Superfund Information Systems: Site Profile

Superfund Site:

PLATTSBURGH AIR FORCE BASE
PLATTSBURGH, NY

Cleanup Activities

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Background

The 3,440-acre former Plattsburgh Air Force Base is located in Plattsburgh, New York. The site is located in a mixed use area consisting of industrial and commercial enterprises, as well as private residences. It is bordered on the north by the Saranac River and the city of Plattsburgh, and on the south by the Salmon River. Lake Champlain, located east of the base, forms approximately one mile of the base boundary.

The base began operations in 1955 as a Tactical Wing under the Strategic Air Command of the United States Air Force. It continued operations under that mission until 1991, when it was reassigned as an Air Refueling Wing. The base closed under the Department of Defense (DoD) Base Realignment and Closure (BRAC) program in 1995. Prior to construction of the Air Force Base, the area occupied by the former base was used by various components of the U.S. military dating back to the Civil War. A history of the site is available on the Plattsburgh Airbase Redevelopment Corporation’s (PARC’s) website at http://www.parc-usa.com.

The site became contaminated as a result of the various activities conducted at an operating Air Force base. Hazardous wastes were generated from base activities including aircraft operation, testing and maintenance, firefighting exercises, the discharge of munitions, and landfill operations. Spills and releases of hazardous wastes from these activities contaminated groundwater, soil, surface water, and sediment at a number of areas at the base.  Cleanup has been ongoing since the 1980’s and is nearly complete. Under current conditions at the site, potential or actual human exposures are under control.

The EPA became involved with the site during the 1980’s after the Department of Defense (DoD) and other federal agencies and departments began examining the potential release of hazardous wastes at their facilities. Initial sampling conducted by the Air Force in 1987 revealed the presence of volatile organic compounds (VOCs) in shallow groundwater monitoring wells down-gradient of the base hazardous materials storage area. These results, as well as sampling results from a number of other areas at the base, caused the EPA to place the site on the Superfund Program’s National Priorities List in November 1989. A Federal Facilities Agreement (FFA) governing the identification, investigation, and cleanup of hazardous wastes at the base was signed by the Air Force, EPA, and the New York State Department of Environmental Conservation (NYSDEC) in 1991. Under this agreement, the Air Force conducts hazardous waste investigations and cleanups under its Installation Restoration Program (IRP) as the lead agency, with oversight of these activities conducted by EPA, NYSDEC, and more recently the New York State Department of Health (NYSDOH). 

 

 

 

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What Has Been Done to Clean Up the Site?

Unburned off-spec JP-4 jet fuel and waste solvents used during activities at the Fire Training Area have contaminated soil and groundwater, resulting in a ground water plume consisting of fuel-related compounds and chlorinated solvents. The chlorinated solvent portion of the plume extended across the base and was over one mile in length prior to the start of remedial activities, reaching within 2000 feet of Lake Champlain. The fuel-related portion extended approximately 2,500 ft. across the base. Four unlined landfills were utilized at the base during various periods of operation for disposal of household wastes and construction debris. Hazardous wastes may have been dumped in the landfills. Leachate from two of the landfills was found to be contaminated with volatile organic compounds (VOCs), including fuel-related compounds, and pesticides, and VOC contamination was detected in groundwater down-gradient of the landfills. Soil contaminated with DDT was found at the Defense Reutilization and Marketing Office (DRMO) storage/maintenance area, the result of leaking drums used to store pesticides at the site. Spillage of solvents used at the Building 2774 and Heavy Equipment Maintenance Facilities contaminated soil and groundwater with dichlorobenzene, trichloroethene (TCE) and other VOCs. The failure of an underground storage tank (UST) used to store waste solvents at the Nose Dock 8 Facility resulted in soil and groundwater contaminated with chlorinated solvents. Operations at a number of other sites at the former base produced additional areas of contamination.

Previous and ongoing investigation and cleanup efforts at the base protect human health and the environment in a number of ways. All areas of contamination have either already been cleaned up or have cleanup remedies (including institutional controls) in place.  Information on the actual remedies is found elsewhere in this site profile.

Since 1991, the EPA has conducted oversight of the investigation and, when required, cleanup, at over 60 sites at the base. The EPA has reviewed, provided comments on, and ultimately approved several hundred technical documents including Preliminary Assessments (PAs), Site Investigations (SIs), Remedial Investigations (RIs), Feasibility Studies (FS’s), Treatability Studies, and Removal Actions. This has also included review and approval of Records of Decision (RODs) for 20 major sites at the base known as Operable Units (OUs). RODs are issued by the Air Force in conjunction with the EPA and are signed by both agencies. NYSDEC issues a concurrence letter on each ROD, such that the agreement of all three agencies is required for a ROD to become final. The RODs are legal documents that memorialize the remedies set forth in Proposed Plans for each site that becomes an OU. The Proposed Plans, developed by the Air Force, with review and comment by the EPA and NYSDEC, are presented to the public with a comment period of 30 days at minimum, and require the approval of the EPA and NYSDEC prior to release to the public.

The EPA has also been responsible for review, comment on, and subsequent approval of all property lease and transfer documents for the former base. The BRAC program calls for the return of all base property to the local community in an expeditious manner, and is administered through a number of regulations, primarily CERCLA 120 h (3), which governs the transfer of federal property to outside parties. CERCLA 120 h (3) requires that all contaminated federal property be cleaned up prior to transfer, while allowing for exceptions if certain conditions are met.  This process began with the development by the Air Force of a Base-Wide Environmental Baseline Survey (EBS), which identified over 1200 environmental factors at the base which could affect the lease and/or transfer of various base properties. The EPA reviewed and commented on several versions of this document, which ultimately resulted in the identification of sites which could be leased and/or transferred outright, and those in need of additional investigation and/or cleanup prior to lease or transfer. Early in the base closure process, in order to expedite reuse by the community, most of the initial properties were leased. Prior to leasing a property, the Air Force developed documents called Findings of Suitability to Lease (FOSLs), along with associated property-specific Supplemental Environmental Baseline Surveys (SEBSs).  These documents required the review and approval of the EPA and NYSDEC prior to leasing of the property. Similarly, the Air Force later developed documents known as Findings of Suitability to Transfer (FOSTs), along with associated property-specific Supplemental Environmental Baseline Surveys (SEBSs). These documents also required the review and approval of EPA and NYSDEC prior to transfer of the property by the Air Force to outside parties. As much of the contamination at the base was cleaned up, only a small number of areas remained with contaminated property and final remedies not in place. The Air Force was able to transfer these properties through the early transfer process. This required the development of Finding of Suitability for Early Transfer (FOSETs), along with property-specific SEBSs and Covenant Deferral Requests (CDRs) by the Air Force. The EPA reviewed and commented on these documents, which ultimately required the approval of the EPA’s Regional Administrator, as well as the Governor of New York State, prior to those properties being transferred. These documents contain legally binding assurances made by the Air Force that the Air Force will continue the associated site cleanups until they are completed to the approval of the EPA and NYSDEC. They also contain restrictions in the form of institutional controls placed in the deed for transfer that will protect human health and the environment until site cleanup is complete.

All Air Force property at the former base intended for transfer to outside parties has already been transferred. Prior to the transfer of former Air Force property to outside parties, the Air Force had to place a covenant in the deed for transfer warranting that all necessary remedial actions had been taken prior to the date of transfer. The property investigation and transfer documents, along with the Air Force covenant, provide strong assurance to the public and new land owners that human health and the environment are protected. In the case of early transfers, the assurances made by the Air Force in the property deeds, along with the approval of the EPA’s Regional Administrator and the Governor of New York State, also provide strong assurance to the public and new land owners that human health and the environment are protected.

Land Use Controls / Institutional Controls (LUC/ICs) were placed in property deeds prior to transfer to outside parties for all sites where contamination remained at the time of transfer. These vary by site but can include restrictions on groundwater withdrawal and discharge, type of land use (e.g., restriction to non-residential uses), and any activities that would interfere with remedy operations, ICs related to Soil Vapor Intrusion (SVI), and the granting of access to the Air Force and regulatory agencies to sites where contamination still remains.  Compliance with LUC/ICs is ensured via annual inspections conducted by the Air Force. Land owners must also self-certify their compliance via a written checklist. The Air Force compiles the results of their inspections and the land owner’s self-certifications into annual LUC/IC Reports which are submitted to the regulatory agencies for review. Any violations are then addressed by the Air Force and regulatory agencies. LUC/ICs remain in place until properties are cleaned up, and can only be removed with the approval of the EPA and NYSDEC.  Additional ICs include access restrictions, e.g., fencing, locked gates, and signage. These are mainly used at areas where remedial systems are still operational, including the former base landfills and the Fire Training Area remedial systems.

With respect to any contamination to be found in the future at the former base, CERCLA 120 h (3) also requires that the covenant made by the Air Force in its deeds for transfer warrant that any additional remedial action found to be necessary after the date of transfer be conducted by the United States. Therefore, the Air Force retains responsibility for investigation of any additional contamination found, and for its cleanup if it is determined to be caused by the Air Force.

The EPA has also been responsible for review, comment on, and approval of Five-Year Reviews conducted by the Air Force for Plattsburgh AFB. These reviews are required under CERCLA every five years for sites at the base which are not yet suitable for unlimited use and unrestricted exposure, i.e. OUs which still have remedies in operation. Thus far, four of these reviews have been conducted, with the most recent Five-Year Review Report completed in November 2014. Based on comments and recommendations made by the EPA and incorporated by the Air Force into the reports, the EPA has approved the protectiveness of all remedial actions at the base.

Last, the EPA also reviews Operation and Maintenance (O and M) Reports submitted periodically by the Air Force for the operation of all remedial systems. This assists the Air Force in ensuring that the systems operate safely, properly, and efficiently.

 

 


 

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What Is the Current Site Status?

Nearly all of the hazardous waste sites at the base have already been cleaned up. Remedial Actions are still in full or partial operation at only five sites at the base. This includes the four base landfills, which were capped in the late 1990’s. Groundwater and surface water monitoring at and near the landfills is still conducted periodically, and the caps are inspected annually for their integrity.

The Fire Training Area (Site FT-002) / Industrial Area Groundwater Operable Unit systems are still partially in operation. These consist of a groundwater collection trench between the runway and flightline; five groundwater extraction wells located down gradient of the FT-002 Source OU (operation suspended); a groundwater treatment system to treat contaminated groundwater from the extraction wells and the runway / flighline collection trench (operation of the treatment system currently suspended); a groundwater collection trench located just east of the flightline whose discharge is treated by an aeration system; a groundwater collection trench located along Idaho Avenue; monitoring of groundwater discharged from all of the collection trenches; Soil Vapor Extraction (SVE) systems installed in Building 2753, Building 2766, and New Building C to address Soil Vapor Intrusion (SVI) underneath the buildings (operation of the systems at Buildings 2766 and New Building C currently suspended); other groundwater and surface water monitoring;  and Institutional Controls to prohibit the use of groundwater, restrict the discharge of groundwater, prohibit development that would interfere with remedial operations or penetrate the subsurface clay confining layer, limit current use and future property development to non-residential uses, and use restrictions related to soil vapor intrusion, including an occupancy restriction for Building 2612.

Current and upcoming work at the former base is largely associated with the investigation of Per and Polyfluoroalkyl Substances (PFAS).  PFAS are a major component of Aqueous Film-Forming Foam (AFFF), used and stored by the Air Force from 1970 until base closure for fire-fighting purposes. PFAS are not currently regulated under federal or New York State laws. As a result, previous investigations and cleanups at Plattsburgh did not include any work related to PFAS. Recent studies have linked PFAS to several types of cancer, including thyroid and kidney, however, and as a result EPA recently issued a Health Advisory Level (HAL) for 2 PFAS compounds in drinking water.  The two compounds are Perfluorooctanyl Sulfate (PFOS) and Perfluorooctanoic Acid (PFAS).  The EPA HAL is 70 parts per trillion (ppt) for total combined PFOS and PFOA in drinking water.

As AFFF was used extensively across Plattsburgh AFB for nearly 30 years, the Air Force began studying the potential presence of PFAS at the former Plattsburgh AFB in 2014. The Air Force conducted a Site Investigation (SI) of the base fire training area site (FT-002) in 2015 to determine the presence of PFAS in soil, groundwater, surface water, and sediment at and down-gradient of the site. PFAS were detected in all media, and in groundwater and surface water above the HAL recently established by EPA for drinking water, in samples collected from, at, and around the fire training area. The Air Force conducted a base-wide Preliminary Assessment (PA) in 2015 to identify other potential areas of AFFF use and storage at the base for sampling investigations. This assessment identified 10 additional areas for investigation, which included aircraft crash and fire areas, AFFF storage and testing areas, fuel spill areas, and receiving surface water bodies. The Air Force conducted a base-wide Site Inspection (SI) for AFFF for these 10 sites in 2016-2017.The SI was limited to determining the presence or absence of AFFF/PFAS at the former base.  EPA, NYSDEC, and NYSDOH reviewed the SI and provided comments on it to the AF.  A revised draft SI was submitted by the AF in 2018 and reviewed by EPA, NYSDEC, and NYSDOH in 2018.  The three regulatory agencies provided comments to the AF in 2018, and a final SI Report was submitted by the AF in December 2018.  Based on the results of the base-wide SI and fire training area SI, the AF eventually plans to conduct a full RIFS to determine the nature and extent of PFAS contamination in all media on and off the former base, to include human health and ecological risk assessments.  A remedy will be addressed in a ROD for PFAS.

The Air Force also contacted over 300 potential off-base groundwater users within one mile of the base boundary, beginning in 2015. Fifty-three private groundwater wells were ultimately identified by the Air Force in its well survey.  The AF began sampling these wells shortly after each well or group of wells were identified.  PFAS were detected at a numer of residences.  At four of these residences, the combined total PFOA and PFOS detected was above or close to the EPA HAL. The Air Force immediately provided bottled water to the four residences and subsequently installed in-home granulated activated carbon (GAC) systems at three of them.  Installation of a GAC system was not possible at the fourth residence, which continues to receive bottled water from the Air Force.  Regular sampling of these drinking water wells and treament systems is being conducted by the Air Force to ensure that the treated drinking water is safe for consumption. The AF submitted a final well survey and sampling report in November 2018 and it was approved by EPA in December 2018.

In 2018, the AF submitted a draft Work Plan for an expanded PFAS SI (ESI).  The purpose of the ESI is to conduct additional on and off base sampling of groundwater to determine whether or not there is any link between the on base and off base PFAS contamination.  EPA, NYSDEC, and NYSDOH submitted comments on the ESI Work Plan to the AF in 2018 and the AF submitted a draft final Work Plan, now called a Supplemental SI, in response to those comments.  EPA and NYSDEC reviewed the revised Work Plan and again submitted comments to the AF.  EPA and NYSDEC approved the AF Response to Comments on the Work Plan and a final Work Plan was submitted on 11/30/18.  The AF began field work on the Supplemental SI in December 2018.  The first data report was received by EPA and NYSDEC in May 2019 and will be used in conjunction with a work plan to be submitted by the AF for additional follow up sampling. 

Additional investigation and cleanup activities are currently being conducted by the AF as part of its Optimization Program.  Under this program tha AF has been re-evaluating previous remedy decisions to make the remedies more efficient.  This includes potential improvements and changes to existing remedies, reductions in sampling and monitoring subject to EPA and NYSDEC approval, and the potential removal of LUC/ICs through the resampling of previously contaminated areas along with conducting more stringent human health risk assessments, or through the implementation of an active physical remedy.  Improvements and changes to existing physical remedies are being conducted as pilot studies.  After review of all applicable documentation, EPA and NYSDEC will consider approval of all improvements, changes, and LUC/IC removal proposals made by the AF. 

 

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Activity and Use Limitations

At this site, activity and use limitations that EPA calls institutional controls are in place. Institutional controls play an important role in site remedies because they reduce exposure to contamination by limiting land or resource use. They also guide human behavior. For instance, zoning restrictions prevent land uses – such as residential uses – that are not consistent with the level of cleanup.

For more background, see Institutional Controls.

Numerous Land Use Controls / Institutional Controls (LUC/ICs) cover much of the former base and are discussed in other sections of this site profile. 

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Sampling and Monitoring

Sampling and monitoring are ongoing at the former base and are discussed in other sections of this site profile.

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Emergency Response and Removal

The Air Force recently installed in-home treatment systems at three off-base residences to address PFAS contamination in their drinking water wells.  The Air Force also provides bottled water to a fourth residence where installation of an in-home treatment system was not feasible.  This work was done on an emergency basis and is discussed further in the Current Site Status section of this profile.  

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Enforcement Information

EPA placed Plattsburgh Air Force Base on the Superfund Program’s National Priorities List in November 1989. A Federal Facilities Agreement (FFA) governing the identification, investigation, and cleanup of hazardous wastes at the base was signed by the Air Force, EPA, and the New York State Department of Environmental Conservation (NYSDEC) in 1991. Under this agreement, the Air Force conducts hazardous waste investigations and cleanups under its Installation Restoration Program (IRP) as the potentially responsible party (PRP) and lead agency, with oversight of these activities conducted by EPA, NYSDEC, and more recently the New York State Department of Health (NYSDOH).

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