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Site Report: Nikolski RRS SS004 Spill/Leak No.4 (aka POL Tank Farm)

Site Name: Nikolski RRS SS004 Spill/Leak No.4 (aka POL Tank Farm)
Address: POL Tank Farm, Umnak Island, Nikolski, AK 99638
File Number: 2621.38.004
Hazard ID: 131
Status: Active
Staff: Axl LeVan, 9074512156 axl.levan@alaska.gov
Latitude: 52.953549
Longitude: -168.848425
Horizontal Datum:WGS84

We make every effort to ensure the data presented here is accurate based on the best available information currently on file with DEC. It is therefore subject to change as new information becomes available. We recommend contacting the assigned project staff prior to making decisions based on this information.

Problems/Comments

This site was the POL Tank Farm for the facility [AKA POL Tank Area]. The tanks were demolished and some soil cleanup occurred in 2007. SS004 consisted of the following tanks: 2 Bulk Diesel Tanks: total volume 210,000 gallons. 1 Bulk Diesel Tank: total volume 336,000 gallons. 2 Disconnected Heating Oil Tanks: total volume 1,311 gallons 1 Disconnected Fuel Tank: total volume 500 gallons 2 Railroad Tank Cars: total volume 10,000 gallons

Action Information

Action Date Action Description DEC Staff
1/1/1994 CERCLA PA CH2MHill was contracted by the USACE to conduct a PA for the Nikolski White Alice Communication System Site. In 1984, the USAF removed PCB soil and transformers. In 1988 the facility was demolished and the debris and asbestos buried in an on-site landfill. SS004 includes the POL Tank Area. Debra Caillouet
11/1/1995 CERCLA SI EMCON was contracted by the USAF 611th to perform a PA/SI. The site was divided into two Installation Restoration Program (IRP) sites and ten areas of concern (AOC). This site-OT01 consists of the former composite building, former transformer building, four former White Alice arrays. Southwest POL Tank - Sample Analytical Result: Analytical results for sample 95NIK002SO are: ND for GRO and 61 ppm for DRO. Twelve VOCs were detected above the method reporting limits. Ten of the analytes were detected in the method blank and are considered laboratory contaminants. Ethylbenzene and xylenes were detected at 0.00036 ppm and 0.00309 ppm, respectively, and are considered estimated concentrations. South POL Tank: headspace reading from the soil was 0.4 ppm. GRO and DRO analytical results were ND and 363 ppm, respectively. Eight VOC analytes were detected but seven of the analytes were also detected in the method blank and are considered laboratory contaminants. Methylene chloride was detected at an estimated concentration of 0.00514 ppm in the sample analysis but not in the method blank. West POL Tank: A petroleum-like odor was noted and the PID reading was 8.2 ppm in ambient conditions. Sample 95NIK004SO was collected in this location at approximately 6 inches bgs. Analytical results for GRO and DRO were 14.6 ppm and 4,900 ppm, respectively. Four VOCs were detected. Acetone was detected at 0.00296 ppm but it was also detected in the method blank and is considered a laboratory contaminant. Analytes 1,2,4-trimethylbenzene, 1,3,5-trimethylbenzene, and P-cymene were detected at 0.000007 ppm, 0.0002 ppm, and 0.00026 ppm, respectively, and are considered estimated concentrations. DRO concentrations were detected at the south, north, and west POL tank at 61 ppm, 363 ppm, and 4,900 ppm, respectively. The ADEC least stringent DRO cleanup concentration for non-UST contaminated soil is 2,000 ppm. VOCs were detected at levels below the USEPA Region 3 risk-based cleanup levels for soil, which ADEC uses as guidance. Remedial investigation is recommended for this area, especially in the vicinity of the west POL tank. Mr. Willie Dushkin, stated that one of the POL tanks leaked. In a letter written by former resident Ilinon Pletnikoff to Senator Stevens, in October 14, 1987, he states "..there is a portion of land of which surrounds the tank farm located at 'Monalisa Beach' that shows sign of diesel fuel on top of the mud." It is recommended that the POL tanks be removed, and the vertical and horizontal extent of impact be assessed. The fuel pumph6use- should be demolished and a search for the potential associated UST be conducted. A soil investigation is recommended around the pumphouse and tank area. Appropriate cleanup levels and remedial actions will be based upon the assessment. Debra Caillouet
2/12/1997 Update or Other Action (Old R:Base Action Code = SI - Site Investigation). SI action added by Shannon and Wilson, Inc., based on Air Force Relative Risk Evaluation Worksheet dated 9/14/95. No other information available. S&W-Miner
12/1/2000 Update or Other Action A site survey was conducted with the 611th, Jacobs Engineering and Jeff Brownlee (ADEC). Debra Caillouet
12/21/2000 Meeting or Teleconference Held Scoping meeting for the remedial investigation at this former White Alice site. The site operated on Umnak Island in the Aleutian Islands from 1957 to 1977. All the facilities except a tank farm and pipeline were demolished and buried on site in 1986. A Preliminary Assessment/Site Investigation was done in 1995. A drum removal was performed in 1997. Ten Areas of Concern and two IRP sites were identified during the PA/SI. Contaminants of concern include PCBs, petroleum, metals and TCE at one AOC. Jeff Brownlee
2/22/2001 Meeting or Teleconference Held Meeting was to get to know the team and goals/plans for summer 2001 work. Debra Caillouet
4/11/2001 Site Added to Database Former Staff
5/17/2001 Meeting or Teleconference Held A public meeting was held in Nikolski on May 14. The Air Force, Jacobs Engineering and ADEC presented information on the cleanup process and the RI work scheduled for 6/2001. The meeting was well attended and well received by the community. Debra Caillouet
6/25/2001 Update or Other Action Staff traveled to Nikolski to review the characterization work being done. Work was proceeding well. Debra Caillouet
11/29/2001 Site Characterization Report Approved This was the only site at which groundwater was present in sufficient quantities to be considered a usable aquifer. Concentration of DRO, BTEX (benzene, toluene, ethylbenzene and xylene) and lead were detected in soils in three distinct areas of the site. DRO was detected in approximately 500 to 4700 cubic yards of soil in the vicinity of the pumphouse and in approximately 2600 to 6600 cubic yards of soil located between the site access road and the beach. It is recommended this soil be removed or other alternatives be further evaluated in the feasibility study. A total of approximately 250 cubic yards of soil impacted by BTEX was located near the fueling area next to the mogas crib. It is recommended that this soil either be removed or other alternatives be evaluated in the feasibility study. Lead was detected in one surface water sample (collected near the pond east of the pumphouse) that exceeded regulatory limits. Review of literature suggests this concentration of lead (8.17 ?g/L) will not have adverse effects on aquatic organisms; therefore, no further action is recommended to address this sample. One groundwater sample contained DRO at concentrations above site regulatory limits. It is recommended that alternatives to address this elevated concentration in groundwater be addressed in the feasibility study. Debra Caillouet
5/15/2002 Meeting or Teleconference Held Staff attended a public meeting in Nikolski Debra Caillouet
8/1/2002 Update or Other Action Supplemental RI report received for review and comment. At Site SS-004, TOC data was collected in the wetland soils of the site to better characterize the soil in the marsh just northeast of the site. The TOC results averaged 5.1% for that area. ACLs were calculated based on the percent carbon, resulting in clean up levels for DRO and RRO of 8,300 milligrams per kilogram. By comparing these ACLs to sample results collected during the 2001 RI, the sample results from the marshy area northeast of the site now fall below cleanup levels. Based on these analytical results, it is recommended that the above described area not be considered for any further action. During the 2002 SRI, two surface water samples were taken south of the POL tank area and analyzed for TAH and TAqH. All samples were non-detect for TAH and TAqH compounds at the site. Debra Caillouet
8/5/2002 Site Characterization Report Approved Staff provided comments on the SRI for AOC-07 and SS004. The Alaska Department of Environmental Conservation (DEC) has completed review of the document entitled Nikolski Radio Relay Station, Supplemental Remedial Investigation for Sites AOC-07 and SS-004, Draft July 2002• DEC received the report August !, 2002 and a corrected Figure 3-2 on August 5.2002. The report meets the requirements of 18 AAC 75.335 for site characterization. Debra Caillouet
10/14/2002 Update or Other Action Staff submitted comments on the draft feasibility study. Debra Caillouet
12/11/2002 Meeting or Teleconference Held Staff participated in the Air Force peer review of the proposed plan for Nikolski. In December 2002, the Air Force conducted a peer review of the draft feasibility study. The peer review team concluded that a risk assessment should be conducted at the composite building and associated White Alice arrays (OT-001), the fuel pipeline (SS-003), and the POL tank area (SS-004). Based on the conclusions of the peer review team, a preferred alternative will not be selected for OT-001, SS-003, SS-004, or the POL outfall area (WP-007) until the risk assessment is completed. Because this change significantly impacted the alternatives developed to address POL contamination, a separate alternative to address the remaining sites with POL contamination has been included in this document in order to implement the peer review team's recommendations. Debra Caillouet
3/28/2003 CERCLA FS Feasibilty Study received. Soil contamination Pump house DRO at 1,200 cubic yards, Lead at 1 cubic yard. Near Beach DRO at 3,400 cubic yards Near the former mogas tank BTEX at 250 cubic yards RAO • Along the beach, prevent migration of DRO (in excess of 230 mg/kg) from soils to groundwater. • Near the aboveground storage tanks, prevent ingestion, inhalation, or migration to groundwater of soil containing DRO in excess of 1190 mg/kg. • Prevent migration of benzene (in excess of 0.0402 mg/kg), toluene (in excess of 15.9 mg/kg), and ethylbenzene (in excess of 19.2 mg/kg) from soil to groundwater. • Prevent contact with soils containing lead in excess of 400 mg/kg. • Restore the aquifer to 1.5 milligrams per liter (mg/L) for DRO. Groundwater DRO contamination is at 7.83 mg/L (Well SS4-MW01). See site file for additional information. Debra Caillouet
6/17/2003 Document, Report, or Work plan Review - other Staff provided comments on the RA WP. 3.1 Page 3-2 last para. The ADEC technical guidance on determination of background concentrations states specifically: "due to the difficulty associated with estimating the true average concentrations at a site, for all background data, the 95% UCL of the arithmetic mean for normal distributions or the geometric mean for log normal distributions must be used." Please provide details regarding the determination of background levels for this site including justification for sample locations and statistical details such as range of data, number of samples, standard deviations, distribution and 95% UCL. Page 3-5 para. 4 last sentence. Please clarify what risk-based screening values were used to screen surface water, fresh water sediment, and marine sediment data. For additional information see site file. Debra Caillouet
7/21/2003 Risk Assessment Workplan Approved Thank you for providing the Alaska Department of Environmental Conservation with your response to the comments provided on the Draft Risk Assessment Work Plan. The State of Alaska, Department of Environment Conservation concurs with the responses. Please provide a schedule for completing the Risk Assessment. Debra Caillouet
10/11/2003 Risk Assessment Report Approved The Alaska Department of Environmental Conservation (ADEC) received the above mentioned report on August 21, 2003. We concur that the work plan meets the requirements of ADEC’s Risk Assessment Procedures Manual, dated June 8, 2000. Thank you for providing a copy of the Final Nikolski RRS Risk Assessment Work Plan. Debra Caillouet
10/13/2003 Risk Assessment Workplan Approved The Alaska Department of Environmental Conservation (ADEC) received the above mentioned report on August 21, 2003. We concur that the work plan meets the requirements of ADEC's Risk Assessment Procedures Manual, dated June 8, 2000. Debra Caillouet
3/17/2004 Document, Report, or Work plan Review - other Letter of 25 February 2004, Air Force Response to (ADEC's) Comments, Nikolski RRS, Baseline Risk Assessment. The response has been reviewed by the risk assessor and me. Overall the response to ADEC comments was well-done and the proposed changes are acceptable. In regards to the response to Lindsay Smith's Comment 5 about calculating cumulative risk, it is acceptable to treat sediment and soil as well as fresh and marine water separately. However the potential cumulative risk to a future resident should be presented as the sum of risks from groundwater and soil. In addition to the previous comments submitted, the clean up level calculated for DRO at the POL tank area (section 6.1.2.2) needs to be addressed. ADEC’s Clean Up Level Guidance and the Guidance for Clean up of Petroleum Contaminated Sites only specify site specific soil conditions that can be modified to develop alternative clean up levels. Dividing the calculated ACL by 40% is not a justifiable method for dealing with the different sorption capabilities of the aromatic and aliphatic portion of DRO. The clean up level will have to be modified before the Risk Assessment can be accepted. It should be the number that was originally calculated in the Remedial Investigation, Appendix K, including both fractions, i.e. 1190 mg/kg. Debra Caillouet
8/6/2004 Document, Report, or Work plan Review - other Staff provided comments on the Nikolski RRS, Baseline Risk Assessment. The DEC default exposure assumptions were retained for the POL tank area site, reflecting the possibility that residential development could occur in the future. It was also assumed that groundwater beneath the site or surface water surrounding the site could one day be used as a drinking water source. Soil Alternative Cleanup Levels (ACLs) protective of the ingestion, inhalation, dermal exposure, and migration to groundwater pathways, were developed. An ACL of 986 milligrams per kilogram for diesel range organics (DRO) was determined to be protective of all of these pathways. An ACL of 0.55 mg/L DRO was determined to be protective of groundwater. These ACLs would result in a cumulative HI of 1.0 for all exposure pathways. Because residential development could occur at the site, potential risks associated with indoor air were evaluated. The available data indicate that toluene, and xylenes migrating from soils to indoor air could present a potential future human health risk, but do not present a current risk because there are no residential buildings on the site. Two compounds were identified as ecological contaminants of concern for POL tank area soils: total xylenes (HQ=200) and lead (HQ=4). The DEC agrees that if residential development is considered for the POL tank area, additional actions may be necessary to address toluene, xylenes, and lead in soils, and DRO in groundwater. The DEC concurs with the alternate DRO cleanup levels of 986 mg/kg in soil and 0.55 mg/L in water. See site file for additional information. Debra Caillouet
1/18/2005 Update or Other Action File number issued 2621.38.004 Aggie Blandford
6/1/2006 Update or Other Action Air Force Technical Approach for Re-Evaluation of Human Health Risk for SS004, POL Tank Area, Nikolski Radio Relay Station (RRS). Since the installation was inactivated, resource use of all of the Nikolski RRS, including SS004, has been limited to occasional recreational visitors. This occasional recreational use is anticipated to continue in the future at SS004. Assuming that SS004 could be used for residential purposes in the future is not consistent with USAF Performance Based Management policy, nor is it consistent with reasonably anticipated future needs or actions by the USAF or other future property owners. The USAF plans to re-evaluate the risk that may be presented in the current and future recreational land use scenario at SS004. Only one sample (SS4-SSO1) had lead concentrations exceeding the screening level of 400 ppm. The lead concentration in this sample was 5,030 ppm. Two surface samples (SS4-TPOI and SS4-SB08) and a subsurface sample (SS4-SBOlIMWOl) collected nearby had lead concentrations below 15 ppm. The USAF intends to re-evaluate risk from lead in soil at SS004 by comparing the mean concentration in soil, as presented in the BRA, with the screening level of 400 ppm. In the BRA, DRO and RRO in soil were evaluated (allocated between percent aliphatic and percent aromatic) as described in ADEC's 2000 Guidance for Cleanup of Petroleum Contaminated Sites. Allocation between aliphatic and aromatic compounds is necessary in order to estimate health hazards from DRO and RRO because of the differing toxicity of aliphatic and, aromatic compounds. Therefore, aliphatic and aromatic concentrations and hazards will be evaluated separately in this re-evaluation of recreational risk. Because recreational use will not involve construction of buildings, indoor air will not be a concern. Risk from exposure to DRO in surface water will be re-evaluated assuming recreational exposure to surface water. As noted in the previous lead discussion for soil, the appropriate measure of lead exposure is the mean concentration. The mean concentration of lead will be compared to the 18 AAC 75 Table C level of 15 ug/L to determine whether lead in surface water has the potential to present a significant risk to recreational receptors at this site. Louis Howard
6/30/2006 Document, Report, or Work plan Review - other ADEC staff provided comments on the tech approach to reevaluation of HH risk for SS004. As discussed during our June 26th meeting and documented during completion of the existing baseline risk assessment for the site, land at SS04 is suitable for residential development. Congress passed legislation requiring the Air Force to cleanup the property and transfer it to the local village corporation. Thus, the corporation is a landowner affected by contamination at the site and according to Alaska law the Air Force must obtain concurrence from the corporation that cleanup to levels less protective than would allow for residential use is required before the DEC could approve such alternative cleanup levels. Additionally, if the affected land owners consent to limitations on future land use, the Air Force, as the responsible party for cleanup, must develop appropriate institutional controls that would restrict future land use to those scenarios for which the cleanup is protective. See 18 AAC 75.340(d) and 18 AAC 75.375. To date, the Air Force has not provided any information to demonstrate how it would establish such controls. Based on all information provided to date, DEC does not approve limiting the future land use scenario for this site to recreational use only. The site is suitable for residential use and the Chaluka Corporation who has selected the land has stated that they plan for residential use of the area. As stated during our meeting, DEC believes going forward with the effort proposed will only result in the unnecessary expenditure of funds that could be better used for cleanup operations. Alaska water quality standards (18 AAC 70) specify groundwater throughout the state is protected for all use classifications. Similarly, the site cleanup rules require groundwater to be considered a potential drinking water source and must be cleaned up to Table C levels unless DEC determines otherwise under 18 AAC 75.350. DEC has not determined groundwater at site SS04 is not a potential future drinking water source; therefore, re-evaluating groundwater using a recreational exposure assumptions does not comply with the regulations and is not appropriate. Your June 28 letter states that if DEC fails to provide requested documentation within ten business days the Air Force assumes DEC accepts the technical approach outlined in the June 1 letter and that the Air Force is permitted to implement land use controls to limit future land use. It would be a mistake to make such an assumption and lack of a response would in no way be considered regulatory approval. See site file for additional information. Debra Caillouet
12/28/2006 Update or Other Action DEC does not concur with the request for a no further action decision, for the following reasons: 1.A viable groundwater aquifer exists at SS004 and a "350 Determination" is not appropriate. 2.Groundwater contamination exceeds applicable cleanup levels. 3.The maximum allowable DRO concentration in soil has been exceeded and support for a higher cleanup level has not been provided. 4.DEC has not approved and does not agree with using the recreational exposure parameters developed for site WP-07 at SS-004. 5.DEC has not approved and does not agree with the calculated mean lead concentration. 6.A site specific DEC approved risk assessment indicates an unacceptable ecological risk; use of the masked shrew as an indicator species is appropriate. 7.Institutional controls have not been defined or developed. 8.Soil beneath the bulk fuel tanks, suspected to include oiled sands, has not been characterized. 9.The community has not had an opportunity to review or comment on the proposed no further action decision. Debra Caillouet
4/2/2007 Document, Report, or Work plan Review - other staff provided comment on the draft removal work plan for SS004. 1. Section 2.0. a. The description of the site does not include the railroad tank cars; please include them in the work plan. b. DEC does not agree that residential use cannot be expected at this area. The implementation & enforcement of ICs are required to prevent this from occurring. c. According to 18 AAC 70.050, GW is protected for Class (1) (A) uses (freshwater water supply). The area that is shown on Figure 6 for Land Use Control encompasses an area much larger than the bedrock knoll where the POL Tanks are located. Most of this area does have sufficient water that could be developed as a drinking water source. A determination that the GW is not a reasonably expected future drinking water source is not applicable. 2. Section 4.0. a. Please remove the statement in Section 4.0, the last paragraph, that it is clear there is no unacceptable risk. DEC did not approve the use of the exposure assumptions developed for other sites at the Nikolski RRS for this site. (18 AAC 75.340(b)) 3. Section 6.0. a. Please remove the last sentence of this paragraph. There has been no determination that the maximum allowable concentration (MAC) is protective of recreational use. b. The use of a removal action to reach the MAC coupled with monitored natural attenuation & ICs should allow the concentrations of the petroleum contaminants to reach 18 AAC 75 cleanup levels in a reasonable time. This work plan when approved will document the cleanup decision for this site. To assure protection the following conditions must be met & compliance with these conditions demonstrated in the final cleanup report for the site. i. Restrictions or controls shall be documented on state &/or federal land status plats &/or plans applicable to the subject property to ensure that human health & the environment are protected from risk of exposure. The Air Force must include how these controls will be enforced. ii. The Air Force must acknowledge that a DEC permit is required for dewatering at the POL tank area & provide information to the DEC Division of Water about the location of contaminant plumes. The Air Force must acknowledge that DEC approval is required prior to off-site transport of soil & that soil containing residual contamination may not be placed in surface water or other environmentally sensitive areas. See site file for additional information. Debra Caillouet
5/25/2007 Document, Report, or Work plan Review - other Comments on the cleanup Plan for SS004 POL Tank Farm Final May 2007. The Alaska Department of Environmental Conservation (DEC) has no objection to implementing the work proposed in the above referenced work plan. However, DEC is not in agreement with and does not approve the proposed alternative cleanup levels. State regulations define cleanup levels. The Method Two soil cleanup levels and Table C groundwater cleanup levels defined in 18 AAC 75.340-.345 apply. The cleanup regulations allow a responsible person to propose alternative soil cleanup levels that take into account site-specific conditions and exposure assumptions that reduce mitigate or eliminate human or ecological exposure to contamination. The cleanup regulations also require DEC to obtain the consent of each landowner who is affected by the contamination at the site before approving a cleanup level less stringent than a cleanup level appropriate to residential land use (18 AAC 75.340 (f)(2)). Comments received from the Chaluka Corporation and the U.S. Department of the Interior, Bureau of Land Management (BLM) both clearly describe the Chaluka Corporation as an affected landowner based on the special legislation enacted by Congress in 2003. Furthermore, Chaluka Corporation has expressed objection to a clean up level that would not support residential use. Therefore, DEC cannot approve a cleanup level that is not appropriate for residential land use. Debra Caillouet
4/10/2008 Exposure Tracking Model Ranking Initial ranking with ETM completed. Debra Caillouet
7/31/2008 Document, Report, or Work plan Review - other Staff sent comments to the Air Force on three draft final cleanup reports for the Nikolski Radio Relay Station. These reports cover actions done under a performance based contract last year and document several violations of the UST regulations. The reports do acknowledge the violations of the regulations and state that corrective action work plans will be provided to DEC. The reports are still missing documentation of waste disposal that was requested in comments on the Pre-draft versions. The Air Force cannot administratively transfer contamination associated with a regulated underground storage tank system (UST) to a CERCLA regulated site. AS 46.03.450 defines a UST as "underground storage tank" means one or a combination of stationary devices, including underground pipes connected to the devices, that is designed to contain an accumulation of petroleum, the volume of which, including the volume of underground pipes, is 10 percent or more beneath the surface of the ground "underground petroleum storage tank system" means an underground storage tank containing petroleum together with its underground ancillary equipment and related containment system, if any; in this paragraph, "ancillary equipment" means devices used to distribute, meter, or control the flow of petroleum to and from the system, including piping, fittings, flanges, valves, and pumps. The areas impacted by the US Ts and the associated piping are regulated under 18 AAC 78. A meeting was held with DEC, AF and DOL staff to discuss the violations and plans for transferring land to the local native corporation. See site file for additional information. Debra Caillouet
8/4/2008 Document, Report, or Work plan Review - other Review comments on the SC Work Plan for SS004. 1.3 Ownership of the runway was transferred to Chaluka Corporation a few years ago. 2.2 Cleanup levels for some PAH's are more stringent for the direct contact pathway than the migration to groundwater pathway. Make sure all analytes are screened against the most stringent pathway. Also, the regulations are in Chapter 18, not Chapter 10. 2.7.3 Please clarify the sample analyses for the MI excavation. Page 2-14 states DRO and PAH, while page 2-18 has DRO, GRO, BTEX, PAHs, and total lead. GRO and BTEX are not required for the backfilled soil. Debra Caillouet
10/15/2008 Meeting or Teleconference Held Meeting with ADEC, AFCEE, 611 CES, BEM staff. ADEC Contaminated Sites stated that the extent of contamination at the aboveground storage tanks (ASTs) and the extent of the smear zone at the pumphouse need to be delineated. ADEC Contaminated Sites also maintains that the groundwater sample collection conducted in 2007 was representative of one point in time and does not indicate that groundwater at the site does not continue to be impacted. Additional soil and groundwater sample analysis information is required to delineate the area. ADEC Contaminated Sites stated that they did not object to the work plan because it removed contaminated material, but in order for the Air Force to gain site closure, the site needs to be delineated. The Air Force stated that the Remedial Investigation approval by ADEC Contaminated Sites in a letter dated March 12, 2002, met the requirements for site assessment and characterization. The ADEC Contaminated Sites disagreed and stated that the Remedial Investigation only served to conclude a release had occurred at SS004. In response to the Draft Final Cleanup Report for SS004, ADEC Contaminated Sites will review and evaluate any additional information provided by BEM’s subcontractor. ADEC Contaminated Sites specifically requested characterization information for the fluids incinerated onsite in the Smart Ash. ADEC Contaminated Sites requests that the concrete from the pumphouse be removed from the shoreline, as it is inappropriate for ocean disposal. ADEC Contaminated Sites will not agree with the report conclusions as written, the Air Force can re-write the conclusions to say that the activities met the intent of the Cleanup Work Plan, or conduct additional site characterization in Summer 2009 and include the information in the Final Cleanup Plan. ADEC Contaminated Sites requires a work plan (including a Sampling and Analysis Plan) for any additional characterization conducted at the site. See site file for additional information. Debra Caillouet
10/31/2008 Document, Report, or Work plan Review - other ADEC response to meeting minutes dated 10/15/2008 for meeting held on 9/24/2008 for TU019, SS005, SS004. SS005 2nd paragraph. DEC requested that the pipeline be characterized for a possible release. That is required as part of the assessment. SS004 3rd paragraph. Please provide both the characterization and volume of fluids incinerated on site. 3rd paragraph. The 3rd sentence is not clear. DEC stated that the conclusions should be written to say that the intent of the work plan was met. Additional site characterization is required to determine the nature and extent of the remaining contamination. Cleanup levels must be determined and then, based on complete characterization of the nature and extent of the contamination remaining, conclusions can be drawn on what, if any, additional remedial actions are necessary. The report that this information would be included in would be a remedial action report, not a cleanup plan. 2nd bullet. A trend must be established for the remaining groundwater contamination. DEC agreed that this could be based on two sampling events per year. Multiple years will be required to determine the trend. 4th bullet. The UST procedure manual requires lab analysis of samples at the rate of two samples for the first 250 ft2 and then one for each additional 250 ft2. These samples are to be based on field screening at the rate on one sample per 100 ft2 with the locations of the highest field screening results used for the collection of the lab samples. Because this was not done when the excavation was open, sampling following these procedures may not be practical. DEC would accept a statistically valid sampling plan to determine the contamination remaining at the limits of the excavation. In either case, 3 samples will not be sufficient. 4th bullet. DEC requires the direct contact levels to be met in the top 15 feet of soil. The migration to groundwater levels are required to be met for all contaminated soil before a site can be closed. It is not clear what the last sentence in this item is meant to describe. DEC does not limit the depth of excavation. 4th paragraph. Please be aware that the recreational exposure factors that had been determined for the sites at High Hill are not applicable to SS004 and will need to be revised specific to SS004. Debra Caillouet
12/29/2009 Document, Report, or Work plan Review - other Nikolski RRS Groundwater and Surface Water Analytical Results, September 2009. The report documents the results of sampling and analysis at the SS004 Tank Farm and ST017 Septic System. At SS004 all monitoring wells were below levels of concern except MW8 located at the beach which contained free product. The seep water at ST017 contained trichloroethylene at 38 µg/l, while this does indicate a decreasing trend it is above the cleanup level of 5 µg/l. The report recommends that sampling for a contaminant of concern be discontinued at a monitoring well after two consecutive results are below cleanup levels and sampling of the well stop when all COCs are below cleanup levels for two consecutive events. Fall and spring sampling events are scheduled from September 2009 through spring 2011. Until a record of decision is signed for these sites DEC can not concur with this recommendation and requests that all wells be sampled as planned. Debra Caillouet
2/23/2010 Document, Report, or Work plan Review - other The Alaska Department of Environmental Conservation received the Technical Memorandum for the groundwater and surface water on February 5, 2010. The report documents the results of sampling and analysis at the SS004 Tank Farm and ST017 Septic System and meets the requirements of 18 AAC 75.335 Site Characterization. At SS004 all monitoring wells were below levels of concern except MW8 located at the beach which contained free product. The seep water at ST017 contained trichloroethylene at 38 µg/l, while this does indicate a decreasing trend it is above the cleanup level of 5 µg/l. Future monitoring requirements will be addressed in the Record of Decision for ST017. Fall and spring sampling events are scheduled from September 2009 through spring 2011 for SS004. Debra Caillouet
8/23/2010 Document, Report, or Work plan Review - other Nikolski RRS Groundwater Analytical Results, May 2010, draft Tech Memo, August 2010 The document reports the results of groundwater sampling at SS004. All wells except the one on the beach (MW8) were below cleanup levels. MW8 did contain free product. In the well sampling logs, MW2 is noted as having 0.01” of free product. The groundwater samples were below cleanup levels. Debra Caillouet
9/24/2010 Document, Report, or Work plan Review - other the final May 2010 groundwater report was recieved with the wrong title page and cover page and the wrong lab data. The Air Force was requested to send the correct information. Debra Caillouet
9/24/2010 Document, Report, or Work plan Review - other The Alaska Department of Environmental Conservation received the Technical Memorandum for the groundwater and surface water on September 23, 2010. The report documents the results of sampling and analysis at the SS004 Tank Farm in May 2010. The report cover and the CD use the title shown in the reference line, not the actual work presented which is Groundwater only and May 2010, not September 2009. The lab analytical package is not for the May 2010 sampling event. Looks like it is the September 2009 package. Please resubmit with the correct cover, title page and lab data. Note I did review the draft back in August that had most of the correct information. Debra Caillouet
10/1/2010 Document, Report, or Work plan Review - other Final Nikolski RRS Groundwater and Surface Water Analytical Results, May 2010, September 2010 The Alaska Department of Environmental Conservation received the corrected Technical Memorandum for the groundwater and surface water on September 29, 2010. The report documents the results of sampling and analysis at the SS004 Tank Farm in May 2010 and is accepted. Debra Caillouet
2/24/2011 Document, Report, or Work plan Review - other On behalf of the Alaska Department of Environmental Conservation I have reviewed the referenced document. As I mentioned during our meeting on February 14, it would be helpful to include the pathway that the cleanup levels are using. One other comment; on Figure 3, the result for SB56B2SO should be GRO at 2600 mg/kg. Thanks for having the meeting to discuss the next sampling event. Debra Caillouet
12/5/2011 Document, Report, or Work plan Review - other Staff provided comments on the proposed plan. Page 3 2002 An ACL was calculated based on percent carbon, resulting in a proposed cleanup level of 1, 190 mg/kg for DRO for site soils. Page 3 2009-2010 Rather than summarizing the results of the 2010 sampling in a sidebar two pages below, why not put it in the text here? And please explain why BTEX compounds are not mentioned when they are listed as exceeding cleanup levels on Page 5 in the COPC column. Page 6 RAO Please use the specific cleanup levels and for the benzo and dibenzo the cleanup level is not based on the migration to groundwater but on the direct contact level. See site file for additional information. Debra Caillouet
2/13/2012 Document, Report, or Work plan Review - other Staff provided comments on the Evaluation of Remediation Alternatives for Sites SS003, SS004 and SS006 at Nikolski Radio Relay Station (Draft) 10 February 2012. Comments are shown below. 1. Page 3, Site SS004. The 4th bullet should state prevent direct contact with soil containing benzo(a)pyrene in excess of. ... 2. Page 3, Site SS004. The Remedial Alternatives must include a remedy for the groundwater. I suspect this would be source removal followed by Monitored Natural Attenuation with Five Year Reviews until the groundwater was below 1.5 mg/L DRO. Debra Caillouet
6/11/2012 Document, Report, or Work plan Review - other Staff provided comments on the Nikolski RRS SS004 Combined Groundwater and Soil Sample Results, September 2009, May 2010 and September 2010, Draft 30 December 2011. Comment on the report is listed below. 1. On page 3 , the second paragraph states that MW 9 TAH and TAqH results were below the water quality standards. Since this well is upgradient significantly from the beach it is unclear why this was evaluated. Please review. 2. The conclusions should include reinstalling MW8 or replacing it. It should also include proper decommissioning of the unused wells. 3. Please provide some information on the proposed pre-design investigation such as when a work plan is expected. Debra Caillouet
7/23/2012 Document, Report, or Work plan Review - other Comment sent to the AF on the Tech Memo: Evaluation of Remediation Alternatives for Sites SS003, SS004 and SS006 at Nikolski Radio Relay Station (Final) 19 July 2012 Debra Caillouet
8/17/2012 Document, Report, or Work plan Review - other Nikolski RRS SS004 Combined Groundwater and Soil Sample Results, September 2009, May 2010 and September 2010, Final August 13 2012 Debra Caillouet
11/15/2012 Document, Report, or Work plan Review - other Staff provided comments on the Evaluation of Remedial Alternatives for Sites SS003, SS004, and SS006 at Nikolski Radio Relay Station, Revised Final, November 2012. On behalf of the Alaska Department of Environmental Conservation, I have reviewed the revised Evaluation of Remedial Alternatives for the three referenced sites at the Nikolski Radio Relay Station. The revision adds costs for monitoring the natural attenuation of the groundwater at SS004 and SS006 and reconciles previous differences with the Proposed Plan for the sites. ADEC believes this represents a reasonable evaluation of the remedies for these sites. Debra Caillouet
5/15/2013 CERCLA ROD Approved Record of Decision signed by John Halverson (ADEC). By signing this declaration, ADEC concurs that proper implementation of the selected remedies for AOCOI, LFOOl, SS002, SS003, SS004, and SS005 will comply with state environmental laws. These decisions will be reviewed and may be modified in the future if information becomes available that indicates the presence of contaminants or exposures that may cause unacceptable risk the human health or the environment. As documented in the Final 2001 RI Report (USAF, 2002a), SS003 has two areas of petroleum contamination above applicable Alaska regulatory limits for soil. The general response actions that can be undertaken to satisfy remedial action objectives (RAOs) for protecting human health and the environment at Nikolski RRS include limited actions (e.g., LUCs), containment, ex situ treatment, in situ treatment, and removal/offsite treatment or disposal. The selected remedy for SS003 is excavation and offsite disposal of POL-contaminated soil, which is in accordance with State of Alaska regulations at 18 AAC 75. No LUCs are applicable to this remedy, because POL-contaminated soils above applicable regulatory limits will be excavated and shipped offsite for disposal. The Air Force will be responsible for implementing, maintaining, monitoring, reporting and enforcing the remedial actions identified for the duration of the remedy selected in this Decision Document. Specific elements of the selected remedy include: Excavation of POL-contaminated soils and transport offsite for disposal at an approved facility. The estimated volume of soil to be excavated at SS003 is approximately 500 cubic yards. Following excavation, no hazardous substances would remain onsite above 18 AAC 75 cleanup levels. Clean fill will be utilized to backfill the site following excavation of contaminated soils. The estimated costs to complete the selected remedy for SS003 are: ? Estimated Capital Cost = $1,000,000 ? Estimated Annual Overhead and Maintenance Cost = $150,000 ? Estimated Total Cost = $1,150,000 It is anticipated that construction efforts to achieve the selected RAOs described for SS003 in Section 2.8 will be 1 year. Debra Caillouet
12/11/2014 Document, Report, or Work plan Review - other Draft Remedial Action Work Plan for Remedy Implementation at the Former Nikolski Radio Relay Station, Alaska December 2014, The plan is deficient in many details and requires significant revision. A complete revised DRAFT document is required. Debra Caillouet
5/4/2015 Document, Report, or Work plan Review - other Staff commented on the Draft-Final RA WP for Remedy Implementation at SS003, SS004, SS006 and OT010. Page 3-6 Table 3-1 Review and correct. Holding time for VOCs is not 180 days. There are six methods in EPA 540-R-09-03 Jan 2011, Appendix B for low level VOCs in soil, the method you have chosen has this caveat This option is NOT a Preferred Option for the CLP because: NaHS0-1 preservation creates low pH conditions that will cause the destruction of certain CLP target analytes (e.g., vinyl chloride, trichloroethene, trichlorofluoromethane, cis- and trans-1,3-dichloropropene). As vinyl chloride and trichloroethene are two of the COCs please chose one of the three recommended methods. VOC water samples are not collected in 1 liter bottles nor are TLC caps used. This also has to be corrected in the UFP-QAPP. Provide method for RRO in water. Table 4-2 The sub-sites/areas that are shown in this table are not identified in the figures. The RODs do not include sub-sites. Provide figures with the sub-sites identified, once that occurs ADEC may or may not concur with the analytes for each area. Duplicates are to be collected at a rate of 10% minimum. 24 is less than 10% of 245. Verify all and correct, as there are others also shown at less than 10%. At SS004 confirmation sampling is to include PAH. Long-Term monitoring at SS006 is to include GRO and DRO. Page 4-1 4.3 The volumes in this section, 39 cy TCE and 186 cy DRO are not in the ROD. The ROD states "estimated volume of soil to be excavated at SS006 is approximately 200 cubic yards". See comment 7, sub-sites are not shown on Figure 4-4. Also note that sample SS6-HA31 has TCE at 0.484 mg/kg which is above the cleanup level but the value is not bolded on Figure 4-4. UFP-QAPP Page 11 Worksheet 6 should be Communications Pathways. Worksheet 10 is the Conceptual Site Model. The information in the table does not apply to either. Please review and fix. The rest of this UFP-QAPP, is not being reviewed. Please do an internal review of this document to assure that the contents of each worksheet is what is explained in the Intergovernmental Data Quality Task Force Uniform Federal Policy for Quality Assurance Project Plans Optimized UFP-QAPP Worksheets March 2012. Please note that the Executive Summary of said document includes this: ... "the information contained in the worksheets continues to capture the elements that would comprise related project-planning documents, such as a Sampling and Analysis Plan (SAP), Work Plan (WP), and Field Sampling Plan (FSP)" and" ... the final, approved QAPP is designed to be a stand-alone document containing all specifications and procedures necessary for project personnel to carry out their assigned responsibilities. For example, the field team should be able to rely on the QAPP for complete sampling instructions, including how to sample, where to sample, how many samples to collect, the types of bottles, preservatives, related QC, etc. If the approved QAPP provides insufficient procedures to carry out all tasks, then SOP's must be attached to the QAPP. If required elements are contained in other documents, those documents may be referenced; however the documents must be available to all personnel responsible for reviewing and implementing the QAPP" ADEC can review this document with the separate Work Plan and Waste Management Plan Quality Control Plan Page 5-2 5.7 The UFP-QAPP has many obvious omissions/errors. Please explain what type of review occurred and why future QA/QC on the actual performance of the work should be trusted. See site file for additional information. Debra Caillouet
11/30/2015 Meeting or Teleconference Held Meeting with MWH scoping 5 year review for Nikolski sites. 5YR under CERCLA will not include this site as remedy was implemented in 2015 and cleanup report is not final. Fred Vreeman
4/1/2016 Update or Other Action Draft-Final Long-term Groundwater Monitoring Report received. Long-term monitoring of groundwater at Site SS004 was temporarily deferred due to the on-going removal action at that site. Ongoing remedial action activities at Site SS004 did not allow for the sampling or installation of a replacement well at the location of SS4-MW08. Well points were purged and sampled using a battery-operated submersible pump outfitted with disposable Teflon tubing. Purging was considered complete when three casing volumes of water had been removed or when water quality parameters had stabilized. Analytical results for both samples were below the applicable cleanup levels listed in Table C of the Alaska Administrative Code (AAC), Title 18, Chapter 75 (ADEC 2015). Groundwater monitoring will continue following completion of the soil removal and well point installation aspects of the Remedial Action at Site SS004 in accordance with the Nikolski RRS Record of Decision for Sites AOC01, LF001, SS002, SS003, SS004, and SS005. Louis Howard
4/7/2016 Document, Report, or Work plan Review - other Staff reviewed and approved the draft final version of the Long-Term Groundwater Monitoring Report for SS004 and SS006. Louis Howard
4/12/2016 Update or Other Action Draft ICs report received for review and comment. ICs at SS004 and SS006 consist of the following: 1. Land Use Controls for each site will be incorporated into the 611th Civil Engineering Squadron Land Use Control Management Plan. 2. A Notice of Environmental Contamination will be placed in the Alaska Department of Natural Resources’ (ADNR’s) land records. 3. Warning signs placed at the boundary of each site will provide contact information for Land Use Control Management. No issues were found during the 2015 ICs inspection at Nikolski RRS Sites SS004 or SS006 that would require additional corrective action or changes to the institutional control plan for the site. Louis Howard
4/19/2016 Document, Report, or Work plan Review - other Staff reviewed and approved the draft Institutional Controls Report for SS004 and SS006. Louis Howard
12/6/2016 Update or Other Action Long-term Groundwater Monitoring Report received for review and comment. Results for all analytes were below groundwater cleanup levels in Table C, 18 AAC 75 (ADEC 2015). The June 2015 monitoring event is the first which resulted in all contaminants of concern being found in concentrations below groundwater cleanup levels for the Site SS006. Annual groundwater monitoring will continue until concentrations of all contaminants of concern are shown to be steady state, or shrinking and contaminant concentrations are decreasing, for three consecutive monitoring events in accordance with the Nikolski RRS Record of Decision for Site SS006 (USAF 2013b). Groundwater monitoring will continue following completion of the soil removal and well point installation aspects of the Remedial Action at Site SS004 in accordance with the Nikolski RRS Record of Decision for Sites AOC01, LF001, SS002, SS003, SS004, and SS005. Louis Howard
2/6/2017 Update or Other Action 2016 Long-term GW Monitoring report received for review and comment. The purpose of this Long-term Groundwater Monitoring Report is to summarize analytical results for groundwater samples collected during the July/August 2016 Monitoring Event at Nikolski Radio Relay Station (RRS). DRO exceeded 1.5 mg/L groundwater cleanup level at WP-11 (22.3), WP-12 (3.09), WP-13 (44.7), WP-14 Duplicate (2.57 mg/L). See site file for additional information. Louis Howard
2/6/2017 Update or Other Action ICs control report received for review and comment. ICs at Site SS004 (Petroleum, Oil, and Lubricants [POL]Tank Area) and Site SS006 (Former Drum Storage Area) are part of the selected remedy for the Nikolski RRS Record of Decision (ROD) for each of the respective sites (USAF, 2013a,b). As a result of the findings of the 2015 Remedy Implementation, Site SS003 (POL Pipeline) was added to the 2016 IC inspection. ICs at SS004, SS006, and SS003 consist of the following: 1. Land Use Controls for each site will be incorporated into the 611th Civil Engineering Squadron Land Use Control Management Plan. 2. A Notice of Environmental Contamination will be placed in the Alaska Department of Natural Resources’ (ADNR’s) land records. 3. Warning signs placed at the boundary of each site will provide contact information for Land Use Control Management. See site file for additional information. Louis Howard
2/8/2017 Document, Report, or Work plan Review - other Staff reviewed and approved the Preliminary Draft Long-term Groundwater Monitoring Report for Nikolski RRS, Alaska dated November 2016. Louis Howard
2/9/2017 Document, Report, or Work plan Review - other Staff reviewed and approved the Preliminary Draft Institutional Controls Report for Nikolski RRS, Alaska dated November 2016. Louis Howard
1/31/2018 Update or Other Action Draft RAO/LTM report received for review and comment. Site observations at SS004 indicated the presence of occasional recreational land users, cattle, and wildlife. Two LUC warning signs that were installed in 2016 were observed to be visible but the sign posts were bent over. It is recommended that these signs be replaced. Several large pieces of concrete debris remain present near where the POL Tanks once stood, on the northeastern edge of the site. Along both sides of the access road that runs up from the coastal area to the POL Tank area there where several open excavations that appear to be “test pits” dug for soil investigative purposes. The excavations are approximately 2-ft wide, 4-ft long, and 2-ft to 4-ft deep. These excavations are holding water and limiting drainage in an already saturated area. Revegetation is sparse in these areas. There is future risk of erosion and risk to recreational land users, cattle, wildlife. Filling in these test pits would eliminate these potential risks. Review of the 2017 groundwater results indicates that DRO concentrations remain above cleanup levels at WP-13 and WP-14. The highest concentration of DRO was found at WP-13, with a concentration of 28.2 mg/kg. During the 2016 LTM event, DRO concentrations were detected above cleanup levels at all of the well points at SS004 except for WP-08R. Annual groundwater monitoring is scheduled to continue at SS004 for 3 more years, at which point the frequency of monitoring may be adjusted or eliminated, according to the amount of natural attenuation achieved, in accordance with the Nikolski RRS ROD for SS004. See site file for additional information. Louis Howard
3/7/2018 Document, Report, or Work plan Review - other Draft Remedial Action – Operations/LTM Report for Nikolski RRS reviewed. Staff concurs with recommendations to replace the two land use control signs with sturdier posts. ADEC requests filling in of the “test pits” to reduce risk to recreational land users, cattle, wildlife as soon as possible. See site file for additional information. Louis Howard
9/8/2020 Update or Other Action DEC approved the "Final Supplemental Work Plan, 2020 Remedial Action Operations, Land Use/Institutional Control, Former Nikolski Radio Relay Station, Alasak, Sites LF001, OT001, SA593, SS003, SS004, TU019, and WP007” dated September 2020. This work plan addresses inspection of the institutional controls/land use controls, as well as groundwater, surface water, pore water, soil, and sediment sampling activities associated with long term monitoring (LTM) at the Former Nikolski Radio Relay Station Sites LF001, OT001, SA593, SS003, SS004, TU019, and WP007, located in Nikolski, Alaska. Melinda Brunner
6/1/2021 Document, Report, or Work plan Review - other Staff provided comments on the 2021 Draft Final Uniform Federal Policy for Quality Assurance Project Plan for Long-Term Management and Remedial Action Operations Activities, Nikolski Radio Relay Station, Alaska, March 2021. The Work Plan described the approach and procedures for site-specific long-term management and remedial action-operation activities at Nikolski Radio Relay Station sites, including annual groundwater sampling for site SS004. The Work Plan covers work being performed over a 5-year period. Axl LeVan
6/24/2021 Document, Report, or Work plan Review - other DEC reviewed and provided comments on the "2020 Remedial Action operations, Institutional Control/Land Use Control Report, Nikolski RRS, Alaska, May 2021", received on May 26, 2021. The report presented the results of the 2020 Long Term Maintenance (LTM) performed at the Former Nikolski Radio Relay Station sites LF001, OT001, SA593 (also known as SS006), SS003, SS004, TU019, and WP007. The site visit was conducted in September of 2020 and included groundwater sampling at Site SS004. Axl LeVan
8/17/2021 Document, Report, or Work plan Review - other DEC approved the "Final 2020 Remedial Action operations, Institutional Control/Land Use Control Report, Nikolski RRS, Alaska, August 2021", received on August 17, 2021. The report presented the results of the 2020 Long Term Maintenance (LTM) performed at the Former Nikolski Radio Relay Station sites LF001, OT001, SA593 (also known as SS006), SS003, SS004, TU019, and WP007. The site visit was conducted in September of 2020 and included groundwater sampling at Site SS004. Axl LeVan
8/20/2021 Document, Report, or Work plan Review - other Staff approved the 2021 Final Uniform Federal Policy for Quality Assurance Project Plan for Long-Term Management and Remedial Action Operations Activities, Nikolski Radio Relay Station, Alaska, August 2021. The Work Plan described the approach and procedures for site-specific long-term management and remedial action-operation activities at Nikolski Radio Relay Station sites, including annual groundwater sampling for site SS004. The Work Plan covers work being performed over a 5-year period. Axl LeVan
7/21/2022 Document, Report, or Work plan Review - other The Alaska Department of Environmental Conservation (DEC) Contaminated Sites Program received a copy of the Draft-Final 2021 Land use/Institutional Controls and Long-Term Management Report, Nikolski Long Range Radar Site, June 2022 on June 27, 2022. This report presents the results of the 2021 Long-Term Monitoring (LTM) performed at the Former Nikolski Radio Relay Station Sites LF001, OT001, SA593, SS003, SS004, SS010, TU019, and WP007. This work was performed October 15 through 18, 2021 and included institution control (IC) and land use control (LUC) inspections. Groundwater sampling also occurred at site SS004. Axl LeVan
9/7/2022 Document, Report, or Work plan Review - other The Alaska Department of Environmental Conservation (DEC) Contaminated Sites Program approved the Final 2021 Land use/Institutional Controls and Long-Term Management Report, Nikolski Long Range Radar Site, August 2022 on August 26, 2022. This report presents the results of the 2021 Long-Term Monitoring (LTM) performed at the Former Nikolski Radio Relay Station Sites LF001, OT001, SA593, SS003, SS004, SS010, TU019, and WP007. This work was performed October 15 through 18, 2021 and included institution control (IC) and land use control (LUC) inspections. Groundwater sampling also occurred at site SS004. Axl LeVan
11/30/2022 Document, Report, or Work plan Review - other DEC reviewed and signed a transport and approval form for used granulated activated carbon from the 2020 groundwater long term monitoring. Axl LeVan
2/8/2024 Document, Report, or Work plan Review - other DEC reviewed and approved the "Draft-Final 2022 Land Use/Institutional Controls and Long-Term Management Report, Nikolski Long Range Radar Site, January 2024". The remaining DEC comment was addressed by the most recent update to the document. Axl LeVan

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