEED FOR A 4
ROD AMENDMENT
1.5 STATEMENT THAT THE ROD AMENDMENT WILL BECOME PART OF THE
ADMINISTRATIVE RECORD 5
1.6 ADDRESS OF LOCATION AND HOURS OF AVAILABILITY OF THE
ADMINISTRATIVE RECORD 5
2.0 SUMMARY OF SITE HISTORY. CONTAMINATION PROBLEMS. AND SELECTED
REMEDY 5
2.1 DP44 SITE HISTORY 5
2.1.1 CONTAMINATION PROBLEMS 5
2.1.2 THE SELECTED REMEDY FOR DP44 AS ORIGINALLY DESCRIBED IN
THEOU3.4.5ROD 7
2.1.3 AMENDED SELECTED REMEDY 8
2.2 SS35 SITE HISTORY 9
2.2.1 CONTAMINATION PROBLEMS 9
2.2.2 THE SELECTED REMEDY FOR SS35 AS ORIGINALLY DESCRIBED IN
THEOU3.4.5ROD 10
2.2.3 AMENDED SELECTED REMEDY 11
2 J ST58 SITE HISTORY 12
2.3.1 CONTAMINATION PROBLEMS 13
2.3.2 THE SELECTED REMEDY FOR ST58 AS ORIGINALLY DESCRIBED IN
THEOU3.4.5ROD 14
2.3.3 AMENDED SELECTED REMEDY 14
2.4 LF03/FT09 SITE HISTORY 16
2.4.1 CONTAMINATION PROBLEMS 17
2.4.2 THE SELECTED REMEDY FOR LF03/FT09 AS ORIGINALLY DESCRIBED
INTHEOU3.4.5ROD 18
2.4.3 AMENDED SELECTED REMEDY 19
3.0 SUMMARY OF COMPARATIVE ANALYSIS 20
3.1 OVERALL PROTECTION OF HUMAN HEALTH AND THE
ENVIRONMENT 20
3.1.1 SITEDP44 20
OU3.4.5 ROD Amendment
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3.1.2 SITESS35 20
3.1.3 SITEST58 20
3.1.4 SITES LF03 & FT09 21
3.2 COMPLIANCE WITH APPLICABLE OR RELEVANT AND APPROPRIATE
REQUIREMENTS (ARARs) 21
3.2.1 SITEDP44 21
3.2.2 SITESS35 21
3.2.3 SITE ST58 21
3.2.4 SITES LF03&FT09 21
3 J LONG-TERM EFFECTIVENESS AND PERMANANCE 21
3.3.1 SITEDP44 21
3.3.2 SITE SS35 21
3.3.3 SITEST58 21
3.3.4 SITES LF03 & FT09 22
3.4 REDUCTION OF TOXICITY, MOBILITY, OR VOLUME THROUGH
TREATMENT 22
3.4.1 SITEDP44 22
3.4.2 SITE SS35 22
3.4.3 SITEST58 22
3.4.4 SITES LF03 & FT09 22
3.5 SHORT-TERM EFFECTIVENESS 22
3.5.1 SITEDP44 22
3.5.2 SITE SS35 22
3.5.3 SITEST58 23
3.5.4 SITES LF03 & FT09 23
3.6 IMPLEMENTABILITY 23
3.6.1 SITEDP44 23
3.6.2 SITESS35 23
3.6.3 SITEST58 23
3.6.4 SITES LF03&FT09 23
3.7 COST 23
3.7.1 SITEDP44 23
3.7.2 SITE SS35 23
3.7.3 SITEST58 24
5.7.4 SITES LF03 & FT09 24
3.8 STATE ACCEPTANCE 24
3.9 COMMUNITY ACCEPTANCE 24
4.0 TECHNICAL IMPRACTICABILITY OF GROUNDWATER RESTORATION 24
4.1 SPECIFIC ARARs 24
4.2 SPATIAL EXTENT OF TI WAIVER 24
4J CONCEPTUAL MODEL 25
4.3.1 SITE CONDITIONS 25
4.3.2 FATE AND TRANSPORT INVESTIGATION . 25
4.3.3 EPA TECHNICAL REVIEW 26
OU3.4.5 ROD Amendment 2
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4.4 EVALUATION OF RESTORATION POTENTIAL 27
4.4.1 SOURCE CONTROL MEASURES 27
4.4.2 RESTORATION TIMEFRAME 27
5.0 INSTITUTIONAL CONTROLS 27
6.0 AFFIRMATION OF THE STATUTORY DETERMINATIONS 30
7.0 RESPONSIVENESS SU1MMARY 30
7.1 BACKGROUND ON COMMUNITY INVOLVEMENT 30
7.2 SUMMARY OF COMMENTS RECEIVED DURING THE PUBLIC
COMMENT PERIOD AND USAF RESPONSES 31
8.0 REFERENCES 31
1.0 Introduction
OU3,4,5 ROD Amendment
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1.1 Site Name and Location: Operable Unit 3,4,5, Source Areas DP44, SS35, ST58,
LF03/FT09, Eielson Air Force Base, Alaska.
1.2 Identification of Lead and Support Agencies
Lead agency: Department of Defense, Eielson AFB, Alaska
Program Manaser: Michael R^abe
354 CES/CEVR
2258 Cerural Ave Ste 100
Eielson AFB, AK 99702-2299
(907)377-1164
Support Agencies: U.S. Environmental Protection Agency, Region 10
Project Manager: Miry Jane Nearman
Office of Environmental Cleanup Unit #4
IKX) - 6th Avenue, HW-124
Seiitle,WA98l01
(206)553-6642
Alaska Department of Environmental Conservation
Project Manager: Roaan Short
610 University Avenue
Fairbanks, AK 99709-3643
(907) 451-2156, (907) 451-2183
1.3 Citation of CERCLA Section 117 and NCR Section 300.43S(c)(2)(ii) and Date of
ROD signature
The OU 3,4,5 ROD amendment has been prepared in accordance with the procedures specified in
CERCLA section 117 and the National Contingency Plan section 300.435 (c)(2)(ii). The original
ROD was signed on 30 September 1995.
1.4 Summary of the Circumstances That Led to the Need for a ROD Amendment
Based on recent sampling results at site ST58, a pilot scale soil vapor extraction system at site
DP44, clarification of RCRA Subtitle C with respect to LF03/FT09, and a re-evaluation of the
Baseline Risk Assessment for OU 3,4,5 and Siwwide Biological Risk Assessment with respect to
site SS35, the selected remedies are being amended from those presented in the original ROD for
OUs 3,4, and 5. The new information indicates that another alternative from those selected in
the ROD provides the best balance of the tradeoffs among the alternatives with respect to the
nine evaluation criteria.
1.5 Statement That the ROD Amendment Will Become Part of the Administrative
Record File
OU3A5 ROD Amendment V"
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The OU 3,4,5 ROD amendment shall be added to the administrative record file in accordance
with the NCP section 300.825(a)(2).
1.6 Address of Location and Hours of Availability of Administrative Record File
The OU 3,4,5 ROD with the Responsiveness Summary and this ROD amendment will be
available in the Administrative Record at the information repositories listed below. Information
used to support the selection of the amended remedy has been included in the Administrative
Record, which is available for public review at:
Elmer E. Rasmuson Library (Archives Section)
Alaska and Polar Regions Department
University of Alaska Fairbanks
Fairbanks, Alaska 99775
(907) 474-6594
2.0 Summary of Site History, Contamination Problems, and Selected
Remedy
2.1 DP44 Site History
Source area DP44 is located near the Large Aircraft Maintenance Hangar (Bldg. 1140). As
originally defined, DP44 included the wastewater disposal leach field from the battery shop
(Building 1141) and the area around Building 1138 between the runway taxiway and Flightline
Avenue west of the North street intersection (see Figure 2.1 in OU3,4,5 ROD). DP44 was
identified as a source area because, in the past, the battery shop and Building 1138 may have
discharged waste into a leach field system within the area. However, subsequent investigations
have not confirmed the existence of this leach field. Most of the contamination in this source
area is located south of the hangar, and is probably related to past jet-engine maintenance
activities in the hangar. Identified contaminants of concern are fuel-related compounds and
solvents in the groundwater and soil.
2.1.1 Contamination Problems
Soil contaminants greater than EPA risk-based screening levels or background concentrations for
DP44 are summarized in Table 2.1. Soil contaminants listed in Table 2.1 are poly aromatic
hydrocarbons (PAHs) that were found at maximum concentrations in a surface soil sample
collected during the drilling of Well 44M03. This sample was collected in a gravel parking lot
that contained fragments of asphalt. Because the parking lot is in close proximity to the runway,
it was routinely maintained by spraying oil for dust suppression. The source of the PAHs could
OU3.4.5 ROD .Amendment 5
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be from exhaust from vehicles parked in the lot, exhaust from aircraft on the nearby runway, or
asphalt residue. These contaminants are highly sorptive and immobile.
The concentrations of solvent and benzene did not exceed screening levels for direct exposure.
However, subsurface concentrations of solvent and benzene were estimated to be sufficiently
high to leach into the groundwater to yield concentrations that exceed groundwater screening
levels. Therefore, even though solvent and benzene contamination in soils does not exceed
screening levels based on direct exposure to the soil, it may be the source of groundwater
contamination through the leaching pathway.
In August 1994, 13 soil borings were drilled in the vicinity of Well 44M04 to determine the
extent and concentration of chlorinated solvents in soils south of the large aircraft maintenance
hangar. Locations for the borings were determined using a soil-gas survey. The soil-gas survey
indicated that contaminated soils extended to the west under the aircraft parking ramp. The
borings were completed through the vadose zone to the water table, located at approximately 3 m
(10 ft) below land surface in this vicinity. Samples were taken at three depth intervals, 0.6 to 1.2
m (2 to 4 ft), 1.2 to 1.8 m (4 to 6 ft), and 2.4 to 3 m (8 to 10 ft) below land surface. The samples
were analyzed for chlorinated solvents and BTEX compounds. TCE and total DCE results are
illustrated in Figures 6.1 through 6.3 in the OU3,4,5 ROD. Low levels (less than screening
levels) of toluene were detected in some of the soil samples.
Table 2.1 Surface and Subsurface Soil Contaminants Greater Than Screening Levels, DP44
Chemical
Anthracene
Benzo(a) anthracene
Benzo(a)pyrene
Benzo(b)fluoranthene
Benzo(g, h. i)perylene
Chrysene
Dibenzo(a. h)anthracene
Indenod. 2, 3-cd)pyrene
Detection Limit
(Hg/kg)
20
10
9
30
40
70
50
50
# Analyzed/
# Detected
4/1
4/3
3/2
4/3
4/3
4/2
4/1
4/3
Concentration
Range (ug/kg)
5500-5500
200-48,000
470-18,000
460-210.000
280-14,000
280-21.000
6500-6500
270-15,000
Location of
Maximum
Detect
44M03
44M03
44M03
44M03
44M03
44M03
44M03
44M03
Groundwater contaminants in samples collected from monitoring wells that are greater than EPA
risk-based screening levels or background concentrations for DP44 are summarized in Table 2.2.
During field investigations at DP44 prior to 1994, benzene and TCE were found in the
groundwater above their 5 ug/L maximum contaminant levels (MCLs). Toluene, ethylbenzene,
and xylene were also detected, but at concentrations below their MCLs. Benzene contamination
above 5 [iz/L covered an area of approximately 3300 m2 (3947 yd2), with Well 44M02 displaying
the highest benzene concentration. Groundwater probe data collected in 1988 indicated that
benzene concentrations up to 4000 ug/L existed near the top of the water table. Benzene
concentrations detected in 1990 had diminished fourfold since the 1988 sampling. By 1992 and
1994, benzene levels decreased to just above the MCL. For details on 1992 and 1994 benzene
OU3.4.5 ROD Amendment
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concentrations at DP44, refer to Figures 6.4 and 6.5 in the OU3,4,5 ROD. The 1992 data were •
used in the risk assessment and are reported in Table 2.2 and Appendix A of the OU 3, 4, 5 ROD.
Two areas of TCE contamination were detected in the groundwater above the 5 ug/L MCL,
including Well 44M03 and Well 44M04, with TCE concentrations above 100 ug/L in Well
44M04. The two sites of TCE contamination appeared to be unrelated and relatively limited,
based on groundwater probe results, which showed no detectable TCE between the sites or at
adjacent probes or wells. The distribution of contamination near Well 44M04 indicated the
source of TCE may be upgradient of DP44.
In August 1994, TCE and total DCE were still present in the vicinity of Well 44M04 in
concentrations similar to previous years. These concentrations, as shown in Figures 6.6 and 6.7
in the OU3,4,5 ROD, were 109 ppb and 121 ppb, respectively. Results from the groundwater
probe samples taken during the soil borings are also shown in Figures 6.6 and 6.7 in the OU3,4,5
ROD. They also show that chlorine solvent contamination extends away from Well 44M04 to
the west under the aircraft parking ramp and to the north toward the hangar. The distributions for
TCE and DCE are slightly different. Vinyl chloride has never been detected in any of the
groundwater samples from DP44. No groundwater samples are available from underneath the
hangar. Wells 44M03, 44M07, and 44M08, to the north of the hangar, show low levels of TCE
and DCE contamination. The concentrations in all three wells are below MCLs. It is not known
whether this contamination results from a second low-level source or is the leading edge of a
plume located underneath the hangar. The total area of TCE-contaminated soils is approximately
6500 m2 (69,000 ft2) with a volume of 20,000 m3 (25,500 cu yd) containing an estimated 3.2 kg
.of TCE.
All contaminants detected at DP44 were in aqueous form. No free-phase solvent or fuel was
encountered. This data in addition to a more detailed accounting of the sampling history and
analytical results can be found in the OU 3,4,5 ROD and the OU 3,4,5 Remedial Investigation
(RD-
Table 2.2 Groundwater Contaminants Greater Than Screening Levels. DP44
Chemical
Benzene
Trichloroetnene
Detection Limit
^g/L)
2
1
# Analyzed/
# Detected
15/2
15/3
Concentration
Range (ug/L)
3.7-5.3
1.2-2500
Location of
Maximum
44M05
44M04
2.1.2 The Selected Remedy for DP44 as Originally Described in the OU 3, 4,5 ROD
The original selected remedy for DP44 was soil vapor extraction/groundwater
monitoring/institutional controls. This alternative was originally chosen because of its
effectiveness for treating chlorinated solvents that are found at this source area and because it
was believed that SVE would reduce risk to human health and the environment sooner than
monitoring and institutional controls alone. Groundwater extraction and treatment/SVE was not
the preferred alternative because of its difficult implementation, and because biodegradation,
OU3.4.5 ROD Amendment
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dispersion, dilution, and adsorption appear to be effectively containing and degrading the
contamination.
The primary components of the original selected remedy were:
• Installation of a soil vapor extraction system to remove solvent contamination in soil posing a
threat to groundwater through leaching.
• Implementation of institutional controls, as described, to prevent exposure to contaminated
groundwater.
• Monitoring of the groundwater to evaluate contaminant levels and identify changes to
contaminant plume configuration until remediation levels are achieved.
The original ROD also Stated that it could become apparent, during the design phase,
implementation, or operation of the SVE system that solvent and fuel-related compounds in the
soil and groundwater had declined or had fallen below levels that would pose an unacceptable
risk. In such cases, the system performance standards or the remedy would be re-evaluated to
allow for the contaminants to naturally degrade.
2.1.3 Amended Selected Remedy
In summer 1995, the Air Force conducted a pilot scale vapor extraction test to evaluate the rate
of contaminant removal. The test results showed very low removal rates indicating that the
contaminant concentration in soil is low. Contaminant concentrations in extracted vapors also
confirmed that the mass of solvents in the subsurface soil is small.
Since the source of contamination is small, little additional contamination is expected to enter the
groundwater from the soils; therefore, contaminant concentrations are expected to decrease
through natural processes. The area of contamination is limited to an area of approximately 600
feet and does not appear to be expanding.
The additional investigation and pilot testing described above indicate that contamination is
being addressed through natural attenuation and biodegradation in both the soils and
groundwater; therefore, the original remedy of soil vapor extraction is proposed to be changed as
follows:
• Residual soil contamination is not expected to act as a continuing source of groundwater
contamination. No further action of soils under CERCLA is proposed.
• Continued monitoring and evaluation to confirm that the groundwater contamination is not
migrating; and that contamination levels are continuing to decrease.
• Implementation of institutional controls to prevent exposure to contaminated soil and
OU3.4.5 ROD Amjndmcm 8
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groundwater in this area.
2.2 SS35 Site History
Site SS35 is located in the central part of the base adjacent:. Central Avenue, about 0.2 mile
south of the Water Treatment Plant. Historical information _> ^complete regarding use of this
site. However. SS35 was used as a mixing area from the ea:!y '.950s to the late 1960s. Asphalt-
cement was mixed in a tank and then used for road mainten^;;;. Waste oils and solvents were
mixed with contaminated fuels and used for road oiling to control dust. About 200 empty
asphalt-cement drums were reportedly disposed of along the r^iks of Garrison Slough. The area
may also have been used for mixing pesticides and cleaning :-ri".:cide spraying equipment.
Contaminants of concern identified are pesticides, particularly DDT, in soil.
2.2.1 Contamination Problems
Geophysical studies were conducted at SS35 to identify potiiiial locations of buried drums and
other materials. During the 1988 geophysical investigation, two anomalies (anomaly areas A and
B) indicating possible buried drums were identified (HLA 19S9). The first anomaly (A) was a
23- by 69-m (25.2- by 75.5-yd) area identified in a location adjacent to Garrison Slough, roughly
corresponding to an excavation area identified on historical aerial photographs. The area did not
appear to have large numbers of buried drums, but does contain smaller areas concentrated with
drums. The second anomaly (B), oriented northwest to southeast near Garrison Slough, may be
an abandoned utility, such as a drainage culvert. Two small areas containing asphalt cement
were present on the ground surface in this area, and aromatic and chlorinated hydrocarbons were
detected near the center of the linear anomaly (B) in a soil gas survey.
A geophysical survey in 1990 identified a third anomaly (O in the northern pan of the source
area extending about 38.1 m (41.7 yd) along the pond shoreline. Partially buried concrete rubble
and demolition debris were visible in the brush and trees at ice shoreline. It was concluded the
area contained buried metal, concrete, and other demolition cerris.
The contents of any drums buried at SS35 are generally unkz:v»-n. In 1989, a number of drums
were uncovered during the connection of Building 3460 to tie utilidor. The burial site of the
drums was located approximately 60 m (66 yd) east of anomaly area C, near the junction of the
utilidor from Building 3460 with the Central Avenue utilide: The contents of one drum
uncovered at this time were analyzed for VOCs and semivoi.^e compounds (SVOCs) and
metals. Its analysis is reported in HLA (1990).
DDT and its derivatives were found at low levels in almost ill surface and subsurface soil
samples collected in the 1988 and 1990 investigations. The behest concentration observed was
396 mg/kg in a surface soil sample collected at 35SS03, locr.r: -.vitnin anomaly area A near
Garrison Slough. Surface and subsurface soil contaminants ::e^r.er than screening levels at SS35
are presented in Table 2.3 below. In addition, one sediment v^rple from the slough (35S01) was
tested for pesticides in 1988. It was located near the inlet o: _:? rond Garrison Slough forms
OU3.4.5 ROD Amendment 9
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adjacent to the source area and showed 0.4 mg/kg of DDD. DDT concentrations were lower, at
0.097 mg/kg. In 1990, a sediment sample (62S04) was collected from the slough adjacent to
SS35 just upstream of the pond. In that sample, DDT and DDD were 62.4 and 58.6 mg/kg,
respectively.
Table 2.3 Surface and Subsurface Soil Contaminants Greater Than Screening Levels. SS35
Chemical
4.4'-DDD
4.4' -DDE
4.4'-DDT
Aldrin
Alpha-BHC
Cblordane
Heptachlor Epoxide
Detection Limit
(ug/kg)
1
N/A
20
1
10
2
N/A
# Analyzed/
# Detected
23/18
23/21
23/22
4/1
8/1
23/8
8/1
Concentration
Range (ng/kg)
0.4-58.500
0.09-19,000
4-396.000
6.2-6.2
17-17
3-410
13-13
Location of
Maximum Detect
35SS03
35DIR05
35SS03
35M01
35DK05
35DIR06
35DIR05
Groundwater contaminants greater than EPA risk-based screening levels or background
concentrations for SS35 are summarized in Table 2.4. In 1992, the measured concentrations of
PCBs and DDT and its derivative products 4,4'-DDD and 4,4'-DDE were at or below their
reported limits of detection.
Table 2.4 Groundwater Contaminants Greater Than Screening Levels, SS35
Chemical
1,2-
DiChloroe thane
4.4'-DDT
Benzene
Beta-BHC
Detection Limit
(ug/L)
0.5
0.1
2
0.05
# Analyzed/
# Detected
12/1
13/2
12/1
13/1
Concentration
Range (\aglL)
3.2-3.2
0.14-0.16
3.5-3.5
0.05-0.05
Location of
Maximum
35GP03
35GP02
35GP03
35GP01
This data in addition to a more detailed accounting of the sampling history and analytical results
can be found in the OU 3, 4, and 5 Record of Decision (ROD) and the OU 3,4,5 RI
2.2.2 The Selected Remedy for SS35 as Originally Described in the OU 3, 4, 5 ROD
The selected remedy as presented in the OU 3,4, 5 ROD was a combination of Alternative 3
(Soil Cover) and Alternative 4 (Possible Removal of Drums), and was determined at the time the
ROD was signed to be the most appropriate remedy for source area SS35. The placement of a
clean soil cover was intended to prevent contact with pesticide-contaminated soil and to prevent
runoff of contaminated soil into Garrison Slough. The buried drums were to be left in place and
OU3.4.5 ROD Amendment
10
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the groundwater, surface water, sediments, and aquatic organisms monitored, as appropriate.
Excavation of the contaminated soil and drums was not considered to be cost-effective.
The cover alternative focused on minimizing DDT migration into Garrison Slough and
eliminating the surface soil exposure pathway. The cover was selected for those areas where
DDT was detected above the residential risk-based levels in the surface soil. The soil cover was
selected primarily for the purpose of limiting the migration of contaminants into Garrison Slough
and to prevent direct soil contact and tngestion by the base personnel and ecological recep::>rs.
The primary components of the original selected remedy were:
• Installation of a soil cover over the surface soil contamination to prevent direct contact by
humans, animals, and surface water runoff into Garrison Slough;
• Removal of drums in the future, if it was determined that they are a continuing source o!~
contamination;
• Monitoring of surface water, sediments, and aquatic organisms in this area, as required to
verify effectiveness of the cover and monitoring of the groundwater to verify that levels remain
below acceptable screening levels.
2.2.3 Amended Selected Remedy
Further evaluation of the sampling data indicated that the contaminant concentrations averaged
over this relative area do not pose an unacceptable risk to human health or the environment. The
maximum concentration found for pesticides did indicate a potential human health risk if this
area were developed for residential use in the future. However, these maximum concentrations
were isolated and were not consistent over the area. In addition, the potential for residential
development in this area is very low. Therefore, additional soil cover is not necessary for
protect!veness; the current soil cover is protective of both human and ecological receptors
(OU3,4,and 5 Conceptual Design, 1996, page 15). The Final Sitewide Biological Risk
Assessment was completed in May 1995 after the original ROD was signed. Based on neu
information in this report, the ecological risk for this source area indicated a environmental
hazard quotient (EHQ) <1 for all summed pathways. The clean soil cover alternative was
originally selected in part because it would mitigate ecological risk. Because the Sitewide risk
work indicated that current ecological risk is not unacceptably-high, the cover is not needed to
mitigate ecological risk.
The concern with respect to surface water runoff into the slough was also re-evaluated. The area
is covered with grass and is relatively flat with little expected soil erosion. In addition, the
concentrations in the soils do not differ significantly from those found in the slough sediment:
therefore, any surface water runoff that does occur is not expected to contaminate the sediments
or surface water. Surface water and sediments in Garrison Slough in this area do not pose .- risk
to human health or the environment.
OU3.4.5 ROD Amendment 1 ]
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Based on this re-evaluation, additional soil cover is not necessary for pr: action of human health
or the environment at SS35. The amended selected remedy is:
• No action under the CERCLA program; and
• Continued monitoring of surface water, sediments, and aquatic organisms at the site to confirm
that concentrations remain at levels that are protective of human health _r. j the environment.
2.3 ST58 Site History
ST58, site of the old Quartermaster service station, is located on the ner.v.vest corner at the
intersection of Division Street and Wabash Avenue. The service station covered approximately
400 m2 (478 yd2).
The Quartermaster service station was operated from 1970 to 1988. The service station was a
source of petroleum products for private vehicles operated by Eielson AFB personnel and their
dependents until 1975, and for Eielson AFB vehicles only after 1975. The service station used
four 95m3 (25,000 gal) above-ground storage tanks, containing leaded and unleaded motor
gasoline (MOGAS) and diesel. Two barrels of motor oil were stored at the service station for
customer use.
Eielson AFB staff removed the above-ground storage tanks and above-ground piping in August
1988. Underground piping was left in place. During removal, workers noted evidence of
product releases. No analytical work was performed. The surface was covered with a meter (a
yard) of fill after the above-ground storage tanks and piping were removed (Liikala and Evans
1995). No spills have been reported at ST58. However, the pipeline that supplied fuel to ST58
was suspected of leaking at the intersection of Industrial Drive and Division Street, east of ST58.
In 1993, approximately 532 cubic meters (700 cubic yards) of fuel-contaminated soil was
removed from the area most highly contaminated for a composting demonstration project and
replaced with clean fill material.
MOGAS and diesel stored and used at the Quartermaster service station Appears to have been
spilled or leaked from the piping and diesel tanks. Some of the volatile :; mponents of petroleum
products released at the surface may have evaporated. The less volatile components probably
seeped into the soil. The less volatile contaminants may have adsorbed :; ihe soils or been
dissolved in surface infiltration and carried to the groundwater. Fuel frc~ large spills, if any
occurred, may have moved through the vadose zone and formed a floaiir.: layer on the water
table. Because the primary potential source of contamination (fuel stor^:; tanks) has been
removed, and the majority of contaminated soils were removed in 1993. :;
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1991), in 1992.(Shannon & Wilson 1992), in 1993 (U.S. Air Force 1994b), and in 1994 (U.S. Air
Force, 1995 a, b,c).
2.3.1 Contamination Problems
Groundwater contaminants greater than EPA risk-based screening levels or background
concentrations for ST58 are summarized in Table 2.6. Investigations conducted during the fall of
1991 and winter of 1992 indicated that benzene concentrations in the groundwater downgradient
of source area ST58 were greater than the drinking water standard. Toluene, ethylbenzene, and
xylene were also detected.
In April 1993, groundwater samples were collected from the same wells. Benzene
concentrations above drinking water standards were again found in several locations. Toluene
and total xylenes were also detected. Gasoline-range petroleum hydrocarbons at a concentration
of 200 |ig/L were detected in one well. Diesel-range petroleum hydrocarbons, ranging in
concentrations from 0.1 to 99 jig/L, were detected in 9 of 12 wells. Samples were analyzed for
lead and it was found in concentrations above the EPA action level (15 |ig/L) in all of the source
area welJs.
A follow-on investigation was conducted in the fall of 1994. Lead and benzene concentrations in
the groundwater remain above the drinking water standard. The extent of benzene and lead
contamination is shown in Figures 7.15 and 7.16 of the OU3A5 ROD.
All contaminants detected at ST58 were in aqueous form. No floating product was encountered,
but it is likely that past fuel releases resulted in transient product plumes that have since
dissipated after the service station was closed and the buried supply pipeline removed from
service.
Table 2.5 Groundwater Contaminants Greater Than Screening Levels, ST58
Chemical
Benzene
Gasoline
Lead
Detection Limit
(ug/L)
5
2000
5
# Analyzed/
# Detected
13/6
14/1
14/13
Concentration Range
(ug/L)
3.7- ISO
261,000-261.000
35- IN)
Location of
Maximum
58MW08
58MW09
58MW12
This data in addition to a more detailed accounting of the sampling history and analytical results
can be found in the OU 3, 4, 5 ROD and the OU 3,4. 5 RI.
2.3.2 The Selected Remedy for ST58 as Originally Described in the OU 3, 4, 5 ROD
OU3.4.5 ROD Amendment
13
-------
At site ST58 Alternative 3, an in situ alternative consisting of bioventing/groundwater
monitoring/institutional controls, was determined to be the most appropriate remedy at the time
the OU 3,4,5 ROD was signed. This alternative was selected to reduce the fuel source in the
soils through degradation of fuel hydrocarbons, and thus reduce the risk to human health and the
environment sooner than with monitoring and institutional controls alone. At the time the OU 3,
4, 5 ROD was signed, no proven method was known for removing lead from groundwater at a
reasonable cost in a reasonable amount of time. However, a treatability test was being performed
at another site ST13/DP26 at Eielson AFB to determine the fate and transport of lead and the
most viable option for extraction and treatment Results from the treatability study were to be
used to further evaluate lead remediation at ST58. Groundwater extraction/bioventing
(Alternative 4) was not the preferred alternative because of its difficult implementation, and
because biodegradation, dispersion, dilution, and adsorption appear to be effectively containing
and degrading the contamination.
Alternative 3 was selected to reduce the long-term source of contamination by preferentially
encouraging the removal of contaminants from the soil through bioventing. Groundwater action
consisted of natural attenuation, institutional controls, and monitoring.
The primary components of the original selected remedy were:
• Installation of a bioventing system to remove fuels contamination in the soil that poses a threat
to groundwater through leaching.
• Institutional controls to prevent exposure to contaminated groundwater.
• Monitoring of groundwater to evaluate contaminant level and identify changes to contaminant
plume configuration until remediation levels are achieved.
2.3.3 Amended Selected Remedy
Because of the 1993 removal of 700 cu. yd. of BTEX contaminated soils from the most
contaminated area of the site, the level of remaining residual soil contamination does not appear
to warrant installation of a bioventing soil treatment system. New information that was not
available in September 1995 when the OU 3,4,5 ROD was signed has been considered during the
RD for source area ST58. The new information includes groundwater and soil vapor chemistry
data collected by EA Engineering in September 1995. The results are shown in Figure 3-18
(OU3,4,5 Draft RD, 1996 ), and indicate that the BTEX concentrations in the groundwater at the
source are present at concentrations approximately an order of magnitude lower than the
concentrations presented in the RI/FS and ROD which supported the selection of the in situ
alternative over the groundwater monitoring/institutional controls alternative. The O7CO, data
collected in the vadose zone of the source area indicate that the soil vapor does contain relatively
low concentration of 0: and relatively high concentration of CO,, suggesting that natural
respiration of hydrocarbons is occurring. The results of the EA data gap work also indicate that
the BTEX plume is less extensive now than it was when the samples were last collected in 1993
OU3.4.5 ROD Amendment 14
-------
(Figures 3-16 & 3-17), and the one well that contained benzene in 1995 (58MW10) had
decreased its concentration over an order of magnitude from that of the 1993 sampling. Benzene
concentrations are below 100 u,g\L, the concentration used for the OU1 and OU2 bioventing
remediation efforts to delineate the area to be remediated. Some of the decrease in the size of the
dissolved plume is attributed to the removal of some of the hydrocarbon source when 700 cu.yd.
of soil was excavated from the former tank pit in 1993 (Liikala & Evans, 1995). However, no
soil was removed in the area of the monitoring well 58MW10. This data seems to support the
conclusion that both source removal and natural attenuation have significantly reduced the area
of the ground water impacted by benzene at ST58.
Natural attenuation of the hydrocarbons at the source area is occurring based on the groundwater
monitoring results collected by EA and based on the results of the testing completed by Utah
Water Research Laboratory for the area of ST13/DP26.
Alternative 2, Institutional Controls, will be selected instead of Alternative 3, In Situ. This
change could be considered a fundamental change that is a logical outgrowth of data gap work
and scoping conducted during the RD.
Additional investigations have indicated that petroleum contamination is being addressed
through natural attenuation and biodegradation in both the soils and groundwater; and therefore,
the original remedy of bioventing is proposed to be changed as follows: Residual soil
contamination does not appear to be adversely impacting the groundwater; therefore, no further
action of soils is proposed. For the lead contamination at ST58, the Air Force, EPA, and ADEC
have determined that groundwater restoration for this confined area is technically impracticable.
Subsequent to the ROD, the Air Force conducted an extensive study of the groundwater lead
contamination at the base to determine the form of the lead and to determine if the area of lead
contamination was expanding. The study determined that the organic lead originally contained
in the fuel has degraded to an immobile, stable inorganic lead that strongly adheres to the soils
within the groundwater and consequently, the groundwater contamination is contained within an
area approximately 500 feet long. Monitoring data collected during the investigations confirm
that the contamination is not expanding. Any remaining source of the more mobile organic lead
will be degraded to the immoble, inorganic lead through treatment and removal of the petroleum
products. It would be extremely difficult or technically impracticable to clean up the
groundwater lead contamination by pumping the groundwater because the lead is so strongly
adhered to the soils within the groundwater.
Under the federal Superfund law, when groundwater restoration is technically impracticable,
action focuses on: (1) containment to prevent contamination migration; (2) source removal to
prevent further contamination of the groundwater; and (3) prevention of exposures. For ST58,
the Air Force, EPA, and ADEC have determined that groundwater restoration for this limited
area is technically impracticable; and therefore, the original remedy of groundwater
extraction/treatment is proposed to be changed to:
• Continued monitoring to confirm that the groundwater lead contamination is not migrating
and is remaining within the currently established containment area. Regulatory requirements
would be waived for lead contamination in groundwater within this limited containment area.
OU'3,4.5 ROD Amendment 15
-------
• Degradation of the organic lead to immo'r.ie inorganic lead will occur as a result of the
degradation of petroleum contamination through the process of natural attenuation.
• Implementation and enforcement of institutional controls to prevent use of the contaminated
soil and groundwater ir. '.rns area to ensure pr: :ection of human health and the environment.
2.4 LF03/FT09 Site History
LF03 is located east or" :he south end of the ru.v.vay and north of the refueling loop (.see Figure
2.1 in OU3.4.5 ROD... FT09 is located withi". :he west-central pan of LF03. LF03 and FTU9 are
approximately 39.5 hectares (98.8 acres). LF"? was used as the main base landfill from 1967 to
1987. The landfill is believed to have received household garbage, scrap lumber and metal,
construction debris, concrete slabs, empty cans and drums from fiightline industrial shops, and
possible waste oils, sper.: solvents, and paint residues and thinners. The six trenches on the east
side of the landfill received most of the waste after 1980. The landfill excavation reportedly
extended below the waier table. The landfill boundaries were established by geophysical surveys
performed by HLA in 1988 and 1989. Potential sources of contamination include the leaching of
landfill debris by groundwater, and subsurface soil and groundwater contamination by leaks from
buried drums or cans.
Fire-training exercises at FT09 occurred from 1955 to 1989 and involved burning waste oils.
contaminated fuel, and spent solvents. Procedures used during the most recent exercises
involved saturating the ground with approximately 20,000 L of water, applying fuel, burning the
fuel for 30 seconds, and extinguishing it with roam. A mixture of 2000 to 4000 L of clean JP-4
and up to 800 L of contaminated JP-4 was used in these exercises. Fire-training exercises were
conducted at least twice per month. Expected contaminants from FT09 include fuel-related
compounds (BTEX) and chlorinated solvents. The mock jet was removed in 1994, and during
the summer of 1995 a new lined fire training facility was constructed.
2.4.1 Contamination Problems
Soil contaminants grea:er than EPA risk-based screening levels or background concentrations for
LF03/FT09 are summarized in Table 2.7. Sair.rie results delineated several areas of soil with
TPH concentrations greyer than 100 mg/kg. An area of surface contamination approximately
30 by 60 m (98.4 by 1^.9 ft) was delineated r.ear a mock-up jet fighter used for fire-training
exercises. An area of su: surface contaminati: n was identified west of the mock-up jet, at a
depth of approximately ; to 2 m (3.3 to 6.6 ft relow land surface, which is just above the water
table. The subsurface TPH contamination may re the result of fire-training activities (such as
spilled fuel) or leakage rrom landfill debris.
As a result of the TPH survey, samples were c '.lected adjacent to the former site of the mock-up
jet. PAHs were detected in all of these sample.- at concentrations ranging from 75 to 410 nig/kg.
The greatest number o:' ?AHs was detected ir. >.;rfacc soil sample 03SYS05. at the west CP.J of
Ol'?.-^ ROD A:noti(!mer.: /6
-------
the mock-up :et. In addition, kerosene was detected in all but one sample. Naphthalene and 2-
methylnaphihalene, which are commonly found in JP-4 fuel, were detected in two samples. The
presence or" '.hese compounds may be attributed to incomplete combustion of fuel used in fire-
trainina exercises.
Table 2.6 Surface and Subsurface Soil Contaminants Greater Than Screening Levels,
LF03/FT09
Q — ical
1 ,2 Dichloroemvlene
Benzo(a)ar>ihracene
Benzo(a)pyrene
Benzo(b)fluoranthene
Benzo(ghiiDerylene
Indeno( 1 ?2.3-cd)pyrene
Kerosene
Detection Limit
(ue/kg)
100
660
660
660
660
660
N/A
» Analyzed/
# Detected
10/1
9/2
' 9/3
9/3
9/1
9/1
10/10
Concentration
Range (ug/kg)
300-300
84-181
79.1-200
83-250
200-200
200-200
48-1,590,000
Location of
Maximum
Detect
03M02
03SYS05
03SYS05
03SYS05
03SYS05
03SYS05
03SS09
Groundwater contaminants greater than EPA risk-based screening levels or background
concentrations for LF03/FT09 are summarized in Table 2.7. Sampling results, prior to 1994,
indicated the presence of VOCs in groundwater atLF03/FT09 ;..s;:-e Ficure ^;..: in OUA.-'V> ROD;.
Leakage from a subsurface JP-4 fuel pipeline approximately 76 m (83 yd) upgradient of Well
03M13 had been cited as a possible source of benzene contamination: however, no toluene,
ethylbenzene. or xylene were detected in samples with the highest benzene concentrations. No
floating product was encountered. The presence of benzene without the other fuel-related VOCs
is characteristic of the leading edge of a plume from an upgradient source because benzene is
more mobile :han the other constituents. Another possibility is the benzene plume may have
originated t'r:m a source in the fire-training area. Solvents were also detected in groundwater at
LF03r prior ;:• 1994.
Table 2.7 Gr^undwater Contaminants Greater Than Screening Levels. LF03/FT09
Chemical
1. 4-Dichlor- benzene
Benzene
Teirachloreir.une (PCE
Trichloroc'.r.Jie (TCE*
VinvlChKr:Je
Detection Limit
(Mg/Li
10
1
0.5
0.5
0.5
# Analyzed/
# Detected
79/2
22/4
22/1
22/6
22/5
Concentration
Range 'uu'/L*
64-82
1.7-20
53-53
0.64-150
0.54-17
Location of
Maximum
03M08
03M08
03M08
03M08
03M08
OLv.-.5 ROD -•:•..•nilmcii'.
-------
Groundwater sampling results in 1989 delineated plumes of trichloroethane (TCE) near Well
03M08 and vinyl chloride near Well 03MOI. TCE was not detected in samples collected
downgradient of Well 03M08 and, therefore, is probably caused by a localized leak from landfill
debris. The plume appeared to have originated near Well 03M01 and extended to the north,
toward Garrison Slough. These solvents were most likely derived from leaking containers of
spent solvent in the landfill. Low concentrations of solvents were also detected in the 1992
groundwater samples.
By the time of the sampling event in August 1994, benzene and chlorinated solvents were below
MCLs (and in many cases below detection limits) in all wells in LF03/FT09, except for Well
03M08 '.::-.-.\' K::".; •:.-: *.:• -h;'u;-/h 8.5) This well contained relatively high concentrations of a
number of contaminants (see Table 2.8), including 4-methyl phenol (p-cresol),
dichlorodifluoromethane (Freon-11), and trichlorofluoromethane (Freon-12). Analyses were not
reported for Well 03M08 in a previous investigation by HLA (1989) because of analytical
difficulties. Well 03M08 was not sampled in 1992. This well is located in the eastern portion of
LF03 in the area of the waste trenches, which were used after 1980. It is important to note that
contaminated groundwater from LF03/FT09 is limited to low concentrations in one well within
the landfill refuse. Groundwater concentrations in wells surrounding the downgradient perimeter
of the landfill are below regulatory levels.
This data in addition to a more detailed accounting of the sampling history and analytical results
can be found in the OU 3, 4,5 ROD and the OU 3,4,5 RI.
2.4.2 The Selected Remedy for LF03/FT09 as Originally Described in the OU 3,4,5 ROD
At site LF03/FT09 Alternative 4, Soil Cover/Composite Cap/Groundwater
Monitoring/Institutional Controls, was determined to be the most appropriate remedy at the time
the OU 3, 4, 5 ROD was signed. FT09 is considered together with LF03, because FT09 is
completely contained within LF03.
This alternative was chosen because it is believed that a composite cap was required under
RCRA Subtitle C for areas that receive waste after 1980. Groundwater monitoring would be
performed at the edge of the waste management area to detect any movement of contaminants.
The cap alternative focused on eliminating the threat of direct contact with buried landfill debris,
and on soil contamination and monitoring of groundwater at the edge of die waste management
area to ensure that federal and State standards are met.
The primary components of the selected remedy were:
• For the portion of the landfill where disposal occurred before 1980, RCRA Part 264 is relevant
and appropriate. Currently, no groundwater at the edge of the waste management area exceeds
regulatory levels: the residual contamination poses a direct contact threat. A cover to address the
OU3A5 ROD Amendment 18
-------
direct contact threat will be installed and maintained in accordance with relevant and appropriate
requirements of Part 264. Groundwater at the landfill will continue to be monitored, as
appropriate, to verify that contaminant concentrations, if any. remain within acceptable screening
levels.
• For the portion of the landfill where disposal occurred alter 1980, RCRA Part 264 is
applicable. The final cover will be constructed to: (1) provide long-term minimization of
migration of liquids, (2) function with minimum maintenance, (3) promote drainage and
minimize erosion, (4) accommodate settling and subsidence, and (5) have a permeability less
than or equal to the natural subsoil present. Post-closure care, including maintenance and
monitoring, will be conducted in accordance with 40 CFR 264.117 and 264.228(b).
• Institutional controls will be implemented to restrict land use. In the event of base closure, any
remaining contamination will be addressed in accordance with CERCLA Section 120.
2.4.3 Amended Selected Remedy
No fundamental changes are proposed to the selected remedy; however, clarification of
regulatory issues is warranted. The Air Force had previously indicated that there was
documented evidence of disposal of hazardous waste in the post-1980 disposal area. A
subsequent search of Air Force and Fairbanks North Star Borough records after the signing of the
original ROD could not confirm this disposal of hazardous waste. Given the lack of
documentation of hazardous waste disposal, RCRA Subtitle C is relevant and appropriate as an
ARAR, but is not applicable. Groundwater concentrations are below regulatory levels, therefore,
an impermeable cover to prevent movement of groundwater through the landfill is not warranted.
The amended selected remedy is clarified as follows:
• Hybrid Landfill Closure includingcover to address the direct contact threat will be maintained
in accordance with relevant and appropriate requirements of the Resource Conservation and
Recovery Act Part 264 and OSWER Directive 9234.2-04FS, "RCRA ARARs: Focus on
Closure Requirements".
.• Groundwater at and adjacent to the landfill will continue to be monitored to verify that
contaminant concentrations remain below acceptable regulatory levels.
• Institutional controls will be implemented to restrict land use to prevent direct exposure
to landfill waste.
3.0 Summary of Comparative Analysis
OU3.4.5 ROD Amendment 19
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The following is a brief discussion evaluating the original selected remedy and the new selected
remedy based on the nine criteria presented in the National Contingency Plan (NCR).
3.1 Overall Protection of Human Health and the Environment
3.1.1 Site DP44: Both the original and the amended remedies satisfy this criteria. The amended
remedy would use institutional controls to prevent the use of contaminated groundwater at the
site until cleanup standards are achieved and would employ long term monitoring. The SVE
portion of the original selected alternative will not provide a significantly greater protection of
human health and the environment or a significantly greater degree of cleanup of soil and
groundwater over biodegradation and natural attenuation, as shown by additional investigation
and pilot testing.
3.1.2 Site SS35: Both the original and the amended remedies satisfy this criteria. The amended
remedy would employ long term monitoring of surface water, groundwater, sediments, and
aquatic organisms to confirm concentrations of contaminants found at the site remain at levels
protective of human health and the environment.
3.1.3 SiteSTSS: Both the original and the amended remedies satisfy this criteria. The amended
remedy would use institutional controls to prevent the use of contaminated groundwater at the
site and would employ long term monitoring. Because a significant volume of BTEX
contaminated soil (700 cu. yd.) was removed from the site in 1993 for a composting
demonstration, the limited contaminant source remaining does not appear to be impacting the
groundwater and bioventing at this site will not reduce the contaminant levels at a significantly
greater rate over natural attenuation and biodegradation, as shown by studies conducted at other
sites on the base. Because of the similarity of site conditions and groundwater lead
contamination between site ST58 and sites ST13/DP26, the decisions reached at site ST13/DP26
regarding the issue of lead contamination in the groundwater (Technical Impracticability Waiver.
and monitoring for lead plume stability) were applied to Site ST58 and are considered protective
of human health and the environment. The Air Force will effectively maintain institutional
controls in this area in accordance with the Institutional Control Plan while contaminant levels
exceed regulatory levels.
3.1.4 Sites LF03 & FT09: Both the original and the amended remedies satisfy this criteria. The
amended remedy would employ maintenance of the existing landfill cap to prevent exposure
through direct contact with materials buried in the landfill, and institutional controls to restrict
land uses. Long term monitoring of groundwater will continue. Because it has been verified that
materials buried in the unlined landfill are in contact with the groundwater, and contaminants in
the groundwater remain below regulatory levels, the impermeable cover proposed in the original
selected remedy is not considered to provide a greater level of protection to human health and the
environment than the existing soil cover in place.
3.2 Compliance with Applicable or Relevant and Appropriate Requirements
(ARARs)
Ot; v-t.5 ROD Amendment 20
-------
The ARARs for the amended selected remedy are the same as those for the original remedy for
all source areas.
3.2.1 Site DP44: The amended remedy is expected to achieve groundwater maximum
contaminant gc^s presented in the original ROD.
3.2.2 Site SS35: The amended remedy complies with all ARARs presented in the original
ROD.
3.2.3 Site ST58: The amended remedy is expected to achieve groundwater maximum
contaminant goals presented in the original ROD, with the exception of the action level for lead.
ARARs for lead contamination in the groundwater at this site have been waived under conditions
of the Technical Impracticability Waiver (TIW) from an engineering perspective.
3.2.4 Sites LFU3 & FT09: The amended remedy complies with all ARARs presented in the
original ROD.
3.3 Long-term Effectiveness and Permanence
3.3.1 Site DP44: Natural attenuation of hydrocarbon and solvent contaminants in groundwater
has been shown through study at Eielson AFB to aggressively degrade these type compounds.
The amended remedy also prevents use of contaminated groundwater at the site through use of
Institutional Controls. Once groundwater MCLs are met, long-term effectiveness and
permanence will be achieved.
3.3.2 Site SS35: Contaminants found in surface waters , sediments, and aquatic organisms on
this site are not at levels which pose an unacceptable risk to human health and the environment.
Long term monitoring of surface water, sediments, and aquatic organisms will continue to ensure
long-term effectiveness and permanence.
3.3.3 Site ST58: Natural attenuation of hydrocarbon contaminants in groundwater has been
shown through smdy at Eielson AFB to aggressively degrade these type compounds. In addition,
organic lead in groundwater at the site is expected to degrade to the immobile inorganic phase.
The alternative also prevents use of contaminated groundwater at the site through use of
Institutional Controls.
3.3.4 Sites LF<»3 & FT09: The amended remedy will prevent digging into the landfill waste
and is effective ir. isolating the landfill contents. Enforcement of the site Institutional Controls
will ensure loni.'-:erm effectiveness and permanence of the selected alternative.
3.4 Reduction of Toxicity, Mobility, or Volume Through Treatment
OtTU.f ROD An-...-.;nicm
-------
3.4.1 Site DP44: Low levels of soil contamination remaining at this source area do not meet the
definition of principal threat. The amended remedy for DP44 does not meet the statutory
preference for treatment as a principal element. Treatment was not practicable due to the
relatively low levels of contamination remaining.
3.4.2 Site SS35: The selected alternative does not include treatment, as the levels of
contaminants at-this site do not pose an unacceptable risk to human health and the environment.
3.4.3 Site ST58: Low levels of soil contamination remaining at this source area do not meet the
definition of principal threat. The amended remedy for ST58 does not meet the statutory
preference for treatment as a principal element. Treatment for the organic contamination in soil
was not practicable due to the relatively low levels of contamination remaining.
Treatment of the lead contamination in the groundwater is technically impracticable from an
engineering perspective.
3.4.4 Sites LF03 & FT09: The selected alternative does not include treatment of the waste
because of the low contaminant concentrations and the large volume of waste. The investigaiion
did not identify "hot spots" of soil or groundwater contamination suitable for treatment within
this large landfill.
3.5 Short-Term Effectiveness
3.5.1 Site DP44: Natural Attenuation is not a short-term cleanup process, and will achieve
cleanup standards much more slowly than active remediation techniques. Neither the amended
remedy or the original remedy pose an unacceptable risk to residents or workers during
implementation. All potential impacts from construction and system operations will be
controlled using standard engineering controls and practices.
3.5.2 Site SS35: Levels of contaminants at this site do not pose an unacceptable risk to human
health and the environment.
3.5.3 Site ST58: Natural Attenuation is not a short-term cleanup process, and will achieve
cleanup standards much more slowly than active remediation techniques. Neither the amended
remedy or the original remedy pose an unacceptable risk to residents or workers during
implementation. All potential impacts from construction and system operations will be
controlled using standard engineering controls and practices.
3.5.4 Sites LFU3 & FT09: N'either the amended remedy or the original remedy pose an
unacceptable risk to residents or workers during implementation. All potential impacts from
construction and system operations will be controlled using standard engineering controls and
practices.
3.6 Implementability
OU.V4.5 ROD A
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3.6,1 Site DP44: Institutional Controls and long-term monitoring are readily implementable and
can be effectively maintained on this Air Force base.
3.6.2 Site SS35: Long-term monitoring of surface water, sediments, and aquatic organisms is
readily impiementable.
3.6.3 Site ST58: Institutional controls and long-term monitoring are readily implementable and
can be effectively maintained on this Air Force base.
3.6.4 Sites LF03 & FT09: Institutional controls and long-term monitoring are readily
implementable and can be effectively maintained on this Air Force base.
3.7 Cost
3.7.1 SiteDP44:
Original Alternative Cost ($000)
Soil Vapor Extraction 1,600
GW Monitoring/ICs 140
Total Cost
3.7.2 SiteSS35:
Soil cover
Surface Water/
Sediment/
Aquatic Org. Monitoring
Total Cost
1,740
Original Alternative Cost ($000)
40
140
180
3.7.3 SiteSTSS:
Bioventing System
G\V Monitoring/ICs
Total Cost
Original Alternative Cost ($000)
51
140
191
New Alternative Cost ($000)
0
140
140
New Alternative Cost ($000)
0
140
140
New Alternative Cost ($000)
0
140
140
3.7.4 Sites LF03 & FT09:
Original Alternative Cost ($000)
New Alternative Cost ($000)
Ol'.V-U ROD Amendment
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Soil cover & components 7100 0
GW Monitoring/ICs 230 230
Total Cost .7,330' 230
3.8 State Acceptance
The S:_r.a of Alaska Department of Environmental Conservation (ADEC) concurs with the
actions selected in this ROD amendment.
3.9 Community Acceptance
No public comments were received, regarding the Proposed Plan, during the public meeting held
May 25. 1996, or during the public comment period from May 13, 1996 through
June 12. 1996. Community participation is discussed in Section 8.0, Responsiveness Summary.
4.0 Technical Impracticability of Groundwater Restoration
4.1 Specific ARARs
The specific ARAR or media cleanup standards for which the TI waiver applies are as follows:
• MCLs and maximum contaminant level goals (MCLs, non-zero maximum contaminant limit
goals [MCLGs], and action levels) established under the Safe Drinking Water Act for
grounduater that may be used for drinking water supply (40 CFR 141 and 18 AAC 80).
The TI waiver will apply only to lead in the groundwater and specifically to the EPA established
action level of 15 ug/L for lead in drinking water.
4.2 Spatial Extent of TI Waiver
The TI -.vaiver will apply to the area having the following boundaries (see Figure A).
• Wabash Avenue on the east
• Division Street on the south
• Flightline Avenue on the west
• A line running east and west along the south side of the Air National Guard operations
building 43129.
The ve.-ical extent of the TI waiver will range from the water table to 30 feet below the average
annual "-aier table depth.
4.3 Conceptual Model
OU3A5 ?>OD Amendment 24
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4.3.1 Site Conditions
The information presented below is from the ITIR for Site ST13/DP26. Because of the similarity
in site conditions and lead contamination between Site ST58 and Site ST13/DP26, the U.S. Air
Force, EPA. and ADEC agree that conclusions reached in the ITIR for Site ST13/DP26 can be
applied to Site ST58. The information presented below is from the ITIR, as follows:
The site limnology is generally homogeneous and is predominantly sand and gravel with very thin
discontinuous layers of silt encountered in less than ten percent of site lithological samples (U.S.
Air Force 1996 page 5-1). The deposition environment consists of fluvial and glacial fluvial
deposits. Most of the sediments were deposited in the principal stream beds during higher
energy deposition. The thickness of the alluvial fan deposits are in the hundreds of feet.
The water bearing zone is characterized by a low hydraulic gradient and highly transmissive
aquifer materials. The mean, hydraulic gradient is 0.002 with the highest (0.05) occurring during
a four week period in May and the lowest (0.0013) occurring over a seven month period from
September to March (U.S. Air Force 1996 page 5.2). A hydraulic conductivity value of 380
feet/day was estimated from an August 1995 pumping test (U.S. Air Force 1996 page 5.1). The
aquifer has a slow vertical rate of mixing which serves to confine groundwater contaminants near
the water table (U.S. Air Force 1993b, page 4.1).
4.3.2 Fate and Transport Investigation
The investigation indicates that the major source of lead contamination is from the floating
product plume as shown in Figure 2. The lead plume is confined to a small and appears to
coincide with the historic extent of the floating product plume. During the investigation,
tetraethyl lead (TEL), the organic lead fuel additive, was detected in a floating product sample at
a level of 519,000 ug/L and at low levels in the groundwater, i.e., 6 ug/L (page ES-3). The
groundwater TEL plume was coincident to that of inorganic lead. The investigation also
established that the lead contamination is confined to depths between 5 and 30 feet below ground
surface (p^ge 5-3).
A RANDOM WALK model predicted that the lead could migrate 50 feet in 500 years (page 5-9).
The report qualified this prediction, however, stating that, because of the uncertainty associated
with predicting lead transport, conservative input parameters (Retardation Factor Rf = 166, page
5-6) were used which demonstrate that the plume will not move appreciably in 100 years and that
the concentrations will have diminished substantially at the core (page 5-23). The report also
points out :hat the lead plume has not migrated over the time period for which lead in
groundwater data are available (1988 through 1995) (page ES-3). Associated lead transport
modeling indicated that aquifer restoration would require approximately 100 years. This
prediction :s also very uncertain for the reasons Stated above.
4.3.3 EPA Technical Review
L'3.4.5 R( ? Amendment
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In a technical review of the report, EPA indicates that the following report conclusions are valid
(see Appendix E, US Air Force 1996 page ES-1).
• The source of the lead is the leaded fuel leaked from the UST> ^nd the associated fuel
hydrant
system as well as unknown buried fuel tank sludge.
• Lead was transported with the fuel product in the vadose zone jjid on the water table.
• Organic lead in the fuel product has degraded to inorganic lead which is strongly adsorbed to
the vadose zone and aquifer matrix.
• The groundwater lead plume has not migrated over the time period for which lead in
groundwater analytical data are available.
The reviewers, however, did not agree with the use of the RANDOM WALK model presented in
the report. The model significantly overstated the mobility of lead in groundwater and the model
uncertainties are so high that the model results cannot be used to make risk management and
remediation decisions (page 5).
A conceptual model, based on empirical data, is represented in figures 3 and 4. In the model,
advection refers to the transport and dispersion of lead contamination by the groundwater. As
the petroleum hydrocarbons with TEL and inorganic lead are dissolved in the groundwater, the
TEL is degraded to inorganic lead relatively quickly through physical, chemical and biological
processes. The report indicates that TEL has a half life of 2 to 8 weeks (page 4-10). When the
conversion occurs, the inorganic lead has a very strong tendency to sorb onto organic matter and
the soil matrix. At this point the inorganic lead is nearly immobilized.
Initially, because migration of the lead is retarded, the BTEX plume may expand beyond the
limits of the lead contamination plume. After the fuel source is removed and biodegradation
continues to act on the fuel, the size of the fuel plume will decrease with time. As the TEL is
transformed to inorganic lead, it is fixed in place. The size of the area contaminated by lead will
not decrease and the lead will not move with the groundwater.
In fact, the BTEX plume at ST13 and DP26 has expanded beyond the extent of the lead plume by
a significant amount and has begun to decrease in size (U.S. Air Force 1996 page 2-7). The air
injection system operation which began in October 1995 is intended to remove the BTEX
contaminant source and is expected to accelerate reduction of the BTEX plume. This activity
will also accelerate the organic lead degradation rate and the resul^m sorption of inorganic lead.
4.4 Evaluation of Restoration Potential
4.4.1 Source Control Measures
The 1988 removal of the four 25.000 gal. above-ground storage tar.ks and associated piping used
for the storage and handling of leaded and unleaded motor gasoline MOGAS) and diesel
removed the primary source ot" fuel and lead contamination at the >.:.\ Motor gasoline (MOGAS)
and diesel stored and used at the Quartermaster Service Station aprr^rs to have been spilled or
OU3.4.5 ROD Amendment 26
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leaked from the piping and diesel tanks during operations at the facility. In 19v3, approximately
700 cu.yd. of fuel contaminated soil was removed from the most highly contaminated area of the
site and used in a composting study (U.S. Air Force, Operable Units 3.4. and : Final Record of
Decision, September 1995, page 7.11). All contaminants detected at ST58 are in the aqueous
form, with no floating product encountered at the site (U.S. Air Force. Oper^c ^ Units 3,4, and 5
Final Record of Decision, September 1995, page 7.12). After decommission^: of the
Quartermaster Service Station in 1988, no fuels have been stored at this site.
Restoration of the site is constrained by the mobility of the lead. Modeling eriorts predict that a
pump an'd treat system will require greater than 100 years to remove the lead : :ntamination. The
report concludes that lead is largely immobile in the subsurface and that com^rr.mation cannot be
cleaned up using pump and treat technology.
No cleanup technology is available that will significantly reduce the time required to restore the
aquifer. Soil excavation to remove the residual contamination is not practical recause the
majority of the contamination is within the saturated zone (U.S. Air Force 19y4i.
4.4.2 Restoration Timefraine
The modeling effort predicted thai restoration of the site using pump and treat technology could
require 100 years or more and suggested that this estimate is conservative and the time could be
significantly longer. The EPA review also Stated that the lead is relatively immobile and cannot
be cleaned up using pump and treat technology.
5.0 Institutional Controls
As part of the institutional controls for contaminated soil and groundwater, the Air Force will develop a
written, installation-wide plan ("Institutional Control Plan" or "1C Plan") that sets out procedures
to assure that institutional controls for soil and groundwater are developed, miir.iained,
monitored, and remain effective. The 1C Plan will be completed within six m,-iihs of the
signature of the ROD amendment and will apply to all areas on the base, including those listed in
this ROD Amendment, requiring institutional controls for soil and groundwaie: AS part of the
remedy. The 1C Plan will be reviewed and approved by EPA and the State or" Alaska and is
enforceable jointly or severally by them.
The 1C Plan shall specify the following:
1.) Eielson AFB will undertake, at a minimum, the following:
a. identify all areas under restriction or control;
b. identify the objectives that must be met by the restrictions an: :ontrols;
c. identify the current and future land users, including, at a min.rr.um. but not
limited to. lessees, contractors, employees, agents, assigns, invitees, ur.c licensees. In
areas where the installation is aware of routine trespassing, the .Air For:e will also
consider trespassers.
OU3.4.5 ROD Amendment 27
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2.) Eielson AFB will establish an Institutional Control ("1C") process to develop
Standard Operating Procedures (SOPs), incorporated into the Base General Plan (or equivalent
document) to ensure 1C development, implementation, and enforceability for each area which has
an 1C as a component of the selected remedy.
a. Eielson AFB shall consider, and demonstrate to EPA and the State, that the 1C process
will cover all entities and persons necessary, including, but not limited to. lessees,
contractors, employees, agents, licensees, trespassers, and invitees.
b. Eielson .AFB shall consider and demonstrate to EPA and the State that the 1C process
will cover all activities, including, but not limited to any and all, routine and non-routine
utility work, soil disturbance, groundwater withdrawals, well placement, drilling, paving,
troop training exercises, recreation uses, building, renovation work on structures or other
activities.
c. Eielson AFB shall specify (e.g., through the SOPs) the particular restrictions, controls
and mechanisms which will be used to achieve the identified objectives.
d. Eielson AFB shall include a data base and master installation map that identifies all
land areas under restriction or control, the objectives to be met by the restrictions or
controls, and the particular restrictions, controls and mechanisms which will be used to
achieve the identified objectives.
e. Eielson AFB shall develop a process to ensure that both EPA and State approval, as
appropriate, are obtained prior to any change in identified land use designation,
restrictions, land users or specific activity for any 1C required.
3.) The 1C Plan will specify that all current or future land users, whether government or
private entities, will be legally required to abide by the decision document and the 1C contained
therein, and specify the enforcement mechanism or tool that will legally bind the land user (e.g.
leases, licenses, contracts, command directives, etc.).
4.) Eielson AFB shall identify the "point of contact" person or organization designated
as being responsible for implementing, monitoring, maintaining and enforcing the 1C process.
5.) Eielson AFB shall identify the source of funding for activities required by the 1C
process at the installation.
6.) Eielson AFB will monitor compliance with all aspects of the 1C process on an annual
basis throughout the period of time necessary to implement and maintain the applicable 1C,
unless another monitoring frequency is agreed to by EPA and the State.
7.) Eielson AFB shall conduct field inspections, at least annually, to assess the condition
of all areas at the installation subject to 1C. These inspections will be used in determining the
effectiveness and prote:tiveness of all 1C and designated land uses, and will be used in
OU3,4.5 ROD Amendment 28
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ascertaining whether the current land and groundwater uses in the areas are consistent with the 1C
for all remediation objectives outlined in the decision document governing that area. The results
of any field inspections shall be documented in a field inspection report, which shall be sent to
EPA and the State within 60 days of the completion of the field inspection. The designated
official responsible for the facility operations shall certify the accuracy of the field inspections
and the continued compliance with all 1C requirements. Eielson AFB shall provide notice of
any change in the designated official to EPA ind the State.
8.) Eielson AFB shall notify EPA and the State immediately upon discovery of any
unauthorized change in an 1C, in land use designation(s), or in any activity which is inconsistent
\viih the identified 1C. Eielson AFB will allcnv EPA and the State upon notification to work
with the installation to determine a plan of action to resolve the unauthorized change/activity.
Where the Air Force believes the unauthorized change creates an emergency situation, the Air
Force can respond to the emergency upon notification to EPA and the State and need not await
EPA or State input to determine a plan of action. Eielson AFB will develop a "feedback loop"
to identify what went wrong with the 1C process, identify how to correct the process to avoid
future problems and requires the correction to be implemented.
9.) Eielson AFB shall notify EPA and the State at least six (6) months prior to, when
possible, but no later than thirty (30) days prior to, any transfer, sale or lease of any property
interest at the installation and define in the notification the process to be utilized to ensure 1C
remain in place, remain effective and remain enforceable.
10.) The 1C Plan, and in particular, the 1C process developed and implemented under that
Plan, shall be reviewed as a part of the CERCLA five year review process.
11.) The removal of 1C, completion of 1C, or no further need for 1C must be a
coordinated decision with approval by EPA and the State. In the event of a disagreement, the
parties will resolve the dispute in accordance with Part XXI, Resolution of Dispute, of the
Eieison Air Force Base Federal Facilitv Agreement.
6.0 Affirmation of Statutory Determinations
The amended selected remedies are protective of human health and the environment and are cost
effective. The amended selected remedies comply with Federal and State requirements that are
legally applicable or relevant and appropriate -o the remedial action with the exception of the
action level for lead established under the Safe Drinking Water Act (40 CFR 141.80). A waiver
of the lead action level is justified because compliance with the requirement is technically
impractical from an engineering perspective. The remedies utilize permanent solutions and
alternate treatment (or resource recovery) technologies to the maximum extent practicable and
saijfy the statutory preference for remedies tlut employ treatment that reduces toxicity.
mobility, or volume as a principal element.
OV.V-.5 ROD Amendment :9
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Because these remedies will result in hazardous substances remaining onsite above health-based
levels, reviews will be conducted at sites DP44, ST58, and LF03/FT09 each 5 years during the
five-year ROD review process to ensure that the remedies continue to provide adequate
protection of human health and the environment.
7.0 Responsiveness Summary
The proposed ROD amendments and XI waiver considered by the U.S. Air Force, ADEC, and
EPA were presented to the public in The Proposed Record of Decision Amendments for
Operable Unit 2 and Operable Units 3,4, 5 which was released to the public in May 1996 and
discussed in a public meeting on 23 May 1996. The proposed ROD amendment document
outlined proposed changes to the selected remedies for addressing soil and groundwater
contamination in the Records of Decision for OU 2 and OU 3,4, 5. The public comment period
for the Proposed Plan was from May 13 to June 12. 1996.
These sections follow:
• Background on Community Development
• Summary of the Comments Received During the Public Comment Period and USAF .
responses
• Remaining Concerns
7.1 Background on Community Involvement
Prior to the addition of Eielson AFB to the EPA National Priority List in 1989, the community
was offered Hide opportunity for involvement in environmental activity. From 1982 until 1989,
the USAF used the Installation Restoration Program (IRP) to identify potential contaminated
areas and investigate what remedial actions might be required. This process was purely technical
and did not evaluate community concerns in the decision-making process. However, after
signing a Federal Facility Agreement with the State of Alaska and the EPA in 1991, the Air
Force began its Superfund clean up program, which does include extensive community
involvement.
A Technical Review Committee (TRC), established in 1992, included three representatives from
the community (selected by local officials and the University of Alaska Chancellor), industry
representatives, and environmental representatives. Many of the TRC participants are members
of the professional public. The TRC was converted to a Restoration Advisory Board (RAB) in
the Spring of 1995. Three community representatives were selected as RAB co-chairpersons,
one each from the communities of Salcha, Moose Creek, and North Pole, Alaska. The RAB met
during the public comment period on May 23. 1996 to review the proposed ROD amendments.
The public comment period, public meeting, and proposed amendment changes for OUs 2, 3. 4,
and 5 were advertised twice in two local newspapers. The advertisement appeared in the
OU3.4.5 ROD Amendment 30
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Fairbanks Daily News-Miner on May 12, 1996 and in the Goldpanner on May 17, 1996. Plans
were mailed to more than 150 people on the clean up mailing list on May 13. In addition,
members of the RAB and 354 CES/CEVR created a short informational commercial which was
aired as a public service announcement thirteen times prior to the public meeting on local
television channels 2, 4, and 11. The Administrative Record is available for public review at the
areas identified in Section 1.5.
7.2 Summary of Comments Received During the Public Comment Period and
USAF Responses
A public meeting was held on May 23, 1996 at the North Pole City Hall in North Pole, Alaska.
Approximately 25 people attended the meeting, including representatives of the Air Force, EPA,
ADEC, and the public. The public comment period on the Proposed Plan extended from May
13 through June 12, 1996. There were no formal verbal comments received during the public
meeting or during the public comment period.
8.0 References
Harding Lawson Associates (HLA). 1989. Installation Restoration Program Remedial
Investigation/Feasibility Study, Stage 3, #2, Eielson Air Force Base. Alaska. Volume III, Draft
Remedial Investigation/Feasibility Study (July 1988-April 1989, Chapter IV. Ad. Record 1390,
Prepared by Harding, Lawson Associates for the Alaskan Air Command, Elmendorf Air Force
Base, Alaska.
\
Harding Lawson Associates (HLA). 1990. Installation Restoration Program Remedial
Investigation/Feasibility Study, Stage 4, Draft Report for Eielson Air Force Base, Alaska.
Volume I through V. Prepared by Harding, Lawson Associates for the Alaskan Air Command,
Elmendorf Air Force Base, Alaska.
Liikala, T. L., and J. C. Evans, 1995. Field Investigation, Source Area ST58, Old
Quartermaster Service Station, Eielson Air Force Base, Alaska. PNL-10358, Pacific Northwest
Laboratory, Richland, Washington.
Shannon & Wilson. 1991. Geotechnical Investigation and Foundation Study Vehicle
Maintenance Facility Air National Guard Eielson Air Force Base, Alaska. Shannon & Wilson,
Inc. Fairbanks. Alaska.
Shannon & Wilson. 1992. Final Report Alaska Air National Guard UST Removal Building
6128, Eielson Air Force Base. Alaska. Shannon & Wilson, Inc. Fairbanks, Alaska.
U.S. Air Force. I993b. Eielson Air Force Base OU-2 Remedial Investigation/Feasibility Study:
Remedial Investigation Report. Eielson Air Force Base, Alaska.
OU3.4.5 ROD Amendment 31
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U.S. Air Force. 1994b. Source Evaluation Report Phase 2 Investigation Limited Field
Investigation Final Report. Eielson Air Force Base, Alaska.
U.S. Air Force. 1995. Environmental Restoration Program, Sitewide Biological Risk Assessment
(Final), Eielson Air Force Base, Alaska.
U.S. Air Force. 1995. Operable Units 3,4, and 5 Record Of Decision (Final), Eielson Air Force
Base, Alaska.
U.S. Air Force. 1995a. Environmental Restoration Program, Operable Units 3,4, and 5
Remedial Investigation Report (Final), Eielson Air Force Base, Alaska.
U.S. Air Force. 19955. Environmental Restoration Program, Operable Units 3,4, and 5 Baseline
Risk Assessment (Final), Eielson Air Force, Alaska.
U.S. Air Force. 1995c. Environmental Restoration Program, Operable Units 3,4,and5
Feasibility Study (Final), Eielson Air Force Base, Alaska.
U.S. Air Force. 1996. Eielson Air Force Base Operable Unit 2, Source Areas ST13/DP26,
Treatability Study Informal Technical Information Report. Air Force Center for Environmental
Excellence, Brooks Air Force Base, Texas.
U.S. Air Force. 1996. Operable Units 3,4, and 5, Conceptual Design, Eielson Air Force Base.
Alaska.
OU3.4.5 ROD Amendment 32
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