September 24, 2015
Scott Baker
Aircraft Services International Group
8133 NE Air Trans Way
Portland, OR 97218
RE: Response to (DEQ) Review Letter of Summary Report dated July 20, 2015 and discussion of data needs for project closure.
ASIG Bulk Fuel Storage Facility, Portland International Airport. ECSI # 1832/5848
Dear Mr. Baker:
DEQ reviewed and has a number of comments on the following document written on your behalf by Advanced Remediation Technologies, Inc. (ART): Response to (DEQ) Review Letter of Summary Report, dated July 20, 2015. Comments are presented below for your consideration.
In a 2002 letter, DEQ provided the following concerns to be addressed at the Bulk Fuel Storage Facility:
• The Bulk Fuel Facility has not had a complete site characterization, preliminary assessment (PA) or DEQ-approved cleanup performed.
• There is inadequate data available to assess potential threats to surface waters or exposure to site/maintenance/utility workers from the remaining contamination.
• Our records indicate that there are still several areas on the site where jet fuel contamination remains from the pre-1989 pipeline release, the 1992 surface release and an underground storage tank release in 1995.
Following this 2002 letter from DEQ, groundwater was sampled from all nine monitoring wells in March 2003 but no additional site investigation work was performed until November 2012. The work performed by ART on November 26 and December 27, 2012 included: installation of thee direct push borings at the margin of the 10,000-gallon UST excavation and the collection of subsurface soil samples, groundwater monitoring and sampling from all nine site monitoring wells, surveying of relative wellhead elevations, and presentation of existing site data into a summary report submitted to DEQ. This 2012 fieldwork described in the March 2014 Summary Report was partially responsive to DEQ’s 2002 concerns.
Site Investigation/Cleanup History
What follows is DEQ’s understanding of the site investigation and cleanup history. Please add information to make this summary complete.
In 1989, six monitoring wells were installed around the periphery of the bulk fuel terminal to investigate the effects of a pre-1989 jet fuel release from an unknown source within the bulk plant. The source of the release was presumed to be associated with a fuel pipeline. A Corrective Action Plan was submitted to DEQ by Chevron Pipe Line Company dated December 20, 1990 recommending “passive cleanup” with semi-annual groundwater monitoring from 1991 through 1994. No pipeline repair, cleanup action, or spill volume was documented in the Corrective Action Plan.
In 1992, approximately 2000 gallons of jet fuel were released to the ground from a drain valve within the AST tank farm (ECSI #1832). Cleanup action in response to the surface release recovered 1250 gallons of jet fuel product, as well the removal of 600 cubic yards of contaminated soil from the site.
In 1995, during the decommissioning and removal of a 10,000-gallon UST, 196 tons of petroleum-contaminated soil was removed from the excavation (ART 2014). Additional monitoring wells and soil borings were installed in the vicinity of the UST excavation to investigate residual soil contamination and monitor groundwater quality.
In 1996, the DEQ Underground Storage Tank Program administratively transferred Bulk Fuel Storage Facility project responsibility to the DEQ Cleanup Program upon recognition of multiple releases at the facility in addition to the leaking UST (DEQ Memo dated February 28, 1996).
Groundwater from some, or all, of the site monitoring wells has been sampled and analyzed sporadically during the project. Groundwater quality has improved with time.
In 2012 ART installed thee direct push borings at the margin of the 10,000-gallon UST excavation and collected subsurface soil samples. 2012 fieldwork included groundwater monitoring and sampling from all nine site monitoring wells and presentation of site data into a brief summary report.
Wellhead elevation surveys were completed in 1989, 1990 and 2012.
Data Gaps that Prevent DEQ Consideration of No Further Action at This Time
• The nature and extent and locality of facility for the site resulting from the three fuel releases has not been determined with the exception of the former slop fuel UST release.
• The Summary Report does not provide a comprehensive environmental site history of fuel releases, spill responses, site investigations, cleanup actions, product recovery, DEQ involvement, environmental media affected, and residual product estimates remaining at the site resulting from pipeline leaks, UST releases, and surface releases.
• The nature and extent of jet fuel contamination at the Bulk Fuel Facility has not been defined, in particular in the down-gradient (westerly) direction. Soil and groundwater analytical data need to be screened against DEQ RBCs for occupational worker and excavation/construction workers as well as ecological (aquatic) risk-based screening values (if the drainage ditch west of the bulk plant is found to be within the Locality of Facility).
DEQ Process to Arrive a No Further Action determination
DEQ project managers are required to prepare a comprehensive site-specific Staff Report in support of a No Further Action determination. These Staff Reports are generally based on information submitted in a project summary report once site characterization, remediation work, and risk assessment work is complete. For the ASIG Bulk Plant site, the brief March 2015 summary document and the Ground Monitoring Reports from 1992 to 2002, provided to DEQ on CD, do not provide adequate information for DEQ to prepare a Staff Report.
Attachment A provides the outline the (minimum) information that is required of DEQ project managers to support of a No Further Action determination. Please refer to this outline and assist DEQ by providing adequate information in a revised Summary Report to support the requested NFA determination for the site.
Closing
Following completion of final site characterization work described above, DEQ requests a project meeting to discuss data gaps, compiling a comprehensive site history, planning and submittal of data to complete nature and extent evaluation, and preparation of a revised Summary Report adequate to support a no further action determination by DEQ.
I can be reached at (503) 229-6015 or Thiessen.Kenneth@deq.state.or.us to address questions.
Sincerely,
Kenneth Thiessen, CEG
DEQ Northwest Region
Distribution:
Lance Downs, ART
Stan Jones, Port of Portland
Keith Johnson, DEQ NWR
ECSI #1832/5848
References:
2014 ART, Summary Report of ASIG’s Bulk Fuel Storage Facility (and other projects) at the Portland International Airport. March 31, 2014.
2002 DEQ, Bulk Fuel Storage Facility Portland International Airport, Request for Expanded Preliminary Assessment. July 9, 2002.
1996 DEQ, Chevron Tank Farm –PDX/ASII USTC File No. 26-89-0012. Feb. 28, 1996.
1990 Chevron Pipe Line Company, Portland Airport, Corrective Action Plan. December 20, 1990.
Attachment A
Outline for DEQ Staff Memorandum in support of a No Further Action determination