first five-year review report for site 22

FIVE-YEAR REVIEW

Final

2015 Five-Year Review Report for Lake Louise Recreation Camp (Site OT001)

Lake Louise, Alaska

United States Air Force Joint Base Elmendorf-Richardson, Alaska

January 2016

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Lake Louise Recreation Camp – Site OT001 Page i 2015 Five-Year Review Report – Final January 2016 AFCEC/10503721/06/06.04/January 2016 Lake Louise FYR Final

TABLE OF CONTENTS

ACRONYMS AND ABBREVIATIONS ................................................................................................ iii EXECUTIVE SUMMARY ................................................................................................................. ES-1 FIVE-YEAR REVIEW SUMMARY FORM ......................................................... SUMMARY FORM-1

1 INTRODUCTION ............................................................................................................................. 1-1

2 SITE CHRONOLOGY ...................................................................................................................... 2-1

3 BACKGROUND ............................................................................................................................... 3-1

3.1 Physical Characteristics ............................................................................................................. 3-1 3.2 Land and Resource Use ............................................................................................................. 3-1 3.3 History of Contamination .......................................................................................................... 3-2 3.4 Initial Response ......................................................................................................................... 3-5 3.5 Basis for Taking Action ............................................................................................................. 3-5

4 REMEDIAL ACTIONS ..................................................................................................................... 4-1

4.1 Remedy Selection ...................................................................................................................... 4-1 4.2 Remedy Implementation ............................................................................................................ 4-3 4.3 System Operation/Operations and Maintenance........................................................................ 4-4

5 PROGRESS SINCE THE LAST REVIEW ....................................................................................... 5-1

6 FIVE-YEAR REVIEW PROCESS .................................................................................................... 6-1

6.1 Administrative Components ...................................................................................................... 6-1 6.2 Community Involvement ........................................................................................................... 6-1 6.3 Document Review ..................................................................................................................... 6-2 6.4 Data Review .............................................................................................................................. 6-2 6.5 Site Inspection ........................................................................................................................... 6-4 6.6 Interviews .................................................................................................................................. 6-4

7 TECHNICAL ASSESSMENT .......................................................................................................... 7-1

7.1 Technical Assessment Questions ............................................................................................... 7-1 7.1.1 Question A: Is the remedy functioning as intended by the decision documents?............... 7-1

7.1.2 Question B: Are the exposure assumptions, toxicity data, cleanup levels, and RAOs used at the time of the remedy still valid? ...................................................................................... 7-2

7.1.3 Question C: Has any other information come to light that could call into question the protectiveness of the remedy? ........................................................................................... 7-2

7.2 Technical Assessment Summary ............................................................................................... 7-3 8 ISSUES .............................................................................................................................................. 8-1

9 RECOMMENDATIONS AND FOLLOW-UP ACTIONS ............................................................... 9-1

10 PROTECTIVENESS STATEMENT ............................................................................................... 10-1

11 NEXT REVIEW .............................................................................................................................. 11-1

12 REFERENCES ................................................................................................................................ 12-1

Page ii Lake Louise Recreation Camp – Site OT001 January 2016 2015 Five-Year Review Report – Final AFCEC/10503721/06/06.04/May 2015 Lake Louise FYR Final

FIGURES Figure 3-1 Location and Vicinity Map ...................................................................................... 3-3 TABLES Table 2-1 Chronology of Site Events......................................................................................... 2-1 Table 3-1 Summary of LLRC COCs and Applicable Cleanup Levels ...................................... 3-6 Table 6-1 DRO Concentrations in Groundwater – 2014 and Historical .................................... 6-3 Table 9-1 Recommended Follow-up Actions for LLRC ........................................................... 9-1 APPENDICES Appendix A – Site Figure from the LLRC Record of Decision, August 2012 Appendix B – Land Use Control Boundary Figure and Descriptions from the Land Use Control

Management Plan, July 2015 Appendix C – Community Involvement Materials Appendix D – Groundwater Sample Location Map from the 2014 Groundwater Monitoring

Report, January 2015 Appendix E – 2014 Site Inspection Photographs from the 2014 Groundwater Monitoring Report,

January 2015 Appendix F – Interview Records

Lake Louise Recreation Camp – Site OT001 Page iii 2015 Five-Year Review Report – Final January 2016 AFCEC/10503721/06/06.04/January 2016 Lake Louise FYR Final

ACRONYMS AND ABBREVIATIONS AAC Alaska Administrative Code ADEC Alaska Department of Environmental Conservation AFCEC Air Force Civil Engineer Center AOI area of interest ARAR applicable or relevant and appropriate requirement BaP benzo(a)pyrene bgs below ground surface CERCLA Comprehensive Environmental Response, Compensation, and Liability Act CFR Code of Federal Regulations COC chemical or contaminant of concern DRO diesel range organics EPA U.S. Environmental Protection Agency ERP Environmental Restoration Program FS Feasibility Study FYR Five-Year Review HI hazard index LLRC Lake Louise Recreation Camp LUC land use control mg/Kg milligrams per kilogram mg/L milligrams per liter MNA Monitored Natural Attenuation MWH MWH Americas, Inc. NCP National Contingency Plan O&M operations and maintenance PA Preliminary Assessment PAH polycyclic aromatic hydrocarbon PCB polychlorinated biphenyl RA Remedial Action RAB Restoration Advisory Board RAO remedial action objective RI Remedial Investigation ROD Record of Decision SI Site Inspection USAF U.S. Air Force UST underground storage tank

Page iv Lake Louise Recreation Camp – Site OT001 January 2016 2015 Five-Year Review Report – Final AFCEC/10503721/06/06.04/May 2015 Lake Louise FYR Final


Lake Louise Recreation Camp – Site OT001 Page ES-1 2015 Five-Year Review Report – Final January 2016

EXECUTIVE SUMMARY The remedy for the Lake Louise Recreation Camp (LLRC; Site OT001) in Lake Louise, Alaska, included excavation of contaminated soil, land use controls (LUCs), and natural attenuation of soil and groundwater impacted by petroleum hydrocarbons. The selected remedy was designed to address Comprehensive Environmental Response, Compensation and Liability Act of 1980 (CERCLA) contaminants in soil and non-CERCLA contaminants in soil and groundwater. The trigger for this Five-Year Review (FYR) is the initiation of groundwater monitoring at the LLRC in June 2009.

This is the first FYR for LLRC. This assessment concluded that the CERCLA remedy was constructed in accordance with the requirements of the 2012 Record of Decision (ROD). The remedial action at LLRC successfully reduced residual concentrations of contaminants in soil to concentrations below the ADEC Method Two Human Health cleanup levels for the under 40-inch zone. In addition, potential sources, including drums and metal debris, have been removed from the site. Therefore, cleanup of LLRC is complete under CERCLA.

All immediate threats from the site have been addressed, and the CERCLA remedy at LLRC is protective of human health and the environment. Long-term, the CERCLA remedy is protective because impacted soil has been removed from the site and post-excavation confirmation sampling has verified that residual CERCLA contaminant concentrations are below applicable soil cleanup levels.

The remedy for non-CERCLA contaminants in soil and groundwater is in progress. Non-CERCLA contaminants (petroleum hydrocarbons and associated polycyclic aromatic hydrocarbons [PAHs]) remain in soil at LLRC at concentrations above cleanup criteria, and additional remedial activities are planned to address these contaminants. Non-CERCLA contaminants also remain in groundwater at concentrations above cleanup levels. Additional characterization will be performed at the LLRC to address non-CERCLA contaminants in soil and groundwater. In the interim, LUCs have achieved the Remedial Action Objective (RAO) to limit exposures to petroleum-contaminated soil and groundwater at LLRC and will remain in place until soil and groundwater concentrations of petroleum hydrocarbons are documented to be below the ADEC Method Two Migration to Groundwater soil and groundwater cleanup levels, respectively.

All immediate threats from the site have been addressed, and the non-CERCLA remedy at LLRC is protective of human health and the environment. Long-term, the non-CERCLA remedy is protective because LUCs are in place to limit potential exposures to contaminated soil and groundwater at the LLRC.

The cleanup at the LLRC is complete under CERCLA. Therefore, there is no statutory obligation to complete future FYRs for LLRC. However, the non-CERCLA remedy for petroleum hydrocarbons included FYRs until cleanup is complete under Alaska State regulations. Additional remedial activities are planned to address petroleum hydrocarbons and associated PAHs in soil, and petroleum hydrocarbons in groundwater at the site will be monitored by the U.S. Air Force (USAF) with oversight from ADEC. In the interim, the LUCs are in place and effective. The LUCs will remain in place until cleanup is complete under applicable Alaska State regulations.

Page ES-2 Lake Louise Recreation Camp – Site OT001 January 2016 2015 Five-Year Review Report – Final


SUMMARY FORM - 1

FIVE-YEAR REVIEW SUMMARY FORM

Site Identification

Site name: Lake Louise Recreation Camp (LLRC)

EPA ID: Not applicable

Region: 10 State: AK City/County: Lake Louise/Matanuska-Susitna Borough

Site Status

NPL status: Final Deleted Other (specify): not listed in NPL

Multiple OUs? YES NO Has the site achieved construction completion? No

Review Status

Lead agency: EPA State Tribe Other Federal Agency: U.S. Air Force (USAF) Author name: MWH Americas, Inc. on behalf of the Air Force Civil Engineer Center (AFCEC) Federal Project Manager: Lori Roy, USAF, AFCEC/CZOP Author affiliation: Contractor

Review period: 2 / 1 / 2014 to 8 / 31 / 2015

Date(s) of site inspection: 7 / 7 / 2014 to 7 / 9 / 2014

Type of review: Post-SARA Pre-SARA NPL-Removal only Non-NPL Remedial Action Site NPL State/Tribe-lead Regional Discretion

Review number: 1 (first) 2 (second) 3 (third) Other (specify)

Triggering action date (from WasteLAN): Not applicable

Due date (five years after triggering action date): June 2014

SUMMARY FORM - 2

FIVE-YEAR REVIEW SUMMARY FORM (continued)

Issues/Recommendations

A. Site OT001

Issue Category: Remedy Performance Description: Additional delineation is warranted to investigate potentially uncharacterized soil at the LLRC. Recommendation: The USAF should conduct additional soil characterization at the LLRC.

Affect Current Protectiveness

Affect Future Protectiveness

Implementing Party Oversight Party Milestone Date

N N USAF ADEC 2016

Issues/Recommendations

B. Site OT001

Issue Category: Remedy Performance/Monitoring Description: Groundwater monitoring results indicate that DRO concentrations are increasing in some wells and that the contaminant plume is unstable. Recommendation: The USAF should conduct an analysis to identify potential data gaps in groundwater contaminant delineation and investigate potential unaddressed groundwater source areas. Pending results of these actions, the USAF may need to evaluate potential remedial options for non-CERCLA contaminants in groundwater.

Affect Current Protectiveness

Affect Future Protectiveness

Implementing Party Oversight Party Milestone Date

N N USAF ADEC 2018

Protectiveness Statement All immediate threats from the site have been addressed, and the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) remedy at the LRCC is protective of human health and the environment. Long-term, the remedy is protective because impacted soil and potential sources have been removed from the site and post-excavation confirmation sampling has verified that residual CERCLA contaminant concentrations are below applicable soil cleanup levels. Cleanup of LLRC is complete under CERCLA. The remedy for non-CERCLA contaminants in soil and groundwater is in progress. All immediate threats from the site have been addressed, and the non-CERCLA remedy at LLRC is protective of human health and the environment. Additional remedial activities are planned to address residual petroleum hydrocarbons and associated polycyclic aromatic hydrocarbons (PAHs) in soil, and petroleum hydrocarbons in groundwater at the site will be monitored by the USAF with oversight from Alaska Department of Environmental Conservation (ADEC). In the interim, the land use controls (LUCs) are in place and effective. The LUCs will remain in place until cleanup is complete under applicable Alaska State regulations. Long-term, the non-CERCLA remedy is protective because LUCs are in place to limit potential exposures to contaminated soil and groundwater at the LLRC.

Lake Louise Recreation Camp – Site OT001 Page 1-1 2015 Five-Year Review Report – Final January 2016

1 INTRODUCTION The purpose of a Five-Year Review (FYR) is to determine whether the remedy at a site is protective of human health and the environment. The methods, findings, and conclusions of reviews are documented in FYR reports. In addition, FYR reports identify any issues found during the review and provide recommendations to address them. The U.S. Air Force (USAF) is preparing this FYR report pursuant to the Comprehensive Environmental Response, Compensation and Liability Act of 1980 (CERCLA) Section 121 and the National Contingency Plan (NCP). CERCLA Section 121 states:

“If the President selects a remedial action that results in any hazardous substances, pollutants, or contaminants remaining at the site, the President shall review such remedial action no less often than each five years after the initiation of such remedial action to assure that human health and the environment are being protected by the remedial action being implemented. In addition, if upon such review it is the judgment of the President that action is appropriate at such site in accordance with section [104] or [106], the President shall take or require such action. The President shall report to the Congress a list of facilities for which such review is required, the results of all such reviews, and any actions taken as a result of such reviews.”

The U.S. Environmental Protection Agency (EPA) interpreted this requirement further in the NCP; 40 Code of Federal Regulations (CFR) Section 300.430(f)(4)(ii) states:

“If a remedial action is selected that results in hazardous substances, pollutants, or contaminants remaining at the site above levels that allow for unlimited use and unrestricted exposure, the lead agency shall review such action no less often than every five years after the initiation of the selected remedial action.”

MWH Americas, Inc. (MWH) conducted the FYR of the remedy implemented at Environmental Restoration Program (ERP) Site OT001, also known as the Lake Louise Recreation Camp (LLRC), at Lake Louise, Alaska. MWH performed this FYR on behalf of the Air Force Civil Engineer Center (AFCEC) under Contract Number FA8903-08-D-8777, Task Order 0158. This FYR was conducted for LLRC from February 2014 through 31 August 2015. This report documents the results of the review. This report is the first FYR for LLRC. The triggering action for this statutory review of LLRC is the initiation of groundwater monitoring at the LLRC in June 2009. The FYR is required due to the fact that, at the time of the 2012 Record of Decision (ROD; USAF, 2012a), hazardous substances, pollutants, or contaminants remained on-site above levels that allowed for unlimited use and unrestricted exposure. The CERCLA chemicals or contaminants of concern (COCs) identified at the LLRC are polychlorinated biphenyls (PCBs), lead, and the polycyclic aromatic hydrocarbon (PAH) benzo(a)pyrene (BaP). Non-CERCLA COCs include petroleum-related compounds, primarily diesel range organics (DRO) and PAHs.

2 Lake Louise Recreation Camp – Site OT001 January 2016 2015 Five-Year Review Report – Final



2 SITE CHRONOLOGY The chronology of site events at LLRC is presented in Table 2-1.

Table 2-1 Chronology of Site Events

Event Date The USAF operated the LLRC as a recreational fishing and boating facility. 1955 to 1965

The buildings at the LLRC were demolished. 1971 An initial Preliminary Assessment/Site Investigation (PA/SI) was conducted at the LLRC. 1993

A Clean Sweep Environmental Survey was performed at the LLRC to inventory debris at the site. 2000

A Phase I Site Investigation (SI) was performed to assess the areas of interest (AOIs) at the LLRC. 2008

A Phase II SI and a Remedial Investigation/Feasibility Study (RI/FS), which included groundwater monitoring, was performed at the LLRC.

2009 to 2010

Additional solid waste removal was conducted at the LLRC under the USAF Clean Sweep Program. 2010

A Focused FS Report, which detailed the contaminant concentrations associated with each LLRC AOI, was issued. 2011

A Supplemental FS Report issued to address the CERCLA COCs identified at four of the LLRC AOIs. 2012

A groundwater monitoring report for the 2011 groundwater sampling conducted at the LLRC was issued. 2012

The Proposed Plan for ERP Activities at the LLRC was released for public comment and a public meeting was held. May 2012

The Record of Decision identifying a recommended remedy for the LLRC was released for public comment. May 2012

The Final Record of Decision, which identified the selected remedy for the LLRC, was finalized and approved. August 2012

The first phase of the remedial action was conducted. September to October 2012 The second phase of the remedial action was conducted. August to September 2013 The third phase of the remedial action was conducted. September to October 2014 Cleanup complete under CERCLA approved by the State of Alaska. 29 April 2015

Key: CERCLA – Comprehensive Environmental Response, Compensation, & Liability Act COC – chemical or contaminant of concern ERP – Environmental Restoration Program LLRC – Lake Louise Recreation Camp USAF – U.S. Air Force


3 BACKGROUND 3.1 Physical Characteristics LLRC is located in the Copper River Valley at an elevation of approximately 2,362 feet. The site is bound to the north by the foothills of the Alaska Range, the east by the Wrangell Mountains, the south by the Chugach Mountains, and the west by the Talkeetna Mountains (Figure 3-1). LLRC is 173 road miles northeast of Anchorage and 16 road miles north of the Glenn Highway at milepost 157 (USAF, 2012a). LLRC is located adjacent to the community of Lake Louise, which has an estimated population of 91. All buildings at LLRC were demolished or relocated in 1971 and only a few former foundations remain at the site (USAF, 2012a). 3.2 Land and Resource Use The USAF acquired LLRC in 1955 from the Bureau of Land Management (BLM) via Public Land Order (PLO) 1509. The USAF operated LLRC as a recreational fishing and boating facility from 1955 to 1965. The camp consisted of: a lodge, dining hall, airmen’s dormitory, boat house and fueling point, power plant, freshwater intake pump house, shower house, small sleeping cabins, and a picnic area (Appendix A, Figure 1-2). A gravel pit (quarry) was also located on the property, west of the camp area. There is also an airstrip at LLRC, which was presumably used by the USAF to access the site (USAF, 2012a). The USAF discontinued use of LLRC in 1965 after a March 1964 earthquake caused extensive damage to the property. The Lake Louise area is currently a designated State Recreation Area and is popular for boating, fishing, hunting, and snowmobiling. The USAF has no further use for the property and intends to relinquish it once cleanup is complete. The State of Alaska has applied (top-filed) to receive the property after it is relinquished by the federal government (USAF, 2012a). There is no current domestic use of groundwater at LLRC or the surrounding area. Groundwater at the LLRC mostly occurs in shallow (less than 5 feet below ground surface [bgs]), thin (less than 5 feet thick) layers above the permafrost. Based on drilling in 2009 and 2010, permafrost occurs at variable depths at LLRC, with the deepest permafrost (around 10 feet bgs) in the southwestern portion of the site, in the middle of the area known as the Tank Trailers Area. The shallow nature of the groundwater makes it susceptible to infiltration by bacteria. Based on the limited volume of water and the presumed poor quality of the water, the shallow groundwater beneath LLRC is not considered a drinking water source under 18 Alaska Administrative Code (AAC) 75.350 (USAF, 2012a). In 2010, the Alaska Department of Environmental Conservation (ADEC) approved a Section 350 determination that eliminated the migration-to-groundwater pathway from being a complete pathway at LLRC, provided surface waters are not impacted or threatened (USAF, 2012a).


Surface water occurs as seeps that flow intermittently in the southern portion of the site (east-southeast of the area known as the Tank Trailers Area). The surface seeps merge into a drainage that flows easterly alongside a gravel road (USAF, 2012a). 3.3 History of Contamination There is currently one designated USAF ERP site at Lake Louise, Site OT001, which covers an approximately 25-acre area and is also known as LLRC (Appendix A, Figure 1-2). There are no operable units at the site. Past activities at LLRC that may have potentially resulted in contaminant releases to the environment include the following:

• Fuel storage, including spills during the transfer of fuels in and out of storage tanks.

• Leaks from fuel lines, tanks, or drums.

• Equipment maintenance activities, including spills or leaks of fuel, lubricants, or solvents during these activities.

• Use of transformers.

• Use of PCB-amended paint and lead-based paint.

• Disposal of wastes and other debris containing hazardous substances. As detailed in the ROD (USAF, 2012a), environmental investigations have been conducted at LLRC since 1993, when a Preliminary Assessment (PA)/Site Inspection (SI) was conducted. The results of the PA/SI identified concrete foundations, a concrete generator pad, stained soil associated with petroleum hydrocarbons, miscellaneous building debris on the ground surface, and numerous 55-gallon drums at LLRC. In 2000, a Clean Sweep Environmental Survey was conducted at LLRC to inventory remaining debris, identify Areas of Interest (AOIs), and provide site recommendations. The survey identified approximately 136 cubic yards of concrete foundations, 16 empty 55-gallon drums, and one septic tank. No other issues or contaminants were noted or analyzed for during the 2000 Clean Sweep Environmental Survey (USAF, 2012a). A Phase I SI was performed in 2008 to further access LLRC AOIs. Thirteen AOIs were addressed during the Phase I SI (Appendix A, Figure 1-2). Based on the findings of the SI, the nine following AOIs were recommended for additional investigation:

• Drum and Debris Area • Power Plant and Buried Drum Area • Tank Trailers Area • Dining Hall Area Leach Field • Lodge Area Underground Storage Tanks (USTs) • Shower Area USTs • Off-Shore Debris in Lake Louise and Lake Dinty • Airstrip Debris Area


A Phase II SI and a Remedial Investigation (RI)/Feasibility Study (FS) were conducted in 2009 and 2010 to delineate contaminants identified during the SI activities and to evaluate remedial options. Groundwater samples were collected in June and October 2009 as part of the RI/FS. The RI/FS concluded that groundwater flow is limited at LLRC and that the limited groundwater flow hinders the migration potential of DRO to surface water. Also in 2010, additional solid waste was removed as part of building demolition and debris removal activities conducted under the USAF Clean Sweep Program. During the 2010 debris removal, multiple drums and assorted debris were noted in the Southeast Debris Area at the LLRC (USAF, 2013d). Table 3-1 summarizes the COCs that have been identified at LLRC. A chemical was considered a COC if it exceeded Method Two cleanup levels (where applicable) or one-tenth ADEC Method Two cleanup levels for the under 40-inch zone for soils or applicable screening criteria for groundwater, unless further evaluation indicated the contaminants posed little risk (USAF, 2012a). Although a number of analytes were reported to exceed the National Oceanic and Atmospheric Administration (NOAA) Screening Quick Reference Tables (SQuiRT) sediment screening criteria, Alaska does not have a framework for screening, assessment, and remediation of contaminated sediment (ADEC, 2013). Therefore, no COCs were identified for the Off-Shore Debris Area. The full list of applicable or relevant and appropriate requirements (ARARs) established for LLRC is detailed in the ROD (USAF, 2012a). 3.4 Initial Response There have not been any enforcement actions at the LLRC. Since 1971, the USAF has been working to remove solid waste and debris from the LLRC. In April 2012, the Proposed Plan identifying the USAF’s preferred remedy for the LLRC was made available to the public, starting the period for public comment. 3.5 Basis for Taking Action COCs in soil at LLRC were detected at concentrations exceeding ADEC cleanup levels for the under 40-inch zone. Cumulative risk calculations for the entire site indicated an excess human health cancer risk (7 x 10-5) and a non-carcinogenic hazard index (HI) of 1.1, which exceeds ADEC risk management standards (USAF, 2012a). The CERCLA COCs identified at LLRC do not degrade and, thus, could enter the food chain if no action was taken to reduce their soil concentrations. Therefore, a response action was determined to be necessary at LLRC to protect public health or welfare and the environment from actual or threatened releases of hazardous substances to the environment and to meet cleanup standards established by the State of Alaska (USAF, 2012a). The EPA has chosen to defer to ADEC for regulatory oversight of the ERP at LLRC.


Table 3-1 Summary of LLRC COCs and Applicable Cleanup Levels

COC

Maximum Concentration

Detected (mg/kg)

Frequency of

Detection

Applicable Cleanup Levela

Affected AOI(s)

Soil

Diesel Range Organicsb 110,000 131/131 10,250 mg/Kg Drum and Debris Area and Tank Trailers Area

Naphthaleneb 29 31/38 28 mg/Kg Tank Trailers Area

Benzo(a)pyrenec 1.3 20/38 0.49 mg/Kg Dining Hall Leach

Field Area and Shower Area USTs

1-Methylnaphthaleneb,c 130 24/38 28 mg/Kg Tank Trailers Area

2-Methylnaphthaleneb,c 34 31/38 28 mg/Kg Tank Trailers Area

Total PCBs (Aroclor 1254) 1.9 7/39 1 mg/Kg Power Plant Area

Lead 3,720 28/28 400 mg/Kg Lodge Area UST

Groundwater

Diesel Range Organicsb 13 45/45 1.5 mg/L Power Plant Area and Tank Trailers Area

1-Methylnaphthaleneb,c 0.045 11/16 0.15 mg/L Power Plant Area and Tank Trailers Area

2-Methylnaphthaleneb,c 0.049 9/16 0.15mg/L Power Plant Area and Tank Trailers Area

Key: a – Cleanup levels were established in the Record of Decision (USAF, 2012a) and consist of ADEC

Method Two Human Health cleanup levels for the under 40-inch zone for soil COCs and the 18 Alaska Administrative Code 75.341 Table C groundwater cleanup levels for groundwater COCs.

b – These non-CERCLA contaminants are being addressed under State of Alaska laws and regulations. c – These compounds are considered COCs because the maximum concentration detected exceeded

one-tenth the ADEC Method Two cleanup level and contributed to cumulative risk. ADEC – Alaska Department of Environmental Conservation AOI – Area of Interest CERCLA – Comprehensive Environmental Response, Compensation, & Liability Act COC – contaminant or chemical of concern mg/Kg – milligrams per kilogram mg/L – milligrams per liter PCB – polychlorinated biphenyl UST – underground storage tank


4 REMEDIAL ACTIONS 4.1 Remedy Selection The ROD for LLRC was signed in August 2012 (USAF, 2012a). The decision established by the ROD was in accordance with and in satisfaction of the requirements of the Defense Environmental Restoration Program (DERP) and applicable State and Federal regulations. Under CERCLA, the following RAOs were identified in the ROD for LLRC:

• Prevent human exposure to PCBs, lead, and BaP in soil exceeding 1 milligrams per kilogram (mg/Kg), 400 mg/Kg, and 0.49 mg/Kg, respectively.

• Prevent migration of PCBs, lead, and BaP to sensitive areas – such as wetlands and surface water.

Under Alaska State regulations, the following RAOs were identified in the ROD for petroleum hydrocarbons at LLRC:

• Prevent human exposure to DRO and PAHs in soil exceeding concentrations in 18 AAC 75.341(c) and (d) Table B1 and B2 (concentrations of 10,250 mg/Kg and 0.49 mg/Kg, respectively).

• Prevent migration of DRO and PAHs to sensitive areas – such as wetlands and surface water.

• Prevent exposure to DRO concentrations in groundwater exceeding the 18 AAC 75.345 Table C cleanup level of 1.5 milligrams per liter (mg/L).

The selected remedies for LLRC were: source removal and offsite disposal for CERCLA COCs in soil; excavation and offsite thermal treatment for petroleum-contaminated soil; land use controls (LUCs) for petroleum in soil and groundwater; and natural attenuation with monitoring for petroleum in groundwater (USAF, 2012a). The major components of the selected remedies are discussed below. Remedy under CERCLA:

• Soil with concentrations of CERCLA COCs (PCBs, lead, and BaP) exceeding ADEC Method Two Human Health cleanup levels for the under 40-inch zone will be shipped from LLRC to treatment or disposal facilities.

• PCB-contaminated soils with concentrations above 1 mg/kg will be transported off LLRC property and disposed of in accordance with the Off Site Rule (40 CFR 300.440).

Removal of the CERCLA COCs will result in achievement of ADEC risk management standards (cumulative carcinogenic risk at or below 1 x 10-5 and a cumulative non-carcinogenic HI at or below 1.0). Following these activities, cleanup will be complete under CERCLA.


Remedy for Petroleum Hydrocarbons under Alaska State Regulations

DRO-contaminated soil with concentrations exceeding the ADEC Method Two Human Health cleanup level for the under 40-inch zone (10,250 mg/Kg) will be excavated, transported, and thermally treated offsite at a permitted facility. For soil, a LUC in the form of a notation in the LLRC land records management plan will be put in place indicating that environmental contamination remains at the site above cleanup levels. Because soil will remain onsite with DRO concentrations between 250 mg/Kg and 10,250 mg/Kg, there will be restrictions on the movement of this soil until the DRO naturally attenuates to below 250 mg/Kg. The LUC will prevent the DRO-impacted soil from being moved and placed in environmentally sensitive areas, such as nearby wetlands, and potentially impacting water quality. Long-term monitoring will be conducted to assess DRO concentrations and to determine when the LUCs are no longer needed. DRO soil sampling will initially occur annually and the results of monitoring activities will be reported by the USAF to ADEC. At the first 5-year point, and each successive 5-year interval, a review will be conducted to evaluate the data. Based on the review, and with mutual agreement between ADEC and the USAF, the monitoring program may be modified accordingly, in terms of sample frequency. Concentrations of petroleum hydrocarbons (DRO) in groundwater will be allowed to degrade through natural attenuation. To prevent the possibility of exposure to DRO in groundwater during the attenuation period (to at or below the groundwater cleanup level of 1.5 mg/L), a LUC in the form of a deed notation will be put in place preventing the shallow groundwater from being used as a drinking water source. The installation of drinking water wells will be prohibited. Long-term monitoring will be conducted to assess groundwater concentrations and to determine when the LUCs are no longer needed. Initial groundwater sampling will verify DRO concentrations are steady state or decreasing. Groundwater sampling will initially occur annually. The USAF will report the results of the monitoring activities to ADEC. At the first 5-year point, and each successive 5-year interval, a review will be conducted to evaluate the data and determine if the remedy is effective or needs modification. Based on the review, and with mutual agreement between ADEC and the USAF, the monitoring program may be modified to revise the sample frequency and the number of wells being sampled. LUCs will apply to the entire LLRC (OT001) site. The USAF will be responsible for the implementation of LUCs (notice in LLRC land records management plan), along with any associated activities – including monitoring, enforcement, and reporting. The USAF will ensure, as appropriate, that any contractor or other authorized occupant of the property subject to LUCs is informed of the LUCs and is made subject to the requirements of the LUCs. The USAF will obtain ADEC concurrence for any changes to activities or restrictions and will provide prompt notification to ADEC of an LUC failure, along with a description of any corrective measures taken or planned. The USAF will provide prior notification to ADEC for the transfer of property associated with LUCs. The USAF may transfer procedural responsibilities to another party by contract, property transfer agreement, or through other means; however, the USAF will retain ultimate responsibility for remedy integrity.


Removal of the COCs was expected to result in achievement of ADEC risk management standards (cumulative carcinogenic risk at or below 1 x 10-5 and a cumulative non-carcinogenic HI at or below 1.0). The ROD stated that, following the soil removal activities, cleanup would be complete under CERCLA and 18 AAC 75 for CERCLA COCs. For petroleum hydrocarbon COCs, the site status would change to Cleanup Complete with LUCs under 18 AAC 75 when no further monitoring was necessary for soil and groundwater. The ROD reported that LUCs would be removed in the future when petroleum hydrocarbon concentrations in soil and groundwater attenuated below the ADEC Method Two Migration-to-Groundwater soil and groundwater cleanup levels, respectively (USAF, 2012a). The ROD identified the USAF as the responsible party for administering all necessary remedial actions, including LUCs at LLRC (USAF, 2012a). 4.2 Remedy Implementation The Remedial Action (RA) at LLRC was conducted in accordance with the ROD (USAF, 2012a). The RA was conducted in three phases to date, and a fourth phase is planned for 2015. The first phase, which was conducted from September to October 2012, included soil and debris removal and investigative sediment sampling (USAF, 2012c, 2013c, and 2013d). The second phase of the RA was performed at LLRC from August to September 2013 (USAF, 2014a) and included the removal of drums and debris from the Off-Shore Debris Area (Lake Louise and Lake Dinty) and the excavation of additional soil from the Shower Area septic system and the former Tank Trailers Area (USAF, 2014a). The third phase, which was conducted from September to October 2014, included removal of a large, partially-buried storage tank from the Off-Shore Debris Area and additional soil excavation at the Tank Trailers Area, and the report on these activities is under review by ADEC and has not been finalized (USAF, 2015a). The major components of the RA were as follows, summarized by area of the LLRC (Appendix A, Figure 1-2):

1. Dining Hall Leach Field Area – Excavation and disposal of BaP-contaminated soil; initiated and completed in 2012.

2. Lodge Area USTs – Excavation and disposal of lead-impacted soil and disposal of the upper septic tank, which had been removed in 2010 and staged at the LLRC; initiated and completed in 2012.

3. Shower Area USTs – Excavation and disposal of BaP-impacted soil; initiated in 2012 and completed in 2013.

4. Power Plant Area – Excavation and disposal of PCB-impacted soil and disposal of a PCB-impacted concrete slab and an engine generator block, which had been removed in 2010 and staged at the LLRC; initiated and completed in 2012. However, concentrations of DRO in groundwater remain above applicable cleanup levels.

5. Drum and Debris Area – Excavation of DRO-contaminated soil for offsite thermal treatment and removal of all visible, surficial debris and approximately 1.5 tons of contaminated soil associated with the debris; initiated and completed in 2012

6. Tank Trailers Area – Excavation of DRO-contaminated soil for offsite thermal treatment; initiated in 2012 and continued in 2013 and 2014. The RA is not complete at the Tank Trailers Area. Residual non-CERCLA contaminants remain at the excavation


sidewalls abutting a gravel, public access road and along the eastern portion of the Tank Trailers Area (USAF, 2015a). In addition, concentrations of DRO in groundwater remain above applicable cleanup levels.

7. Off-Shore Debris Area – Investigative sediment sampling; characterization of potential impacts from the drums; and removal of approximately 2 tons of decayed drums, tires, and assorted metal debris from the near-shore water of Lake Louise and Lake Dinty; initiated in 2012, continued in 2013, and completed in 2014. All inventoried drums and debris were removed, including a large (approximately 1,500 to 2,000-gallon), partially-buried storage tank (USAF, 2015a).

The RA has been fully implemented at all areas of LLRC, except the Tank Trailers Area. An additional RA is planned to address the non-CERCLA contaminants that remain in soil at LLRC. However, the PAHs detected are methylnaphthalenes, which are components of petroleum products. The residual PAHs and DRO contamination in soil at the Tank Trailers Area and DRO contamination in groundwater at the Tank Trailers Area and the Power Plant Area are, therefore, considered non-CERCLA contaminants. The cleanup of the LLRC under CERCLA is complete. The soil sampling to monitor DRO concentrations included as part of the remedy for non-CERCLA contaminant in soil has not yet been initiated. The monitoring of DRO concentrations in soil will be initiated once the RA for the non-CERCLA contaminants that remain in soil at the Tank Trailers Area is complete. Groundwater monitoring in accordance with the remedy for non-CERCLA contaminants in groundwater was initiated in 2009. The results of the groundwater sampling are discussed in Section 6.4. The LLRC remedy also includes a deed notation and LUCs to limit exposures to petroleum-contaminated soil and groundwater at the LLRC. The deed notation on the LLRC property has been filed with PRSC Real Estate Section (L. Roy, personal communication, 28 December 2015). In July 2015, the USAF issued the Land Use Control Management Plan for the Pacific Air Forces Regional Support Center Installation (USAF, 2015b), which includes the LLRC. The Management Plan identifies that there are LUCs in effect at Site OT001 at LLRC. The LUC boundary figure from the 2015 Management Plan is provided in Appendix B. Also included in Appendix B are the relevant portions of the LUC Management Plan Table 2-1, which describes the LUCs that are in effect at Site OT001 (USAF, 2015b). 4.3 System Operation/Operations and Maintenance There were no operations and maintenance (O&M) activities identified in the ROD (USAF, 2012a) that were associated with the selected remedies at LLRC. However, the annual groundwater monitoring specified in the ROD could be considered O&M. Ms. Lori Roy, Remedial Project Manager for the USAF, AFCEC/CZOP, estimates that the annual O&M costs for the first 5 years are approximately $197,000 per year (personal communication, 19 March 2015).


5 PROGRESS SINCE THE LAST REVIEW This is the first FYR for the LLRC (ERP Site OT001).


6 FIVE-YEAR REVIEW PROCESS 6.1 Administrative Components The LLRC FYR team was led by Ms. Lori Roy, Remedial Project Manager for the USAF, AFCEC/CZOP, and included AFCEC, MWH, and ADEC staff with expertise in site investigation and remediation. The review team established the FYR schedule, which included the following components:

• Community involvement. • Document review. • Data review. • Site inspection. • Local interviews. • FYR Report development and review.

The schedule extended through August 2015. 6.2 Community Involvement Activities to involve the community in the FYR were initiated with a notice published in the local newspaper [The Valdez Star] on 3 September 2014 (Appendix C). The public notice regarding the FYR was also submitted via email on 26 August 2014 to representatives from the following local entities:

• Lake Louise Lodge, the largest gathering place on the lake; • Native Village of Kluti-Kaah; • Native Village of Tazlina; • Copper River Native Association; and • Lake Louise Community Non-profit Corporation.

Members of the community were invited to submit any issues or concerns regarding the LLRC cleanup program to Ms. Lori Roy, the USAF Remedial Project Manager, by 15 October 2014. However, no responses were received from members of the community. A Restoration Advisory Board (RAB) has not been established for LLRC. The USAF supports establishing an RAB at each installation where there is sufficient and sustained community interest. In 2001, the community declined the opportunity to establish an RAB and has not expressed interest in establishing an RAB for the LLRC in the subsequent years (USAF, 1997, 2001, and 2008).


6.3 Document Review This FYR consisted of a review of relevant documents, including groundwater monitoring data. The ROD (USAF, 2012a) served as the source document for the RAOs. In addition, the following documents and records were reviewed:

• Final 2011 Groundwater Monitoring Report (USAF, 2012b).

• Final Sampling and Analysis Plan for the Remedial Action at Lake Louise Recreation Camp, Lake Louise, Alaska (USAF, 2012c).

• Final Lake Louise Recreation Camp Work Plan, 2013 Environmental Long Term Management and Remedial Action-Operations at Multiple 611 Civil Engineering Squadron Locations. (USAF, 2013a).

• Final Work Plan Addendum No. 1 for the Remedial Action at Lake Louise Recreation Camp, Lake Louise, Alaska (USAF, 2013b).

• Final Supplemental Work Plan, Groundwater Monitoring at Site OT001, Lake Louise Recreation Camp (USAF, 2014b).

• Final Groundwater Monitoring Report, Environmental Long Term Management, Lake Louise Recreation Camp (USAF, 2015c).

An Administrative Record has been established for the LLRC by the USAF and was reviewed as part of this FYR. The Administrative Record contains information that has been used to support USAF decision-making and is available to the public in the AFCEC/CZOP offices on Joint Base Elmendorf/Richardson and online (http://afcec.publicadmin-record.us.af.mil/Search.aspx). 6.4 Data Review Groundwater data from 2009, 2010, 2012, 2013, and 2014 were reviewed as part of the FYR (USAF, 2012b and 2015c). Groundwater data were also collected in 2015 but are outside the scope of this FYR and will be included in the next FYR. The monitoring wells at LLRC are located in vicinity of the Tank Trailers and Power Plant Areas (Appendix D, Figure 3). The primary purpose of the annual groundwater sampling is to determine the concentration of DRO in groundwater at LLRC and to evaluate trends by comparing data with historical results (USAF, 2012b). The annual groundwater samples were analyzed for DRO and PAHs. In 2014, the samples were also analyzed for Monitored Natural Attenuation (MNA) parameters (USAF, 2014b and 2015c). A one-time MNA assessment for site groundwater was a requirement of the LLRC ROD (USAF, 2014b). In 2014, PAHs were detected in groundwater, but all concentrations were below the ADEC Groundwater Cleanup Level established for these constituents. DRO results from 2014 indicate that concentrations exceed ADEC Groundwater Cleanup Levels in eight of the 10 groundwater wells. Table 6-1 summarizes the 2014 and historical DRO concentrations in groundwater at LLRC.

http://afcec.publicadmin-record.us.af.mil/Search.aspx


Table 6-1 DRO Concentrations in Groundwater – 2014 and Historical

Sample Location

DRO Concentration (µg/L) Spring 2009 Fall 2009 Fall 2010 Fall 2011 Fall 2013 Summer 2014

Power Plant Area MW01 2,800 3,100 5,600 8,500 2,130 5,220 MW02 4,800 6,700 6,100 8,000 11,900 10,900 MW03 6,500 5,200 4,700 7,100 15,700 NS MW04 510 340 260 270 541 430 MW05 NS 2,200 2,200 2,600 1,270 4,730 MW06 NS 3,300 4,900 NS NS 582

Tank Trailers Area MW07 NS 13,000 4,900 7,200 17,600 54,400 MW08 NS 1,100 NS NS 1,730 1,860 MW09 NS 600 490 410 136 NS MW15 NS 8,200 4,500 5,300 2,970 2,900 MW17 NS NS 6,500 6,900 4,820 1,850 MW19 NS NS 2,500 NS NS 1,840

Source: USAF, 2015c. Key: µg/L – micrograms per liter DRO – diesel range organics NS – not sampled Bold – Exceedance of Alaska Department of Environmental Conservation Table C, Groundwater

Cleanup Level for DRO of 1,500 µg/L. A comparison of LLRC groundwater data from 2009 through 2014 indicated an inconclusive trend overall in DRO concentrations (USAF, 2015c). DRO concentrations over time have been decreasing in some wells and increasing in other wells, indicating an unstable contaminant plume. An increasing trend was observed in five of the ten wells analyzed, indicating an overall advancing contaminant plume and suggesting that natural attenuation rates are less than the existing contaminant plume’s contribution of dissolved concentrations of DRO to LLRC groundwater (USAF, 2015c). The results indicate that the LLRC contaminant plume may be in an advancing state in the vicinity of four wells (MW01, MW02, MW05, MW07, and MW08) (USAF, 2015c).

Previous studies indicated that natural attenuation of the petroleum hydrocarbons in LLRC groundwater would be particularly slow due to the conditions at the site. The results of the 2014 MNA assessment analyses confirmed these prior studies (USAF, 2015c). Site conditions affecting natural attenuation rates include cold subsurface temperatures and limited groundwater flow, which reduces dispersion and groundwater recharge. In the Tank Trailers Area of LLRC, the plume appears to be confined by a suspected thaw bulb and free product was detected in


2010 and 2011. The free product may serve as a continued source for dissolved phase hydrocarbons; however, no measureable free product was observed in 2014 (USAF, 2015c). No new or previously undetected potentially toxic or mobile transformation products have been identified during sampling events; therefore, all detected contaminants have cleanup goals as specified in the ROD (USAF, 2012a). 6.5 Site Inspection A site inspection was performed at the LLRC from 7 through 9 July 2014 as part of the annual groundwater LTM work at the site. Details of the site inspection were included in the Final Lake Louise Recreation Camp Groundwater Monitoring Report (USAF, 2015c). The site inspection focused on the monitoring wells throughout Site OT001 and included an evaluation of the general site conditions in the Power Plant Area and the Tank Trailer Area at LLRC. There were no issues identified at the LLRC during the site inspection. The photo documentation from the report is provided in Appendix E. The results of the site inspection confirmed that there were no changes in land use at the LLRC and there was no evidence of unauthorized access to the site or use of site groundwater (USAF, 2015c). LUCs were evaluated by examining the LUC Management Plan (USAF, 2015b), as described in Section 4.2. The LUCs are in place and are functioning as intended. Ms. Lori Roy, Remedial Project Manager for the USAF, AFCEC/CZOP, confirmed that the deed notation on the LLRC property has been filed with PRSC Real Estate Section (L. Roy, personal communication, 28 December 2015). 6.6 Interviews Interviews were conducted with various parties connected to LLRC, which does not have a facility manager, because it is an inactive site. Therefore, an interview was conducted on 29 December 2014 with Ms. Lori Roy, Remedial Project Manager for the USAF, AFCEC/CZOP. An interview was also conducted on 22 December 2014 with Ms. Meredith Savage, Project Manager for ADEC. The complete interview records are provided in Appendix F, and the interviews are summarized below. Ms. Savage and Ms. Roy both indicated the remedy at LLRC is functioning as intended. Neither Ms. Savage nor Ms. Roy was aware of any issues or incidents at the site or knew of any complaints filed in relation to the site. Ms. Roy stated that the remedy for LLRC was fully implemented during the 2014 field season and that all components of the remedy were in place.


7 TECHNICAL ASSESSMENT 7.1 Technical Assessment Questions 7.1.1 Question A: Is the remedy functioning as intended by the decision documents? The selected remedy for the LLRC was designed to address CERCLA contaminants in soil and non-CERCLA contaminants in soil and groundwater at the site. The review of documents, ARARs, risk assumptions, and the results of the site inspection indicate that the CERCLA remedy is complete. The RA at LLRC successfully reduced residual concentrations of COCs in soil to concentrations below the ADEC Method Two Human Health cleanup levels for the under 40-inch zone. Although PAHs remain in soil at the Tank Trailers Area of the LLRC, the detected methylnaphthalenes are components of petroleum products. Therefore, the results of the soil removal activities indicate that the cleanup of the LLRC is complete under CERCLA. Non-CERCLA contaminants remain in soil at the LLRC at concentrations above cleanup criteria, but an additional RA is planned to address these contaminants. However, further characterization is required before the additional RA can be performed. ADEC has expressed concern that there is potentially uncharacterized contaminated soil at the LLRC and has recommended that additional sampling be conducted at the LLRC. In the interim, LUCs are in place to prevent movement of the soil or its placement in environmentally sensitive areas. The remedy for non-CERCLA contaminants in soil is in progress and the USAF will continue implementing remedial actions in accordance with the ROD and with oversight by ADEC. As another part of the non-CERCLA remedy, the ROD stated that the first 5 years of groundwater sampling would verify if DRO concentrations are steady state or decreasing. However, the monitoring results indicate that DRO concentrations are increasing in some wells and that the contaminant plume is unstable. ADEC has expressed concern that increasing contaminant concentrations in groundwater may indicate unaddressed source areas. The non-CERCLA groundwater remedy is in progress and the USAF will continue implementing remedial actions in accordance with the ROD and with oversight by ADEC. The LUCs have achieved the RAO to limit exposures to petroleum-contaminated soil and groundwater at LLRC and will remain in place until soil and groundwater concentrations of petroleum hydrocarbons are below the ADEC Method Two Migration-to-Groundwater soil and groundwater cleanup levels. No activities were observed that would have violated the LUCs for soil or groundwater. There are no issues that would place the protectiveness of the remedy at risk. There were no opportunities for system optimization observed during this FYR. The monitoring well network provides sufficient data to assess the progress of natural attenuation and evaluate plume stability at the LLRC.


7.1.2 Question B: Are the exposure assumptions, toxicity data, cleanup levels, and RAOs used at the time of the remedy still valid?

The conceptual exposure model included in the ROD (USAF, 2012a) identified soil, air, sediments, surface water, and biota as exposure media at LLRC. Numerous exposure pathways were evaluated, and incidental ingestion and dermal absorption of contaminants were considered the most likely exposure pathways. There have been no changes in the physical conditions of the site that would affect the protectiveness of the remedy. Changes in Standards

As the remedial excavations have been completed at LLRC, the ARARs for CERCLA soil contaminants cited in the ROD have been met. There have been no changes to the standards for the CERCLA COCs at the LLRC. There have been no changes to the standards for the non-CERCLA COCs at the LLRC. The ARARs for petroleum hydrocarbons and associated PAHs in soil and petroleum hydrocarbons in groundwater have not been met; however, implementation of the non-CERCLA remedy is in progress. There have been no changes to the ARARs for LLRC and there are no new standards affecting the protectiveness of the remedy. Changes in Exposure Pathways, Toxicity, and Other Contaminant Characteristics

Prior to the 2012 ROD, ADEC approved a Section 350 determination that eliminated the migration-to-groundwater pathway from being a complete pathway at LLRC, provided surface waters are not impacted or threatened (USAF, 2012a). There have been no identified impacts to surface waters at LLRC; therefore, there are no changes to the exposure pathways at the site. In addition, there have been no changes in the toxicity factors for the COCs that were included in the baseline risk assessment. There has been no change to the standardized risk assessment methodology that could affect the protectiveness of the remedy. The remedy for CERCLA contaminants in soil progressed as expected and cleanup is now complete under CERCLA. The remedy for non-CERCLA contaminants in soil and groundwater is in progress. 7.1.3 Question C: Has any other information come to light that could call into question the

protectiveness of the remedy? The soil excavations were performed, as specified in the ROD, and post-excavation confirmation samples verified that residual soil concentrations of CERCLA COCs are below applicable cleanup standards. Therefore, there is no information that calls into question the protectiveness of the CERCLA remedy. Regarding the remedy for non-CERCLA contaminants, ADEC has indicated that additional characterization is required in soil and that there may be unaddressed source areas causing

7-3

increases in DRO concentrations in groundwater. Free product was detected in one groundwater monitoring well (MW-8) in 2010 and 2011, but was not observed in 2014. LTM will continue at the LLRC to assess contaminant movement and plume stability over time and monitor for free product. There is no other information that calls into question the protectiveness of the non-CERCLA remedy. 7.2 Technical Assessment Summary Based on the data reviewed, the site inspection, and the interviews, the CERCLA remedy at LLRC is complete. There have been no changes in the physical conditions of the site that would affect the protectiveness of the CERCLA remedy. The ARARs identified for the CERCLA soil contaminants in the ROD have been met, and the cleanup of LLRC is complete under CERCLA. There is no information that calls into question the protectiveness of the CERCLA remedy. The remedy for non-CERCLA contaminants in soil and groundwater is in progress. Further characterization of non-CERCLA soil COCs is required, and an additional RA is planned to address potential source areas at the LLRC. Groundwater monitoring results indicate increasing contaminant concentrations and an unstable contaminant plume. The USAF will continue implementing remedial actions in accordance with the ROD and with oversight by ADEC. In the interim, the LUCs have achieved the RAO to limit exposures to petroleum-contaminated soil and groundwater at LLRC and will remain in place until soil and groundwater concentrations of petroleum hydrocarbons are below the ADEC Method Two Migration-to-Groundwater soil and groundwater cleanup levels. There have been no changes in the physical conditions of the site that would affect the protectiveness of the non-CERCLA remedy. There have been no changes in the toxicity factors for the non-CERCLA COCs that were used in the LLRC baseline risk assessment, and there have been no changes to the standardized risk assessment methodology that could affect the protectiveness of the remedy. There have been no other changes in the exposure assumptions and no new contaminants have been identified at LLRC. However, additional characterization activities are required to investigate non-CERCLA contaminants in soil and groundwater at the LLRC. There is no other information that calls into question the protectiveness of the non-CERCLA remedy.


8 ISSUES There are no issues related to site conditions or activities at LLRC that currently prevent the remedy from being protective. The CERCLA remedy is complete, but the non-CERCLA remedy is in progress. Although additional characterization activities are required to investigate non-CERCLA contaminants at the LLRC, the LUCs that are in place to prevent exposures to contaminated soil and groundwater maintain the protectiveness of the non-CERCLA remedy at the LLRC.


9 RECOMMENDATIONS AND FOLLOW-UP ACTIONS Table 9-1 summarizes the recommended follow-up actions for LLRC. There are no recommended improvements for LLRC.

Table 9-1 Recommended Follow-up Actions for LLRC

Issue Recommendations and Follow-up Actions

Party Responsible

Oversight Agency

Milestone Date

Affects Protectiveness

(Y/N) Current Future

Additional delineation is warranted to investigate potentially uncharacterized soil at the LLRC.

The USAF should conduct additional soil characterization at the LLRC.

USAF ADEC 2016 N N

Groundwater monitoring results indicate that DRO concentrations are increasing in some wells and that the contaminant plume is unstable.

The USAF should conduct an analysis to identify potential data gaps in groundwater contaminant delineation and investigate potential unaddressed groundwater source areas. Pending results of these actions, the USAF may need to evaluate potential remedial options for non-CERCLA contaminants in groundwater.

USAF ADEC 2018 N N

Key: ADEC – Alaska Department of Environmental Conservation CERCLA – Comprehensive Environmental Response, Compensation, and Liability Act DRO – diesel range organics LLRC – Lake Louise Recreation Camp N – no Y – yes


10 PROTECTIVENESS STATEMENT The selected remedy for the LLRC was designed to address CERCLA contaminants in soil and non-CERCLA contaminants in soil and groundwater at the site. All immediate threats from the site have been addressed, and the CERCLA remedy at LLRC is protective of human health and the environment. Long-term, the CERCLA remedy is protective because impacted soil and potential sources have been removed from the site and post-excavation confirmation sampling has verified that residual CERCLA contaminant concentrations are below applicable soil cleanup levels. Cleanup of LLRC is complete under CERCLA. The remedy for non-CERCLA contaminants in soil and groundwater is in progress. All immediate threats from the site have been addressed, and the non-CERCLA remedy at LLRC is protective of human health and the environment. An additional RA is planned to address residual petroleum hydrocarbons and associated PAHs in soil, and petroleum hydrocarbons in groundwater at the site will be monitored by the USAF with oversight from ADEC. LUCs are in place and effective and will remain until petroleum hydrocarbon concentrations in soil and groundwater are documented to be below the applicable cleanup levels. Long-term, the non-CERCLA remedy is protective because LUCs are in place to limit potential exposures to contaminated soil and groundwater at the LLRC. The USAF certifies that the remedy for LLRC (ERP Site OT001) is protective of human health and the environment and complies with Federal and State requirements that are legally applicable or relevant and appropriate.

SUZANNE W. BILBREY, P.E., GS-15 Date Director, Environmental Management Directorate


11 NEXT REVIEW The cleanup of LLRC is complete under CERCLA. Therefore, there is no statutory obligation under CERCLA to complete future FYRs for the LLRC (ERP Site OT001). However, the non-CERCLA remedy for petroleum hydrocarbons in soil and groundwater included FYRs until cleanup is complete under Alaska State regulations. The next FYR will be completed 5 years after the date of this FYR.


12 REFERENCES Alaska Department of Environmental Conservation (ADEC), 2013. Technical Memorandum:

Sediment Quality Guidelines (SQG). January.

U.S. Air Force (USAF). 1997. Final Management Action Plan, Lake Louise Recreation Camp, Alaska. November.

USAF, 2001. Management Action Plan, Lake Louise Recreation Camp, Alaska. December.

USAF, 2008. Lake Louise Recreation Camp, Alaska, Site Investigation, Phase 1 Report. December.

USAF, 2012a. Final Record of Decision, Lake Louise Recreation Camp (OT001), LLRC, Alaska. August.

USAF, 2012b. Lake Louise Recreation Camp, Alaska, Environmental Restoration Program, Final 2011 Groundwater Monitoring Report. January.

USAF, 2012c. Final Sampling and Analysis Plan for the Remedial Action at Lake Louise Recreation Camp, Lake Louise, Alaska. September.

USAF, 2013a. Final Lake Louise Recreation Camp Work Plan, 2013 Environmental Long Term Management and Remedial Action-Operations at Multiple 611 Civil Engineering Squadron Locations.

USAF, 2013b. Final Work Plan Addendum No. 1 for the Remedial Action at Lake Louise Recreation Camp, Lake Louise, Alaska. August.

USAF, 2013c. Final Remedial Action Report, Lake Louise, Alaska. December.

USAF, 2013d. Final Cleanup Report for the Southeast Debris Area, Lake Louise Recreation Camp, Lake Louise, Alaska. August.

USAF, 2014a. Final Lake Debris and Soil Removal Report. March.

USAF, 2014b. Final Supplemental Work Plan, Groundwater Monitoring at Site OT001, Lake Louise Recreation Camp. May.

USAF, 2015a. Draft 2014 Cleanup Activities Report, Lake Louise Recreation Camp (in review). January.

USAF, 2015b. Land Use Control Management Plan, Pacific Air Forces Regional Support Center Installations. July.

USAF, 2015c. Final Groundwater Monitoring Report, Environmental Long Term Management, Lake Louise Recreation Camp. January.

U.S. Environmental Protection Agency (USEPA), 2011. Recommended Evaluation of Institutional Controls: Supplement to the “Comprehensive Five-Year Review Guidance,” OSWER Directive 9355.7-18. September.

APPENDIX A

Site Figure from the LLRC Record of Decision, August 2012

APPENDIX B

Land Use Control Boundary Figure and Descriptions from the Land Use Control Management Plan, July 2015

TABLE 2-1 Description of Land Use Control Types Currently in Effect at Pacific Regional Support Center Environmental Restoration Program Sites Land Use Control Management Plan 2015, Pacific Air Forces Regional Support Center Installations, Joint Base Elmendorf-Richardson, Alaska

Installation: IRP Site(s) with LUCs

in Effect1 Purpose and Objectives Prohibitions/Restrictions Engineered

Elements Expected Durations Monitoring/ Inspections/ Reporting/ Maintenance Administrative Elements

Lake Louise Rec Camp OT001

Prevent unacceptable and/or significant risk to human health, safety, or welfare, or the environment

For soil, an LUC in the form of a notation in the LLRC land records management plan will be put in place indicating that environmental contamination remains at the site above ADEC cleanup levels. Because soil will remain onsite with DRO between 250 mg/Kg and 10,250 mg/Kg, there will still be restrictions to the movement of this soil until the DRO naturally attenuates to below 250 mg/Kg. For groundwater, an LUC in the form of a deed notation will be put in place stating that the shallow groundwater should not be used as a drinking water source and the installation of drinking water wells will be prohibited. DRO in groundwater will be allowed to attenuate naturally and long term monitoring will be conducted to assess groundwater concentrations and to determine when the LUCs are no longer needed.

• (None specified) Until DRO in soil naturally attenuates to below 250 mg/kg and until DRO and PAH concentrations naturally attenuate in groundwater below the ADEC cleanup levels.

• DRO soil sampling will initially occur annually. The USAF will report the results of monitoring activities to the ADEC. At the first five year point, and each successive five year interval, a review will be conducted to evaluate the data.

• Long term monitoring of groundwater will be conducted annually. At the first five year point, and each successive five year interval, a review will be conducted to evaluate the data and determine if the remedy is effective or needs modification.

• LUCs will apply to the entire OT001 site. The USAF will be responsible for the implementation of LUCs (notations in LLRC land records management plan), along with any associated activities including monitoring, enforcement, and reporting.

• The USAF will ensure, as appropriate that any contractor or other authorized occupant of the property subject to LUCs is informed of the LUCs and is made subject to the requirements of the LUCs.

• The USAF will obtain ADEC concurrence for any changes to activities or restrictions and will provide prompt notification to ADEC of an LUC failure, along with a description of any corrective measures taken or planned.

• The USAF will provide prior notification to ADEC for the transfer of property associated with LUCs. The USAF may transfer procedural responsibilities to another party by contract, property transfer agreement, or through other means; however, the USAF shall retain ultimate responsibility for remedy integrity.

• The USAF will record an LUC in the form of a deed notation will be put in place preventing the shallow groundwater from being used as a drinking water source.

Naknek Recreation Camp 1: OT032, LF003, SS004, ST001

Ensure no exposure pathways exist to the contamination at Rapids Camp.

Concentrations of petroleum hydrocarbons (DRO) in the groundwater will be allowed to degrade through natural attenuation. •To prevent the possibility of exposure to DRO in the groundwater during the period of natural attenuation (to at or below the groundwater cleanup level of 1.5 mg/L), an LUC in the form of a deed notation will be put in place preventing the shallow groundwater from being used as a drinking water source.

• (None specified) Until field and analytical data support the conclusion that contamination levels remain below ADEC 18 AAC 75 Table C groundwater cleanup levels (determined during a Five• Year Review).

Annual groundwater monitoring Landfill cap inspection and maintenance. Five-Year Reviews

Include exact areas of LUCs in survey data. If land transfer occurs, USAF will retain right of entry for monitoring purposes or investigating any additional (newly discovered) contamination. LUCs enforced through General Plan and orders, as necessary, from the Commander of the King Salmon Air Station.

Naknek Recreation Camp 2: LF001 SS004, SS005

Prevent drinking of groundwater contaminated above 18AAC 75.345. Ensure proper management of soil contaminated above Method Two Cleanup levels

• No installation of water supply wells • No excavation without proper soil

and waste management plan

• (None specified) (None specified) • Periodic visual inspections will be conducted to verify effectiveness of LUCs.

• Notice that soil exceeds ADEC Method Two cleanup levels protective of unrestricted use

• LUCs documented in King Salmon Base General Plan and with District Recorder for King Salmon Area; King Salmon Base General Plan to include a map of the LUC locations

• USAF to coordinate with ADEC regarding any changes to LUCs, land use, and activities that might disrupt effectiveness of LUCs.

• USAF dig permit and construction review system to restrict incompatible activities from the sites

• Property transfer to require USAF right of entry to continue site monitoring, transfer documents to include description of remaining contamination, and would be require ADEC approval.

Nikolski: OT001 (TU019 included administratively)

• Protect the public health or welfare or the environment from actual or threatened releases of hazardous substances into the environment

• Prevent exposure to non• CERCLA COCs remaining in place after implementation of the selected remedy

• Reduce human or environmental exposure to contamination, and prevent activities that may result in increased exposure or spread the extent of contamination

• No surface excavations or digging without ADEC approval

• Area not to be used for residential purposes

(None specified) The ICs will remain in effect indefinitely or until the COCs at OT001 are below applicable 18 AAC 75 cleanup levels, at which point the ICs can be eliminated with the approval of ADEC in accordance with 18 AAC 75.375(f).

• USAF will conduct Five-Year Reviews of the remedy since substances will remain onsite at levels above applicable State of Alaska cleanup levels specified in 18 AAC 75. These Five-Year Reviews will also report on the effectiveness of the ICs. Reviews may become more frequent if conditions change.

• USAF will also provide a monitoring report to ADEC every 5 years after each monitoring event.

• All surface excavation or digging activities within Tract 37C are subject to ADEC approval as may be required by State of Alaska regulations [e.g., 18 AAC 75.325(i)]

• The ICs established by the State of Alaska regulations will remain in effect indefinitely or until the COCs at OT001 are below applicable 18 AAC 75 cleanup levels, at which point the ICs can be eliminated with the approval of ADEC in accordance with 18 AAC 75.375(f).

• If the site remedy is found to be deficient during an inspection, ADEC will be contacted and further corrective action will be planned. ADEC will be notified if the property subject to ICs is transferred or if any significant changes are made to the use and activity restrictions of the ICs.

• • • •

• • • •

Installation: IRP Site(s) with LUCs

in Effect1 Purpose and Objectives Prohibitions/Restrictions Engineered

Elements Expected Durations Monitoring/ Inspections/ Reporting/ Maintenance Administrative Elements

Nikolski: WP007 • Protect the public health or welfare or the environment from actual or threatened releases of hazardous substances into the environment

• Limit the use of those areas of the site that have contamination remaining in place

• Reduce human or environmental exposure to contamination, and prevent activities that may result in increased exposure or spread the extent of contamination

• No surface excavations or digging without ADEC approval

• Area not to be used for long• term residential purposes

• No residential use or occupancy within Tract 37C in excess of 33 days per year by any one individual (40 CFR 761.3)

(None specified) The ICs will remain in effect indefinitely or until the COCs at WP007 are below applicable 18 AAC 75 cleanup levels, at which point the ICs can be eliminated with the approval of ADEC in accordance with 18 AAC 75.375(f).

• USAF will conduct Five-Year Reviews of the remedy since substances will remain onsite at levels above applicable State of Alaska cleanup levels specified in 18 AAC 75. These Five-Year Reviews will also report on the effectiveness of the ICs. Reviews may become more frequent if conditions change.

• USAF will also provide a monitoring report to ADEC every 5 years after each monitoring event.

• All surface excavation or digging activities within Tract 37C are subject to ADEC approval as may be required by State of Alaska regulations [e.g., 18 AAC 75.325(i)].

• The ICs established by the State of Alaska regulations will remain in effect indefinitely or until the COCs at WP007 are below applicable 18 AAC 75 cleanup levels, at which point the ICs can be eliminated with the approval of ADEC in accordance with 18 AAC 75.375(f)

• If the site remedy is found to be deficient during an inspection, ADEC will be contacted and further corrective action will be planned. ADEC will be notified if the property subject to ICs is transferred or if any significant changes are made to the use and activity restrictions of the ICs.

Nikolski: SS006 (Former Drum Storage Area)

• Protect public health or welfare or the environment from actual or threatened releases of hazardous substances into the environment

• Limit the use of those areas of the site that have contamination remaining in place

• Reduce human or environmental exposure to soil and groundwater contamination, and prevent activities that may result in increased exposure or spread the extent of contamination

No residential use. No excavation without prior ADEC approval.

Fence The ICs will remain in effect indefinitely or until the COCs at SS006 are below applicable 18 AAC 75 cleanup levels, at which point the ICs can be eliminated with the approval of ADEC in accordance with 18 AAC 75.375(f).

Annual monitoring until TCE and breakdown products are in steady state or decreasing for three consecutive monitoring events. Conduct 5-year reviews. Maintain fence.

• Conduct 5-year reviews. • All surface excavation or digging activities within Tract 39A are subject to ADEC

approval as may be required by State of Alaska regulations [e.g., 18 AAC 75.325(i)],2008.

• The ICs established by the State of Alaska regulations will remain in effect indefinitely or until the COCs at SS06 are below applicable 18 AAC 75 cleanup levels, at which point the ICs can be eliminated with the approval of ADEC in accordance with 18 AAC 75.375(f)

Nikolski: ST017 • Limit the use of and exposure to surface water down slope from ST017 that is contaminated with TCE in excess of 5.0 ug/L

• Protect the public health or welfare or the environment from historic releases of hazardous substances into the environment

No use of surface water downgradient of ST017 for drinking water until TCE concentrations are below 5.0 ug/liters

Signs warning individuals against use of the seep area down slope of site ST017 as a drinking water source.

• The ICs would remain in effect indefinitely or until such time the COC (TCE) levels are below the applicable MCL (5.0 micrograms/Liter)

• The signage will remain in place until the TCE concentration falls below the MCL (5.0 ug/L).

• Long• term surface water monitoring on adjacent Chaluka Corporation property every five years, starting in 2012

• Five-Year Reviews (which will report on the effectiveness of the ICs as well as the level of TCE remaining in the surface water)

• IC monitoring reports prepared periodically and submitted to ADEC

• (None specified)

Russia

Canada ALASK

!A Lake Louise Recreation Area

$ 0 300 600

Miles

Lake Louise

OT001

Lake Dinty

Excavation and digging restrictions Restrictions on groundwater use and/or disposal Existing structure Demolished structure Installation boundary

Notes: 1. LUC = Land Use Control. LUC boundaries depicted on

this figure are preliminary pending final analysis of survey information. LUC boundaries will be updated once this information is available.

2. Data from 611th GeoBase for Lake Louise Rec Camp. Geo-

3. Data are rendered in UTM Zone 6N, WGS84, Meters. 4. For more detailed land use restriction information, see

individual site summaries.

$ 0 250 500

Feet

FIGURE 2-20 Installation Map - Lake Louise Recreation Camp Land Use Control Management Plan 2015 Pacific Air Forces Regional Support Center lnstallations Joint Base Elmendorf-Richardson, Alaska

R:\AFCEC 611THASG\TO370\MAPFILES\LAKELOUISE.MXD RGRABAREK 3/6/2015 4:37:04 PM

APPENDIX C

Community Involvement Materials

APPENDIX D

Groundwater Sample Location Map from the 2014 Groundwater Monitoring Report, January 2015

APPENDIX E

2014 Site Inspection Photographs from the 2014 Groundwater Monitoring Report, January 2015

Lake Louise Recreation Camp Groundwater Monitoring Report

FA8903-10-D-8593; CDRL A001C

January 2015 1

Photo 1: Well MW01, July 2014

Photo 2: Well MW02 secured with new replacement lock, July 20143


FA8903-10-D-8593; CDRL A001C

January 2015 2




FA8903-10-D-8593; CDRL A001C

January 2015 3

Photo 5: Well MW07 secured with new lock, July 2014

Photo 6: Well MW08 with casing above stick-up, July 2014


FA8903-10-D-8593; CDRL A001C

January 2015 4

Photo 7: Well MW09 during purge process, July 2014

Photo 8: Well MW15 during headspace analysis, July 2014


FA8903-10-D-8593; CDRL A001C

January 2015 5




FA8903-10-D-8593; CDRL A001C

January 2015 6

Photo 11: Power Plant Area, from the center facing east, with MW04 in background

Photo 12: Power Plant Area, from the center facing north


FA8903-10-D-8593; CDRL A001C

January 2015 7

Photo 13: Power Plant Area, from the center facing west

Photo 14: Power Plant Area, near to MW02 facing south


FA8903-10-D-8593; CDRL A001C

January 2015 8

Photo 15: Power Plant Area with MW01 in background

Photo 16: Tank Trailer Area from west, facing southeast, with MW07 in background


FA8903-10-D-8593; CDRL A001C

January 2015 9

Photo 17: Tank Trailer Area visible standing water, free of apparent sheen

Photo 18: Tank Trailer Area facing north from access road

APPENDIX F

Interview Records

Interview Questions for the Project Manager Site OT001 (Lake Louise Recreation Camp)

1. Was the second phase of the remedial action (removal of drums from the Off-Shore

Debris Area [Lake Louise and Lake Dinty] and excavation of additional soil frm the Shower Area septic system and the former Tank Trailers Area) completed during the 2014 field season or earlier? If so, are there any components of the remedy that have not yet been implemented?

2. Is the report regarding the second phase of the remedial action available? Can we obtain a copy of the report?

3. Is the 2013 groundwater monitoring report for the LLRC available? Can we obtain a copy of the report?

4. The Site OT001 remedy includes Land use controls (LUCs). For soils impacted by petroleum hydrocarbons, an LUC in the form of a notation in the LLRC land records management plan to restrict movement of this soil is required. For groundwater, an LUC in the form of a deed notation preventing the shallow groundwater from being used as a drinking water source is required. Can you provide documentation showing that these LUCs are in place and information regarding the dates that these LUCs were established?

5. Could you provide estimated costs for the annual soil and groundwater monitoring performed at Site OT001?

6. Is the remedy at Site OT001 functioning as expected?

7. Do you know of any problems or difficulties that have been encountered which have impacted remedy implementation or progress at Site OT001?

8. Have any problems been encountered which required, or will require, changes to the OT001 ROD?

9. Are you aware of any community concerns regarding this site or implementation of its remedy? If so, please give details.

10. Are you aware of any events, incidents, or activities at the site such as vandalism, trespassing, or emergency responses from local authorities? If so, please give details.

11. Do you have any general comments, suggestions, or recommendations regarding the management of this site, remedy implementation, or ongoing work at the site?

first five-year review report for site 22

Documents