JBA_ORC_Site_Visit_Presentation_30Jul19.pdf

Warfighters Supporting Warfighters!

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Air Force Installation & Mission Support CenterAir Force Installation & Mission Support Center

JB ANDREWS

ENVIRONMENTAL

RESTORATION PROGRAM

OVERVIEW

William K. Burris, PG

AFCEC/CZOE

30 July 2019

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Welcome

On behalf of the Air Force Civil Engineer Center, Air Force District of Washington, and Joint Base

Andrews, the Home of Air Force One!

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Your Host

Air Force Material Command Air Force Installation Management Support Center

Air Force Civil Engineer Center Environmental Directorate

Environmental Operations East JBLE/JBA/Dover Installation Support Section Environmental Restoration Program Manger

William K. Burris, PG aka… just Bill

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The AGENDA

Part A: Introduction

Part B: Regulatory Considerations and Issues at JB Andrews

Part C: Logistical Challenges of Working at JB Andrews

Part D: JB Andrews Administrative Record & GFI

Part E: Overview and Status of JB Andrews Environmental Sites

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Part A: Introduction

Who is here?

USACE Remarks

ERP mission

Caveats and disclaimers

Installation Overview

Site List

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Who is here?

USAF / AFCEC

USACE

Regulators

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USACE Baltimore District

Remarks from the Corps

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JB ANDREWS ERP

JB Andrews ERP operates under the following:

1) Protect Human Health and Safety

2) Support the Mission

3) Effective Stewardship of Taxpayer Dollars

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Caveats and Disclaimers

Everything presented here today is based on our most up to date understanding of scope of the project, timelines, current acquisition strategy, etc.

All information must still be considered provisional until a final RFP is released.

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Andrews Overview Facility Assets Valued at over $660 Millon Over 4,400 Total Acres (not incl. Remote Sites) Over 380 Bldgs (minus housing) over 6M sq ft 111 miles of roadways

21.8M sq ft of airfield pavements

Approx. 2,900 Residents (2010 Census)

Over 14,000 uniformed and civilian employees

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History of JB Andrews

Camp Springs Air Base was established in Sept. 1942 and the runways became operational in May 1943. Renamed Andrews Field in

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History of JB Andrews

Used to train Pilots on P-47 Thunderbolt

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Andrews AFB rebuilt in late 1950s early 1960s

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ERP Overview

2 National Priority Listed (NPL) Sites:

JB Andrews Brandywine DRMO

32 sites at JBA in Federal Facility Agreement (FFA)

71 Sites total

34 Sites Closed

1 LTM

11 Sites Active Remediation 25 Sites various stages of investigation ranging from RI to no action closeout

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Andrews Sites

Andrews has been in operation since 1943. As expected with over half a century of functioning as a active air base, there have been several releases of contamination into the environment.

These sites fall into several broad catagories:

Spill Sites – Landfills – LUST – Fire Training Areas

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ORC site list

ORC Site List SS-01 Brandywine DRMO

FT-02

LF-05

LF-06/LF-07/BLNA (Monitoring Only)

ST-08

ST-10

SS-11 Davidsonville

ST-14

SS-22

SS-26

SS-28

TU-167

LF-581/SWMU-66

INCLUDED MMRP SITES

FI-346

RR-004

RR-348

SR-347/A

TS345/A

ZZ349/A

Where is Brandywine DRMO? SS-01

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Where is Davidsonville, SS-11?

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Part B

Regulatory Considerations and Issues at Joint Base Andrews

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Part B

JB Andrews Regulatory Status

CERCLA and the JB Andrews Federal Facility Agreement

Document Review Times

Records of Decision

Challenging Regulatory Issues

Maryland Department of Environment Oil Control Program

QAPPs

Questions

… and a finally your second break

… again you are welcome.

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JB Andrews Regulatory Status

JB Andrews in on the NPL – with Federal Facility Agreement (FFA)

Brandywine DRMO is on the NPL – Separate listing and FFA

Davidsonville is NOT on the NPL – State regulated cleanup

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CERCLA/ NON-CERCLA

Two kinds of sites

CERCLA – Subject to the FFA No Permits, that includes wells.

RI must be based on high quality defensible data.

Still have to meet Applicable Requirements (ARARs).

Includes Sediment and Erosion control.

Non-CERCLA: Petroleum only. Regulated by the Maryland Department of Environment Oil Control Program. (ST-08/SS-22) Need well permits.

If Remediation system is in place than applicable permits are required.

If removal occurs then Sediment & Erosion Control / Storm water permits may be required.

SS-11 is State regulated cleanup under Federal Facility Program.

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Wells

Wells in Maryland!

If applicable well permits are filed with County.

Well abandonment requires rig mobilization.

No stick up wells in the Airfield.

Two inch wells are fine now.

WELL DATA MUST BE PROVIDED TO ERPIMS!

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ERPIMS

AFCEC manages the USAF Environmental Resources Program Information Management System (ERPIMS).

https://www.afcec.af.mil/What-We- Do/Environment/Restoration/ERPIMS/

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Code of Maryland REgulations

Sediment & Erosion Control / Storm water Management

On USAF property these plans are reviewed by the state. There is no County Grading Permit process for work on USAF property.

Where will you need these? Excavations.

Plan on working with an expeditor.

Budget for Super Silt Fence.

https://mde.maryland.gov/programs/Water/StormwaterManagementP rogram/Pages/erosionsedimentcontrol.aspx

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Our Regulatory Partners

P.G County Health Department

Maryland Department of Environment Federal Facilities is the key department Oil Control is the exception

Environmental Protection Agency, Region III

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Review Times

Ignore the FFA review times.

Working Copy to USAF and USACE for review. We are pretty good at turning these around in about 30 days… at least until lately…

Once RTCs have cleared then the document can be submitted to regulators. Expect EPA comments in 45 to 75 days (the current record is over a year).

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Review Times

EPA comments can be very challenging to reconcile. You may need to work with USAF in doing so. Some will actually require USAF response (like PFAS related comments)

Maybe say… another 45 days to reconcile RTCs. Then the document can go final… if it made it through OPSEC & Policy Review.

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But wait… there’s more!

ESDs, RACRs, FS, PPs, and RODs require USAF legal review. This typically takes 21 days.

ESDs, RACRs, PPs, and RODs require EPA legal review. This is typically 60 days.

Any changes made by EPA must be rerun by USAF legal!

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Typical FS if there are no major issues

Working Copy – USAF/ USACE review 4 weeks

Revise per comments 1 week

Back check/resolution by USAF /USACE 2 weeks

USAF Legal review 3 weeks

Revise/receive USAF legal approval 3 weeks

Regulator Review of Draft 8 weeks

Revise per regulator comment/USAF approval 4 weeks

USAF legal check/approval 2 weeks

Regulator review/approve responses 4 weeks

Draft Final OPSEC & Policy Review 1 week

Finalize Total 32 weeks after initial submittal

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There will be a slight delay.

ESDs, RACRs, and RODs need USAF signatures.

4 to 6 months!

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Records of Decision

JB Andrews RODs are highly prescriptive.

Almost any change in a remedy will likely require an ESD.

Keep in mind how long an ESD will take to get in place if you are proposing a change in a remedy to save in life cycle costs, or establish an alternative approach.

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Emerging Contaminants

PFOS/PFOA

1,4 Dioxane

Impact on Investigation Derived Waste?

No central USAF policy… yet… Current JB Andrews Policy… manage as unregulated waste unless the IDW was generated specifically for sampling for PFAS.

This policy may change in the future.

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MDE Oil Control Program

We have two sites in the ORC managed by MDE Oil Control.

CERCLA process and approach are NOT applicable.

MDE will close a site based on qualitative risk.

MARYLAND ENVIRONMENTAL ASSESSMENT TECHNOLOGY for

LEAKING UNDERGROUND STORAGE TANKS

Yes that is the MEAT Guidance:

https://mde.maryland.gov/programs/LAND/Documents/MEAT%20Guidance% 20Document%20Rev%20Email%207%2017%20%2713.pdf

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MDE Oil Control Program

MDE Site Closure No Source No Free Product (just sheen or preferably less) No One Drinking It Levels Trending Down

In USAF program MDE site closure is equivalent to RC. The site cannot be SC until you reach UU/UE.

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QAPPS

We have agreement from the regulators that there can be one basewide UFP Quality Assurance Program Plan (QAPP) for the contract…

… kind of sort of….

Each project/site needs a QAPP specific to each project. Wherever possible it should refer to the basewide QAPP to limit the size and review time.

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Labs

Laboratories

DOD ELAP labs only for the CERCLA sites https://www.denix.osd.mil/edqw/accreditation/home/dod-elap-fact-sheet/

OCP sites… we Prefer DOD ELAP but OCP does not care.

Standard OCP sampling MTBE, BTEX, TPH-GRO, TPH-DRO, Naphthalene

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Welcome to Part C

Logistical Challenges of Working at JB Andrews

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Part C

JB Andrews is hard to understand

Airfield logistics

Some Basewide Stuff for the ORC

… and a finally your third break

… and again you are welcome.

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Heads Up

Trying to get stuff done at JB Andrews is hard.

AFCEC staff and support contractors will try to assist in establishing and maintaining the needed lines of communication when attempting to get work done.

Sometimes they are even successful.

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Airfield Access

Flight line Access

Called Pathfinder for years…

Then changed to FLEX…

Then changed to RAB???

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Flight Line Access

Flight Line Badge Controlled Area – Favorable background check Restricted Area – Secret Clearance (Interim will suffice) Presidential Areas – Just not going to happen

NO I CANNOT SHOW A MAP!

Airfield Driver… CAC Card Network Access

T-1 NAC (6 to 9 months if not more) 3 to 4 weeks to get account set up

On line training Practical training day Practical training night

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Tangent

ORC sites that are at least in part in the Controlled Movement Area

ST-10

LF-06

MMRP Sites

SS-22

TU-167

(maybe? The contamination is not yet delineated and it may extend into a restricted area)

ORC sites that are at least in part within the Restricted Area

FT-02

ST-14

SS-26

ORC Sites that are at least in part within Presidential Areas

SS-28

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Construction Escort

Air field Driver

Trained on security protocols, markings

Trained to use radio and talk to the tower

Keeps all workers within required distance

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Temporary Airfield Construction Waiver

Need to get a…

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Temporary Air Field Construction Waiver

Need to submit a request to the FAA

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Temporary Air Field Construction Waiver

Need to generate a Operational Risk Assessment

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Temporary Air Field Construction Waiver

Then you need to meet with airfield ops and all impacted parties to determine when and how to get the work done?

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During the ops meeting

You will have to work with these guys

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During the ops meeting

… and these guys.

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And some other things

Air Field Construction Barriers

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What else did 8a2 learn

FOD

Ramp Freezes

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Concrete?

Airfield concrete is 18 to 24 inches thick with plenty of rebar.

Need a FOD box around the coring system.

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Patching Holes

Must use Set-45 quick setting concrete… absolutely no cold mix asphalt patch.

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Ready yet?

No now it’s time for dig permits.

Roughly two weeks

Must be walked around

Comm is long pole in this tent

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Dig Permit

In the past the best strategy to do RI type work has been to use Triad approach with screening data to delineate plumes and select well installation locations.

Use well data to support the Human Health Risk Assessment.

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Day of Drilling

Problems with Drill Crew getting access?

Outstanding warrant?

Real ID Act?

Moving airfield construction barriers

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ERPIMS

All the data has to be submitted to ERPIMS.

This includes GIS location and sample depths.

These packages are NOT easy to assemble and submit.

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Regulatory Review

EPA has at least three reviewers. RPM, Hydrogeologist, and Toxicologist.

Review typically lasts 45 - 75 days.

MDE Review is shorter

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Typical issues

Vapor Intrusion?

Find the source?

Collect samples from the top of the Calvert Formation?

Is the Plume completely delineated?

Another mobilization?

Elevated metals like arsenic with no real idea where it came from?

Speciate chromium?

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Basewide Issues for the ORC

The ORC contractor will need to…

Support the Tier I team Facility Facilitator Record Keeping Coordinate the Agenda

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Basewide Issues for the ORC

The ORC contractor will need to…

Update the Community Involvement Plans Every Two years Complete Restoration Advisory Board Surveys per DERP manual

We don’t have RABs.

Update Community Involvement Plans There are three JBA, Brandywine, Davidsonville

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Basewide Issues for the ORC

The ORC contractor will need to…

Update the Installation Conceptual Site Model.

Annual update of installation Groundwater Level Map

Includes annual water level sampling across the installation monitoring network

Update CSM with new boring / well data every two years Annual update GIS / ERP maps

Transmit GIS layers to Installation GeoBase group Print hard copy maps for distribution to ERP and base Civil Engineer Squadron Use

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Basewide Issues for the ORC

The ORC contractor will need to…

Manage the Base wide Monitoring Well Network Remove unneeded wells.

Repair wells.

First Priority – Remove/replace stick up wells In the airfield!

More details on this will be provided in the RFP.

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Basewide Issues for the ORC

The ORC contractor will need to…

Support JB Andrews In Management of Administrative Record.

Ensure final documents are bookmarked pdf less than 25 mb in size.

Assist in categorizing and assigning metadata for final documents.

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Basewide Issues for the ORC

The ORC contractor will need to…

Develop Annual Land Use Control Reports This includes maintenance of existing land use control signs.

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Basewide Issues for the ORC

The ORC contractor will need to…

Support AFCEC in obtaining Real Estate Easements and Licenses of Entry on private property This means writing Environmental Baseline Surveys (EBS)

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Welcome to Part D

Navigating the JB Andrews Administrative Record

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Air Force Civil Engineer Center

Please type the website below into your browser to search and review public documents using the Public Administrative Record http://afcec.publicadmin-record.us.af.mil/

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Air Force Civil Engineer Center

•Welcome Page

•Click Here to enter site

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Air Force Civil Engineer Center

•Find Joint Base Andrews •Find Joint BaseAndrews 1.Select Active Duty

2.Scroll Down the Installation List to select ‘Joint Base Andrews, MD’

3. Click Search button

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Keep in Mind

Brandywine DRMO may be a separate CERCLA site. However it is listed as SS-01 in the Joint Base Andrews AR.

There is no separate Brandywine DRMO site on the installation list.

Davidsonville is also included as SS-11 with the rest of the JB Andrews sites.

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Air Force Civil Engineer Center

•Search Results

•Search results will be displayed here

•Click the magnifying glass in order to view the pdf of the document

•NOTE: Please see the following pages for directions on how to locate particular documents

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Air Force Civil Engineer Center

Search Tips

Joint Base Andrews has thousands of records. It is best to narrow your search by filling in a few of the fields to help limit the results. These search parameters are listed in order of usefulness:

AR Number Select a Site or Multiple Sites Subject or Title line Author Date range (Use MM/DD/YYYY) Recipient

The following pages of this guide will show you how to search the AR using the following methods:

Select a Site or Multiple Sites AR number

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Air Force Civil Engineer Center

•Specific Site Search Page •Find Specific Joint Base Andrews Sites 1.Scroll Down the Installation List to select ‘Joint Base Andrews, MD’

2.Select the associated Joint Base Andrews site from the ‘Sites’List •NOTE: To select multiple site use the ‘Shift’ or ‘Ctrl’ Key

3. Click Search button

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Air Force Civil Engineer Center

•Specific Site Search Page Results

•Search results will be displayed here

•Click the magnifying glass in order to view the pdf of the document

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Air Force Civil Engineer Center

•How to use the AR# to Find a Specific Document

1.Make sure Joint Base Andrews, MD is selected in the Installation List

2. Enter the provided •AR# here

3.Click Here to start the document search

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Air Force Civil Engineer Center

•AR# Search Page Results

•Search results will be displayed here

•Click the magnifying glass in order to view the pdf of the document

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Air Force Civil Engineer Center

•Viewing a Document You now have the option to SAVE

•the document to your local hard drive •or network drive.

You can also PRINT the document to your local or network printer.

Note: If the AR website is inactive for 10 minutes or more your browsing session will expire

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Air Force Civil Engineer Center

•Search Tips & Help Document •Click Here to review Help document and SearchTips

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Air Force Civil Engineer Center

For more information about the Joint Base Andrews Environmental Restoration Program, please visit the website below https://www.jba.af.mil/About-Us/Environmental- Mission/

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Government Furnished Information

Draft documents and documents not yet entered into the AR

Past Presentations

Regulatory meeting minutes

ERPIMS data (January 19 Data)

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Key Points Documents

Overview of the ORC objectives for each site.

Background for each site

Specific Details that must be considered in reaching the goal for each site.

Key documents list with specific AR#s

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Part E

Overview and Status of JB Andrews Environmental Sites

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Let’s Review

ORC Site List SS-01 Brandywine DRMO

FT-02

LF-05

LF-06/LF-07/BLNA (Monitoring Only)

ST-08

ST-10

SS-11 Davidsonville

ST-14

SS-22

SS-26

SS-28

TU-167

LF-581/SWMU-66

INCLUDED MMRP SITES

FI-346

RR-004

RR-348

SR-347/A

TS345/A

ZZ349/A

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Active Sites Not In the ORC

FT-03 and FT-04 (would be at SC except for PFAS)

LF-06/LF-07 (Final Remedy) (Monitoring is in the ORC)

SWMU-12 (RI is ongoing )

LF-34 (RI is just getting started)

LF-555 (RI is just getting started)

SA-507 (RI is ongoing)

SWMU-69 (stalled because of PFAS)

Yes these will be included in a future contracting effort.

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Andrews Geology

Andrews is located on a topographic plateau that feeds into five stream systems.

Andrews is located on the Upland Deposits. A mix of sand, silt, gravel, The Upland Deposits are underlain by the Calvert Formation. This thick clay “holds up” contamination.

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Andrews Geology

Release

In general releases into the subsurface ultimately migrate to the creeks.

Calvert Formation

Andrews Geology

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Brandywine DRMO SS-01

The following history is ridiculously condensed that it is essentially fiction.

Feel free to mine the AR for the long and painful history.

Where is Brandywine DRMO?

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In the town of Brandywine Maryland

8 Acre site

North Brandywine Rd

Next to CSX railroad

TRS ERH PROCESS

•Electricity is directed into the subsurface area.•TRS ERH PROCESS•TRS ERH PROCESS

•TRS Power Control Unit

•Electrical Resistance Heating•Electrical Resistance Heating

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Proposed Plan & Record of Decision

Proposed Plan Issued to Public in December 2016

Public Meeting on December 2016

Record of Decision – signed March 2018

System finally operational in April 2019

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ERH at Brandywine

• Treatment from 2‐37 ft bgs

• Original design included 65 sheet pile electrodes and 36 bored electrode pairs

• Modified during construction to address site constraints such as utilities/CSX requirements

• Two equipment compounds

• Vapor recovery

• 9 groundwater monitoring wells

• 17 temperature monitoring points

Site Plan

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SS-01 Expectations for the ORC

Achieve RA-O Essentially continues monitoring Easy yes?

Not really. You need to work with CSX to access most of the monitoring wells.

Reduce Lifecycle Costs What does that mean?

Remove wells from private property.

Support Real Estate activity – Generate Environmental Baseline Reports Demo the old pump and treat systems

Anything Else?

Maybe repave parts of Cherry Tree Crossing Road

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FT-02

The remedy is injections to support reductive bioremediation

Achieve RAO and Reduce LCCs.

Try to find ways to minimize mobilizations onto the airfield.

Check colony count specified in the ROD.

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LF-05

•Leroy’s Lane Landfill

-Operation from late 1950s until the late 1980s

- Received construction debris, sludge, solvent waste, municipal type waste, medical waste, underground storage tanks, and who knows what else

-Covers approximately 14 acres -The only site on Andrews where GW contamination has migrated off site.

LF-05

LF-05 1994 Aerial Photograph

GW Contamination

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Selected Remedy

Cap over the waste to eliminate infiltration of water.

Funnel and gate system to prevent contamination from migrating off-site.

Injections of substrate to treat off-site contamination

Cap

Funnel and Gate

Land Use Controls

Construction Dec 2010

LF-05: Completed Cap

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LF-05 Expectations for the ORC

Achieve RA-O and Reduce LCCs

What does that mean?

Maintain the Cap Maintain the Gates

Anything Else?

Work to limit the footprint of offsite LUCs as much as possible!

Remove as many offsite wells as possible.

There may be Real Estate Actions that require EBS.

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Southern Side of the Airfield

LF-6

LF-7

BLNA

Achieve IRA-O and RA-O

Essentially conduct monitoring per MDE Acceptance Variance from ARARs.

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Southern Side of the Airfield

MMRP Sites Removal of lead shot from

Skeet Ranges (less than an acre)

Lots of PP/RODs

ISSUES:

Milcon Construction!

Any disturbance of the earth 5000 Sf or greater, OR 100 CYs of cut or fill, requires MDE blessing of S&E plan.

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ST-08

Motor Pool Oil Control Site

Closed by MDE.

Considered RC by USAF but not

SC.

Recent Sampling found roughly 2 inches of product in one of the well.

Anticipate annual sampling with passive recovery.

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ST-10

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ST-10: Changing Standards

When ROD was signed (2005) the Risk Based Standard for Naphthalene was 18 ppb in groundwater.

We have reached that level in our clean up efforts.

However the current standard is 0.165 ppb in water.

We have not reached that level.

Now What?

Get the site to SC! UU/UE. It should be doable.

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SS-11

Located North of JB Andrews.

TCE Contaminated Groundwater

Not on the NPL

State regulated cleanup.

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SS-11

Contamination extends approx. 400 feet laterally from the source area.

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SS-11

Contamination extends to depth of 70 feet beneath the ground surface.

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SS-11

Bio-remediation by reductive dehalogenation

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Expectations for the ORC

Currently Achieve RA-O and Reduce LCCs

The current remedy is under evaluation.

Coordination is required to access portions of this site.

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ST-14

Started as a gas station investigation when… whoops what is this solvent doing here?

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2017 Plume Locations and bioremediation barriers

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The Big Issue:

EPA wants Vapor Intrusion Investigation of all buildings location within 100 feet of the plume.

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ST-14 ORC expectations

Achieve RA-O and achieve Revised CSM, Updated Groundwater Monitoring Program, Remedy Evaluation and Alternatives Analysis, and ESD or ROD Amendment

Vapor Intrusion must be addressed.

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SS-22

Jet fuel release.

Current contract goal is to reach regulatory site closure.

Site is messed up geology due to infinite utility cuts and fills and buried pavement and who knows.

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SS-22

2014 BTEX

Plume map

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SS-22 Issues

Dual Phase recovery system lowered water table and attempted to capture majority of LNAPL.

Dissolved plume is dramatically reduced in size.

Still no guarantee that the state will close the site.

Status for the ORC? Currently Achieve RA-O/LTM Currently envision monitoring.

The MDE OCP may require that the system be reactivated or request that further remedial action be conducted.

Yes this may change based on OCP regulatory status.

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SS-26

Chlorinated Solvents

Challenging work area

Natural interception trench?

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SS-26

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SS-26 Issues

Active portion of the airfield in midst of 113th ANG operations.

Bioremediation Remedy is installed.

We are still determining if we have reached RIP.

ORC goal will likely be achieve RAO with reduced LCCs.

ISSUES: A new pavement project is due to occur maybe right about the start time of the ORC.

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SS-28: Ever expanding plume

2009:

PA/SI Results

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SS-28: Final Results

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SS-28

Oh that’s where that came from.

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From the Proposed Plan SS-28

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SS-28 Issues

ORC Goal: Obtain RIP That means Remedial Design, Implementation, Operation.

PP final… ROD complete by October 2019?

EPA wants Vapor Intrusion Investigation

Portions of the site are in Presidential Areas and will require difficult coordination to access.

Airfield construction related to the new Presidential Hangar MilCon is starting now and may interfere with remedy implementation

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TU-167

Located between ST-14 and SS-22

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Location of TU-167

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Included as part with SS-22 (an OCP site)

PBR contractor took samples and found chlorinated solvents.

Site was disassociated from SS-22 and USAF funded a new site characterization study.

Site characterization study indicates presence of chlorinated solvents in 100 ppb range in groundwater near the Calvert.

LNAPL – waste oil in mass below the former waste oil UST.

Some Benzene hits scattered.

History of TU-167

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TU-167 VOCs

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Complete an RI, FS, PP, and ROD

The nature and extent of the chlorinated solvent contamination is not delineated.

We recommend you develop a phased approach to the RI.

Triad?

Expectations for TU-167

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LF-581

Also known as SWMU-66 and hardfill Area D-5

Discussed Earlier in Part B

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EM-61 Results

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ORC Status

Achieve SC

Currently the plan is to issue a No CERCLA Action FS/PP/ROD

Conduct removal under MDE regulatory oversite.

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FIRST BREAK

Whew… that was hard… Lunch Time?