| Action Date |
Action |
Description |
DEC Staff |
| 3/1/2000 |
Update or Other Action |
Research Results RE: Materiel at PACAF Bases. As part of this effort, Hart Crowser conducted historical research & compiled data pertaining to CWM at Air Force Bases located in Alaska, Hawaii, Wake Island, & Guam. This work was performed by Hart Crowser under contract with the U.S. Army Corps of Engineers (Corps), Alaska District (Contract DACA85-95-D-0010, Delivery Order 30).
This report summarizes the findings of research conducted by Hart Crowser & its subcontractor, History Associates, Inc., to determine the movement, use, & possible disposal of Air Force CWM & toxic chemical agents at installations in Alaska. Toxic chemical agents in bulk, as filler in munitions, or in training kits, which may have been buried or otherwise disposed of on Air Force property, are the focus of this research.
Available documents indicate that the Air Force & its predecessor, the Army Air Force (AAF), have handled CWM & toxic chemical agents in Alaska from 1941 through at least 1954. The agents involved were exclusively mustard (H or HS) & lewisite (L). It appears that chemical training & the concurrent use of Chemical Agent Identification Sets (CAIS) began in 1941 & continued through at least the mid-1950s. Of the total reported quantities of CWM shipped to Air Force installations in Alaska, located records can account for the disposal of approximately 66 percent of bulk toxic chemical agent supplies & 39 percent of munitions filled with toxic chemical agents.
Based on our understanding of common practices for the period, it is likely that most of the unaccounted for CWM were either disposed of by ocean dumping, or transferred to another command. However, procedures indicate that for small amounts, such as what is contained in CAIS or single rounds of artillery, local burial was allowed. CAIS have been exhumed in two areas in Alaska, including Fort Wainwright & Fort Richardson. In addition, CAIS have washed ashore at Dutch Harbor likely representing material dumped at sea forty years earlier.
It is possible that CAIS were present & disposed of at Air Force bases throughout Alaska. From the orders & field manuals that we collected, it appears likely chemical defense training took place at every, or nearly every, base in Alaska during WWII, & such training involved the three types of CAIS available to the Army & the Army Air Force at that time. Furthermore, chemical warfare defense training by Alaska Air Command personnel continued into the 1950s. In 1969, the advent of the international Chemical Weapons Convention (CWC) process prohibited further use or deployment of toxic chemical agents by United States government agencies.
Toxic Chemical Munitions at Air Force Sites in Alaska
This section presents a general history of chemical warfare agents in Alaska, followed by conclusions drawn for the locations specified in the scope of work for this project. Although CWS personnel began serving in Alaska in 1941, bulk toxic chemical agents & munitions arrived later, but appear to not have been stored initially at AAF bases. In January of 1942, the proposed plan for CWS troops was to establish twelve distribution points in addition to Elmendorf Field. At that time, two men each were sent to Annette, Yakutat, & Kodiak.
On February 14, 1942, the Quartermaster General advised the Commanding General of the Alaskan Defense Command that, per his request, the Army Transport Service would "deliver ten tons mustard gas at Fort Greely, Kodiak (Fort Greely was originally located on Kodiak, & the Fort of the same name was not built near Delta Junction until the 1950s) & nine tons at Dutch Harbor," an Army Ground Forces & a Navy station, respectively (JGK-76). Furthermore, according to a monthly materiel status report for the Alaska Defense Command, as of 15 April 1942 there were 6,960 75mm & 155mm HS shells, but no HS bombs in the theater (JGK-121). The 155mm howitzer batteries were stationed at Elmendorf, Kodiak, & Annette, & artillery batteries (caliber not mentioned) were stationed at Cold Bay, Unmak, & Port Heiden.
Probably as part of the preparation to retake Attu & Kiska, in September 1942, the Commanding General, Alaska Defense Command requested the shipment of vesicant agent & airplane spray tanks to stations of his command to permit prompt retaliation in event of enemy use of toxic materials (JCH-3). Chemical warfare supplies of various types were stocked at Fort Richardson. As the enemy was pushed westward, these supplies were shipped to forward supply points.
These stocks included everything from gas masks to toxic chemical agents (JCH-5). Basically, the bombs & bulk agents followed the bomber groups west, so that offensive chemicals were immediately ready for retaliatory strikes.
See site file for additional information.
|
Louis Howard |
| 3/30/2006 |
Update or Other Action |
Factsheet for MMRP on EAFB received. Air Force is evaluating three locations on Elmendorf Air Force Base (AFB) under the Military Munitions Response Program (MMRP). We are seeking any information the public may have regarding the history of these locations in an effort to learn more about possible past uses that may not have been documented. We are particularly interested in information regarding munitions at any of these three sites or other locations on Elmendorf AFB. In order for us to use information provided by the public during a field investigation scheduled for late May, we would like to receive all information by May 15, 2006.
The MMRP is a comprehensive program that will address the potential health, safety, and
environmental hazards present at former munitions response sites that were in operation through
the year 2002. Munitions response sites are areas the Department of Defense (DoD) has
historically used for munitions-related activities and are now closed or inactive. All designated MMRP sites have been found to contain or are suspected of containing unexploded ordnance (UXO), discarded military munitions (DMM), or munitions constituents (MC). The program
focuses on how potential munitions remaining on a site could affect people or the environment
The overall goals of the MMRP are to identify location, type, and to what extent munitions are
present; determine the hazards to human health and the environment; establish goals and
metrics to track progress; prioritize which sites require response actions before others; conduct necessary response actions; and transfer land consistent with the munitions response completed.
The first step in the MMRP is the Comprehensive Site Evaluation (CSE) which is conducted in
two phases. Phase I consists of historical record reviews, visual surveys, limited geophysical
surveys, and personal interviews; and Phase II involves a thorough site investigation with soil
and water sampling. We are currently initiating Phase I of the CSE in order to prioritize sites in Alaska for future work. Field work is scheduled for May of this year.
Elmendorf AFB is one of several military installations in Alaska included in the MMRP. There
are three suspected sites:
• B-26 Crash Site: this crash site is approximately one acre in size and contains airplane
wreckage. This site is remote and access is limited. Suspected munitions include .50 caliber
and larger ordnance.
• Small Arms Range: this site is approximately 10 acres in size and was used as a small
arms and grenade training range. The site is in a remote location in the northern portion of
the base and has limited access. Suspected munitions include small arms and grenades.
• Suspected Skeet Range: this site is approximately one acre in size and may have been
used as a skeet range. This site is remote with limited public access allowed. No evidence
of munitions of any type has been found at this location.
|
Louis Howard |
| 4/3/2006 |
Update or Other Action |
Letter from ADEC to DOD re: State of Alaska Department of Environmental Conservation's Expectations of the Munitions Response Site Prioritization Protocol Program.
The AK Department of Environmental Conservation (ADEC) wishes to thank you for the opportunity to participate in the application of the Munitions Response Site Prioritization Protocol (MRSPP) to Military Munitions Response Program (MMRP) sites throughout AK. We feel that active participation & cooperation between DOD, ADEC, EPA & other stakeholders is critical to ensuring the success of the program. The MRSPP is a congressionally mandated rule developed by the DOD to prioritize munitions response sites for cleanup under the DERP & BRAC acts. As such, we understand DOD is the lead agency responsible for cleanup & that ADEC involvement in application of the protocol is primarily a support role. However, the closure of sites under CERCLA & state environmental regulations will require ADEC &/or the US EPA concurrence.
To this end, ADEC is requesting that you & your contractors submit for review & comment the various work plans & documents used in the MRSPP process that correspond to applicable CERCLA documentation requirements (i.e. PA, SI, RI, FS, EECA, etc.). This request applies to all documents already generated in implementing the initial stages of the protocol as well as those that are yet to be generated under the MRSPP process.
We are making this request to provide for credible, legally defensible site characterization & evaluation in the MRSPP process while at the same time providing for efficient & timely ADEC review. Review of historical records, work plans & reports & other supporting documents will allow the project team to ensure that the information gathered is consistent throughout the installations & ADEC & that the appropriate information is gathered to make informed decisions. As sites are investigated, it is likely that several will require additional sampling due to unexpected circumstances. Review & approval of documents as the process moves forward will help minimize information or data gaps that may otherwise develop.
In the long run, concurrent review & approval of various documents will help reduce costs to DOD through a collaborative decision making process which ensures that site characterization, remedial assessment, & remedial actions are consistent with state & federal regulations. As these documents would need to be reviewed prior to “NFA” decisions, review during the MRSPP process will allow remedial action &/or final status decisions to be made in an expedited manner. Likewise, up-front regulatory acceptance should lead to faster agreement on site prioritization & appropriate, timely implementation of remedial actions.
Signed
John Halverson, Environmental Program Manager |
John Halverson |
| 12/29/2006 |
Update or Other Action |
Phase I draft final AF MMRP CSE Phase I report received. Elmendorf Site TS003 (MRA 2003) is a suspected skeet range, approximately 1 acre in size and may have been used as a skeet range. This site is remote with limited public access allowed. No evidence of munitions of any type has been found at this location.
No evidence of ordnance, pyrotechnics, explosives, propellants,
chemical warfare material, or radiological weapons has been found. The site has no access
controls (public access allowed).
Elmendorf Site TS003 is suspected to have been used as a skeet range in the 1940s. According
to a 1944 plat map, the Hillberg Lake area was designated as a recreation area with a skeet range. It is unknown if the skeet range was ever constructed.
A 2002 investigation by the Air Force determined that the 1944 map, with updates through 1949,
is the only historical evidence of a skeet range ever existing in this location. A 1950 aerial
photograph shows several buildings and disturbed ground in the suspected skeet range area;
however, the suspected skeet range was not obvious in the photograph. A 1962 aerial
photograph shows that the existing Hillberg Ski Area had been built, although the suspected
skeet range was again not obvious in the photograph. Several interviews conducted with local
skeet shooters and skeet range employees yielded no evidence of the presence of a skeet range in
the vicinity of Hillberg Lake. One employee of the Fort Richardson skeet range recalled that
retired military personnel stationed at Elmendorf sometimes talked of the presence of a skeet
range somewhere on Elmendorf AFB.
The MRA was found to be heavily vegetated and surrounded by mature trees. A small
clearing, which appeared to have been recently made by a bull dozer, was found in the center of
the suspected skeet range location. Several pieces of scrap metal were found in the clearing. The topography of the immediate area of the suspected skeet range is gently rolling. Barbed wire found just to the south of the suspected skeet range and was traced south into the woods and to a hill and marshy area behind the ski area maintenance facility. A four foot by eight foot pit, resembling a mortar emplacement, was discovered facing out toward the barbed wire fencing. Barbed wire was also found running into the woods, where a three-strand fence was discovered to run before a series of shallow, rectangular pits that had been backfilled
somewhat by erosion over time. It was unclear whether these features were associated with
military or recreational activities. There were no obvious signs of formal target houses or
shooting positions found.
One complete shotgun shell and several broken clay pigeons were found during the site visit.
The unexpended shotgun shell was found in the frequently used ski area parking lot adjacent to
the suspected range and appeared to be in good (operational) condition, suggesting it was not of
the appropriate vintage to be associated with the MRA. This was confirmed by the team UXO
expert, who identified the shell as less than one or two years old. The discovery of spent clay
shotgun targets, along with a partial clearing, support the conclusion that the area was used for shooting at some point. However, based on the physical evidence, it appears that it had not been heavily used and may not have been a formal range.
Geophysical mapping was conducted over two grids covering an area of approximately one
quarter acre. One grid was mapped in the clearing in the center of the suspected skeet range
location and the second grid was mapped between the slope of the ski hill and the range. The
subsurface investigation indicates little debris remains in the subsurface of the skeet range area. Anomaly densities in both grids were low with the highest anomaly density detected at 8
anomalies per acre. Many of these anomalies could be attributed to metal scrap on the surface. |
Louis Howard |
| 1/8/2007 |
Document, Report, or Work plan Review - other |
Staff reviewed and commented on the Comprehensive Site Evaluation Elmendorf Air Force Base December 2006.
General: A detailed description of each interview conducted should be included either in the text or as an appendix. In addition a more detailed description of the Archival research should be included including a description of important documents.
3.1: The first sentence is a little awkward. Please revise stating average summer highs and lows and average winter highs and lows.
4.0 General: Please include a section detailing the historical aerial photographic coverage reviewed as part of this investigation. Please include the years reviewed, frames, flight line, and indicate extent of coverage and source. The result of the site specific evaluation of aerial photography should be included in each section. While some interpretation is included in Section 7.0 it is not present in other section.
5.3.4.1, 6.3.4.1 & 8.3.4.1: The last sentence is a little confusing and appears to indicate that Multi incremental sampling will help in identifying contaminant “Hotspots”. Please revise to state that “The sampling approach including a combination of discrete and composite (Mulit-Incremental) soils samples will help in identifying …….”.
|
Guy Warren |
| 2/4/2008 |
Update or Other Action |
Letter from DOD Regional Environmental Coordinator Region 10 to ADEC Jennifer Roberts RE: Reporting on DOD Support of Explosives or Munitions Emergencies.
As the Department of Defense (DoD) Regional Environmental Coordinator (REC) for Region
10, my staff and I, along with the other Military Services, work with envITonmental and natural
resource agencies to exchange information on envITonmental topics, coordinate related projects
and initiatives, avoid cor.i!icts when possible, and help resolve issues efficiently. Our REC team appreciated the opportunity to discuss your request for notification of DoD explosives or
munitions emergency responses in support of civil authorities.
The DoD is firmly committed to assisting civil authorities, primarily those in law enforcement,
in responding in a timely and effective manner to explosives and munitions emergencies. DoD
provides this support to ensure the public safety of Alaskans and the envITonment. To continue to provide this support, we would like clarification on a couple of important issues.
First, although the DoD Explosive Ordnance Disposal (EOD) team's mission is generally limited to responding to military munitions, these teams often provide support to civil authorities when non-military explosives or munitions are encountered. When supporting requests by civil authorities, we do not believe DoD personnel are the "person in charge" pursuant to Alaska regulations for the purposes of notifying DEC. (See, e.g., 18 AAC 75.300 & 75.990(86).)
Nevertheless, as a matter of comity, but without relinquishing any legal arguments, rights or
defenses, DoD is voluntarily providing DEC the attached summary of DoD explosives or
munitions emergency responses from January through December 2007. The DoD is also willing
to discuss, if necessary, any additional reporting requests that you may have regarding DoD
explosives or munitions emergency responses in support of civil authorities. As part ofthis
discussion, DoD would like to know whether the notifications requested of DoD are the same as
those requested of other federal, state, or local emergency response personnel. (See, 42 USC
6961.)
Second, the DoD is also concerned about a provision in 18 AAC 75.315(b) that appears
to require a person who is not a responsible person, but who voluntarily undertakes an initial
response action, to perform a comprehensive cleanup. This provision is of concern to us because
DoD EOD teams voluntarily respond to all requests from civil authorities for support of an
explosives or munitions emergency regardless ofwhether a military munitions is involved,
although they are not legally required to do so.
This regulation may impose cleanup liability on DoD for its voluntary response. We would like to discuss this concern with your office and perhaps pursue a written agreement between the DEC and DoD that delineates the roles and responsibilities of each party.
I would appreciate the opportunity to further discllss our concerns with you and your
staff, and so I have asked my points of contact for this issue, Ms. Aubrey Baure and Maj Judith
Walker, to contact you in the near future.
Signed
Clare Mendelsohn DoD Regional Environmental Coordinator Region 10. |
Jennifer Roberts |
| 8/29/2008 |
Document, Report, or Work plan Review - other |
Staff reviewed the Draft Final of CSE Supplemental Phase I Site Evaluation Findings Report & MMRP CSE Phase II Work Plan EAFB Contract W91238-06-D-0019 Task Order DK01. ADEC has no comments on the Draft Final Supplemental CSE Phase I Findings Report Revision 01 July 2008.
General Comments
1. Lack of continuity between CSE Phase I report recommendations & CSE Military Munitions Response Program (MMRP) Phase II work plan
2. Lack of specificity regarding visual survey procedures, & Digital Geophysical Mapping (DGM) procedures (What they are & where they will be used). Also number & proposed location of samples is not provided. Nor is a general procedure for characterizing Small Arms Ranges (SAR).
3. The investigation proposed does not address potential sub-surface impacts from munitions use &/or disposal.
Figure 1-2 Installation Overview & Site Layout Page 3
The “C” battery appears to be located off Base. ADEC requests clarification from the AF on whether this site correlates with one of the formerly used defense sites (FUDS) AAA sites in Anchorage.
Table 1-1 Data Requirements for Elmendorf Air Force Base CSE Phase II
Suspected Skeet Range (TS003) Page 6
ADEC was under the impression the recommendation from CSE Phase I for this site was MC sampling. ADEC commented that this site will require characterization for lead. The final report includes statement that “never used by the AF as a formal training range & should be removed from considerations under the MMRP. ADEC disagrees & is unsure how comment resolution ended up this way, but this site could easily be closed with a couple of MI soil samples for lead. See ADEC’s draft “Guidance on Multi-Increment Soil Sampling” (as amended through March 2007) for further details on MI soil sampling at http://www.dec.state.ak.us/spar/guidance.htm#csp.
3.0 Interim CSM & Exposure Pathway Analysis Page 23
The text states the conceptual site model describes MC sources & possible receptors, & the interactions that link them. ADEC requests the Air Force change the text regarding the ICSM to state:
“It describes sources of MEC &/or MC at a site; actual, potentially complete, or incomplete exposure pathways (sediment, surface water, & GW); current or reasonably anticipated future land use; & potential receptors. The source-receptor interaction is a descriptive output of the ICSM.”
Section 4.5 Project Schedule
Table 4-1 Page 47
ADEC requests the AF provide the meeting notes from the Kick-off meeting & a list of all participants that attended the June 2008 meeting.
Section 5.4 Visual Survey Page 52
The section contains no specifics regarding the proposed visual surveys. ADEC requests the AF provide clarification on whether handheld detectors will be used & whether GPS tracking will be implemented during these surveys. ADEC requests the AF provide additional information on what % of the sites of interest will be visually surveyed. Since the AF is relying totally on visual surveys for sites of interest, this work plan should include a better description of the procedures that will be used.
Table 5-1 Non-Intrusive Surveys Page 61
If the “Munitions Known/Suspected” is “None Anticipated”, then ADEC requests the AF provide information on why these sites with this information are MMRP sites. It would seem appropriate to include what is suspected to be at the sites.
Table 5-5 Proposed Analytical Sampling Page 64
ADEC requests the AF check the information provided in the table with the CSE Phase I recommendations. This table should be consistent with the recommendations from CSE Phase I.
Section 5.5.1 XRF Survey & Surface Soil/Subsurface Soil Sampling Page 65
The text states “the soil will be further prepared by squeezing a representative aliquot through coffee filter papers to remove moisture.” This statement does not make much sense. ADEC recommends the AF delete the text & provide additional detail what will be done in the event saturated soil is located in the sampling area.
Table 9-4 Data Quality Objectives for Various Ordnance Sites
Comments apply to “Develop a decision rule” sections in Table 9-4. If no MEC are observed NFA is recommended. If MEC is observed a presumptive remedy may be recommended.” There are several problems with this decision rule. MEC is specifically defined as UXO, DMM, & explosive soil. MD is specifically not included in this definition. MD on the surface of the site should be cause for additional action. Also this totally ignores the subsurface of the site. This investigation is focused on visual surface surveys & therefore does not address potential sub-surface munition items. Therefore it is not possible to make any determinations regarding potential sub-surface conditions based on this investigation.
Section 9.8.2.2 Explosives Page 110
ADEC requests analysis include lab sub-sampling following air drying, grinding & mixing. |
Louis Howard |
| 9/15/2008 |
Update or Other Action |
Letter from Jennifer Roberts ADEC to Ms. Clare Mendelsohn, DoD Regional Environmental Coordinator. RE: Reporting on DoD Support for Explosives or Munitions Emergencies
I received your February 4,2008 letter and apologize for not responding sooner. The Alaska
Department of Environmental Conservation (ADEC) has a long and positive working
relationship with the Department of Defense (DoD). We understand DoD's primary mission is
national defense and appreciate the emergency response support DoD voluntarily provides to
civil authorities and the public. One such area of support is responding to discoveries of
munitions or explosives.
ADEC agrees that when Explosive Ordnance Disposal (EOD) teams respond to non-military
munitions or explosives, off military lands, DOD's response personnel are not considered the
"person in charge" with respect to Alaska hazardous substance reporting and response
requirements. When conducting voluntary responses under these circumstances, ADEC does
not consider DoD to be incurring liability for complete cleanup under 18 AAC 75 .315(b). We
hope this addresses your concerns with respect to this matter. If not, we are open to pursuing a
written agreement between ADEC and DOD delineating roles and responsibilities in these
cases.
With respect to your question of whether the notifications requested of DoD are the same as
those requested of other federal, state, or local emergency response personnel, the answer is
yes. In the event of a discovery of a release on a property, the property owner, for example, the federal agency, state agency, or other owner of that property, is required to notify ADEC. In addition, ADEC's Prevention and Emergency Response Program guidance has been amended
to include cross program coordination with the Contaminated Sites Program staff whenever
such reports are received.
The 2007 EOD emergency response summary for Alaska was helpful in better understating the
scope of these actions. ADEC's concern on being notified of the discovery of military
munitions or explosives is in ensuring former ranges, training areas, and munitions storage and
disposal areas where these items may remain are identified and addressed, as necessary, to help ensure protection of human health and safety. We would like additional information on a few
ofthe responses to help determine whether further investigation is warranted and will followup
on those via email. We also are interested in receiving similar periodic (semi-annual)
summaries of EOD responses. |
Jennifer Roberts |
| 2/25/2009 |
Document, Report, or Work plan Review - other |
Review of the Final Work Plan MMRP CSE Phase II Work Plan Elmendorf AFB, January 2009. 2.12.12 Special Considerations (Chemical Warfare Materiel, Depleted Uranium, etc.) Page 17 ADEC requests the Air Force provide a statement regarding the presence or absence of DU should be included in this section. ADEC requests confirmation from the Air Force that “Bioenvironmental Engineering” will notify the Tech Escort Unit in the event that CWM is identified.
Table 5-2 Non-Intrusive Surveys Page 51
See comment 1. Ammo Area B site is no longer shown on Figure 1-2. Also Munitions Known/Suspected should probably be the same as for Former Explosives Storage Area. Also not mentioned anywhere else in the report.
5.5.1 Visual Survey Page 61
Chemical Corps Building and Storage Area (CW006): Reconnaissance should not be limited to concrete building pads. Storage pads and internal roads should be identified from historical aerial photography and ADEC requests the Air Force include them in the investigation.
5.8 Analytical Program Page 68
This list does not include all analytes proposed for sampling as indicated in Table 5-6. ADEC requests the Air Force include references to the analytes. This comment is relevant for many subsequent sections and tables (e.g. Section 7.2, Table 7-1, Table 9-8, Section 9.8.2, etc.)
|
Louis Howard |
| 4/8/2010 |
Update or Other Action |
CSE Phase II report received.
Elmendorf MRS TS003 (MRA2003) is a suspected skeet range encompassing about one acre
and is located at 6796941 Northing and 348775 Easting (UTM, Zone 6 North, WGS 84, meters). The MRS is accessed from 41st St. and is positioned near the base ski area. The site is heavily vegetated with tall grasses and alder and is surrounded by mature trees. A small clearing, which appeared to have been made by a bulldozer, was found in the center of the suspected skeet range location. An all terrain vehicle (ATV) trail also crosses through the northern portion of the MRA. The topography of the immediate area of the suspected skeet range is gently rolling, transitioning to a hilly and marshy area behind the ski area maintenance facility. There are no obvious signs of formal target houses or shooting positions.
The Suspected Skeet Range is suspected to have been used as a skeet range in the 1940s. According to a 1944 plat map, the Hillberg Lake area was designated as a recreation area with
a skeet range. It is unknown if a formal skeet range was ever constructed.
A 2002 investigation by the Air Force determined that a 1944 map, with updates through 1949,
is the only historical evidence of a skeet range ever existing in this location. A 1950 aerial
photograph shows several buildings and disturbed ground in the suspected skeet range area;
however, the suspected skeet range was not obvious in the photograph. A 1962 aerial photograph shows that the existing Hillberg Ski Area had been built, although the suspected skeet range was again not obvious in the photograph. Several interviews conducted with local skeet shooters and skeet range employees during the CSE Phase I investigation yielded no evidence of the presence of a skeet range in the vicinity of Hillberg Lake. One employee of the Fort Richardson skeet range recalled that retired military personnel stationed at Elmendorf sometimes talked of the presence of a skeet range somewhere on Elmendorf AFB.
The visual survey of the Suspected Skeet Range (MRS TS003) was conducted on 6 July 2009. No evidence of shooting positions or formal skeet houses was observed during the visual survey. The total amount of skeet observed during both the visual survey and the XRF sampling effort amounted to less than one handful of clay target fragments. Based on field observations, it appears that this suspected skeet range had only minimal use. There was no evidence of UXO, DMM, or MD noted at the Suspected Skeet Range (MRS TS003) and no evidence of hazardous waste disposal was observed.
A total of 50 XRF samples for lead and seven analytical samples for PAHs were collected.
Lead concentrations in all XRF samples were below the most conservative human health screening criteria (400 mg/kg). Lead was detected above the most conservative ecological screening criteria (11 mg/kg) in 48 XRF samples (max concentration was 119.38 mg/kg). The maximum
concentrations of each PAH analyte was detected in sample SRP-SS-05. PAHs were detected above the most conservative human health screening criteria in six of seven analytical samples. Small amounts of skeet debris and the PAH exceedances were present in soil primarily in the western portion of the site. Constituents at the Suspected Skeet Range (MRS TS003) consist of PAHs from clay targets.
Further military munitions response action is recommended for the the Small Arms Range, and
the Suspected Skeet Range. At all other sites investigated under this CSE Phase II, there was
no evidence of UXO, DMM, MD, or hazardous waste disposal observed and no further military
munitions response is recommended.
Based on the results of the laboratory analyses, there were PAHs detected above human health
screening criteria. It is recommended that the volume of impacted soil be removed from the site
to eliminate further potential contamination to the site. |
Louis Howard |
| 5/6/2010 |
Document, Report, or Work plan Review - other |
Review comments on the Draft Final Work Plan MMRP CSE Phase II Report Elmendorf AFB, April 2010. 14.5 Future Response Actions and Objectives Page 14-3 ADEC concurs with the removal action at the Small Arms Range (MRA 2001) (MRSR001) and the Suspected Skeet Range (MRA 2003) (MRS TS003). ADEC is issuing a written determination no further military munitions response actions are needed at the remainder of the MRAs on Elmendorf Air Force Base. This determination may be reviewed and modified in the future if new information becomes available that indicates the presence of contaminants or exposures that may cause an unacceptable risk to human health or the environment.
|
Louis Howard |
| 8/4/2010 |
Document, Report, or Work plan Review - other |
Review comments of the Final Report MMRP CSE Phase II Report EAFB July 2010.
The Alaska Department of Environmental Conservation (ADEC) has received the above document for review on July 26, 2010. ADEC has no further comments on the document and concurs with Section 14.5 Future Response Actions and Objectives Page 14-3 proposed removal action at the Small Arms Range (MRA 2001) (MRSR001) and the Suspected Skeet Range (MRA 2003) (MRS TS003). ADEC is issuing a written determination no further military munitions response actions are needed at the remainder of the MRAs on Elmendorf Air Force Base. This determination may be reviewed and modified in the future if new information becomes available that indicates the presence of contaminants or exposures that may cause an unacceptable risk to human health or the environment.
|
Louis Howard |
| 9/7/2011 |
Update or Other Action |
ENGINEERING EVALUATION/COST ANALYSIS SEPTEMBER 2011 SMALL ARMS RANGE (MRA 2001/MRS SR001) and SUSPECTED SKEET RANGE (MRA 2003/MRS TS003) received. In support of the Military Munitions Response Program (MMRP), this engineering estimate and cost analysis (EE/CA) has been prepared to evaluate Non-Time Critical Removal Actions (NTCRA) at Small Arms Range (Munitions Response Area [MRA] 2001/Munitions Response Site [MRS] SR001) and the Suspected Skeet Range (MRA2003/MRS TS003) at the JBER Elmendorf Air Force Base (AFB) in Alaska.
The removal action purpose, scope, and an identification of Applicable or Relevant and Appropriate Requirements (ARARs) for the removal activities at JBER-Elmendorf. Removal Action Objectives (RAOs) for the Small Arms Range (MRS SR001) and the Suspected Skeet Range (MRS TS003) are as follows:
-Determine the appropriate screening criteria to apply for nitroglycerin at the Small Arms
Range by delineating the concentrations and extent of nitroglycerin in soil;
-Delineate the extent of PAH contamination in soil at the Skeet Range;
-Reduce the risk to human health and the environment through the removal of contaminated soil; and
-Obtain a No Further Action status for the Sites.
At the Suspected Skeet Range (MRS TS003), soil sampling will be performed to delineate the extent of PAHs above human health residential screening criteria, removal of PAH-impacted soil to below cleanup levels, and confirmation sampling. Detailed descriptions of the removal actions, data collection methods, and the quality assurance and quality control procedures will be provided in a separate Removal Action Work Plan.
PAH-impacted soils (approximately 4,200 BCY) will be removed to below cleanup levels and
transported for disposal at a pre-approved facility.
This EE/CA was developed in accordance with requirement under CERCLA as amended and consistent with the NCP, Section 300.415. A comparative analysis was performed to evaluate alternatives to mitigate contaminant-associated hazards at the Small Arms Range (MRS SR001) and the Suspected Skeet Range (MRS TS003) at JBER-Elmendorf, Alaska. The preferred alternative was Contaminated Soil Removal and Off-site Disposal. Contaminated soil removal best meets the RAOs for the Small Arms Range (MRS SR001) and the Suspected Skeet Range (MRS TS003) at JBER-Elmendorf, Alaska. The total project cost is estimated to be $3,393,650. |
Louis Howard |
| 9/20/2011 |
Site Added to Database |
A new site has been added to the database |
Mitzi Read |
| 9/21/2011 |
Exposure Tracking Model Ranking |
Initial ranking with ETM completed for source area id: 79163 name: JBER-Elmendorf Skeet Range MMRP |
Louis Howard |
| 9/23/2011 |
Update or Other Action |
Staff provided comments on the NTCRA draft work plan.
1.2 Add text, such as the following: “The USAF is undertaking the proposed removal action, as lead agency pursuant to CERCLA, Section 104(a). In accordance with 40 CFR 300.415(j), removal actions conducted under CERCLA are required to abate, prevent, minimize, stabilize, mitigate, or eliminate the release or threat of release of substances hazardous to public health, welfare, and the environment.”
4.2.8 All loads will be covered during transport to its disposal facility (18 AAC 60.015. Transport. (a) A person who transports solid waste shall keep the waste contained during transport.)
Table 4-3
JBER must ensure that they full comply with § 300.440 “Procedures for planning and implementing off-site response actions”, also known as the “Off-Site Rule” when transporting wastes to an off-site disposal facility.
5.1 18 AAC 75.990 (123) “subsurface soil” means soil that is more than two feet below the surface defines subsurface soil.
A-14 5.1 TestAmerica and any other corporate laboratory/backup laboratory will need to be currently certified/approved for the proposed analyses mentioned in this work plan. Please identify which TestAmerica laboratory will be utilized for this project on JBER since there are multiple laboratories listed on ADEC’s approved laboratory list.
WS-19 MI sampling requirements (as specified in ADEC’s MI Sampling guidance) will need to be incorporated and differ from those presented here.
C-2 All work conducted under this work plan is prepared as part of a Non-Time Critical Removal Action (NTCRA) under the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) Section 104 not a Remedial Investigation (RI).
|
Louis Howard |
| 11/1/2013 |
Update or Other Action |
Staff received the draft site closure report (MMRP) for several sites which also included the Suspected Skeet Range MRS TS003.
TS003 Suspected Skeet Range
The site encompasses about one acre & is located at 6796941 Northing & 348775 Easting (Universal Transverse Mercator, Zone 6 North, World Geodetic System 84 meters). The MRS is located near the ski area on base & is accessed from 41st Street. After completion of the 2012 Non-Time Critical Removal Action (NTCRA), there was no MEC hazard or significant MC risk to human health & the environment. Analytical results from confirmation samples collected at the site showed results below ADEC cleanup levels in the remaining soil, with the exception of one sample location, ELRA-SSR-S42-1, which was collected at MRS TS003 where the concentration of one PAH constituent (benzo(a)pyrene) was above the ADEC Under 40-Inch Zone cleanup level of 0.49 mg/kg. It was not possible to excavate further due to its close proximity to an adjacent building. However, based on the preliminary risk screening, using the 95 percent UCL, the concentration of benzo(a)pyrene on a site-wide basis at this site is below the ADEC cleanup level of 0.49 mg/kg. The remaining soil with benzo(a)pyrene is primarily under the building foundation & inaccessible.
Stockpiled soil was transported off site after being characterized to ensure legal compliance in the areas of profiling, transporting, & disposal. Contaminated soil was then transported to the appropriate facility. With the approval from the ADEC & the EPA & agreement that the site does not present a significant threat to human health & the environment, TS003 is eligible for site closure.
DA002 B-26 Crash Site
The 2009 CSE Phase II investigation revealed that there was no evidence of MEC observed at any location on site. Due to the nature of the site & existence of small arms ammunition, six XRF surface soil samples & two analytical surface soil samples were collected to determine whether there were impacts to surface soil from small arms debris or fuel from the aircraft. Based on the results of the visual survey & analytical sampling, no further military munitions response action was recommended for the site. These findings show that the site does not pose a threat to human health, safety, welfare, or the environment, & that site closure is appropriate. With approval from the ADEC & the EPA & agreement that the site does not present a significant threat to human health & the environment, MRS DA002 is eligible for site closure.
FR004 Susitna Gunnery Range Fire Point
Samples were collected & analyzed for GRO, DRO, RRO, metals, & explosives. There were no analytes detected in concentrations exceeding the human health screening criteria in any sample. No evidence of MEC was observed at any location, which presents no significant threat to human health & the environment; thus, no cleanup activities are required. Site conditions & land use are consistent with “No further military response action” without land use controls, making any land use acceptable.
Based on the existing conditions & the information available, Site MRS FR004 does not pose a significant threat to human health & the environment; therefore a site closure designation under ADEC 18 AAC 75.380 & CERCLA is appropriate.
FR005 Mortar Range 1A
Two analytical samples were collected, & there were no detections of explosives, GRO, DRO, or RRO, & VOCs were detected below the human health screening criteria. The only analyte found above both background & ecological screening criteria was copper associated with the active EOD range.
No further military munitions response action was recommended for Mortar Range 1A. Based on these findings, the site does not pose a threat to human health, safety, welfare, or the environment, & site closure is appropriate. With the approval from the ADEC & the EPA & agreement that the site does not present a significant threat to human health & the environment, FR005 is eligible for site closure.
CW006 Former Chemical Corps Building & Storage Area
The 2009 CSE Phase II investigation revealed that there was no evidence of MEC or MD observed at any location on site. Based on the results of the visual survey, analytical samples were not collected, & no further military munitions response action was recommended for the site. Based on these findings, the site does not pose a threat to human health, safety, welfare, or the environment, & site closure is appropriate for MRS CW006. With the approval from the ADEC & the United States Environmental Protection Agency (EPA), & agreement that the site does not present a significant threat to human health & the environment, MRS CW006 is eligible for site closure.
See site file for additional information. |
Louis Howard |
| 11/25/2013 |
Document, Report, or Work plan Review - other |
The Alaska Department of Environmental Conservation (ADEC) has received the above document for review and comment on November 1, 2013. ADEC has reviewed the information provided and concurs with the site closure for the following: B-26 Crash Site (DA002), Susitna Gunnery Range Firing Point MRS FR004, Mortar Range 1A MRS FR005, Small Arms Range MRS SR001, Former Chemical Corps Building and Storage Area MRS CW006, Former Explosives Storage Area MRS XU007, AA Batteries A, B, D, G, H West, H East, and HQ MRS ML922, AA Battery South West MRS ML923, Four Former 40-mm Gun Positions MRS ML924, AA Battery North of North-South Runway MRS ML925, and the Airplane Target Butts North of East/West Runway MRS ML926.
Based on the information available, ADEC has determined the sites have been adequately characterized under 18 AAC 75.335 and have achieved the applicable requirements under the site cleanup rules. This decision is subject to a future ADEC determination that the cleanup is not protective of human health, safety, or welfare, or of the environment, and further site characterizations and cleanup may be necessary under 18 AAC 75.325-.390. See attached comment form for the Suspected Skeet Range MRS TS003.
2.4 Justification for Site Closure
ADEC agrees with the conclusion the Suspected Skeet Range (TS003) does not present a significant threat to human health and the environment and is eligible for site closure under the MMRP. ADEC, in accordance with 18 AAC 75.380(d)(1), has determined that site closure and no further remedial action or investigation is appropriate at TS003 under the MMRP.
However, the EPC calculations for benzo(a)pyrene (BAP) contamination at the site do not account for the unknown concentrations beneath the “Storage Building” at TS003. The contamination is currently inaccessible and has not been fully characterized.
ADEC will require that the Air Force note on their land records that BAP contamination exists at TS003 near the building foundation and in the event that the remaining contaminated soil becomes accessible (by the building or other structures being removed) the Air Force will be required under 18 AAC 75.300 to notify ADEC and evaluate the environmental status of the contamination in accordance with applicable laws and regulations; further site characterization and cleanup may be necessary under 18 AAC 75.325-.390.
Pending written confirmation that these land use controls have been documented by Air Force, a cleanup complete determination with institutional controls will be assigned to TS003 in ADEC’s database.
|
Louis Howard |
| 11/29/2013 |
Institutional Control Record Established |
Institutional Controls established and entered into the database. |
Louis Howard |
| 12/9/2013 |
Cleanup Complete Determination Issued |
ADEC has reviewed the Air Force's responses to ADEC's comments and finds the responses adequate. Please finalize the document and the site will be assigned a cleanup complete with institutional controls designation. Residual PAHs remain at the site but is inaccessible. |
Louis Howard |
| 3/24/2015 |
Update or Other Action |
Distance to Subsurface Water Right Location is approximately 640 feet, Drinking Water Program CASE ID: LAS 25386, Customer Name: USDOD USAF 673 CEC/CEIEC, Water system name: USAF JBER Elmendorf HILLBERG SKI Area, located at BUILDING 23400, Active, Groundwater Well source, Water System No. AK2218475. 2 service connections, 200 persons served. Source Facility ID: 34183, Source ID: WL001, Legacy PWSID: 218475.001. AF POC Danica Wright, NCOIC, Industrial Hygienest. 907-384-0424, 673 Bioenvironmental Engineering, 604 Richardson Drive, JBER AK-99506. danica.wright@us.af.mil. |
Louis Howard |
| 9/16/2016 |
Update or Other Action |
Supplemental WP received to address the groundwater sampling, institutional controls (IC) inspection, and landfill cap inspection activities associated with the 2016 Long Term Monitoring (LTM) at the Joint Base Elmendorf-Richardson (JBER), Sites PL081, CG551, ST408, CG530, SO510, SS522, SO507, SS418, TS003, CG543, CG529, TU107, ST048, CG509, SO508, SO549, AT035, AT029, SS019, and DP009.
As a requirement of the 2016 Environmental Long Term Monitoring contract, the following work shall be performed at JBER Site TS003:
? Perform IC inspection |
Louis Howard |
| 3/22/2017 |
Update or Other Action |
2016 Draft Report for Remedial Action Operation and Land Use/Institutional Control at JBER received for review and comment.
Based on the USAF Site Closure Report (2014a), it indicates ADEC will require ICs that note
that benzo(a)pyrene contamination may exist at TS003 near the building foundation, at
concentrations that exceed ADEC standards. In the event that the remaining contaminated soil
becomes accessible (by the building or other structures being removed), the USAF will be
required under 18 AAC 75.300 to notify ADEC and evaluate the environmental status of the
contamination in accordance with applicable laws and regulations; further site characterization
and cleanup may be necessary under 18 AAC 75.325-390.
The inspection of Site TS003 revealed no evidence of ground disturbance at this site. Revegetation
appeared to be occurring on site. Various buildings, vehicles, pieces of equipment, and active aboveground storage tanks were observed on site and no erosion was observed along the access roads. Photographs 1 through 4 in Photograph Log A6 present the general condition of Site TS003.
See site file for additional information. |
Louis Howard |
| 4/12/2021 |
Document, Report, or Work plan Review - other |
DEC submitted comments on Draft JBER Basewide UFP-QAPP dated February 2021. |
William Schmaltz |
| 5/19/2021 |
Document, Report, or Work plan Review - other |
DEC Reviewed and approved of Basewide Uniform Federal Policy - Quality Assurance Project Plan. QAPP summarizes general activities for a 5 year period on JBER. |
William Schmaltz |
