Division of Spill Prevention and Response

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Site Report: Port Heiden - Fort Morrow FUDS


Site Name: Port Heiden - Fort Morrow FUDS
Address: East of Meshik Village, Port Heiden, AK 99549
File Number: 2637.38.003
Hazard ID: 73
Status: Active
Staff: Louis Howard, 9072697552 louis.howard@alaska.gov
Latitude: 56.945450
Longitude: -158.622635
Horizontal Datum:NAD83


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

In 1987 various wastes were identified: asbestos, PCBs (polychlorinated biphenyls), diesel, asphalt, transformers. The Corps of Engineers conducted cleanup work in 1990-92 on both Fort Morrow and the Air Force White Alice Communication System (WACS) site. PCB contaminated soil was excavated and shipped out-of-state. Military buildings and debris were disposed of in two permitted landfills. Thousands of 55-gallon drums were collected, emptied and disposed of with the other debris in the landfills. The bulk fuel tank farm located on the shoreline in the old village of Meshik, which supplied fuel to the White Alice Site, was included in the removal action. The fuel tanks were removed and sold to Reeve Aleutian Airways (Reeve ceased operations on Dec. 5, 2000)and approximately 10,000 cubic yards of petroleum contaminated soil were excavated and thermally treated. Diesel fuel was observed on the groundwater. Due to cost over-runs the FUDS cleanup work was not completed and many areas where soil removal was planned did not get addressed. No draft or final reports were completed. RCRA (resource conservation recovery act) EPA ID#AK3210890080 Hazardous waste activity: generator 1. Cleanup being performed by Army Corps of Engineers under FUDS = Formerly Used Defense Sites. Land slated for transfer to BLM after cleanup with final disposal to private/state sector. CERCLA ID AK8570028698. Port Heiden has 2 former military installations: The larger of the two, Fort Morrow was a WWII Army Air Corps base (now a formerly used defense site, FUDS) and Port Heiden Radio Relay Site (RRS) or White Alice Communication System (WACS) site, which is still owned by the Air Force. Fort Morrow was authorized for construction in December 1941 as an airfield and necessary protective garrison for the air defense of Alaska and the naval base at Dutch Harbor. In 1942, the War Department acquired 1,023,927.22 acres for Fort Morrow. Construction began in July 1942 and included cantonment buildings, a hospital and docking facilities. Following WWII, the site was abandoned. The CAA/FAA had the property from 1948 to the 1960s. In 1966 when the State of Alaska (DOT/PF) took over ownership of the airport. In the 1950s the Air Force acquired 172.04 acres within the former Fort Morrow and constructed the WACS (Port Heiden). The Air Force operated the WACS until 1969 when converted to Radio relay site, which became obsolete in the 1970s and was abandoned in November 1978.



Action Information

Action Date Action Description DEC Staff
12/31/1938 Update or Other Action To ensure a federal focus on aviation safety, President Franklin Roosevelt signed the Civil Aeronautics Act in 1938. The legislation established the independent Civil Aeronautics Authority (CAA), with a three-member Air Safety Board that would conduct accident investigations and recommend ways of preventing accidents. The legislation also expanded the government's role in civil aviation by giving CAA power to regulate airline fares and determine the routes individual carriers served. In 1940 President Roosevelt split the CAA into two agencies, the Civil Aeronautics Administration, which went back to the Department of Commerce, and the Civil Aeronautics Board (CAB). The offshoot of the original CAA retained responsibility for ATC, airman and aircraft certification, safety enforcement, and airway development. CAB responsibilities included safety rulemaking, accident investigation, and economic regulation of the airlines. On the eve of America's entry into World War II, for defense purposes, CAA extended its air traffic control system to include operation of airport towers. In the postwar era, ATC became a permanent federal responsibility at most airports. The postwar era also witnessed the advent of commercial jets. Louis Howard
6/17/1942 Update or Other Action Building Fort Morrow - Orders provided for the construction of a new garrison & staging field, which was to be built within six months. The program called for containment buildings, docking facilities, & storage of avgas* in drums. Housing, hospital facilities, warehouses, cold storage, & a Kodiak "T" hanger with the technical facilities to provide Air Corps operations & maintenance were also provided. (NOTE TO FILE: In 1942, the Supercharge Rating Test was introduced for aircraft engines. The effect on supercharging, however, was that the engine performance vs TEL levels did not match the earlier testing done on non-supercharged engines (called normally aspirated) when the original octane rating system was created. The result was testing to map engine performance vs TEL in supercharged engines. This mapping then resulted in the supercharge rating for aviation gasoline. Also in 1942, leaded military fuels in excess of 100 MON & 125 PN (supercharge number) were being used, the name of this fuel was quickly changed to be called 100/130. Between 1942 and the end of WWII in 1945, near the end of the WWII, grade 115/145 Avgas was introduced. The engine demands on the fuel to produce more horsepower were tremendous, and so the 115/145 fuel was developed with 8 mg of TEL per gallon.) On June 17, 1942, 2nd Lt. Oral B. Dold & fifty enlisted men of Company B, 807th Engineers arrived at Port Heiden with their mission to make plans for the construction of roads & to find a suitable site for the airport. According to an engineer who experienced the initial landing, entering Port Heiden was as treacherous for the U.S. Army as it was for the Russian Orthodox priests: Upon approaching Port Heiden from the Bering Sea side, a string of islands appears, stretching across the mouth of the bay. The entrance to the bay is very difficult to locate if one is unfamiliar with the locality. The entrance is located between the northeasternmost point of the string of islands & the mainland itself. The water depth in the channel varies from approximately 2 to 11 fathoms at low tide & the water within the bay itself is very shallow being non-navigable except in channels at low tide. Upon the arrival of troops at Port Heiden there were no buildings or structures except for the saltery, an old church, & a few sod huts at Meshik Village. Because of extreme tides & dangerous shoals situated beneath the shallow waters of Port Heiden, all ships had to anchor in the open sea approximately 4 miles off shore. Lighters unloaded troops & supplies. As soon as the troops reached shore, some were immediately employed in setting up a temporary campsite, while others were employed in unloading barges. Because no barge dock or mechanized equipment was available to the troops for unloading operations, all cargo was "man-handled." According to one witness, the troops experienced typical Aniakchak weather, for it was "blustery, wind & fog prevailed & the water very choppy, making the loading of barges a most difficult task." Moreover, the men were at the mercy of other natural forces, for "the loading & unloading of supplies [was] governed by the tides." The temporary campsite was established approximately three hundred yards northeast of Meshik village, with the Russian Orthodox Church substituting as the first Army HQ. For the first few days, the troops endured the personal discomforts of living in tents & unloading by hand. The permanent campsite they would construct was necessary for the refueling & servicing of airplanes on their flights to & from the Aleutian Islands. Moreover, if an attack came from the Pacific, the men needed to be prepared as soon as possible. Fort Morrow was constructed so that it could also serve as a tactical operating base at a moment's notice. Therefore, personnel were immediately engaged in preparing defense positions such as gun emplacements, foxholes, slit trenches & barbed wire entanglements along the Port Heiden beachfront. John Halverson
9/28/1942 Update or Other Action Areas Used by the Chemical Warfare Service During the 1900s (historical division U.S. Army Chemical & Biological Defense Command compiled by Kathy Ciolfi). Fort Morrow Alaska Ltr. (Letter) 470.6 (CWS), 1st Lt. J.A. Romanczuk, Asst. AG., to C CWS., 28 Sep 42., Subj: Toxic Agents for Alaska Defense Command. 1. The Commanding General, Alaska Defense Command has requested the shipment of vesicant agent and airplane spray tanks to stations of his command. He is fully cognizant of the War Department instruction, April 25, 1942, prescribing approval of War Department prior to use of toxic chemicals. 2. Recommend early shipment to stations in Alaska as Follows: Station HS Tons Airplane Spray Tanks M-10 & filling lines, complete Pump Fort Glenn 50 100 6 Fort Randall 50 100 6 Longview 50 100 6 (Adak-Longview Army Airfield: Although this operational area was initially named "Longview Army Airfield," by early 1943, it was renamed Davis Army Airfield.") Fort Greely 30 75 4 Fort Richardson 30 200 16 3. Recommend for future planning but not immediate delivery, for stations as follows: Station HS Tons Airplane Spray Tanks M-10 & filling lines, complete Pump Fort Morrow 15 50 4 Naknek 15 50 4 Bethel 15 50 4 Cordova 15 50 4 Annette 15 50 4 Louis Howard
10/12/1942 Update or Other Action Public Land Order 48 signed on Oct. 12, 1942, Alaska; withdrawing public lands for military purposes. Revoked by PLO No. 528 (13 FR 6977, 7432). Federal Register citation: 11 FR 8362–8370. General Land Office Public Land Order No. 48 Fort Morrow, Alaska, Port Heiden Area, Alaska Peninsula, Alaska. Description: Beginning at a point on the Alaska Peninsula 56 degrees 40 minutes North latitude, 158 degrees 20 minutes West latitude, Thence by metes and bounds, West, along parallel of latitude 56 degrees 40 minutes N., to line of mean high tide on east shore of Bristol Bay; Northeasterly, along line of mean high tide, Bristol Bay, to a point, approximate latitude 57 degrees 12 minutes N., longitude 158 degrees 20 minutes W.,; Southeasterly, in a straight line, to line of mean high tide on the most northerly point on the shore of Amber Bay , approximate latitude 56 degrees 52 minutes N., longitude 157 degrees 24 minutes W., Southwesterly, along line of mean high tide, Amber Bay, Aniakchak Bay, Sithum Bay, around Cape Kurulum to a point west shore of Hook Bay, approximate latitude 56 degrees 32 minutes N., longitude 158 degrees 9 minutes W., Northwesterly, in a straight line to the point of the beginning. PLO No. 528 Nov. 17, 1948 See PLO No. 22. FR citation: 13 FR 6977, 7432. PLO No. 22 Aug. 6, 1942 .. Arizona; withdrawing public lands for bombing range, War Department. Revoked by PLO No. 528 (13 FR 6977, 7432). FR Citation: 7 FR 6376 John Halverson
5/24/1943 Update or Other Action Order No. 9337 of April 24, 1943 and section 4 of the act of May 24, 1928, c. 728. 45 Stat. 729 (49 U.S. C. 214) it is ordered as follows: Subject to valid existing rights, the tract of public land described below by metes and bounds is hereby withdrawn from all forms of appropriation under the public land laws and reserved for the use of the Civil Aeronautics Administration (CAA), Department of Commerce, in the maintenance of air-navigation facilities, the reservation to be known as the Air-Navigation Site Withdrawal No. 247. The area described contains approximately 10,350 acres. It is intended that these lands shall be returned to the administration of the Department of Interior, when they are no longer needed by the Department of Commerce for the purpose of which they are reserved. Public Land Order No. 48 of October 12, 1942, reserving certain public lands for the use of the War Department for military purposes is hereby revoked. Louis Howard
10/7/1945 Update or Other Action Despite the environmental obstacles, between 1942 and 1943, the Army had transformed the Aniakchak landscape surrounding Port Heiden into a working air base. By the end of summer, 1942, the Army established a weather reporting station. During September and October, the Civil Aeronautics Authority (CAA), the predecessor to the Federal Aviation Administration (FAA), made a survey for a radio range, control tower, radio station, and hangar — facilities that contributed to the safe landing of Army personnel, including Major General Simon Buckner and Colonel Lawrence Castner, who visited Fort Morrow on September 4, 1942. By February 5, 1943, the range station was completed. On the same day, the Army Airways Communion System commissioned a point-to-point and air-to-ground facility, further improving the control over planes in the area after the control tower was commissioned on November 15, 1943. On the same day, the hangar was also completed. In late 1943, the installation of runway boundary marker lights was finished. [25] That year, Mayor Fiorello H. La Guardia of New York City, who arrived with Brigadier General Frank L. Whittaker, visited Fort Morrow. Apparently, they stayed for one hour. When news reached Fort Morrow that allied troops had gained victory in Europe during the spring of 1945, the day was celebrated as a special holiday with free beer and buffet lunch all day at the mess hall. Then, on September 4, 1945, less than a month after the American B-29 Enola Gay dropped an atomic bomb over Hiroshima, Japan, and effectively ended World War II, Brigadier General Paul E. Burrows returned to Fort Morrow for a brief visit. At a meeting with all base personnel in attendance, he informed Fort Morrow's officers that it had been decided that the base would be closed as an Army post. As one witness recalled, "though there was no demonstration at the time, everyone was overjoyed at the prospect of returning to a more cheerful part of the world." On October 7, 1945, orders arrived, officially inactivating the Army Air Base, Fort Morrow. John Halverson
3/25/1949 Update or Other Action FAA involvement at Port Heiden began March 1949 with PLO No. 562/ANSW No. 247, which withdrew 10,351) acres for use by FAA (formerly CAA) in the maintenance of air navigation facilities. FAA Real Estate: PLO No. 562/ANSW No. 247 - Withdrew 10,350 acres of land for use by CAA in maintenance of Air Navigation Facilities; the reservation is to be known as ANSW No. 247. PLO No. 48 of October 12, 1942, was revoked so far as it was affected by ANSW No. 247. Louis Howard
5/26/1952 Update or Other Action Withdrawing Lands for Use of Department of the Air Force for Military Purposes. By virtue of the authority vested in the President. and pursuant to Executive Order No. 10355 of May 26, 1952, It is ordered as follow a: 1. Subject ·to valid existing rights and the provisions of existing withdrawals, the following-described public lands in Alaska. are hereby withdrawn from all forms of appropriation under the public land laws. Including the mining but not the mineral leasing laws nor disposals of materials under the act of July 31. 1947 (61 Stat. 681: 30 U.S.C. 601-604), as amended. and reserved for use of the Department of the Air Force for military purposes. The total acres withdrawn by this order is 1,188.37 acres. 2. The withdrawal made by paragraph la of this order shall take precedence over but not otherwise affect the reservation made by Public Land Order No. 2216 of December G, 1960, for the Izembak National Wildlife Range, provided, that personnel of the United States Fish and Wildlife Service shall have access to the lands for management of the wildlife resources. 3. Public Land Order No. 562 of February 18, 1949, which created Air Navigation Site Withdrawal No. 247, is hereby revoked so far as it affects the lands described In paragraph lb of this-order. 4. The withdrawal made by paragraph le of this order shall be subject to the right of the grazing lessee to enter upon the land& to round up livestock. Louis Howard
5/11/1961 Update or Other Action FAA Real Estate: PLO No. 2374 - Transferred 62 acres from CAA, ANSW No. 247, to the United States Department of the Air Force for military purposes. Louis Howard
9/13/1961 Update or Other Action FAA Real Estate: PLO No. 2495 - Revoked 6,292 acres, which were used by FAA in maintenance of an air navigation facility, from ANSW No. 247. Louis Howard
4/15/1966 Update or Other Action FAA Real Estate: Quitclaim Deed - The United States transferred and conveyed a portion of ANSW No. 247, as revised by PLO No. 2495, to the State of Alaska. The land transferred consisted of 3,500 acres which was used by FAA for air navigation facilities. The difference in acreage is unexplainable but may be due to eroding shoreline and exclusion of submerged lands. See United States Survey 9398 in document 7, page 7. Louis Howard
3/1/1978 Update or Other Action FAA Real Estate: Contract No. DOT-FA78AL-8767 - The State of Alaska licensed FAA for 61.98 acres to install, operate, and maintain the RCAG, NDB, directional measuring equipment (DME), and single frequency outlet (SFO) facility. The license is renewable annually, but not to extend beyond September 1998. Louis Howard
12/16/1985 Interim Removal Action Approved U.S. Army Corps of Engineers Alaska District ER-86-01 Public notice proposes to clean up debris at Port Heiden including an abandoned WWII army base & a "White Alice" (WA) communications site. The proposed action is to remove & dispose of unsafe & unsightly structures & associated debris. The project consists of removal & disposal of: 1) approximately 280 Quonset/Pacific Huts; 2) collapsed wood frame buildings (150); 3) Two (2) large fuel tanks (250,000 gallon); 4) Three (3) radio towers (two 100 ft. & one 50 ft. tall); 5) (8,000+) 55 gallon metal barrels; 6) a "White Alice" (WA) site- four (60 ft.) parabolic troposcatter antennas & feedhorns, a (30,000 sq. ft. ) reinforced 2 story concrete building with central (45 x 45 ft.) five story tower, interconnnecting electrical conduits, a 24,000 gallon fresh water storage tank, two buried (20,000 gallon) fuel tanks, two small (150 sq. ft.) concrete buildings, & a septic system; 7) miscellaneous materials including: metal scraps & debris, equipment, vehicles, steel pipe, wire, etc. 8) Asbestos material (approximately 80 cubic yards) Cleanup plans involve collapsing the Quonsets & transport of the debris to burial sites. Other metal debris, including barrels, sheet metal, equipment, vehicles, towers, pipe, & other miscellaneous materials will be collected & transported to disposal pits & also buried. Wooden material will be collected & moved to specified sites for burning. Removal of WA site will involve demolishing the concrete buildings by drilling & blasting, using heavy equipment, or use of a wrecking ball. Metal towers will be dismantled for salvage or burial. Large tanks will remain intact for use by local residents, salvaged, or drained, dismantled & buried if no use is found. Any petroleum products will be drained or pumped from tanks or fuel lines for reuse or disposal. All disturbed sites will be revegetated following cleanup activities. Disposal methods & specifications WILL follow STATE, FEDERAL & local regulations & procedures. Cleanup will promote the long-term positive effects on visual aesthethics, removing dangerous debris & structures, & by removing the potential for petroleum products to leach from rusting tanks fuel lines & barrels. Environmental restoration will occur through natural processes once structures & debris are removed. The environmental assessment (EA) identifies that no significant environmental impact will occur from cleanup of Department of Defense structures & debris at Port Heiden. The appropriate resource agencies have been contacted & informed of the proposed action & none have indicated objections to the Findings of No Significant Impact (FONSI). The accompanying EA & document review support the conclusion that the proposed project does not constitute a major Federal Action significantly affecting the quality of the human environment. Therefore, an environmental impact statement is not neccessary for the proposed clenanup of DOD debris at Port Heiden. Current land use of Fort Morrow & the WA site is determined by the road system & location of useable structures. The road system provides transportation routes for hunting & fishing, berry picking & other subsistence & recreational activities. The airport is important both to the economy & as the only transportation link outside of the community. Possible community expansion or camp construction may occur in response to oil & gas development in the area. Borrow sites are located throughout the site associated with existing roads & the airport. Future upgrading of the existing runways will utilize additional gravel sites. More recently borrow pits & selected sites were used by the Air Force for disposal of wastes & material from the WA site. Adjacent to the old military dock, a site was used for garbage disposal by the military & more recently by the Village of Meshik creating a mixture of metal debris & garbage. Use of old wooden buildings on the Fort by local residents is occurring primarily in the airport & dock sites. Buildings are used for storage or shop space. No unique or historic buildings or sites were found or identified within the project area. The fuselage & wings of a P-38 World War II aircraft were located & remain in an existing disposal site adjacent to the airport. No archeological sites were identified within Fort Morrow or at the beach area. The village of Meshik is located on a centuries old site adjacent to the World War I1 dock & WA fuel storage tanks. The immediate dock area was searched for possible sites but due to the great deal of disturbance of the ground by development & wave action, any traces of sites were removed long before now. Funding for action is under the Public Law 98-212 which implements the DOD Defense Environmental Restoration Account (DERA). John Halverson
5/6/1986 Update or Other Action ADEC received a letter from the Air Force stating that it had completed cleanup actions including removal of industrial chemicals including PD680 solvent*, battery acid, paints, engine starter fluids, detergents, oils and fuels. It also stated that PCB contaminated soil was removed and shipped to CONUS (?). The letter states that the Corps would likely be doing additional building demolition and debris removal in the future. *Each item the Govt. orders must have an N.S.N, a National Stock Number, unless the Agency gets special permission to local purchase the item. Each N.S.N. item goes out for bid and has an associated minimum specification. The specification for PD680, aka. Stoddard Solvent, back in the 1980's and before this time, was for a petroleum based degreaser with a specified flashpoint. No requirement for non-halogenated existed. Besides that, because Alaska was so far from vendors that supplied the Government, many federal agencies in Alaska purchased solvents locally. There were no qualifications on those solvents and more often halogenated solvents worked with less effort than pure petroleum distillates, so they were preferred. NSNs ordered through the PD-680 specifications had some batches with TCE, Methylene chloride, etc; it depended on who the supplier to the Government was at the time. So as a result between 1980 and 1983, some PD680 batches were in fact halogenated. For historical releases it pays to be suspicious of drums that say PD680 or Stoddard Solvent. John Halverson
11/11/1986 Update or Other Action In 1986, samples were collected as part of a Corps of Engineers' site investigation throughout Port Heiden area including the WACS and POL Tank Area. Results indicated the presence of PCBs up to 15 mg/kg in the vicinity of the auto shop, and halogenated VOCs up to 84.2 ug/kg outside the generator room. One sample was collected from the POL tank area and was analyzed for heavy metals; none were found. TO FILE: *PCBs belong to a broad family of man-made organic chemicals known as chlorinated hydrocarbons. PCBs were domestically manufactured from 1929 until their manufacture was banned in 1979. Aroclors 1016, 1242, 1254, and 1260 are complex mixtures of polychlorinated biphenyl (PCB) congeners, prepared by the chlorination of biphenyl. For Aroclors 1242, 1254, and 1260, the chlorination reaction was stopped when the weight percent chlorine of the product had reached 42, 54, or 60%, respectively. By contrast, Aroclor 1016 was prepared by the fractional distillation of Aroclor 1242, which excluded the higher boiling (i.e., more highly chlorinated) congeners. Aroclors 1016, 1242, 1254, and 1260 were the most widely used PCBs in the United States, and accounted for 92% of all 1958-1977 production (Monsanto, 1980). Polychlorinated biphenyls were versatile materials which found use in a variety of applications including plasticizers, printing inks, and heat exchange, dielectric, and hydraulic fluids. The dielectric properties, chemical stability, and noncombustibility of PCB fluids made them a particularly attractive alternative to flammable mineral oils for use in capacitors and indoor transformers. Concerns in the late-1960s regarding the environmental accumulation of highly chlorinated PCB mixtures resulted, in 1971, in a voluntary cessation of the manufacture of Aroclors 1232, 1248, 1260, 1262, and 1268; the introduction of Aroclor 1016; and to a restriction in PCB usage to totally enclosed systems. The Toxic Substances Control Act of 1976 made the manufacture, importation, sale, or use of PCBs illegal after 1978. Jennifer Roberts
4/21/1987 Update or Other Action FINDING OF NO SIGNIFICANT IMPACT In accordance with the National Environmental Policy Act of 1969, as amended, the U.S. Army Engineer District, Alaska, has assessed the environmental impacts of the following action: Defense Environmental Restoration Account Port Heiden, Alaska The project consists of removal & disposal of: 1. 280 Quonset huts. 2. 150 collapsed wood frame buildings. 3. Two 250,000-gallon fuel tanks. 4. Three radio towers (two 100-foot, one 50-foot). 5. 8,000 55-gallon barrels. 6. A White Alice site: four 60-foot parabolic troposcatter antennas & feedhorns; one (30,000 sq. ft.) reinforced two-story concrete building with a central five-story tower (45 x 45 ft.); interconnecting electrical conduits; one 24,000-gallon freshwater storage tank; two 20,000-gallon buried fuel tanks; two small concrete buildings (150 sq. ft.); & a septic system. 7. Miscellaneous material, including: metal scraps, equipment, vehicles, steel pipe, wire, & other debris. 8. Asbestos material (approximately 80 cu. yds.). 9. Residue & waste POL, less than 3,000 gallons. These debris & structures are located on the flat tundra plain adjacent to Port Heiden on the site of Fort Morrow, a World War II Army air base. Structures & debris are found in several distinct areas within a five-mile radius of the Fort Morrow runway. Cleanup plans involve collapsing the quonsets & transport of the debris to burial sites. Other metal debris, including barrels, sheet metal, equipment, vehicles, towers, pipe, & other miscellaneous materials will be collected & moved to specified sites for burning. Equipment & vehicular use will be limited to sites on or near the existing road system. Machinery usage in areas away from any roads will be restricted to soft, rubber-tired vehicles or prohibited. Removal of the White Alice site will involve demolishing the concrete buildings by drilling & blasting, using heavy equipment, or use of a wrecking ball. Metal towers will be dismantled, & buried if no use is found. Any petroleum products will be drained or pumped from tanks or fuel lines for reuse or disposal. All disturbed sites will be revegetated following cleanup activities. Disposal methods & specifications will follow State, Federal, & local regulations & procedures. Ground surface disturbance & equipment noise, are unavoidable short-term impacts. Burning wood materials & equipment operation will produce smoke which will quickly dissipate in the strong, steady winds. Cleanup will promote the long-term positive effects on visual aesthetics, by removing dangerous debris & structures, & by removing the potential for petroleum products to leach from rusting tanks, fuel lines, & barrels. Environmental restoration will occur through natural processes once structures & debris are removed. The environmental assessment (EA) identifies that no significant environmental effects will occur from cleanup of Department of Defense structures & debris at Port Heiden. The appropriate resource agencies have been contacted & informed of the proposed action. Comments were received, & the USFWS, Western AK Ecological Services objected to deficiencies in the assessment. The EA was identified as being incomplete in three areas: 1) the lack of site-specific information regarding the chemical nature of hazardous &/or toxic substances & the extent of their habitat contamination; 2) the presence of generic, unsubstantiated statements regarding the environmental safeguards to be employed to minimize impacts; & 3) identification of SW &/or HW disposal sites. During meetings & consultation with the USFWS, the objections were addressed with the following resolutions: that the Corps would improve the assessment in order to incorporate the USFWS concerns; to include the USFWS in the project plans & specifications review; to provide the results of Toxic/Hazardous Material sampling & determine the effects of these materials on the environment; to provide details of criteria used for establishing disposal sites; & to establish a closer working relationship with the USFWS. The U.S. Army Engineer District, Alaska, will remove & dispose of abandoned DOD facilities, structures, & debris at Port Heiden, Alaska. Cleanup includes removing & disposing of debris at both Fort Morrow, a World War II Army base, & an abandoned White Alice Communications System (WACS) site. Cleanup will involve demolishing buildings, dismantling structures, burning wooden debris, & burying non-salvaged material in ADEC approved on-site landfills. Fuel & water tanks will be drained, cleaned, & crushed before burial. Several tanks have been identified for salvage & will remain intact as will several wooden buildings. Petroleum products will be collected, placed in containers, & tested for Toxic/ Hazardous Material (THM), as will any other materials suspected of being toxic or hazardous. See site file for additional information. Louis Howard
12/8/1987 Update or Other Action Engineering Report DERP Sampling Results and Cleanup Design for Port Heiden and Port Moller by the AK Dist Corp of Engineers Materials and Instrumentation Section received. Problem: Quonset huts, wooden buildings, 55-gallon POL drums, vehicles, and other debris were abandoned on this site by the Army after World War 11. White Alice Radio relay site facilities built in the 1950s including a main composite building, four antenna and support structures were abandoned by the Air Force in 1978. As a result of vandalism and the lack of maintenance, the structures have weathered and deteriorated to the point where most structures have portions missing or have partially collapsed creating structural and debris hazards. Detached building materials have created debris hazards such as exposed nails, broken timbers, and metal with sharp edges. Climbing and falling hazards emanate from the uncovered underground tanks access ports, electrical trenches in the concrete floor slab in the unlighted composite building, and the easily accessible roof of the multistory composite building. Asbestos containing materials (ACM) have been identified at the Port Moller White Alice Radio Relay Site composite building. Damaged or deteriorating ACM can result in a release of asbestos fibers creating unsafe conditions. Emissions of asbestos to the ambient air are controlled under Section 112 of the Clean Air Act. In addition, containerized fuels, solvent and asphalt, and soil contaminated by PCB's and POL'S have been identified in several areas. The aforementioned safety hazards satisfy the technical-related criteria set forth in the DERP policy and guidance concerning unsafe conditions which present "a clear and present danger." PCB contaminated soils exceeding 50 ppm are to be excavated and disposed of in accordance with RCRA regulations. Disposal options available include incineration at an incinerator approved by EPA for burning PCB's, or landfilling at an EPA approved hazardous waste landfill. Along the concrete slab at the Composite building at Port Heiden. The corresponding sample locations are 92, 94, 98, and 102. The area to be excavated includes the 20 foot section along the concrete slab, out 5 feet and down to the clay layer at 1 foot, for a total area of 100 cubic feet. The remaining 50 feet along the concrete slab is also suspected of being contaminated above 50 ppm and will likely require excavation. The total area suspected of requiring cleanup is 350 cubic feet. Around the concrete foundation of a collapsed quonset hut near the FAA tower site(samples are labeled CAA Tower Site). The corresponding sample locations are 40, 41 and 45 - 48. It is anticipated that an additional 270 cubic feet of soil on the other side of the foundation (to the right of sample location 47) will also require excavation for a total amount of soil anticipated for removal of 340 cubic feet. Remove soil of known contamination greater than 50 ppm. Care must be taken to avoid bulking contaminated soil with non-contaminated soil (less than 50 ppm) as mixing of the two soils types in an attempt to reduce the final concentration of bulked soil will not be allowed. POL DRAIN: All areas represented by samples 135 through 138 will require excavation and bulking. The bermed areas represented by samples 135 and 138 will be bulked separately from areas represented by samples 136 and 137. As with the PCB contaminated soil, care must be taken to assure that uncontaminated soil is not included with the contaminated soil in an attempt to reduce the overall concentration of contaminated soil to be disposed of. Dilution will not be considered an acceptable pollution solution. The amount of soil to be excavated is estimated to be 2,700 cubic feet, with an additional 2,000 cubic feet suspected of requiring excavation. Waste oil spill - A 20 square foot area 1.5 feet deep of soil surrounding a drum, sampled as 128DR, contains waste oil. Since concentration of priority pollutants and EP Toxicity metals are below RCRA hazardous waste concentrations the spill resulting from that waste oil will not be treated as a hazardous waste material. The contaminated soil will be removed, bulked and incinerated along with the lube oil and lubricant contaminated soil. DEC burning permit requirements will be adhered to. The following areas will require additional chemical testing: 1. White Alice PCB contaminated soil. 2. FAA (CAA) Tower site PCB contaminated soil. 3. The POL drain contaminated soil. To be tested for volatile organics, EP toxicity metals and aroma. 4. Waste water obtained from oil water separation operations. 5. Analysis of the transformer fluid for PCB's. See site file for additional information. John Halverson
3/16/1988 Update or Other Action ADEC received a copy of a letter from the Alaska Department of Health and Social Services Div. Of Public Health to EPA (Mr. Jacques Gusmano). Mr. M.E. Lefever PHN Naknek Health Center (cc'd Carol Carlson CHA Port Heiden and Colleen Berg(sp)). It is my understanding that EPA plans to do a cleanup in Port Heiden this summer. What are the plans for disposing of all the old army trash. WIll any testing for trace chemicals be done in the soil and water supply? My interest in this process comes from seeing a higher rate of abnormal pap smears in the women of this village. Thirty to fourty percent of women who live there year around have had abnormal paps, some developing into cancer. I don't know if there is a documented connection between possible trace chemicals dumped by army refuse (garbage), and gonadal cancer. Certainly there is some reason why these people are demonstrating more abnormal paps than their relatives in Pilot Point and the Chigniks. I would be interested in any comments you have on my observations. Colleen Burgh
2/17/1989 Update or Other Action Corps of Engineers DACA85-89-B-004 DERP Debris Cleanup and Site Restoration document. SL=surface soil grab, SM=surface soil composit of 2 or more soil grab samples, SD=sediment sample, DR=drum sample, WA=water sample, GW=groundwater (domestic) sample. Tests EPA SW-846: VOC gs-ms method 8240/634), BNA, semi-VOC (GS-ms method 8270/625), PCB (GC 8080/608), RCRA metals, EP TOX Metals, 18 drinking metals, HAL. Vol. Organics (GC method 8010/601), PAH (GC Method 8100/610), and CL BC (GC 8120/612). NOTE 5 Sheet C-1 Asphalt spill[s] in several small areas, remove to approximate depth of 2 feet. Buildings are categorized and numbered and have dimensions listed as well as some tanks next to buildings being noted on each sheet. Louis Howard
2/28/1989 Update or Other Action In 1989, Underwater Construction & Associates, Inc. (UC&AI), was contracted to perform demolition, restoration, and remediation activities in 13 areas of Port Heiden. Areas included Fort Morrow, Federal Aviation Administration (FAA) areas; the RRS and related POL tanks at Meshik. The original remedial action cleanup contract involved the demolition of unsafe/debris buildings (BD/DR), including 430 WWII structures, and five Cold War large antennas/buildings containing asbestos. CON/HTRW and HTRW to be remove included approximately 8,000 55-gallon POL barrels, four POL underground storage tanks, 250 cubic yards of polychlorinated biphenyls (PCB) contaminated soil, and approximately 250 cubic yards of POL-contaminated soil. All of the BD/DR, and the CON/HTRW under the original contract were cleaned up. Additional POL contaminated soil still remains on the site, which will be addressed under the F10AK002704 Ft. Morrow HTRW project. NOTE TO FILE: Building Demolition and Debris Removal Projects. BD/DR projects are response actions at an area of an eligible FUDS property to address the demolition and removal of unsafe buildings and structures and the removal of unsafe debris. Worksheet B-2 in Appendix B shall be used to document BD/DR eligibility under the FUDS program. For BD/DR projects where hazardous substances are not present, the CERCLA removal action process need not be followed. If a non-incidental (see paragraph 3-2.5.1) actual or threatened release of a CERCLA hazardous substance, pollutant or contaminant (including munitions and MC) is identified during the performance of BD/DR program category activities, DoD policy requires that appropriate response action under the installation restoration or military munitions response program categories be conducted. All such responses are to be conducted in accordance with CERCLA, EOs 12580 and 13016, the NCP, other applicable laws, and applicable DoD and Army policies. BD/DR projects are eligible if the title, deed, or other transfer document conveying the property from DoD specifically requires DoD to undertake BD/DR activities; or, all of the following conditions are met: - Subsequent to DoD ownership, the property must have always been on lands owned by State, Local Government, or Alaskan Native Corporation. - The conditions must have been hazardous as a result of prior DoD use and must have been inherently hazardous when the property was transferred or disposed of by GSA before 17 October 1986. - Inherently hazardous BD/DR must present a clear danger, likely to cause, or having already caused, death or serious injury to a person exercising ordinary and reasonable care Examples of Inherently Hazardous Structures and Debris Presenting a Clear Danger (see note) Structural hazards (excluding structures or debris 6 ft or less in height above the surrounding grade) - Leaning or weakened load bearing walls or supports. - Sagging roofs or floors. - Unprotected openings in a roof or elevated floor that are 8 × 8 in. or larger. - Broken or missing stairs or railings. - Deteriorated mortar or loss of bricks on chimneys and stacks. - Weakened load-bearing wood frame members through such natural processes as termite infestation or weathering (dry rot). Cave-in or engulfment hazards - Evidence of falling rocks from tunnel ceilings or walls. - Excavations that resulted in unstable or soft material 5 ft. or more in depth or height. - Deteriorated or collapsing tunnel linings. Falling hazards - Open pits, manholes, silos, wells, or shafts that are 8 × 8 in. or larger in size and more than 6 ft. in depth. - Open-sided platforms or floors more than 6 ft. above the next lower level. Climbing hazards - Any structure more than 10 ft. above a level, which is readily climbable using any integral parts of the structure (i.e., a ladder attached to a tower). Drowning hazards - Any pit, depression, or tank, that can collect or contain standing water, for example, swimming pools, USTs, underground missile silos, septic tanks, and sewers. Other hazards - Exposed nails, broken timbers, SHARP metal, and unstable concrete block piles. - Openings large enough for a child to enter (8 × 8 in. or larger), in which he/she could be trapped or which would permit exposure to other hazards (e.g., an uncovered manhole leading to a septic tank). Note: These conditions must have been the result of DoD use and inherently hazardous when the property was transferred or disposed of prior to 17 October 1986. Louis Howard
11/30/1989 Cleanup Plan Approved US Army Corps of Engineers risk assessment accepted by ADEC. Total Petroleum Hydrocarbons at 5,000 mg/kg, TPH 100 mg/kg near village (POL Tank Area) and PCBs at 25 mg/kg. John Halverson
1/7/1990 Update or Other Action (Old R:Base Action Code = RAPR - Remedial Action Plan Review (CS)). Northwest EnviroService Inc. letter to Underwater Construction and Assoc., Inc. proposing to conduct bioremediation tests on soils from the composite building. POL drainfield, the area referred to as "the black lagoon". John Halverson
5/7/1990 Site Added to Database Fuel oil and PCBs contamination. John Halverson
5/10/1990 Update or Other Action FAA Real Estate: Contract No. DTFA04-90-L-80905 - Licensed FAA for 0.92 acre of land to install, operate, and maintain an automated weather observation station (A WOS). The license is renewable annually, but not to extend beyond September 30, 2010. Louis Howard
9/7/1990 Report or Workplan Review - Other Steve W. Eng. with ADEC sent Sound Environmental Services Inc, a conceptual approval letter regarding their conceptual design involving the "Bolsing" process for remediation of 4,000 cubic yards of contaminated soil. 9/11/90 approval given for use of 5,000 gallons of wastewater produced during the steam cleaning operation in the remediation process. Wastewater generated while cleaning and crushing 19,000 drums. Jennifer Roberts
4/16/1991 Update or Other Action (Old R:Base Action Code = RAPR - Remedial Action Plan Review (CS)). U.S. Army Corps of Engineers Alaska District Public Notice (ER 91-11) regarding the Defense Environmental Restoration Program Incineration of Petroleum-Contaminated Soils. The COE proposes to clean approximately 20,000 yards of soil by incinerating it in an incinerator designed for that purpose. The backfilled soil that has been treated will be reseeded in accordance with recommendations of the Alaska Plant Materials Center in Palmer. Eileen Olson
6/5/1991 Update or Other Action Army Corps of- Engineers Risk analysis received which describes the hazards present in the contaminated soil at Port Heiden. The Solid Waste Landfill Permit issued by the Alaska Department of Environmental Conservation stipulated that some soil saturated with POL could be landfilled at the approved on-site locations. The term "saturated" has been defined as 5,000 milligrams total petroleum hydrocarbons (TPH) in one kilogram of soil (5,000 mg/kg or 5,000 ppm). During the process of restoring the site, the Alaska District determined that additional soil contaminated with POL's should be remediated. The permitted landfills were only large enough for the amount of material initially estimated to require disposal; therefore, not enough space remains for the additional contaminated soils. The ADEC has established interim guidelines which propose cleanup levels of 100 mg/kg. Solid waste landfill permits will not be issued for the disposal of POL-contaminated soils. An EA was distributed for public review on April 16, 1991, for the remediation of the additional contaminated soil. The quantity is estimated to be between 18,000 and 20,000 yd. Recommendations from the Alaska District COE were: soils with TPH levels in excess of 5,000 mg/kg should be remediated by incineration, preferably at high temperature. The 5,000 mg/kg was the concentration in the original cleanup level. The risk evaluation substantiates this level as not being excessively harmful to human health and the enviroment. Soils with TPH concentrations in excess of 100 mg/kg should be remediated by incineration in those areas nearest the village. These areas are delineated in the plans located in the appendix. The 100 mg/kg is a cleanup level proposed by the Alaska Department of Environmental Conservation. This level would virtually eliminate any risk to human health. The soils should be replaced, fertilized, and seeded with grasses after remediation. This would act as a cap over the remaining contaminated soils. Capping the remaining soils is similar to landfilling. With the major source of contamination removed, the clay layer between the contamination and ground water, and a vegetated cap, the remaining TPH soil becomes unavailable. This would allow natural processes to degrade the contamination. Jennifer Roberts
6/20/1991 Cleanup Level(s) Approved Jennifer Roberts (Fed. Fac. Coordinator) sent letter to Louis R. Pylant Lt. Col. Corps of Engineers Environmental Restoration and Civil Works Section re: Port Heiden Formerly Used Defense Site Risk Analysis dated June 19, 1991. The department has reviewed the "Final Risk Analysis for Alternative Cleanup Levels at Port Heiden, Alaska" submitted by the Corps of Engineers on June 19, 1991. The risk analysis adequately addresses the concerns generated by utilizing a cleanup level of 5,000 parts-per-million total petroleum hydrocarbon (TPH) for remote areas of the Port Heiden Formerly Used Defense Site (FUDs) cleanup. This 5,000 parts per million (cleanup level) does not include: benzene, ethylbenzene, toluene, and total xylenes (BTEX). It is the department's understanding that the petroleum contamination at this area is old weathered fuels in which the BTEX components have volatilized off and are no longer and issue. This letter approves of the work proposed in the Final Risk Analysis with a remote site specific cleanup level of 5,000 parts-per-million for TPH. Jennifer Roberts
6/25/1991 Update or Other Action Corps of Engineers submitted a revised Environmental Assessment (EA) and Finding of no significant impact (FONSI) under NEPA. The EA calls for thermal treatment of approximately 20,000 cubic yards of petroleum contaminated soil. It also referenced a previous EA that addressed building demotion and debris cleanup and landfilling on-site. John Halverson
7/15/1991 Site Ranked Using the AHRM Initial ranking. John Halverson
8/22/1991 Update or Other Action Letter from Major David R. Neeley, Corps of Engineers, Alternate Administrative Contracting Officeer RE: Port Heiden Cleanup contract and previous conversations with Jennifer Roberts/Ron Godden of ADEC. For asphalt and asphaltines, our plan (CORPS) will be: -Double bag (super sacks) all asphalt and asphaltine material under 5,000 ppm and place in landfill Site "A". -All asphalt and asphaltine material over 5,000 ppm will be run through the incincerator to attempt to lower the TPH levels. If tests result in levels below 5,000 ppm, then the above procedure will be followed. -All asphalt and asphaltine material which still tests higher than 5,000 ppm after one (1) run through the incinerator, will be transported to an approved site. During this process, especially if it is proven that 5,000 ppm or less cannot be achieved, the material will be left undisturbed and identified on the As-Built drawings. The landfill will have a cell designated for asphalt materials. This cell will be lined and designated on the As-Builts. Jennifer Roberts
10/1/1991 Update or Other Action (Old R:Base Action Code = RAPR - Remedial Action Plan Review (CS)). VECO sent in Sampling analysis plan and quality assurance project plan for remedial action efforts at site. Primary difference between this one and previous ones is there are no gas chromatographs being used at the field lab and no PCB analysis performed in 1991. No Method 8015 or 8020 performed at field lab instead it will be done at Chem. and Geo. lab in Anchorage or Columbia Analytical Services in Kelso WA. Field testing by use of a PID &/or FID to detect hydrocarbon vapor will be attempted, but it was found to be unreliable in 1990. John Halverson
10/24/1991 Update or Other Action ADEC issued an Air Quality Control Permit to Operate (no. 9125-AA004) to VECO for a mobile soil remediation unit that was to be used to treat petroleum contaminated soil at Port Heiden (State I.D. AK910827-14A). There are 24 conditions of the permit. Violation of any one of these conditions may result in revocation or suspension of the permit in accordance with 18 AAC 50.310. The permit expires on December 30, 1993, and you must request renewal at least thirty days prior to that date for continued operation of the facility. Violation of any condition of the permit may subject you to civil or criminal penalties as provided in AS 46.03.760, AS 46.03.765, AS 46.03.780 and AS 46.03.790. This permit does not relieve you from the responsibility to apply for any other permit or approval required by the department or the U.S. Environmental Protection Agency (EPA). Please be advised that State regulations may differ from Federal regulations, if you have any questions regarding compliance with these regulations, you should contact EPA or the department. John Halverson
11/1/1991 Report or Workplan Review - Other ADEC sent VECO David L. Robbins a letter re: Port Heiden POL Contaminated Soil Remediation Contract DACA 85-89-C-0042 Revision 001. The work plan revision 001 dated 10/31/1991 addressing the department's requirements was received and reviewed. On Page 3, "Plan of Work" section, there appears to be a contradiction with page 6 "Revegetation" section. The last sentence of Paragraph 2 states "No vegetation required by Case 21." while page 6 states that any area subjected to damages will be revegetated. Please clarify exactly what the work plan will address. On the Table of Priorities, on page 2, there appears to be a typographical error in the Remediation Limits heading. The current heading is "5,000 PP" which should read "5,000 PPM". Please make the above corrections and resubmit the work plan for final approval. Jennifer Roberts
11/5/1991 Cleanup Plan Approved ADEC approved the POL Contaminated Soil Remediation Port Heiden, Revision 002, dated 11/4/91. John Halverson
12/3/1991 Update or Other Action ADEC was informed by CH2M-HILL staff assigned to conduct stack testing of the VECO soil remediation unit at the Port Heiden Corps of Engineers cleanup. It is not meeting AQC permit requirements and all work has stopped. The contractor got into some contaminated pumice. When they tried to process it, it exploded in the drum mixer and released SiO2 vapor (a VERY toxic compound). The SiO2 vapor supposedly condensed in the stack after the baghouse. There was about a half an inch of material on the filter and samples have been taken in for analysis. In any event, it appears to be much higher than the 0.05 grains per standard cubic foot particulate emission standard. The material coated the entire sample train and is impossible to get off except with hydorfluoric acid. The small particle size measured 0.02 micron, and supports the condensation theory. There were also many carbon monoxide spikes due to the policy of not allowing any blending of material. The ENARC monitor was never tested due to all of the particulate problems. The CORPS of Engineers is scrapping this remediation approach and may try bio-remediation in the spring of 1992. * note - no report has been provided to ADEC for the work that was done. Jennifer Roberts
12/18/1991 Update or Other Action FAA Real Estate: AIM Document - Summarizes FAA facilities and real property at Port Heiden FAA Station, Port Heiden, Alaska. Louis Howard
1/23/1992 Update or Other Action ADEC received a report from CH2MHill, prepared for VECO, describing emission problems (high silicon dioxides and particulates) with the thermal treatment unit and describing alternatives to fix the problems. John Halverson
1/31/1992 Offsite Soil or Groundwater Disposal Approved Letter to Corps of Engineers Dan Owens re: Port Heiden Landfill approval for asphalt disposal. 12 cubic yards of asphalt material being placed at the landfill under permit is not a problem due to the original permit stipulations. It is the Corps of Engineers' decision to allow your contractor to leave the asphalt material in place at the landfill. Louis Howard
1/31/1994 CERCLA PA CERCLA Preliminary Assessment dated January 1994 Contract No. DACA85-92-D-0007 Delivery Order 0007 received. The Port Heiden WACS site (CERCLIS ID No. AK8570028698) is within Fort Morrow, halfway down the Alaska Peninsula. From 1981 through 1992, the USAF and COE conducted removal and remediation activities and site investigations in Port Heiden at the WACS site, Fort Morrow (World War II facilities), and the Federal Aviation Administration (FAA) tower at the airstrip. Because the bulk of the debris and hazardous materials at Port Heiden was of DOD origin, and "ownership" could not be dearly distinguished among periods of use-World War II, WACS site, and FAA-the COE combined all areas into a DERP cleanup from 1990 to 1992. Table 2.2-2 summarizes the remedial activities that occurred at Port Heiden by type of material encountered. If known, the amounts and locations of contaminants, disposal methods, and remaining haT_rds are identified. Quantities in some cases are estimated amounts. In accordance with the National Environmental Policy Act of 1969, the COE released a public notice, environmental assessment (EA), and finding of no significant impact (FNSI) on a proposal to clean up debris at Port Heiden, including the abandoned Word War II U.S. Army base of Fort Morrow and the WACS site (COE, 1985). Review comments were received from resource agencies. The U.S. Fish and Wildlife Service (USF&WS), found the EA, FNSI, and cleanup design to be inadequate in three areas: (1) the lack of site-specific information regarding the chemical nature of hazardous and toxic substances and the extent of their habitat contamination; (2) the presence of generic, unsubstantiated statements regarding the environmental safeguards to be employed to minimize the impacts; and 3) identification of solid-waste and bzTardous-waste sites (USF&WS, 1986). As a result of the comments, a revised public notice, EA, and FNSI were issued in 1987 (COE, 1987). The revisions included maps identifying locations of existing barrel dumps, proposed landfills, fuel tanks, and buildings to be demolished. During this same period, the COE hired a contractor to inventory debris and produce preliminary plans and specifications for the DERP cleanup of the site. June 1986, August 1987, and June 1988, the COE collected samples of soil, surface water, groundwater, fluids from drums and transformers, and miscellaneous building materials at Fort Morrow and the WACS site. The analytical results and field observations identified the following sources of contaminants at the WACS site (Figure 2.2-1): • Asbestos in pipe insulation, floor tiles, and wallboard • PCB-contaminated sludge in floor trench • PCB-contaminated soils (200 parts per million [ppm]) to the west and north of the composite building in the upper 2 feet of soil • Soil contaminated by POL (saturated) and metal (total arsenic, 19 ppm; barium, 136 ppm; chromium, 15 ppm; lead, 28 ppm) in an outfall and sewer drain, called "the black lagoon" • UST on east side of building Also, the entire Fort Morrow area was inventoried for debris, and environmental samples were collected for laboratory analyses. Primary areas of concern included the following items: • Fuel-tank foundation rings at Meshik • Pipeline running from Meshik to the WACS site • Debris, including some asbestos from more than 400 World War II Quonset huts and buildings • Thousands of mostly empty POL drums scattered in piles • Scattered transformer casings. • PCB-contaminated (190 ppm) soil at the former FAA site • Asphalt drums and spill areas • USTs and known fuel spills * Landfill near the airfield containing domestic garbage and debris • Water wells improperly abandoned In 1989, the COE issued revised plans and specifications for the DERP cleanup and restoration of DOD facilities at Port Heiden, including Fort Morrow, the WACS site, and the FAA site. The plans and specifications were reviewed by various resource agencies, including the EPA and Alaska Department of Environmental Conservation (ADEC), and by the public. In late 1989, the COE awarded the cleanup contract to Underwater Construction and Associates, Inc. (UC&AI), of Anchorage. Before field work, UC&AI submitted a quality assurance project plan, health and safety plan, hazardous waste handling plan, and revegetation plan. The following information on the cleanup was taken from COE (1990) and UC&AI (1990) daily inspection reports and laboratory reports (Northwest Enviroservice, Inc., 1990, 1991, and 1992). Soil cleanup levels were negotiated with the ADEC as follows: 25-ppm of PCBs at the WACS site composite building 10-ppm of PCBs at the FAA site (because of the proximity of a residence) 100-ppm of TPH at all sources See site file for additional information. Louis Howard
4/12/1994 Update or Other Action EPA Region 10 sent letter to USAF Lt. Colonel Rodney L. Hunt 11th CEOS. The letter was to inform the Air Force that EPA Region 10 has completed the review of the Preliminary Assessment (PA) report for the Port Heiden White Alice Communication site located near Port Heiden, Alaska. The PA and supplemental information have been evaluated in accordance with 40 CFR Part 300 Appendix A, which is EPA's Hazard Ranking System (HRS) used to evaluate federal facilities for inclusion on the National Priorities List (NPL). From our evaluation, EPA has determined that the facility does not score high enough to be proposed for inclusion on the NPL. Therefore, a recommendation of no further remedial action planned (NFRAP) on the EPA's part will be included in our Federal Agency Hazardous Waste Compliance Docket tracking system. If new or additional information to be proposed for the NPL, EPA must reevaluate your facility accordingly. EPA's NFRAP designation does not relieve your facility from complying with appropriate Alaska state regulations. The Superfund Amendments and Reauthorization Act (SARA) of 1986, Section 120(a) (4) requires federal facilities to comply with state cleanup requirements and standards when not listed on the NPL. This facility will not be removed from the Federal Agency Hazardous Waste Compliance Docket, but as noted earlier, will be listed for no further action by EPA. Mark Adar Federal Facilities, Site Assessment Manager. NOTE to File: CHAPTER 103--COMPREHENSIVE ENVIRONMENTAL RESPONSE, COMPENSATION, AND LIABILITY SUBCHAPTER I--HAZARDOUS SUBSTANCES RELEASES, LIABILITY, COMPENSATION Sec. 9620. Federal facilities (a) Application of chapter to Federal Government (1) In general Each department, agency, and instrumentality of the United States (including the executive, legislative, and judicial branches of government) shall be subject to, and comply with, this chapter in the same manner and to the same extent, both procedurally and substantively, as any nongovernmental entity, including liability under section 9607 of this title. Nothing in this section shall be construed to affect the liability of any person or entity under sections 9606 and 9607 of this title. (2) Application of requirements to Federal facilities All guidelines, rules, regulations, and criteria which are applicable to preliminary assessments carried out under this chapter for facilities at which hazardous substances are located, applicable to evaluations of such facilities under the National Contingency Plan, applicable to inclusion on the National Priorities List, or applicable to remedial actions at such facilities shall also be applicable to facilities which are owned or operated by a department, agency, or instrumentality of the United States in the same manner and to the extent as such guidelines, rules, regulations, and criteria are applicable to other facilities. No department, agency, or instrumentality of the United States may adopt or utilize any such guidelines, rules, regulations, or criteria which are inconsistent with the guidelines, rules, regulations, and criteria established by the Administrator under this chapter. (3) Exceptions This subsection shall not apply to the extent otherwise provided in this section with respect to applicable time periods. This subsection shall also not apply to any requirements relating to bonding, insurance, or financial responsibility. Nothing in this chapter shall be construed to require a State to comply with section 9604(c)(3) of this title in the case of a facility which is owned or operated by any department, agency, or instrumentality of the United States. (4) State laws State laws concerning removal and remedial action, including State laws regarding enforcement, shall apply to removal and remedial action at facilities owned or operated by a department, agency, or instrumentality of the United States or facilities that are the subject of a deferral under subsection (h)(3)(C) of this section when such facilities are not included on the National Priorities List. The preceding sentence shall not apply to the extent a State law would apply any standard or requirement to such facilities which is more stringent than the standards and requirements applicable to facilities which are not owned or operated by any such department, agency, or instrumentality. Jennifer Roberts
3/13/1996 Update or Other Action ADEC received a Preliminary Assessment/Site Inspection report from the Corps. The report was prepared for the Air Force, under contract to EMCON. It summarized the site history including prior investigation and cleanup work. The following areas were evaluated: Composite Building (OT01): between 1981 - 1990 petroleum and PCB-contaminated soil were excavated and treated or landfilled; 1991 asbestos was removed and placed in Landfill A; confirmation samples indicated the 5,000 mg/kg TPH and 25 mg/kg PCB cleanup levels were achieved near the NW corner of the building; Black Lagoon (southwest of OT01): estimates 4,000 cubic yards of petroleum contaminated soil >5,000 mg/kg remain, PCBs present but <25 mg/kg reported; Grey Lagoon (AOC02): estimated 150 cubic yards of POL contaminated soil remains; Fuel pipeline (~ 4 miles long): recommended site investigation; POL Tankfarm: ~10,000 cubic yards of soil excavated from 1990-92. Free product found in excavation, area eroded ~ 15' back from shoreline between 1992 and 95; Landfill A; cap appeared good, recommended posting asbestos sign and preparing a landfill closure report; Landfill B (~1/2 mile south of airport): cap appears ok, recommended a landfill closure report. Ray Burger
12/27/1997 Update or Other Action ADEC received a Management Action Plan from the Air Force summarizing the site history and outlining proposed investigation and cleanup. It calls for further remedial investigation in 1999. Ray Burger
6/6/1998 Update or Other Action ADEC received a copy of a letter from the Bristol Bay Area Health Corporation to the Corps of Engineers. The letter requested further site characterization at Port Heiden and again raised concern over what appeared to be a high cancer rate in the village. John Halverson
6/13/2002 Update or Other Action DEC received a fax and letter from the Lake and Pennisula Borough and the City of Port Heiden about a phone call from an annonymous worked who reported dumping drums of hazardous material into a trench on the northwest side of the former White Alice site and that the chemicals could cause health problems for the villlagers. The letters requested DEC assistance in following up on the call and ensuring the former military sites are cleaned up properly. John Halverson
6/19/2002 Update or Other Action DEC sent letter to the Corps of Engineers and the 611 CES (Air Force) informing them on the community concerns and asking for cooperation in compling the site records, conducting a site inspection and community meeting, and ensuring the sites are adequately characterized and cleaned up. John Halverson
6/21/2002 Update or Other Action Letter sent to Mayor Matson re: Former White Alice Site Communication System Site at Port Heiden. Thanks for sending the June 13th letter about the recent phone call and report on drums of wastes being dumped into trenches in the past at the White Alice site. ADEC has reviewed the information in our files and contacted the Air Force and U.S. Army Corps of Engineers (Corps) environmental cleanup managers. You may know that these agencies have done some sampling and cleanup work at the White Alice Site and the surrounding areas during the 1980s and early 1990s. However, cleanup work has not been completed and both agencies have plans for future work. The reason both of these Department of Defense (DOD) agencies are involved is that the Air Force is responsible for environmental cleanup on property that it owns or has owned after 1986. The Corps, under the Formerly Used Defense Sites (FUDS) program, is responsible for environmental cleanup associated with past military activities on land that was transferred out of the DOD control before 1986. *NOTE Engineer Regulation 200-3-1 FUDS Program Policy:defines a FUDS Property as real property that was under the jurisdiction of the Secretary and owned by, leased by, or otherwise possessed by the United States (including governmental entities that are the legal predecessors of Department of Defense [DoD] or the Components) and those real properties where accountability rested with DoD but where the activities at the property were conducted by contractors (i.e., government-owned, contractor operated [GOCO] properties) that were transferred from DoD control prior to 17 October 1986. During WWII, the Army Air Corps developed Fort Morrow as part of the air defense efforts. It was shut down shortly after the ware. During the Cold War, the Air Force constructed and operated a White Alice Site on a portion of the old Fort Morrow to again assist in air defense actions. The Air Force still owns or controls a parcel of land around the former White Alice Site, while a large portion of the old Fort Morrow has been transferred to others. It is unclear whether the trenches the caller had reported dumping drums of waste into were sampled or included in any of the prior cleanup activities. John Halverson
8/9/2002 Update or Other Action Butch Douthit Friday, August 09, 2002 8:18 AM Halverson, John 'Laurie Mulcahy'; Tom J Schmid Re: Port Heiden - Airport Improvement Project Laurie requested I let you know the scope of our airport project. The Runway Resurfacing project will consist of resurfacing both runways (5/23 &13/31), constructing full safety (widening from 200' to 300') areas and replacing the lighting system. Runway 5123 will have a new dimension of 100 feet by 5,000 (previously 6,250) feet and runway 13131 will have a new dimension of 100 feet by 4,000 (previously 4,600) feet. The apron and taxiways will be reconditioned with new lighting and surface course. All the electrical controls and rotating beacon will be relocated to the maintenance building. The barrels on the existing segmented circle will be replaced with panels. The 100' runway widening Is Into/over areas "worked" during our last project -In 1988 so there should be no surprises there. Our material sites -are on the north side of the airport. One site Is undisturbed ground, the second has seen some previous gravel extraction. I can be reached at 269-0605 or Tom Schmid, the design engineer can be reached at 269-0612. H. M. (Butch) Douthit Halverson, John- wrote: We are looking through the files now and checking with the Air Force and the Corps to make sure that we have all the pertinent documentation on past assessment and cleanup work. Do you have areas where you're planning to do much digging? If not, It shouldn't be a concern. If yes, you may want to have someone stop over with some diagrams and we could look at what we have. The Air Force cleanup work was long enough ago that there wasn't any coordination with DEC, but we do have Information showing that they have more to do. The Corps cleanup contract went over budget, they were not able to finish and never even did a report documenting what was completed and what remains. We are looking at going out to meet with interested community members and doing a site visit sometime during the week of Sept. 9. They received a phone call from someone that used to work at the site and he reported that he was instructed to, and did, dump drums of wastes in a trench near the old white alice site. It has people pretty concerned. Original Message From: Laurie Mulcahy [mallto:laurie_mulcahy@dotstate.ak.us] Sent: Thursday, August OS, 2002 4:34 PM To: Halverson, John Cc: Harvey M Douthit Subject: Re: Port Heiden - Airport Improvement Project John: we reviewed a previous airport upgrade EA that indicated an ADEC approved site closure. Let me know of your areas of concerns, we are just About ready to advertise that project. Laurie Halverson, John- wrote: We recently had some concerns raised by villagers at Port Heiden over contamination associated with the old military sites there. As I was going through our file information I saw a Feb.7, 2002 letter about a runway resurfacing project 1# 55071 that OOT&PF is working on. The letter, from Jerry O Ruehle, and attached Information states that DOT does not expect to run Into contamination but that there Is some potential, to because of past military activities; it states that DEC approved the cleanup and site closure during the 80's and 90's. However, that Is not the case. Both the Air Force 8nd the Corps of Engineers have done cleanup work in the past and both still have future projects scheduled to complete the necessary cleanup. This may not adversely effect the planned airport improvement project. But I want to make sure that DOT does not have the mistaken Impression that the site was cleaned up to applicable levels and closed out. Louis Howard
9/5/2002 Site Visit traveled to Port Heiden on September 4, 2002 with Ron Pflum (Corps of Engineers) and Larry Underbakke (611 CES, Air Force) to meet with villagers and inspect the site in response to concerns over the old military sites. Sandra Borbridge (Air Force Tribal liaison) joined us later in the day. We met with Lynn Carlson (City and Village), Scott Anderson (Tribal Environmental Coordinator), and Gerta K (City) to discuss the site characterization and cleanup history and their concerns over the sites. Many residents expressed concern over health problems and their thoughts that there may be a link between past military activities and health problems. Scott Anderson, Tribal Environmental Coordinator and Lynn Carlson helped coordinate the meeting and site inspections. The surface cleanup work appears to have been very thorough and the landfills are adequately covered. Subsurface characterization is needed. Residents want their water wells sampled and had applied for a grant from TASWER to conduct the sampling. DEC, the Corps and Air Force staff said they would work together to help get wells sampled. They described trenches that had anti-aircraft guns in them between the airport and the shoreline and finding a cache of ammunition (30-06, 45 cal and larger) in the dunes near the shoreline. People used what they thought was salvageable and reported left the rest. We walked the area on Thursday with Amil and Scott, but were unable to find any OE items. The area may have eroded and become grown over with grasses. Someone pointed out concern over what had been dumped off-shore. They said the navigational charts show there is military debris in certain areas that could be a hazard to navigation or fishing gear. Amil later showed us a 37 mm cartridge and a projectile that had rifling marks (has been fired) that is in his mother's house. The cartridge is cracked and empty but the projectile has been put back into it. John Halverson
9/6/2002 Update or Other Action Email message from John Halverson to Larry Underbakke (611 CES PM at the time) I talked with Amil Christensen and Lynn Carlson. The 37 mm round we saw was at Amil's mom Anne's house. He is going to talk to her about it, take a couple digital photographs and email them to me. He said hell make sure they leave it alone where it won't get knocked around. I'11 forward the photos on to the Army EOD Sgt. Sullia. I talked with him earlier today and they are willing to respond but he said that Christensen's would have to agree to tum the item over. He said sending them photos would help identify exactly what it is and how much of a concern it is. Ron, I don' know if you have seen the article and link pasted below. ---Original Message---- From: Underbakke Larry Mr 611CES/CEVR [mailto:Larry.Underbakke@ELMENDORF.af.mil] Sent: Monday, September 09, 2002 7:43 AM To: Halverson, John' Subject: RE: (CPEO-MEF] Old explosives, new jitters in Butner John, I am checking into this. I will get back to you when I get some info. This is a WWII army round but we will see what we can do. Please let Ron Pflum know also. --Original Message----- From: Halverson, John [mailto:JHalvers@envircon.state.ak.us] Sent: Friday, September 06, 2002 2:36 PM To: Larry Underbakke Subject: FW: (CPEO-MEF] Old explosives, new jitters in Butner Larry, by coincidence Jennifer forwarded this to me this AM. It describes the Army detonating a WWII 37 mm round that been previously fired. The projectile that has been put back on the casing that Anne had in her house had been fired (based on the rifleing marks). I didn't figure that projectile would have had an explosive charge, but I may be wrong. What do you think? H it does, I need to make sure they are aware of it. Louis Howard
9/9/2002 Update or Other Action Staff contacted the Army Explosive Ordnance Disposal (EOD) team at Fort Richardson regarding the ordnance item in a residence at Port Heiden. The EOD representative (Sgt. Bryant 384-7603) said they were willing to go out and destroy the item, if the home owner wanted. DEC staff coordinated with the village and EOD to dispose of the item. John Halverson
9/18/2002 Update or Other Action After conducting the site visit earlier this month, staff researched options for groundwater characterization at Port Heiden and found out the the City of Port Heiden is on the Village Safe Water program's list for a Water and Wastewater Feasibility Study in FY03. The scope calls for evaluating the current systems, the aquifers, water use and estimated future needs. It may include some limited testing, but not sampling 30 wells; it is a civil works project rather than environmental. Staff is working with the Corps of Engineers to sample existing wells under the Native American Lands Environmental Mitigation Program (NALEMP). John Halverson
4/30/2003 Meeting or Teleconference Held DEC and the Air Force participated in a public meeting at Port Heiden to update the community on Air Force plans for conducting remedial investigation work in 2004 and completing a proposed plan, record of decision and implementing a remedy by 2007. The Corps does not have work planned for Fort Morrow until 2011, but will re-evaluate the schedule based on any new information (water well sample results). John Halverson
6/5/2003 Update or Other Action Keres Environmental is sampling all water wells in Port Heiden under the Native American Lands Environmental Mitigation Program (NALEMP). Sampling plans were reviewed by DEC and the Corps and each well will be tested for VOC, PAHs, PCBs, and metals. Sampling will be conducted during the first week of June and results are anticipated by early August. John Halverson
7/31/2003 Update or Other Action Mala Kaylan took down a new spill report from ADOT 269-0527. Date discovered 7:00 p.m. July 30, 2003. Date reported 7/31/2003 9 a.m. Cans of product buried underground. No cleanup yet. Borrow Pit: Cans of unknown material, unknown blueish green liquid on ground. Louis Howard
8/3/2003 Update or Other Action ADOT R Deley Fax to ADEC F Wesser. Frank - here are our results. We are thinking of burying it in place. Any thoughts? ADOT email correspondence Sean Holland to Rae Deley: Forwarding the test results for the stuff found at Port Heiden. Looks like it is benign. I will wait for your recommendations, but should we simply cover it where we found it? Frank Wesser
9/3/2003 Update or Other Action Fax from ADOT R De Ley to ADEC F Wesser re: drum location Frank here is some information of the Port Heiden Airport. I have included a few maps to give you the lay of the land. The State status plat for this area is T 37S, R 59W, S.M. The material site of interest is in Sections 15, 16, 21, and 22. The land use map shows where the airport is in relation to town and local creeks & the ocean. The Borrow Area 1 is marked with an arrow. The ADOT plan sheet that shows the location of Borrow Area 1 where the waste and blue green fluid was found in relation to the runway & the road. I have a call in to our engineers & will give you a more exact location when I have it. If you have any questions give me a call. Thank you, Rae D. 269-0527 Louis Howard
9/8/2003 Update or Other Action ADEC L. Bush to F. Wesser If you can give me copies of everything pertinent to the subject, I will send it all to the person doing the water quality assessment. F. Wesser to L. Bush Could we look into including this site into the Limited Drinking Water Ouality Assessment project within Port Heiden? ADOT has great location maps of the burrow pit site and you have seen the analytical report from sample taken. ADOT Rae Deley to F. Wesser ADEC: Good morning Frank-I sent you a fax this morning with a map showing the approximate location where buried wastes were found in Port Heiden. And I also included a larger area where there might be more buried waste material (an area which we did NOT investigate). As a part of the fax, I included the names and phone numbers of people who might be able to provide first hand information on the material & the sampling method. If you have any questions, give me a call. Rae D. 269-0527 Frank Wesser
9/9/2003 Spill Transferred from Prevention Preparedness and Response Program During ADOT project, an excavator discovered a bluish green type solid waste with a cylinder (6" X 24") nearby during digging in the burrow pit for fill material and reported this to Rae Deley. The cylinder was speculated to be a fire retardant or maybe part of a fire retardant system. The solid waste was sampled around it by MacTech and analyticals did not indicate cleanup level concans by ADEC cleanup tables. (Lab results attached). Other solid waste is in around the burrow pit which ADOT left in place. Apparently, the local knowledge believes the solid waste was covered by imported soils and may be on top of a ravine. The site bas potential military history and a science officer with the military, Rich Mausey phone: 428-6614 did not see any concerns with the copy of analyticals that he reviewed. The site bas potaltial military history and a science officer with the military, Rich Mausey phone: 428- 6614 did not see any concerns with the copy of aoalyticals that be reviewed. Other solid waste is in around the borrow pit which ADOT left in place. Apparently, the local knowledge believes the solid waste was covered by imported soils and may be on top of a ravine. Also, according to Rae Deley with ADOT she bas heard other solid waste issues are neaIby this one site with the same burrow pit and possibly other pits nearby. This site is being transferred to Lynne Bush (Contaminated Sites Program) to potetially add to a CSRP DoD project characterizing water quality within and around sites such as this one in Port Heiden. Title of project: "Limited Drinking Water Quality Assessment of Domestic Wells in the The Native Village of Port Heiden". Maps and lab results are included. Frank Wesser
5/10/2004 Update or Other Action Michael J. Walsh Colonel, Corps Of Engineers, Chief of Staff issues Engineering Regulation No. 200-3-1. It is the policy of the USACE that the policies contained in this ER are the overarching USACE policy for management & execution of the FUDS program & takes precedence over previous USACE FUDS program policy & guidance. The USACE MUST comply with the DERP statute (10 USC 2701 et seq.), CERCLA, 42 USC § 9601 et seq., Executive Orders (EOs) 12580 & 13016, NCP, & all applicable DoD (e.g., DoD Management Guidance for the DERP [28 September 2001]) & Army policies in managing & executing the FUDS program. Because of the linkages between the DERP & CERCLA & the delegation of certain Presidential authorities under CERCLA to DoD, CERCLA is DoD's preferred framework for environmental restoration. Where a regulatory agency seeks to use another framework, USACE Districts shall: Seek formal approval of the decision to follow a framework other than CERCLA. Ensure that the actions undertaken also comply with all applicable CERCLA requirements, especially in the areas of the content of decision documents & the maintenance of an Administrative Record. Consistent with the statutory program goals of the DERP, DoD has established 3 program categories to classify activities at FUDS properties & projects: installation restoration program (IRP), military munitions response program (MMRP), & building demolition/debris removal program (BD/DR). 1) IRP. For the FUDS, the IR program includes the Hazardous, Toxic, & Radioactive Waste (HTRW) & Containerized HTRW (CON/HTRW) project categories. IR program category is defined as the conduct of response actions (i.e., the identification, investigation, & remedial actions, or a combination of removal & remedial actions) to address releases of: Hazardous substances or pollutants & contaminants (as defined in the CERCLA). Petroleum, oil, or lubricants (POL). Under the DoD Management Guidance for the DERP, funding appropriated to the Environmental Restoration (ER)-FUDS account may be used to remediate releases of petroleum where the release poses an imminent & substantial endangerment to the public health or welfare or to the environment [10 USC 2701(b)(2)]. DoD-unique materials. Hazardous wastes or hazardous waste constituents. Low-level radioactive materials or low-level radioactive wastes. Explosive compounds released to soil, surface water, sediments, or groundwater as a result of ammunition or explosives production or manufacturing at ammunition plants. 2) MMRP. The MMRP category is defined as response actions (i.e., the identification, investigation, & remedial actions, or a combination of removal & remedial actions) to address Munitions & Explosives of Concern (MEC) or Munitions Constituents (MC). This includes the removal of foreign military munitions if it is incidental to the response addressing DoD military munitions at a FUDS property. 3) BD/DR Program. This program category is defined as the demolition & removal of unsafe buildings & structures at FUDS properties that were owned by, leased to, or otherwise possessed by the U. S. & under the jurisdiction of the Secretary of Defense & transferred to state, local governments, or Native Corporations of AK. FUDS Project Definition. Within this Program, USACE has defined a FUDS Project as a unique name given to an area of an eligible FUDS property containing one or more releases or threatened releases of a similar response nature, treated as a discrete entity or consolidated grouping for response purposes. This may include buildings, structures, impoundments, landfills, storage containers, or other areas where hazardous substance are or have come to be located, including FUDS eligible unsafe buildings or debris. Response actions at FUDS projects fall under the Installation Restoration (HTRW & CON/HTRW), MMMRP (MEC & MC), or BD/DR program categories. An eligible FUDS property MAY have more than one project. The DoD Goals for the DERP, established for the FUDS program in the DoD Financial Management Regulation (FMR), require USACE to develop an execution strategy that includes the following. Reducing risk to human health & the environment through implementation of effective, legally compliant, & cost-effective response actions. Having final remedies in place & completing response actions. Requiring certain percentages of FUDS projects in the program to progress to specific stages of the response process by specific dates (i.e., milestones). The objective of the BD/DR program is to protect human health & safety by demolishing & removing unsafe buildings, structures, & debris resulting from past DoD operations. Louis Howard
5/10/2004 Update or Other Action Formerly Used Defense Sites (FUDS): real property that was under the jurisdiction of the Secretary and owned by, leased by, or otherwise possessed by the U. S. (including governmental entities that are the legal predecessors of DoD or its Components) and those real properties where accountability rested with DoD but where the activities at the property were conducted by contractors (i.e., govt.-owned, contractor-operated [GOCO] properties) that were transferred from DoD control prior to 17 October 1986. The FUDS eligibility status of former DoD property is NOT affected by its being the current responsibility of another federal agency. Only properties transferred from DoD control before 17 October 1986 are FUDS, unless: - The property had already undergone an eligibility determination, and - The final Inventory Project Report (INPR) stating that the property was FUDS eligible was signed prior to 30 September 2000, and - The property was listed in FUDSMIS as a FUDS property before 30 September 2000. Ineligible Properties: The specific criteria for property ineligibility under the FUDS program are: Properties Declared Excess but Not Conveyed: This includes properties that were identified by a DoD Component as excess prior to 17 October 1986 but were not conveyed to another entity until after 17 October 1986. The GSA Federal Mgt. Regulation, Chapter 102, Subchapter C, Part 102-75 provides that the landholding agency remains responsible and accountable for excess and surplus real property, including related personal property, and must perform the protection and maintenance of such property pending transfer to another Federal agency or disposal. The landholding agency is responsible for complying with the requirements of the NCP and initiating or cooperating with others in the actions prescribed for the prevention, containment, or remedy of hazardous conditions. Non-DoD Ownership: This includes properties that were not under the jurisdiction of the Secretary2 and owned by, leased by, or otherwise possessed by the U. S. (including governmental entities that are the legal predecessors of DoD or the Components). State National Guard Properties: This includes State National Guard properties unless they were formerly under the jurisdiction of the Secretary and owned by, leased by, or otherwise possessed by the U. S. (including governmental entities that are the legal predecessors of DoD or the Components) at the time of activities that resulted in the hazardous conditions. Non-U.S. Properties: This includes properties outside the U. S. or outside those districts, territories, commonwealths, and possessions over which the U. S. has jurisdiction. Defense Plant Corp.: This includes Defense Plant Corp. (DPC), and similar properties for which successor agencies and departments other than Defense are responsible for environmental restoration activities. Civil Works Properties: This includes all Dept. of the Army Civil Works properties, (i.e., the non-military activities of the USACE), unless previously under military control at the time of activities that resulted in hazards. Acts of War Properties: This includes properties where a release occurred solely as a result of an act of war. Offshore Ordnance Properties: Properties where military munitions are more than 100 yards seaward of the mean high-tide point are not eligible. Properties Without Records: This includes properties for which there are no records showing that the property was formerly under the jurisdiction of the Secretary and owned by, leased by, or otherwise possessed by the United States (including governmental entities that are the legal predecessors of DoD or the Components), or where there is no documentation showing that accountability rested with DoD. Restoration Already Initiated: This includes a FUDS at which a Component has already initiated environmental restoration activities. Duplicate Properties: This is a property that is known by a different name, yet is the same physical property already listed in the FUDS inventory. DoD Active Installation: This includes properties still under the jurisdiction of DoD components. FUDS Project: A FUDS project is a unique name given to an area of an eligible FUDS property containing one or more releases or threatened releases of a similar response nature, treated as a discrete entity or consolidated grouping for response purposes. This may include buildings, structures, impoundments, landfills, storage containers, or other areas where hazardous substance are or have come to be located, including FUDS eligible unsafe buildings or debris. Response actions at FUDS projects fall under the Installation Restoration (HTRW and CON/HTRW), Military Munitions Response Program (MMRP ), or Building Demolition/Debris Removal (BD/DR) program categories. An eligible FUDS property may have more than one project. Louis Howard
11/5/2005 Update or Other Action Keres Environmental sampled 42 domestic (private) wells out of 52 wells identified in Port Heiden under the Native American Lands Environmental Mitigation Program (NALEMP). The 42 domestic wells were the only ones that were either functioning or accessible for sampling. Samples were analyzed for: diesel range organics (DRO), gasoline range organics (GRO), volatile organic compounds (VOCs), polynuclear aromatic hydrocarbons (PAHs), via the selective ion method (SIM), pesticides, polychlorinated biphenyls (PCBs), and safe drinking water act (SDWA) primary metals plus lead, iron, and copper. The first and second areas chosen for potential impact identified by the community members based on their location relative to the Port Heiden housing areas were located north and south of the road to Annie Christensen's house. The third is west of the New Meshik Mall, and the fourth is north of the new HUD area toward the west end, and the fifth is on the northeast side of the road from new HUD to the airport. Additionally, an old drum storage area is located north and west of the hazardous waste site on either side of an unnamed community road. The drum site is also of interest to the community. The other areas of interest and the other identified hazardous waste site are not located near housing and generally lie west/northwest of Port Heiden. Only six organic compounds were identified during sampling, all were below federal and state maximum contaminant levels (MCLs) for drinking water. "Maximum contaminant level" or "MCL" means the maximum permissible level of a contaminant in water that is delivered to any user of a public water system. "Contaminant" means a physical, chemical, biological, or radiological substance or material in water that, in sufficient quantity, makes water unfit for human consumption. Arsenic and iron were observed in the analytical results. Arsenic was below the Federal standard of 10 ppb or 10 ug/L (0.010 mg/L) and the State standard of 50 ppb or 50 ug/L (0.050 mg/L). Iron in 29 of the 42 domestic wells sampled exceeded the secondary maximum contaminant level of 0.3 mg/L or 300 ppb (300 ug/L) applicable only to community water systems not private domestic wells. According to the US EPA, National Secondary Drinking Water Regulations (NSDWRs or secondary standards) are non-enforceable guidelines regulating contaminants that may cause cosmetic effects (such as skin or tooth discoloration) or aesthetic effects (such as taste, odor, or color) in drinking water. EPA recommends secondary standards to public water systems but does not require public water systems to comply. However, states may choose to adopt them as enforceable standards. State of Alaska defines public water systems as either a: "Class A public water system" means a public water system that (A) is expected to serve, year-round, at least 25 individuals, (B) is expected to serve, year-round, at least 15 residential service connections; or (C) regularly serves the same 25 or more individuals for at least six months of the year; or a (13) "Class B public water system" means a public water system that is not a Class A public water system, and that regularly serves at least 25 individuals each day for at least 60 days of the year; or a (14) "Class C public water system" means a public water system that is not a Class A public water system, a Class B public water system, or a private water system. "Private water system" means a potable water system serving one single family residence or duplex. The department will require a "public water system" to meet the secondary MCLs if the department determines that public health is threatened or that exceeding a secondary MCL is not in the public interest. Groundwater is not contaminated since 18 AAC 75 states: “contaminated groundwater” means groundwater containing a concentration of a hazardous substance that EXCEEDS the applicable cleanup level determined under the site cleanup rules. Louis Howard
8/24/2006 Update or Other Action File number issued 2637.38.003. Aggie Blandford
10/20/2006 Meeting or Teleconference Held On October 20, 2006, Alaska Department of Environmental Conservation (ADEC) staff was notified by Mr. James Johnson at the Alaska Division of Homeland Security and Emergency Management that numerous drums are being exposed and eroding into Bristol Bay at Port Heiden. Community members noticed the eroding drums and contacted Mr. Johnson. Louis Howard
10/23/2006 Update or Other Action Photographs showing the drums were electronically from the community members on October 23, 2006. Louis Howard
10/26/2006 Update or Other Action DEC sent a letter to the Army Corps of Engineers requesting a time critical removal action to address an eroding drums at the Port Heiden Radio Relay Station. On October 20, 2006, Alaska Department of Environmental Conservation (ADEC) staff was notified by Mr. James Johnson at the Alaska Division of Homeland Security and Emergency Management that numerous drums are being exposed and eroding into Bristol Bay at Port Heiden. Community members noticed the eroding drums and contacted Mr. Johnson. Photographs showing these drums were sent to you electronically from the community members on October 23, 2006. The drums are located in the area known as “D650” from the Port Heiden/Port Moller DERP Debris Cleanup (CORPS of Engineers Diagram 2) conducted in the early 1990s. These drums are a solid waste and contain potentially hazardous substances which could impact the shoreline and the waters of the State (Bristol Bay) creating pollution and an unacceptable risk to human health and the environment. Several State statutes and regulations that potentially apply to erosion of these wastes into surface waters are listed below. -Alaska Statute (AS) 46.03.100. Waste Management and Disposal Authorization: (a) A person may not construct, modify, or operate a sewerage system or treatment works or dispose of or conduct an operation that results in the disposal of solid or liquid waste material or heated process or cooling water into the waters or onto the land of the state without prior authorization from the department. -AS 46.03.710. Pollution prohibited: A person may not pollute or add to the pollution of the air, land, subsurface land, or water of the state. -AS 46.03.745. Hazardous substance release: Except for a controlled release, the reporting of which is the subject of an agreement with the commissioner under AS 46.09.010 (b), a person may not cause or permit the release of a hazardous substance as defined in AS 46.09.900. -AS 46.03.822. Strict liability for the release of hazardous substances. -18 AAC 70.015. Antidegradation Policy: prohibits any reduction of water quality except within mixing zones of permitted discharges. -18 AAC 75.325. Site cleanup rules - general provisions include requirements to: -Use permanent remedies to maximum extent practicable -Minimize spread of contamination to uncontaminated areas -Prevent, eliminate, or minimize potential adverse impacts to human health, safety, and welfare, and to the environment, onsite and offsite, from any hazardous substance remaining at the site Additional federal laws, including the Clean Water Act and Resource Conservation Recovery Act, likely apply to the current or threatened release of solid and potentially hazardous wastes into the marine environment. The Department requests the Corps of Engineers take immediate action, through a time critical removal action or other appropriate means, to mitigate this release of solid waste and potentially hazardous substances to the environment. Due to the serious erosion problems at the site and the fact the drums extend into the surface water, the Department requests a response to this letter by November 20th outlining how the Corps of Engineers intends to contain or remove wastes in the landfill. John Halverson
11/8/2006 Update or Other Action The Army Corps of Engineers responded that it will conduct a Site Inspection to determine whether the drums contain waste or contaminants that would allow their removal under the FUDS program. If eligible wastes are identified, a removal will be conducted during 2007, subject to available funding. John Halverson
11/22/2006 Site Visit On 21 through 22 November 2006, an initial site visit was conducted to address local community concerns brought to the attention of the Alaska Department of Environmental Conservation (ADEC) during October 2006. Residents and community officials observed the eroding edge of an apparent FUDS drum disposal site. Residents and community officials from the City of Port Heiden had recently observed an apparent FUDS buried drum dump whose seaward edge is eroding, thereby exposing and releasing drums from the coastal bluff. The specific objective of this site visit was to determine whether any exposed drums contained liquids. The site is an actively eroding beach area on land belonging to the City of Port Heiden, located several miles south of the Port Heiden airport. The nearest feature to the site is an abandoned aboveground storage tank farm about 0.1 miles directly northeast of this site. The site can be accessed on an existing road shown as Seal Beach Road on city planning maps. Prior to mobilization, a right-of-entry was obtained from the city of Port Heiden by USAED Project Manager Ron Pflum on 20 November 2006 During the site visit, the exposed drums were observed, numbered, and checked for contents. The field staff noted during the initial site visit that approximately 60 feet south of the exposed beach drums, another area of eroded bluff contained wood and plastic debris, some lead-battery waste, and other buried waste of more recent origin than the drum disposal site. Louis Howard
12/18/2006 Update or Other Action The Corps concluded that there is no HTRW contamination associated with this dump and the site should be associated with BD/DR or at best CON/HTRW contamination only. A trip report was sent to ADEC. As a result, due to a possibility of finding POL in a drum and the discovery of parts of a battery, the CORPS decided to generate a CON/HTRW project to remove the dumps and since the beach appears to be eroding at a rate of 10 to 30 feet per year. The CORPS is working to add the CON/HTRW project to this years FUDS program to prevent all the drums from eroding into the ocean. NOTE TO FILE: Hazardous, Toxic, and Radioactive Waste (HTRW) Projects. HTRW projects include environmental response actions at an area of an eligible FUDS property as the result of DoD activities related to hazardous substances, pollutants, and contaminants as defined in CERCLA; petroleum, oil, or lubricants (POL); DoD-unique materials; hazardous wastes or hazardous waste constituents; low-level radioactive materials or low-level radioactive wastes; and explosive compounds released to soil, surface water, sediments, or groundwater as a result of ammunition or explosives production or manufacturing at ammunition plants. ER-FUDS funding can be used for HTRW restoration activities involving the cleanup of petroleum in soils or groundwater, even though it may not be subject to regulation under CERCLA, where the Secretary of Defense determines that such activities will result in correction of environmental damage posing imminent and substantial endangerment to the public health or welfare or to the environment [(10 USC 2701(b)(2)]. Response actions at these latter projects are carried out under authority provided for in the DERP and not as the result of legal requirements imposed on DoD by statute. Containerized Hazardous, Toxic, and Radioactive Waste Projects (CON/HTRW) projects include response actions at an area of an eligible FUDS property to address: -Underground storage tanks (USTs), aboveground storage tanks (ASTs), transformers, hydraulic systems, investigative derived waste (IDW), abandoned inactive monitoring wells, etc. Response actions for drums containing hazardous substances, pollutants, and contaminants are performed under the HTRW project category. - Incidental removal of contaminated soils resulting from a leaking UST or other container. - Long-term corrective actions required by RCRA Subtitle I involving significant soil and groundwater response actions following UST closure/removal actions. Ineligible projects include the following: - Projects where the current owner refuses right of entry. - In these cases, the geographic military District shall notify the appropriate authorities, such as EPA, State environmental regulatory agencies, and local government agencies involved with public safety. - For projects or properties where military munitions are reasonably believed to be present and access is denied, USACE will notify ODUSD (I&E) through the chain-of-command of the circumstances surrounding the denial of right of entry. According to the DoD Mgt. Guidance for the DERP, HQDA is responsible for making appropriate referral to the Attorney General of the U. S. per CERCLA §104(e)(5)(B). - Where projects response actions would mitigate hazards that resulted from civil works activities rather than military activities. - Funding in the ER-FUDS appropriation is not authorized for reimbursement of current landowners or other PRPs for any response actions initiated or completed with regard to DoD contamination on an eligible FUDS property. - Where project response actions would abate asbestos-containing materials (ACM) or lead-based paints, unless: - The ACM or lead-based paint is incidental to the completion of response actions at an approved project, or - In situations where the ACM were not incorporated as an integral component of a facility but were released into the environment by DoD disposal actions resulting in an on-site CERCLA hazardous substance release for which DoD is responsible. - Projects involving underground storage tanks or other structures that have been beneficially used by any owner subsequent to DoD. For a CERCLA release from a beneficially used UST or transformer subsequent to DoD control, a PRP project may only be proposed if there is evidence of a CERCLA release resulting from DoD use. Louis Howard
5/24/2007 Report or Workplan Review - Other Staff reviewed & commented on 2007 Work Plan, Port Heiden Drum Aread Removal Action Draft May 2007. 1.2 Page C-1-2: The 3rd & 4th bullets state that the Preliminary & Quality Assurance (QA) labs have not been determined. ADEC requests the following information be sent when the labs have been chosen: ADEC approval letter for those that will be performing AK method analysis (i.e. AK 101-3) -laboratory approval identification number -expiration date of laboratory approval number -specific laboratory methods, matrices & the specific analytes they are approved for. 1.3 Page C-1-2: The text references QA requirements being defined in this document which include the ADEC Technical Memorandum 06-002 (ADEC 2006a). The Technical Memorandum dated October 9, 2006 also states: “All reports submitted to ADEC containing analytical laboratory sample results shall contain a completed Laboratory Data Review Checklist & a Quality Assurance (QA) Summary. The Lab Data Review Checklist is located online at: Http://www.dec.state.ak.us/spar/guidance.htm#methods, & must be completed, signed & dated by the firm submitting the report to ADEC. It is not to be completed by the analytical lab that performed the sample analysis. The QA Summary must be included as a specific text section in the report. All lab results, including lab quality control (QC) sample results, must be reviewed & evaluated for quality, validity & usability. The text must include any affects on data validity &/or usability due to field sampling & laboratory quality control discrepancies.” ADEC requests inclusion of a reference to completion of the Lab Data Review Checklist & a Quality Assurance (QA) Summary. Additionally, ADEC will require the submittal of one Lab Data Review Checklist per lab report. If the USAED or its consultant, submits reporting documentation to ADEC that contains three (3) lab reports, then three (3) checklists must also accompany the documentation, regardless of the sampling events in the field. The text also states that the primary lab will be used whenever possible. Another lab may be used following consultation with the USAED Project Chemist. ADEC requests that this additional lab submit the information requested above under comments for section 1.2. ADEC requests clarification on whether or not the primary lab will be analyzing soil for PCB since it is absent from the list of chemical analyses on pages C-1-5 & C-1-6. Table A-2 Sample Summary & page A-5-3 does list PCB by SW8082 will be conducted for soil samples: Excavation Confirmation, Stockpile Preconstruction/Post construction, Waste Characterization. Finally, the text on page C-1-8 states that the analytical data will be evaluated for compliance with project-specific data quality objectives (DQOs). If this means complying with the Technical Memorandum 06-002 (dated October 9, 2006) & completing the Lab Data Review Checklist(s) & a Quality Assurance (QA) Summary, the ADEC concurs. Table C-2 Page C-1-10: ADEC requests the table or text reflect which units are being referred to (i.e. ug/kg or mg/kg for soil). Additionally, ADEC requests the table be changed to reflect these action levels: -Residual range organics (RRO) ADEC action limit (Under 40 inch Zone) will be 10,000 mg/kg (ingestion) which is more stringent than 11,000 mg/kg (migration to groundwater) listed in the table. -Benzo(a)pyrene will have the more stringent action limit of 1 mg/kg (ingestion). -Trichlorethene (TCE) has an updated cleanup level for Method Two Under 40 inch zone: 0.020 mg/kg for migration to groundwater (see Technical Memorandum 06-003 dated August 10, 2006). -1,2,4-trimethylbenzene action level will be 92.2 mg/kg (inhalation) which is more stringent than 95.2 mg/kg (migration to groundwater) listed in the table. -Polychlorinated biphenyls (PCBs) are missing from the Table C-2 Sight Investigation Parameters for soil matrix. However, it appears in numerous places within the document as being investigated for this effort. ADEC will require the inclusion of PCBs in the table for soil matrix & the action level will be 1 mg/kg as found in 18 AAC 75, Table B1, Method Two, Soil Cleanup Levels. For unrestricted land use, PCBs in soil shall be cleaned up to one mg/kg or less, unless ADEC determines that a different cleanup level is necessary as provided in 18 AAC 75.340(i), as, for example, in a subsistence food gathering area. Louis Howard
6/8/2007 Update or Other Action Supplemental Environmental Assessment and Findings of No Significant Impact for Drum Removal Action at Port Heiden by the DERP FUDS Program. The U.S. Army Corps of Engineers, Alaska District (Corps) proposes to remove drums and other military debris from a former landfill on the Bering Sea coast near Port Heiden, Alaska. The landfill is being actively eroded by wave action, and drums of presumed military origin are being exposed and deposited in the tidal zone. The proposed action affects a very limited area, and is considered follow-on work to previous Corps removal actions at Port Heiden addressed in environmental assessments dated 1985 and 1991 The proposed project is authorized under the Defense Environmental Restoration Program - Formerly Used Defense Sites (DERP-FUDS), which provides the means to clean up contaminated wastes and unsafe structures and debris from areas formerly used by the DOD. Need for Action-Ongoing coastal erosion is exposing buried military drums and other debris at a former landfill, and causing exposure in the tidal zone to dangerous debris and possible hazardous materials. This process and the associated risks will continue unless the drums are proactively removed from the landfill site. Preferred Alternative: Comprehensive Drum Removal Action-This alternative would proactively remove drums and associated military debris from both the tidelands and the landfill, to the extent that can be done safely and with minimal environmental impact. The porlion of the landfill containing drums is estimated to extend 200 feet along the shoreline by 125 feet inland, and to be roughly 6 feet deep. The entire area impacted by removal and staging activities is expected to be less than one acre. The project site is on land owned by the community of Port Heiden. Access to the site would require landing a barge and traversing state tidelands. Port Heiden community plans designate a clam digging area and subsistence fishing area along the beach north of the project site. The Corps has coordinated with the Alaska Department of Natural Resources (DNR letter dated 14 March 2007) to identify work practices that will ensure protection of coastal resources. The stipulations in the DNR letter include: All activities at the site shall be conducted in a manner that will minimize the disturbance to the natural character of the beach. All waste generated by the Corps and its contractors will be removed or otherwise disposed of as required by state and federal law. Refueling of equipment and the storage of petroleum products on state-owned tidelands is prohibited. Sorbent material in sufficient quantity to handle operational spills must be on hand at all times. Any spill of fuel or other pollutant shall be reported immediately to the Alaska Department of Natural Resources, Division of Mining, Land, and Water (Mr. R. Sam Means, 907-269-8548). The Corps and its contractors shall also immediately notify the Alaska Department of Environmental Conservation (ADEC) of cumulative petroleum spills greater than 55 gallons occuning outside a containment area, and spills of any size to a waterbody or of a substance other than petroleum. Louis Howard
7/31/2007 Site Characterization Workplan Approved Final Work Plan-This Work Plan outlines the scope of work to be conducted at the Port Heiden Drum Area, Port Heiden, Alaska, during the 2007 field season. The work described herein will be performed under U.S. Army Engineer District, Alaska (USAED), Environmental Remediation Services Contract Number W911KB-06-D-0006, Task Order 04. Under this contract, Jacobs Engineering Group Inc. (Jacobs) will remove drums of military origin and associated petroleum, oil, and lubricant (POL)-contaminated soil at the Formerly Used Defense Sites (FUDS) at Port Heiden, Alaska. The project objective is to remove potential sources of contamination contained within or emanating from drums and within underlying soil in a manner that is protective of human health and the environment. SCOPE OF WORK-The following definable features of work under this task order are: • Mobilization • Removing drums and contaminated soil at the drum area • Environmental media sampling • Shipment of drums and contaminated soil to approved disposal facility • Site restoration and backfilling of excavation areas with clean soil • Surveying at the site to document excavation boundaries and sample locations The contaminants of potential concern at the drum area at Port Heiden are sources of contamination contained within or emanating from drums. Due to the unknown contents of the drums, samples will be subject to a full suite of analyses that includes gasoline-range organics (GRO), diesel-range organics (DRO), residual-range organics (RRO), polynuclear aromatic hydrocarbons (PAH), volatile organic compounds (VOC), pesticides, polychlorinated biphenyls (PCB), and Resource Conservation and Recovery Act (RCRA) metals. The removal action will begin on the beach, where visible drums will be removed first. Periodically during the removal, the underlying soil will be screened for contamination using a PID and visual and olfactory observation. Initially, soil screened for any deflection above background readings may be considered contaminated. Headspace PID screens will be compared to analytical results throughout the project to help correlate project specific PID screening action levels. Soil determined to be contaminated will be excavated and either temporarily stockpiled onsite or placed directly into 1-cubic-yard Super Sacks to be loaded into a shipping Container Express unit (CONEX) for transport offsite. If additional drums are encountered during excavation activities, those drums will be removed and the same liquid characterization and soil field screening routine performed. In order to most efficiently characterize the soil following the removal actions, one discrete soil sample will be collected from the removal area. Following the removal activities within the areas, the soil will be field screened using a PID. A minimum of two field screening samples will be collected from each 250 square feet of removal area. Field screening locations will be selected based upon visual and olfactory indications of contamination including stressed or stained vegetation and soil exhibiting a fuel odor. The discrete soil sample will be collected at the location exhibiting the highest PID result. If field investigations indicate that soil removal actions are not necessary, these locations will not be field screened. Louis Howard
8/23/2007 Update or Other Action Email from USACE R. Pflum discussing the drums and contaminated soil under the ground water. Note that the drums and contaminated soil in question run for about 100 feet parallel to the beach. Also attached are two photos of the area and the MSDS for Pentanonic, which we want to try to use to mitigate the POL contamination. What are your thoughts? USACE C. Floyde email to R. Pflum RE: Pot Heiden Path Forward. The contaminated groundwater is sort of a "pre-existing condition"; it's presumably been there nearly as long as the landfill has been there. It's no surprise that the area is contaminated... we just didn't anticipate that the groundwater would high enough for us to get into... or that we'd be chasing drums downward into groundwater. I don't remember any historical report of a contaminated seep at the base of the bluff. It's conceivable that we may create such a seep if the fill material is more coarse than the native bluff soil, and we create a preferential pathway for groundwater to leave the bluff, or for precipitation to percolate more easily into the site soils and raise the groundwater level. It seems to me that it would be appropriate to do something to mitigate the risk of increased groundwater migration brought about by our removal action (maybe some kind of geotextile or silt barrier laid above the groundwater level), but trying to launch an ad hoc groundwater remediation as part of what was originally an emergency removal action may not be feasible (or even permissible). We'll let the ADEC know what's going on. We would ultimately need/want their agreement on a serious groundwater remediation approach, but I don't think we need to wait for their blessing before proceeding with stabilizing the site for the end of the season. ADEC subsequently denied the use of Pentanonic at the drum removal site. Louis Howard
10/11/2007 Update or Other Action Community member sent photos of additional debris and eroding dump adjacent or near the area where a removal action was conducted early this summer by the CORPS. Louis Howard
10/12/2007 Update or Other Action ADEC requests confirmation from the CORPS regarding additional debris and drums adjacent to the area where they conducted a removal action. Louis Howard
10/18/2007 Update or Other Action CORPS responds to ADEC request. The old dump is located adjacent to the drum dump, which has been removed. The contractor has now de-mobilized. This dump is labeled "Village Landfill" on the old drawings and is located in the old village. Most of the dump contains domestic waste and most of the few drums are blue in color, which are not Army issue. Also, the fact that a few of the non blue drums do have Army or Air Force marking on them does not mean they were used by the base. Many Army drums were given away to the Natives after the Army left. To try to prove that the dump is related to previous DOD activities would require conducting an historic investigation of the dump, which normally takes one to two years. In other words, the CORPS would have to treat the dump as a potential PRP site. Louis Howard
11/6/2007 Meeting or Teleconference Held Conference call with CS staff, personnel from ADEC, Lake and Peninsula Borough, City of Port Heiden and the Port Heiden Village council to discuss significant erosion events that are occurring at the village from intense fall storms. The latest storm has eroded into a landfill area and has exposed numerous drums and other solid waste. Local residents maintain that this landfill was created by DoD and much of the waste is theirs. However the USACE is maintaining that the landfill is not DoD related and is an issue for the local community. The USACE determination is based on a notation on a site As-Built that indicates the site as a “Village Landfill” and the fact that much of the solid waste does not appear to be directly related to the military (fishing nets, snowmachine parts, etc.). While some 55-gallon drums do have markings indicating that they originated from DoD these could have been reused by the village and then disposed in the unpermitted landfill or dump area. ADEC has requested a formal determination from the USACE regarding their position on the landfill dump area. Once this information is available the ADEC site manager will confer with management, evaluate the evidence, and make a determination as whether the evidence supports the USACE or Port Heiden. Louis Howard
11/19/2007 Meeting or Teleconference Held The Lake and Peninsula Borough in conjunction with the City and Village of Port Heiden is requesting your attendance on a teleconfernce Monday November 19th, 2007 at 1:00 PM to disuss the Erosion problem in Port Heiden. teleconference number is: 1-866-339-5580 Access Code is: *2288317* Port Heiden has been hit with a series of winter storms that have caused significant beach erosion that has exposed an old landfill. The last storm took 7-10 feet of the beach.The landfill is dumping lots of debris and some old military barrels into the ocean. The purpose of the meeting is to disuss the best immediate actions to take and also to try and determine who has responsibility. The City and Village of Port Heiden and the Military have all contributed waste to the landfill in the past. In addition there are some old buildings near the ocean front that could possibly have asbestos in them according to the local citizens. Agend is as Follows: 1. Discuss the erosion problems on the landfill - Determine ownership - Decide on an immediate action plan - Identify possible funding sources 2. Discuss the old buildings on the Beach and the best solution - Determine best course of action - Identify possible funding sources I have attached community profile maps of Port Heiden to help in the discussion. The L&P Borough will moderate the meeting. Louis Howard
11/23/2007 Update or Other Action USCG POLEREP ONE P 202123Z NOV 07 ZUI ASN-P07324000024 FM COMCOGARD SECTOR ANCHORAGE AK TO CCGDSEVENTEEN JUNEAU AK//DRM/DPI/DRE/DP/DRMC// COMCOGARD NPFC WASHINGTON DC COGARD FINCEN CHESAPEAKE VA COMPACAREA COGARD ALAMEDA CA COMCOGARD MLC PAC ALAMEDA CA//FCP// COGARD NSFCC ELIZABETH CITY NC INFO COGARD MSD KENAI AK COGARD MSD KODIAK AK COGARD MSD UNALASKA AK COGARD AIRSTA KODIAK AK BT UNCLAS //N16465// SUBJ: POLREP ONE, DISCHARGE OF UNKNOWN PRODUCT FROM ABANDONED DRUMS,PORT HEIDEN, ALASKA. MISLE CASE NUMBER 383181 1. SITUATION:(ALL TIMES LOCAL) A. 191330NOV07: SECTOR ANCHORAGE BECAME AWARE OF EROSION AFFECITING AN OLD UNREGULATED LANDFILL AT THE VILLAGE OF PORT HEIDEN, ALASKA. THE LANDFILL CONTAINS UNKNOWN PRODUCTS AND MAY HAVE BEEN STARTED BY THE MILITARY IN THE 1950'S. B. WX: TODAY: TODAY...N WIND 30 KT. SEAS 14 FT. SNOW SHOWERS. FREEZING SPRAY. .TONIGHT...NE WIND 25 KT BECOMING VARIABLE 15 KT AFTER MIDNIGHT. SEAS 9 FT. RAIN AND SNOW SHOWERS. .WED...SW WIND 20 KT BECOMING SE 20 KT IN THE AFTERNOON. SEAS 5 FT. SNOW AND RAIN SHOWERS. .WED NIGHT...E WIND 20 KT. SEAS 7 FT. .THU...NW WIND 35 KT. SEAS 14 FT. .FRI...SW WIND 30 KT. SEAS 14 FT. .SAT...SE WIND 25 KT. SEAS 10 FT. C. AGENCY JURISDICTION: USCG, EPA, DEC, AND DOI. D. RESOURCES AT RISK: WATERFOWL. E. O/O INFO: NOT IDENTIFIED 2. ACTION: A. 201720Z NOV 07: NOTIFIED THAT 2 SECTOR PERSONNEL WERE ENROUT TO VILLAGE TO DO AN INITIALL ASSESSMENT. D. 201747Z NOV 07: LEFT MESSAGE FOR EPA FOSC TO CALL SECTOR IN REGARDS TO A JOINT ASSESSMENT. E. 201754Z NOV 07: PUT PST ON STAND BY TO RESPOND WITH RS, RT AND AIR MONITORING CAPABILITY. F. 201814Z NOV 07: CONTACT AK DEC ON CURRENT SITUATION, REQUESTED STATE NOTIFY US OF WHO WOULD BE SOSC. MR. BROWN TO FORWARD UP REQUEST. G. 201815Z NOV 07: OPENED FUND, CPN C08022. H. 201824Z NOV 07: MR HOWARD STATED HE WILL BE THE AK SOSC AND WILL ALSO CONTACT THE ACOE PROJECT MANAGER, REQUESTED AN INITIAL 1500 UNIFIED COMMAND MEETING. I. 201858Z NOV 07: TALKED TO MR. CARR, HE IS WILLING TO WORK WITH CG ON ASSESSMENT BUT CAN NOT DO SO WITHIN ANY SHORT TIME PERIOD. STATED THAT THIS TYPE OF INCIDENT IS MORE OF A REMEDIAL PROJECT AND WOULD BE UNDER THE REALM OF THE AN EPA RPM OUT OF EPA REGION 10 IN SEATTLE. J. 201906Z NOV 07: MST1 HARVEY RECEIVED NOTICE FROM MRS SONDRINI AND MR TOWNSEND TO INFORM THEM WHEN AND IF THE CPN GOES ABOVE 50,000. K. 201914Z NOV 07: LEFT MESSAGE REQUESTING A RETURN PHONE CALL TO DISCUSS SITUATION AND ANY EPA INVOLVEMENT. 3. FUTURE PLANS AND RECOMMENDATIONS: A. SECTOR ANCHORAGE TO HOLD JOINT AGENCY MEETING AT UNIT AT 0900 20NOV07 4. CASE STATUS: A. MEDIA INTEREST: NONE B. CASE PENDS. C. CURRENT CEILING COST: $25,000 CURRENT CG PERSONNEL COST TO DATE: $0.00 CURRENT CG EQUIPMENT COST TO DATE: $0.00 CURRENT CG TRAVEL COST: $0.00 CURRENT CG CONTRACTOR COST: $0.00 CURRENT CG PURCHASE COST: $0.00 CURRENT CG PRFA COST: $0.00 5. COMMENTS A. NONE BT NNNN Louis Howard
11/27/2007 Meeting or Teleconference Held On 26 and 27 November, Jacobs and USCG representatives met in Anchorage and conducted premobilization meetings, during which the following site visit team was assembled and briefed for the November 28 site visit: • Jacobs Engineering: Brian Roberts 907-751-3356 brian.roberts@jacobs.com • USCG: Paul Moyer 907-350-1361 paul.moyer@uscg.mil, Luke Potter 415-720-4163, Mike Comeshak 415-286-1665 • ADEC: Louis Howard 907-696-7192 louis.howard@alaska.gov • USAED: Gordon Osgood 907-727-7816 During the premobilization meetings, team members worked jointly to define site visit responsibilities and objectives and developed a site-specific safety plan for the visit. A secondary objective of these meetings was to resolve contract actions, equipment rentals, and purchase of small consumables prior to mobilization to the site. Louis Howard
11/28/2007 Site Visit On November 28 at 07:00, team members assembled at Security Aviation facility on Carl Brady drive at Ted Stevens Anchorage International Airport. The team loaded men & equipment into a Cessna 441 Conquest & departed the airport at 07:45. Based upon concerns about this area reported by local residents, the USCG conducted a site visit to Port Heiden on 28 November 2007. The primary objective of this site visit was to ascertain if any containerized hazardous material was present at this beach area & posing a threat to the navigable waterways. In order to meet this objective, USCG contracted with Jacobs to provide a qualified sampler to the site visit, investigate any suspect containers of hazardous materials, & provide an overall opinion regarding the nature of any existing or previously spilled materials. At 09:30, the team landed at Port Heiden & disembarked the aircraft. Security Aviation maintained the aircraft on standby in radio communications for the entire site visit. Upon arrival, the team met with City of Port Heiden on-scene coordinator Derek Schraffenburger. The team loaded into a local rental vehicle & assembled at a nearby warehouse & office facility for the first stop of a three-part site safety & health orientation. Mr. Roberts, acting as the site team safety officer, conducted the briefing in three parts & at three locations. The second part of the briefing was conducted at 10:00 at the Port Heiden medical clinic. During this stop, the team liasoned with Native Village of Port Heiden representative Lynn Carlson. The third & final portion of the safety briefing & site orientation was conducted at 10:15 at the beach area. During this portion of the briefing, the team reviewed emergency response procedures & task-specific safety discussions. At approximately 10:45, the team began its walking assessment of the beach. Weather at the site was approximately 43 degrees Fahrenheit, high overcast, & gusts to 25 from the southeast. The tide was incoming from the recent low-tide event, & overall conditions were excellent to optimize the site visit. Between 10:45 & 12:30, the team walked the beach area east of the existing bluff line, north to south, to inspect 100 percent of the debris that was visible & eroding onto the beach. The most prominent feature of the beach access location is the road to the beach, which is visible immediately south of the eroding dump site (Figure 3-1). In general, debris was visibly concentrated in an area on the beach immediately west of the eroding dump site, along an axis approximately 350 feet long north to south. Sparse metal debris at this site was evident on the site as far as 1,500 feet south of the beach access road & 500 feet north of the beach access road. Metal debris in the intertidal zone included several dozen drums & two engine blocks. All of the visible drums were deteriorated through, & most were missing bungs. The site assessment team ascertained that none of the visible drums was capable of containing product currently or in the recent past. No sheen or odor emanated from the drums or debris. In addition to metal drums & engine blocks, a wide variety of plastic, wooden, & glass waste was scattered along an obvious high-tide line. These objects were concentrated along the grassy low areas east of the existing bluff. The nature of the items is too numerous to list fully but included soap bottles, food containers, glass bottles, shoes & clothing, buoys & fishing gear. None of these articles appeared to present a present or future chemical release hazard to the environment. Everything resembled general discarded solid waste. One abandoned 1960s vintage bulldozer is near the beach bluff along the access road, 15 feet from the eroding shoreline. The site assessment team was able to confirm that the abandoned bulldozer contains motor oil on the dipstick as well as a lead-acid battery. The bulldozer may also contain diesel fuel, which could not be confirmed. The site visit team closely inspected the upland areas surface soils for any signs of sheen, distressed vegetation, or staining. One area of surface appeared to be slightly discolored, 34 feet immediately east of the abandoned bulldozer. Soil at this location was examined with a photoionization detector (PID), & no elevated field screening results were detected. At the request of USCG, Jacobs collected an analytical soil sample from this location (07PHSS01) & analyzed it for the full list of analytes. No elevated results of any compounds were detected. One article of concern observed during the site visit, a polyethylene fuel bladder on the beach appeared to contain a petroleum product. During earlier site visits, this bladder had been observed, from the bluff over the beach, at approximately 500 feet north of the beach access road and appeared to be almost completely empty. See site file for additional information. Louis Howard
12/17/2007 Update or Other Action Port Heiden Drum and Dump Area Trip Report Technical Memorandum received. This Technical Memorandum summarizes the details of a site visit to the Port Heiden Drum and Dump Area on 28 November 2007. This site is located southwest of the current town site of New Meshik, also known as Port Heiden. The nearest permanent structure to the site is an aboveground storage tank farm about 0.1 direct miles northeast of this site. Old Meshik is south of the site approximately 0.25 miles. This site was used previously as both a military and civilian dump site. Prior to the 2007 site visit, the military conducted a removal action with the objective of removing the Formerly Used Defense Site (FUDS) military drum disposal area. The objective of this site visit was to identify any potentially hazardous materials currently leaking from this site and potential responsible parties. On 10 August 2007, the U.S. Army Engineer District, Alaska (USAED), mobilized to the site to conduct a removal action at the drum area. Upon arrival at the site, four test pits were dug to determine the extent of the buried drums associated with the FUDS drum area. Test pit 1 contained no drum material or other debris and helped establish a northern maximum extent. Test pit 2 had drums starting approximately 1 foot below ground surface. Test pits 3 and 4 contained no drum material or debris. Following this initial test pitting, excavation of the drum area began just southwest of test pit 2, advancing south in an arc shape. Drum material was heavy and continuous in the central portion of the excavation but thinned toward the southern boundary, which was determined by the lack of drums over two excavator bucket widths and the onset of domestic waste. The nature of the domestic waste included household trash, food-related trash, personal hygiene items, shoes, and other clothing indicative of residential landfills. The excavation and removal of drums in this area continued until native soil material free of drums and other debris was encountered in all directions. The westward excavation continued toward the bluff and eventually connected with drum removal at the beach. The southern expansion along the bluff also continued until no drums or drum debris was located. Domestic waste was encountered along the southern wall of the bluff. The excavation boundary was established by finding either native soil (to the north, west, and east) or by the visual confirmation of lack of FUDS-era drums. Over 2,500 buried steel drums were removed and disposed of offsite. Approximately 200 tons of petroleum contaminated soil was removed and recycled offsite. Analytical soil samples were collected from the excavation floor and sidewalls. All analytical results were confirmed to meet ADEC cleanup criteria evaluated by Method Two migration to-groundwater soil cleanup criteria. The drum area was restored with gravel imported from a local borrow pit and reseeded. Final demobilization from the Drum Area occurred on 10 October 2007. It was during this demobilization that the domestic waste was first observed eroding from the abandoned landfill. At the end of the excavation and drum removal, a series of test pits was placed around the site. Locations for the test pits were a result of local staff indicating that there had historically been drums in those locations. Test pits 5, 6, 7, 8, 9, and 10 were free of drums and other debris. Test pits 11, 12, 13, and 14, to the south of the excavation, were free of drums but yielded domestic trash intermingled with soil. Sparse drum debris was commingled with domestic waste on the southern perimeter of test pit 11. Based on observations at the surface and during the excavation and test pitting, the Port Heiden Drum Area appears to be separated from the unpermitted landfill to the south. The nature of the debris in the unpermitted landfill indicated that the landfill was of a more recent origin than the FUDS drum area. No suspected hazardous materials were observed immediately adjacent to the drum and dump areas. No sheens, odors, or other obvious signs of a spill or release were observed. One polyethylene fuel bladder immediately north of the site appeared to be the source of a small diesel spill on the beach. This bladder contained a small amount of what appeared to be diesel fuel that may still be recoverable. One abandoned bulldozer is currently near the eroding coastline at this site. This bulldozer contains a lead-acid battery, motor oil, and other engine fluids. By comparing survey measurements from 13 September 2007 to the 28 November survey measurements, the following were calculated: • The maximum observed coastal erosion in this area is 56 feet. • The minimum observed coastal erosion in this area is 9 feet. • The average coastal erosion observed over this time was 29 feet. See site file for additional information. Louis Howard
1/10/2008 Update or Other Action Port Heiden Drum Area Remedial Action Report received. The 2007 Port Heiden Drum Removal Action was accomplished between August and October 2007 at the Port Heiden Drum Disposal Area in Port Heiden, Alaska. The project objective was to remove potential sources of contamination contained within or emanating from buried drums and within underlying soil in a manner protective of human health and the environment and to eliminate Formerly Used Defense Site liability at the site. Contaminants of potential concern were gasoline-range organics, diesel-range organics (DRO), residual-range organics, polynuclear aromatic hydrocarbons, volatile organic compounds, pesticides, polychlorinated biphenyls, and Resource Conservation and Recovery Act metals. The U.S. Army Engineer District, Alaska, contracted this removal effort through Environmental Restoration Services Contract Number W911KB-06-D-0006, Task Order 04. Fifty-three tons of metal drum debris (approximately 2,500 drums) were removed from the site. Approximately 3,000 cubic yards of soil was removed in association with the drum excavations. Of the excavated soil, approximately 84 cubic yards was shipped via barge to the Waste Management Inc. Columbia Ridge Landfill in Arlington, Oregon, for disposal. All Drum Disposal Area excavation soil confirmation samples yielded results below Alaska Department of Environmental Conservation Method Two cleanup criteria. The site has been restored to meet the landowner’s satisfaction. Excavation Progression: Upon arrival at the site, four test pits were dug to determine the extent of the buried drums associated with the FUDS drum area. These test pits are labeled 1 through 4. Test pit 1 had no drum material or other debris and helped establish a northern maximum extent. Test pit 2 had drums starting approximately 1 foot below ground surface. Test pits 3 and 4 also had no drum material or debris in them. Following initial test pitting, excavation of the drum area began just southwest of test pit 2 and continued in an arc shape, generally advancing south. Drum material was heavy and continuous in the central portion of the excavation but thinned toward the southern boundary, which was determined by the lack of drums over two excavator bucket widths and the onset of domestic waste. The nature of the domestic waste included household trash, food-related trash, personal hygiene items, shoes, and other clothing indicative of residential landfills. From the southeastern wall of the excavation, excavation expanded north and then west. The excavation to the north continued until native soil material free of drum or other debris was encountered. The westward excavation continued toward the bluff and eventually connected with drum removal at the beach. The southern expansion along the bluff also continued until no drums or drum debris was located. Domestic waste was encountered along the southern wall along the bluff. The excavation boundary was established by finding either native soil (to the north, west, and east) or by the lack of FUDS-era drums. At the end of the excavation and drum removal, a series of test pits was placed around the site, as suggested by the local hire crew who recalled seeing drums historically in those locations. Test pits 5, 6, 7, 8, 9, and 10 were free of drums and other debris. Test pits 11, 12, 13, and 14, to the south of the excavation, were free of drums but yielded domestic trash intermingled with soil. Sparse metallic debris was commingled with domestic waste on the southern perimeter of test pit 11. The contents of the confirmation test pits further supported that the 2007 RA had successfully removed the FUDS-liability drums and debris. All impacted vegetated areas from the 2007 RA were seeded and fertilized on 13 September 2007, with the exception of the area cleared for the waste storage. The landowner requested that the area be left cleared for future uses. The City of Port Heiden Representative inspected and accepted the restoration of the affected areas prior to demobilization. Louis Howard
2/21/2008 Report or Workplan Review - Other ADEC Letter to the CORPS of Engineers represented by JACOBS Engineeering (B. Roberts) RE: Draft 2007 Report Port Heiden Drum Area Removal Action January 2008, Contract W911KB-06-D-0006 Task Order 04. Based on a review of the data presented in the document, which describes the removal of approximately 2,500 drums, 84 cubic yards of contaminated soil, 200 gallons of contaminated water, and the landowner (City of Port Heiden) approval of site restoration activities on affected land, ADEC has determined no further remedial action is required at the former Port Heiden Drum Disposal Area. ADEC is basing this determination on the most current and complete information made available to it by the Corps of Engineers. ADEC reserves its rights, under 18 AAC 75 Oil and Other Hazardous Substances Pollution Control regulations and AS 46.03 to require additional assessment and/or corrective action if information indicates the site conditions pose an unacceptable risk to human health, safety, or welfare, or the environment from formerly used defense site disposal activities. Louis Howard
4/6/2009 Report or Workplan Review - Other Staff review and commented on the US CORPS of Engineers Closeout Report submitted by Ron Pflum (USCOE) for the Port Heiden Drum Area Removal Action February 2009, DERP-FUDS Property No. F10AK0027 Projects: F10AK002702 CON/HTRW. Introduction Page 5- The text states: “the only contaminant of concern in this project was to remove drums of military origin and associated petroleum, oil, and lubricant (POL)-contaminated soil at the FUDS at Port Heiden, Alaska.” An August 23, 2007 email communication from you and Christopher Floyd, also with the CORPS, indicated that contaminated groundwater which needed to be addressed. This location needs to be mentioned in the report and whether any sampling was done to confirm the contamination present in the groundwater. Additionally, the CORPS will need to add this site the HTRW project for further characterization or investigation if it has not already eroded into the ocean. The area is known for having a high rate of shoreline erosion. If this is the case, then the report needs to mention it has occurred and nothing is left to investigate relating to the groundwater contamination. Area Use Map-ADEC requests the CORPS investigate the “Old Munitions Dump Site” under the MMRP. Also, ADEC requests clarification on the origin of the map since it appears to be from multiple sources and has hand drawn areas in blue as well as the highlighted areas in green without any legend explaining the source of the information and significance of the colors. 4.3 Removal Activities Page 11-ADEC requests clarification from the CORPS regarding whether or not any confirmation soil and water samples were taken directly from the excavation areas (bottom and sidewalls). Additionally, ADEC requests the CORPS state whether or not these confirmation samples meet cleanup levels. If so, state it as such in the text. There is the matter of the observed contaminated groundwater seeping from the dump observed by the CORPS in August 2007 which needs to be resolved. Louis Howard
5/21/2009 Report or Workplan Review - Other Staff reviewed and commented on the USACE CON/HTRW Project Closeout Report for Port Heiden Project# F10AK002702. Introduction, Page 5 The text states: "This report supports the conclusion that the work performed since 1989 is complete, and that no further action is required for this project to be protective of human health and the environment from past activities by the Department of Defense." ADEC requests the CORPS change the text to state "This report supports the conclusion that the CON/HTRW work performed since 1989 is complete, and that no further action is required for this project to be protective of human health and the environment from past activities by the Department of Defense." The text states: "While the project classification is CON/HTRW, the only contaminant of concern in this project was to remove drums of military origin at the FUDS at Port Heiden, Alaska." The 2007 fieldwork was to address the drums. If the document is to address closure of all CON/HTRW work since 1989, there were ASTs, USTs, transformers (?) and likely other containerized wastes that were removed. ADEC requests additional information be provided in the document regarding these other sources. If not, then restrict the focus of the document to only speak to the drum removal action conducted in 2007. Figure 1-1 Page 6 ADEC requests the CORPS clarify whether the objective of this document is to close out the area of concern from 2007 or the entire FUDS CON/HTRW project. The figure should be renamed Drum Disposal Area if the document is for this area of concern. 4.1 Removal Planning Activities Page 8 The text states "Empty drums have reportedly been retrieved from the beach area by local officials within the last year." ADEC requests the CORPS elaborate on whether it is known whether or not additional drums were eroding into the shoreline during 2008. 5 Summary of Remedy Page 11 The text states: "The objectives of the Port Heiden Drum Area RA were achieved by the removal of all drums and contaminated soil exceeding site cleanup levels. Approximately 2,500 drums were removed from the site, and the FUDS site has been successfully restored." ADEC requests the CORPS elaborate on whether the confirmation samples show the CORPS removed all the contaminated soil that exceeded the cleanup levels. If not, the wording needs to be revised. Louis Howard
8/21/2009 Report or Workplan Review - Other ADEC staff reviewed and commented on the Port Heiden HTRW POL/PCB/ASPHALT FUDS Project (F10AK002703). The Alaska Department of Environmental Conservation (ADEC) was recently notified that the Alaska District intends to close the Port Heiden HTRW POL/PCB/ASPHALT FUDS Project (F10AK002703). The Alaska District will address remaining contamination at Port Heiden under the Fort Morrow F10AK02704 project. Regardless of which project work is conducted under, ADEC expects the Alaska district to address all contamination that meets FUDS eligibility requirements under the Fort Morrow Project. ADEC does not object to the closure of the Port Heiden HTRW POL/PCB/ASPHALT project (F10AK002703), as long as the Alaska District continues to address FUDS eligible contamination at the site. NOTE to file: While the site is not listed on the CERCLA NPL, it is expected and required that the USACE will follow CERCLA process in its investigation at Fort Morrow for CERCLA hazardous substances. The Secretary of the Army shall conduct environmental restoration at FUDS properties consistent with the statutory and regulatory requirements discussed in sections 4 and 5 of this enclosure. The DoD should not conduct further environmental restoration activities based on changes in land use initiated by current property owners that are inconsistent with the previous remediation conducted by the DoD or LUCs attached to the property. 4. DoD ENVIRONMENTAL RESTORATION PROGRAM a. Environmental Restoration Activities. The DoD Component shall adhere to these tenets when conducting environmental restoration activities: (1) The DoD shall maximize the use of its DERP authority and delegated CERCLA authorities (e.g., as a lead agency), as discussed in section 1 of this enclosure. (a) The DoD may conduct environmental restoration pursuant to CERCLA; other applicable Federal, State, or local laws addressing environmental restoration (e.g., RCRA corrective action); or a combination thereof. 1. In instances where a regulatory agency seeks to use a framework other than DERP and CERCLA (e.g., sections 300f-300j-26 of Reference (r)), the DoD Component is encouraged to comply with all CERCLA requirements as well, especially with respect to the content of DDs, public involvement, and the maintenance of the administrative record. 2. When a regulatory agency seeks to use an authority for environmental restoration other than CERCLA, RCRA corrective action, or USTs pursuant to section 6991 of RCRA and subpart F of part 280 of Reference (s) (e.g., sections 6934 and 6973 of RCRA, commonly known as RCRA 3013 or 7003 orders, respectively), and the DoD Component is considering such an agreement, the DoD Component shall document the facts related to the situation and its DAS for the Environment or equivalent shall be the authority for the decision. The DoD Component DAS for the Environment shall notify the DUSD(I&E), by memorandum, early in the alternative approach discussions that discussions with the regulatory agency were initiated, and of the outcome when the discussions are complete. An exception to this requirement would be when addressing a petroleum release from an AST or distribution pipeline. (5) RI/FS. The DoD Component shall characterize the site and evaluate various alternatives for remediation of the site during the RI/FS. Once the DoD Component initiates the FS phase, the site shall continue through the selection of the remedial option, the development of a proposed plan, and the signing of the DD. (See subparagraph b.(5)(a)3.h. of this section if the RI determines that the site is protective and no remedial action is selected.) Although different in their focus and goals, typically the DoD Component will perform the RI and FS as concurrent, integrated events. Louis Howard
6/22/2010 Site Visit Trip Report (CORPS) FORT MORROW Site Reconnaissance and Geospatial Data Acquisition Port Heiden, Alaska, Alaska District Pacific Ocean Division, U.S. Army Corps of Engineers July 2010 Version 1.0 A site reconnaissance visit was conducted by USACE Alaska District (POA) on 22-24 June 2010 to Port Heiden, Alaska to observe features of former Fort Morrow. Port Heiden is located on the west coast of the Alaska Peninsula, approximately 140 miles southwest of King Salmon, Alaska (Figure 1). One purpose of the site visit was to meet with community members to obtain information about their concerns related to environmental impacts from Fort Morrow. An additional purpose of the visit was to collect geospatial information in support of future Formerly Used Defense Site (FUDS) activities at Fort Morrow, and to familiarize project management and engineering representatives with the site characteristics. Ordnance was found in the past by a community resident, reportedly from an area near the northwest corner of the Fort Morrow area. A map prepared by the Lake & Peninsula Borough (LPB) shows an “old munitions dump site” in an area that was observed on this site visit to be a large ground scar area (Appendix B).The ground scar is located along the western road at: • Easting 1504218 feet • Northing 1086019 feet (NAD 83, Alaska State Plane, Zone 6) The LPB map also indicates an “old bunker area” in grass-covered ground just up off the beach at the following location: • Easting 1503198 feet • Northing 1081096 feet (NAD 83, Alaska State Plane, Zone 6) Garage Area The garage area is located a short distance south of the airfield. Community representatives reported the garage was used by Alaska Department of Transportation and Public Facilities (ADOT&PF) after the military. The garage structure has been demolished, and the concrete foundation remains. Piles of equipment/vehicle skeletons are located southeast of the shop foundation. Maps from 1989 show drum storage in the area surrounding the garage. Spills were indicated on the 1989 maps at some of these drum areas, and some impacted soil was removed. An underground storage tank was removed from outside the west wall of the shop, and a spill was indicated near the southeast corner of the garage. Across the road to the north from the garage are several long trenches. Drums were reportedly stored. An infirmary was located at the eastern edge of the Fort Morrow area. Based on 1980s maps, the infirmary compound contained infirmary buildings, an x-ray and lab building, warehouse, administration building, recreation building, kitchen and mess hall, pump house, power house, radio station, several quarters, and several hospital wards. A concrete foundation was found in the southern part of the infirmary compound and buried piping was identified. One pipe smelled of petroleum. A location at the northwestern corner of the Fort Morrow area was shown in preliminary draft AGC information as a spill location, and was reported by the community as an ordnance location. The location was visited and found to be a large flat ground scar of sand and gravel surface soil. No debris was found. Hardened tar pieces were found at the surface. The surface appearance of soil at Fort Morrow sites suggests drilling would not be difficult, and that UVOST would be a possible investigative tool. Boring logs from prior Air Force work conducted along the former fuel pipeline and at the WAC site should be reviewed to verify this assumption. Louis Howard
7/23/2010 Exposure Tracking Model Ranking Initial ranking with ETM completed for source area id: 71053 name: Former Army Post Louis Howard
9/9/2010 Update or Other Action Email from CORPS to ADEC RE: Port Heiden/Fort Morrow Triad Meeting (9/23/2010) The proposed meeting on 23 September 2010, is intended really as preparation for the future TRIAD, not a formal TRIAD meeting itself. * We plan to discuss our current list of TRIAD representatives to verify the appropriate parties are included. * We plan to discuss the draft scope of work for contracting TRIAD support to decide if we have included the appropriate major elements and enough meetings. * We plan to present the spatial data that we have developed thus far, to facilitate a preliminary understanding of the former Fort Morrow area. We do not plan to make decisions at this meeting, as that will await the TRIAD meetings when all appropriate parties are represented. Instead, this meeting is simply an opportunity to share information early on and gather input from ADEC that may make the TRIAD more effective. We would be happy to include EPA in this preparation meeting. Thanks for the suggestion. Louis Howard
9/9/2010 Update or Other Action Email from ADEC to CORPS RE: Port Heiden/Fort Morrow Triad Meeting. Looks like the attached statement of work is to aid in selecting a contractor for the TRIAD approach at Fort Morrow/Port Heiden. ADEC does not get involved in the contractor review process and/or contractor selection process for cleanup projects. Please advise what the September 23rd meeting will be about other than a general discussion of the site. Request an agenda be provided with (but not limited to) the following: *Clear purpose of meeting *Goals, and *expected outcome of the meeting. If PCB contamination or CERCLA hazardous substances* are present, then I would highly recommend EPA be invited to participate as a team member of this TRIAD project. *Hazardous substance as defined by section 101(14) of CERCLA, means: Any substance designated pursuant to section 311(b)(2)(A) of the CWA; any element, compound, mixture, solution, or substance designated pursuant to section 102 of CERCLA; any hazardous waste having the characteristics identified under or listed pursuant to section 3001 of the Solid Waste Disposal Act (but not including any waste the regulation of which under the Solid Waste Disposal Act (42 U.S.C. 6901 et seq.) has been suspended by Act of Congress); any toxic pollutant listed under section 307(a) of the CWA; any hazardous air pollutant listed under section 112 of the Clean Air Act (42 U.S.C. 7521 et seq.); and any imminently hazardous chemical substance or mixture with respect to which the EPA Administrator has taken action pursuant to section 7 of the Toxic Substances Control Act (15 U.S.C. 2601 et seq.). The term does not include petroleum, including crude oil or any fraction there-of which is not otherwise specifically listed or designated as a hazardous sub-stance in the first sentence of this paragraph, and the term does not include natural gas, natural gas liquids, liquified natural gas, or synthetic gas usable for fuel (or mixtures of natural gas and such synthetic gas). Louis Howard
9/23/2010 Meeting or Teleconference Held Port Heiden/Fort Morrow Formerly Used Defense Site (FUDS) F10AK0027-03 Technical Project Planning initial team meeting *(precursor to the TRIAD meetings). Attendees: USACE Ron Pflum FUDS PM Ken Andraschko FUDS Program Manager Meseret Ghebresllassie Technical Lead Engineer Lisa Geist Environmental Engineering Supervisor Gordon Osgood GIS support Pat Riley Real Estate, Acquisition Team Lead Chris Floyd Environmental Resources Wayne Crayton Environmental Resources ADEC Louis Howard ADEC Project Manager Earl Crapps ADEC Chemist Marti Early ADEC Risk Assessor Issues: Road contaminated with PCBs. Air Force or FUDS responsibility? PCBs “everywhere”… Also used solvents, Air Force documented PCE contamination. Need to define Areas of Concern or break up site based on types of use. Need “strawman” proposal for AOCs and investigation parameters, layout of site before next meeting. UFP-QAPP by area in appendix? ADEC cleanup level is 1 ppm for PCBs based on unrestricted use. Village of Port Heiden and Air Force cleanup project digging up all soils greater than 1 ppm and hauling to lower 48 for disposal. Need to get landowner concurrence for alternate cleanup level. If landowner doesn’t agree, ADEC must stick with Method 2. Already 3 landfill cells that have failed at Port Heiden? Perceived lack of innovative technologies that can successfully remediate PCBs. Recommendation from Marti Early that FUDS get HSS (Health and Social Services) Division of Alaska (Epidemiology) involved to address public health concerns of the community. Subsistence surveys may be necessary to avoid unnecessary conservatism in a risk assessment, high community concerns already expressed, consumption survey would have to be federally reviewed. Also good to get ATSDR and Army Public Health Command involved early? Contacts: Nim Hah (?) with HSS, Joe Sarcone with ATSDR. Tentative schedule should be communicated with TPP team: Contractor selected Kick off TPP meeting Field/site visit Workplan reviews Etc… Caution that ADEC regulations require impartial 3rd party to collect data, UVOST would need pre-approval or waiver if conduct the work in house. Magnetometer data – Louis advised yes will need for ALL drum areas. Possibly for UXO on beach area? Goal at TPP meetings, present historical data and reports, determine whether this data is too old or not, put points on a map for where investigation is needed. Action items: Need to compile USACE chemistry data, put sample locations into Geodatabase. Zoom into areas on map, start drawing points or polygons, areas to investigate, what percentage of fuel storage areas need data, etc. Will contractor prepare the figures for the Work Plan or will USACE? How much of the legwork will the Corps perform vs a contractor. Contractor facilitates the meetings and takes notes? SOW needs to clarify and clearly identify the roles/responsibility of Corps vs Contractor. In advance – need to determine landownership and other stakeholders. Clean closure only, otherwise need consent of landowner for anything greater than unrestricted use. ADEC can’t make a landowner agree to ACL. Property boundaries vs risk assessment and AOCs need to think about. Air Force: PCE, some pesticides (found in Remedial Investigation only, not during removal action). Triad approach – decide on Method 2 vs site specific. Need contingency if discover a bigger problem than able to address using Method 2. Groundwater plume not defined. Also need to comply with other State of Alaska regulations such as 18 AAC 60, 70, 80 (solid waste, surface water, drinking water) and federal TSCA regulations for PCBs. Preliminary ARARs should be defined in management plan or Work Plan or UFP-QAPP. Chris Floyd needs to be involved early so he can consult with US Fish and Wildlife Service for example. ADEC has universe of ARARs they can provide. Louis Howard
2/2/2011 Meeting or Teleconference Held Part I of II Fort Morrow/Port Heiden Investigation Triad Systematic Planning Meeting No. 1. The objectives of the first day meeting were discussed and include: • Overall project Plan and Schedule • Establish the Triad team members and their roles • Learn all agencies view and concerns • Establish a common understanding of the project scope The objectives for the second day of the meeting were discussed are include: • Delineating the overall project boundary • Subdividing the project boundary into manageable areas of concerns (AOCs) • Identifying the chemicals of potential concern (COPCs) within each AOC. General discussion about lessons learned, quality assurance and quality control so the data is acceptable to ADEC, and mobilization issues. Mr. Earl Crapps of ADEC offered to provide a summary of his lessons learned from previous triad planning programs for sites such as Fort Morrow. C: Wayne Crayton explained the purpose and importance of the Triad Meeting, the expectations, and the goals of the Triad group. C: Earl Crapps, ADEC, commented on the concerns ADEC has regarding the Triad process and the issues that have arisen in the past using the process. Major concerns are utilizing only one field season for data collection. General discussion concerning sampling—techniques, variations, field seasons, and conceptual site models. Ideally all required data would be collected in one field season, but the group agreed that it may take two field seasons to collect the all of the data due to the likely “surprises” found in the first field season. It was agreed that these topics would be finalized in later planning meetings. There was more general discussion of the investigation and removal actions covered by both the FUDS and NALEMP programs. C: Mr. Pflum commented that Landfills A and B are closed and permitted in accordance with ADEC regulations. Although one of the landfills is thought to be on property owned by the ADOT. Q: Mr. Christensen remarked that the road from the village toward the airport is heavily contaminated with PCBs and is the road everyone uses to haul fish in the back of pickups. He asked is there is a health hazard associated with this? A: Mr. Crapps stated that if the road is contaminated and in use, there is a health risk. Discussion regarding road PCB levels and whether this issue may warrant a time critical removal action. The Army and USAF past practices at Port Heiden was again discussed in light of who has the responsibility to investigate other roads in the area for the presence of PCBs. Ms. Kearney of North Wind provided a summary of decisions/action items. 1) ADEC mentioned they had participated in 20 Triad processes, noting most had not worked well. It was suggested that ADEC present a summary of their lessons learned from previous triad meetings. Mr. Crapps agreed to present their lessons learned at the start of the next day. 2) Ms. Ghebresllassie indicated the USACE, USAF, and BLM need to do an operational history search to determine if the past practices or historical records from each agency indicate if oil was used as a dust suppressant and if it may have had PCB contamination. She agreed to report on the findings at the next meeting. The operational past practices identified will be back checked with the local community. 3) Mr. Stephen Fusilier, BLM, and Mr. Gordon Osgood and Ms. Pat Riley-Ramsey of the USACE, will coordinate on property ownership, including boundaries of property, including landfills. 4) Ms. Gerda Kosbruk will provide previously collected data on subsistence aspects (berries, caribou, fish, etc.) to Ms. Ghebresllassie. 5) Ms. Ghebresllassie will call the Alaska Department of Health & Human Services and ATSR regarding health issues in the village, and possibly invite them to future meetings. 6) Mr. Myers of Sundance Consulting will check on programs covered by NALEMP (concrete slabs and landfill monitoring). 7) Ms. Ghebresllassie and Mr. Pflum will look into developing a project specific website for the triad meetings. 8) Mr. Pat Roth will provide PCB data from the Draft Final Report submitted by Weston at the next meeting so that the extent of the PCB sampling on the roads could be evaluated. 9) Ms. Kearney committed to providing copies of all of the presentations on CD to everyone in the group by the next meeting. Day 1 Parking Lot Issues 1) Define land ownership— BLM, Native Corporations and the Port Heiden village residents 2) PCB contamination on roadway operational history 3) ADEC—Lessons Learned presentation due February 3, 2011—day 2. 4) Risk Assessment vs. Method II—collect other data? Use resources efficiently—levels of contamination in food sources. 5) NALEMP—non-funded FUDS items 6) Real time critical removal action for the PCB contamination on the roads? Louis Howard
2/3/2011 Meeting or Teleconference Held Part II of II Mr. Earl Crapps of ADEC gave a presentation on his lessons learned from over 20 previous Triad planning efforts. Mr. Crapps delineated the following elements to keep in mind during a Triad planning process. • The Triad meeting is not a substitute for any regulation or policy, this includes the CERCLA process with a set time frame & required dates & public notices, but also for some state regs & state guidance. • Team consensus is imperative to the process. Stakeholders & team members are encouraged to come to the meetings without a predetermined view of what to do with the site. • Decisions & agreements from these meeting should be accurately reflected on all submittals—to that end ADEC encourages the use of two worksheets. The first, the non-sampling uncertainty worksheet would include items such as land ownership. The second is the sampling uncertainty worksheet. Both of these documents should be incorporated into the Work Plan to facilitate the approval process. • Use of soil & groundwater modeling should be agreed upon by all team members & stakeholders in advance or it can cause delays & problems with reviews & approvals of planning documents & reports. • Data quality & quantity—screening levels need to be determined early in the project. Screening level data vs. definitive laboratory results is an important consideration as ADEC recognized only definitive data for site management & closure decisions. However, use of an on-site laboratory is encouraged to increase data collection efficiency & prevent data gaps. • Mr. Crapps stated that it is very difficult to collect both characterizational & risk-based data in one field season. Both investigation activities require different quantity & quality of data. A risk assessment or risk-based cleanup site must be well characterized first to identify any data gaps. • Mr. Crapps indicated background information is important to consider especially regarding metals, i.e., arsenic. However, he cautioned everyone to be careful of using background information. ADEC won’t accept any background data for any man-made contaminants such as DDT. • Once in the field, modifications to the work plan are expected to happen—be sure to include all team members in the revisions to the work plan that are made to address real-time conditions. Following Mr. Crapp’s presentation there was general discussion regarding consensus, risks, regulations, policies. Further discussion regarding the use of the worksheets supported by ADEC. Mr. Crapps committed to provide the sampling & non-sampling worksheets to Ms. Ghebresllassie. Since the decision was made by the group to stay with the AOC boundaries as currently delineated, Mr. Crayton suggested going through the Chemical of Potential Concern (COPC) spreadsheet that was included as the last page in the meeting informational packet. Mr. Howard of ADEC indicated that he had taken a stab at filling out the spreadsheet to identify the COPCs associated with each feature at the site. The group went through the spreadsheet Mr. Howard prepared & modified the features to eliminate redundant items & items thought to not have chemical contamination associated with them & assign associated COPCs per feature based on group consensus. There were a number of items flagged that will need more research before COPCs can be assigned. There was discussion specific to looking for possible radioactive contamination from the former hospital/laboratory facilities & from radium dials – should fixed based laboratory samples be collected or should field screening instruments be used? What type of radioactive contamination is likely to present based on the limited information available (i.e. alpha or gamma)? The type expected would drive the type of field screening conducted. After a lengthy discussion, Mr. Crayton suggested making this a parking lot item. There was discussion on the need for a common naming convention for feature types as multiple features are found at numerous locations across the site. Ms. Kearney listed the action items resulting from the discussion on the second day of the meeting: 1) Mr. Crapps will provide the ADEC sampling/non-sampling worksheets to Ms. Ghebresllassie 2) The group needs to develop a common naming convention, consolidated list of names, i.e., shop—metal vs. wood 3) Mr. Osgood will go back through the delineation of the AOCs to ensure that no features are dissected by the AOC boundaries. Day 2 Parking Lot Issues: Ms. Kearney went through the items written in the “Parking Lot” 1) Triad—Sample/No Sample worksheets referenced by ADEC for use in Triad meetings 2) MMRP/Sampling for explosive composites—to be done under this project or not? 3) Radioactive screening methods to be used. 4) Road surface sampling—what, where, why? Louis Howard
2/11/2011 Update or Other Action John Halverson (ADEC) sent letter to the US Army Engineer District, Alaska Attn: CEPOA-PM-C (FUDS) (Ken Andraschko) RE: Fort Morrow at Port Heiden - Request for Archive Search Report and MMRP Project. Based on the military use of Fort Morrow during World War II, the Alaska Department of Environmental Conservation (ADEC) is requesting the Corps of Engineers conduct an Archive Search Report and prepare an Inventory Project Report (INPR) to determine FUDS Program eligibility for an MMRP project at the site. This request is based on the following information: • historical records that indicate there were several ammunition storage areas and defense positions at the FUDS; • village residents have reported discovery of buried caches of small arms munitions; • during 2002, an Explosive Ordnance Disposal team from Ft. Richardson responded to an unexploded ordnance item (reportedly a 20 mm anti aircraft artillery projectile) that was on display in one of the homes; and • an Area Use Map contained in the Port Heiden CONjHTRW project closeout report, dated February 2009, that identifies an "old munitions dump site". This information raises enough concern to support conducting an archive search report and determining whether an eligible MMRP project exists at the site. If you have any questions regarding this letter, please feel free to call me at 269- 7545. John Halverson
2/14/2011 Update or Other Action NOTE TO FILE: Army (FUDS)-OE Program stages-The DERP-FUDS OE Program has three major stages: inventory, study, & removal. 1) The inventory stage is culminated in the Preliminary Assessment of Eligibility (PAE), which consists of property identification, real estate search to verify previous Department of Defense (DoD) (formerly Department of War) ownership or usage, & the determination of property & project eligibility under the FUDS Program. The PAE is not intended to be equivalent to the CERCLA Preliminary Assessment (PA). A site inspection by the local USACE geographic district is usually accomplished during the PAE. An Inventory Project Report (INPR) is prepared to report the findings of the PAE & the environmental contamination, if any, for project determination. The INPR consists of a Property (Site) Survey Summary Sheet, a Findings & Determination of Eligibility (FDE) signed by the USACE Division Commander, a Project Summary Sheet, & a Risk Assessment Code (RAC) Worksheet for all OE project sites. The INPR is executed at the local USACE geographic district, reviewed & FDE signed at the USACE division level, reviewed by the Huntsville OE Center of Expertise & Design Center, & approved at the USACE division level. The INPR is given a Safety review & a Quality Technical review at the Huntsville Center resulting in either concurrence or recommendations for change. The local district should forward a copy of the approved FDE to the landowner as well as to the USEPA for NPL projects. In the past no party outside of USACE has had any input to the INPR; no reviews or comments solicited. This has caused some conflict, especially when we have a determination of No Further Action (NOFA) or, under the newer term, No DoD Action Indicated (NDAI). This is being looked into between HQUSACE & EPA. Regulator & other stakeholder involvement in the NDAI decision-making process will be incorporated into the process in the near future. Please keep in mind that a NDAI determination means that no action is contemplated at the present time. An OE response action will be initiated upon discovery of any condition considered hazardous. The approved INPR will become part of the AR & will be placed in the local information repository after the SI Phase has been completed & an OE response action project started. The approval of a positive INPR authorizes the Huntsville Center to enter into the study stage & prepare an Archives Search Report (ASR) for the site. 2) The study stage includes the Site Inspection (SI), which is an on-site survey to augment the data collected in the PAE, generate additional historical field data, determine the nature of confirmed or potential OE contamination on-site, & evaluate relative risk. The OE SI is not the same as an SI for other remedial projects in that it does not determine the extent of OE contamination; therefore no intrusive sampling is performed during the OE SI. The ASR compiles information obtained through historical research at various archives & records holding facilities, interviews with individuals associated with the site or its operations, & personal visits to the site. All efforts are directed towards determining possible use or disposal of chemical warfare materiels & conventional munitions & explosives on the site. The ASR includes a RAC Worksheet based on the findings of the ASR, which supercedes or replaces the INPR RAC, & a Project Fact Sheet, which gives a synopsis of the site & the recommended strategy for removal action. When exact procedures are worked out & published, public & regulator input will be required & employed during this process. The final ASR will become part of the Administrative Record & will be placed in the local information repository after the SI Phase has been completed & an OE response action project started. The study stage also includes the EE/CA for an OE removal project, which is similar to the remedial investigation & feasibility study (RI/FS) for a remedial project. Intrusive sampling may be conducted during the EE/CA phase. 3) The OE removal stage consists of removal design, removal action, & recurring reviews. Once an INPR is approved, making a site DERP-FUDS eligible, & a hazardous situation is discovered where there is an immediate threat due to public exposure to OE with the risk of injury or death, a Time Critical Removal Action (TCRA) may be warranted. This can occur at any phase of OE response actions, i.e., the PAE, SI, or EE/CA. TCRAs are removal actions conducted to respond to an imminent danger posed by the release or threat of a release, where cleanup or stabilization actions must be initiated within six months to reduce risk to public health or the environment. A TCRA is intended to address only the imminent safety hazard posed by the presence of OE, not the cleanup requirements that can be deferred for later action during the Non-TCRA process. Louis Howard
2/15/2011 Update or Other Action email from Earl Crapps to CORPS (Meseret G.) uncertainty worksheets. Here is an example of the Sampling and Non-Sampling Worksheets. Also, if possible you may want to consider having someone from the ACOE Seattle office facilitate the Ft. Morrow Triad. I do not know if Kym Takasaki is still with them, but they have always done a good job in the past, resulting in a more efficient and productive meeting. Earl Crapps
3/14/2011 Meeting or Teleconference Held Fort Morrow/Port Heiden Remedial Investigation Triad Systematic Planning Meeting No. 2 The objectives of the first day this meeting were discussed & include: • Identify features & associated COPC within each area of the established AOCs. • Identify media, pathways & receptors by developing the CSM. • Achieve group consensus on the role of the CSM in developing sampling & analyses design. • Discuss to what extent we’ll be completing certain types of sampling for contaminants of potential concern at each feature—with later summary to be in a table or spreadsheet form. • Product of this meeting will lead to North Wind preparing a QAPP & Field Sampling Plan. Gordy Osgood of the USACE gave a brief recap on the information presented at the previous meeting for the benefit of new attendees. The maps presented looked at areas of Port Heiden known for military activity—collectively Areas of Concern A through M. These AOCs identified military features, i.e., warehouses, mess halls, fuel storage locations, etc. AOCs A through M—some easy, some hard. COPCs—Teresa Lee spoke about the types of contamination known for the area—mostly fuels & PCBs from historical activity. Gordy spoke about areas of concern that James Christensen had mentioned at the previous meeting. He also asked the folks from Port Heiden to bring forward any additional information they might have. SUMMARY OF ACTION ITEMS FOR DAY 1 1. Scott Anderson to provide data from previous surface water sampling in the AOC E to Teresa Lee of the USACE. 2. Gordy to go through the GIS database & give names to all features labeled as “not-doc”. 3. Teresa to follow up on data from POL spill in AOC K during building demolition project in the late 1980’s. 4. Gordy to delineate red dots shown on GIS maps in AOC J. 5. Gordy, Teresa, & Gerda to identify whether PCB spill in AOC B was cleaned up completely & whether any data exists. 6. Teresa to look in historical reports to see if any data was collected from the former drum storage areas. SUMMARY OF PARKING LOT ISSUES FOR DAY 1 1. Roads – What investigation is required & who is responsible for investigation/cleanup of specific road segments? Area of Concern ROAD SYSTEM (RS) The Air Force has taken responsibility for the main road leading from the village to the radar station. Ron: The USACE needs more evidence that the other roads are contaminated prior to testing. It was agreed by everyone that the road system should be an AOC. Wayne: There continues to be concerns about PCB contamination on the secondary roads. A more cursory investigation will be done for the road & if contamination is found, then USACE will start a new project to further address the issue. Meseret: We can design a site investigation level testing program for PCBs on the road. Then if PCB contamination is found they will open a new project to more thoroughly investigate PCBs on the road. Louis: How to handle PCBs on roads in AOCs that have PCB contamination from spills. Wayne: Should road be a separate AOC? Discussion regarding road PCBs, testing methods & sampling procedures. Ron: We could institute a new project under a PA (preliminary assessment). A new project number won’t be given unless the PA finds evidence of contamination. Action Item: Ron to determine whether a SI level investigation of the road is included in the RI/FS or a separate PA is conducted for the roads. Marty: Another global concern is the water—surface & ground. Wayne: Should surface water be its on AOC or should the surface water bodies stay in the AOC where they are located? SUMMARY OF ACTION ITEMS FOR DAY 2: 1. Pat Roth & Meseret to determine boundaries of USAF property & Features. 2. Louis was to look at permit for Landfill A in AOC M to see if the Alaska District has responsibility to maintain cover. This turned into a Parking Lot issue when it was determined that the Alaska District does have responsibility. 3. Gerda & Meseret are to check history of village landfill in AOC F & determine if it is FUDS eligible. 4. Judy with DOT to provide leasing information on their property at Port Heiden from 1966 forward. 5. Meseret to contact John Carnahan with ADEC in Fairbanks to get the results of the Phase I Hoeffler Consulting did in the AOC A. 6. Ron to determine whether it is better to conduct an SI level investigation of PCBS on the road during the RI or institute a new project under a preliminary assessment to investigate possible PCB contamination on the roads. 7. Kishor/Gordy/Arden to evaluate Features/COPC table to see if certain similar features could be consolidated but yet still keep the detail associated with each original feature. SUMMARY OF PARKING LOT ISSUES DAY 2 1. Alaska District & ADEC to determine the level of responsibility Alaska District has to maintain cover over Landfill A. Louis Howard
3/18/2011 Update or Other Action Kenneth Andraschko FUDS Program Manager sent letter John Halverson (ADEC). This letter is in response to your letter, dated 11 February 2011, requesting that we conduct an Archive Search Report (ASR) and prepare an Inventory Project Report (INPR}to add a Military Munitions Response Program (MMRP) project for Fort Morrow, Alaska. We will add a Preliminary Assessment (PA) phase to the Fort Morrow property to be conducted in FY2012. Under the PA phase, we will conduct the ASR to detetermine if an MRRP project is required on the Fort Morrow property. If we find the project justified, we will modify the Fort Morrow INPR to add an MMRP project. NOTE TO FILE: Military Munitions Response Program (MMRP) Projects. The DoD Management Guidance for the DERP, issued by ODUSD (I&E) on 28 September 2001, established a new program category for Military Munitions Response Program (MMRP). MMRP projects include response actions at an area of an eligible FUDS property related to military munitions and explosives of concern (MEC) and their constituents (MC) as the result of DoD activities at FUDS. MMRP projects can include response actions for the removal of foreign military munitions if it is incidental to the response addressing DoD military munitions at a FUDS property. In a given area containing both MEC and MC, Army policy requires that imminent human safety threats be addressed first [ASA (I, L&E) Memorandum, Subject: Interim Guidance for BWM and Non-Stockpile Chemical Warfare Materiel Response Activities, 5 Sep 1997]. This does not preclude consideration of other response actions, such as fencing or providing bottled water, that are required to deal with imminent threats to human health and the environment associated with the property. Response actions at MMRP projects address: - MEC (formerly designated within the FUDS program as OE or OEW), which distinguishes specific categories of military munitions that may pose unique explosives safety risks, includes: - Unexploded Ordnance (UXO), as defined in 10 USC 2710(e)(9); - Discarded military munitions (DMM), as defined in 10 USC 2710(e)(2); or - Munitions constituents (e.g., TNT, RDX) present in high enough concentrations to pose an explosive hazard - MC, which are materials originating from unexploded ordnance, discarded military munitions, or other military munitions, including explosive and non-explosive materials, and emission, degradation, or breakdown elements of such ordnance or munitions [10 USC 2710(e)(4)]. - Recovered Chemical Warfare Materiel (RCWM). John Halverson
3/23/2011 Report or Workplan Review - Other USACE Comment response to ADEC Comments received. The sentence revised to read "the only contaminant of concern in this project was to remove drums of military origin at the FUDS at Port Heiden, Alaska." Groundwater contamination at the drum storage area will be investigated under F10AK002704 Fort Morrow Project with the other HTRW site issues. This PCO report is to address the CON/HTRW project only. MMRP can’t be addressed under this CON/HTRW or HTRW FUDS projects. MMRP is a separate issue and this question can be raised or addressed during the MMRP project plan. Yes, confirmation soil samples at the floor of the excavation were collected before backfilling (2007 JE Report). Louis Howard
5/17/2011 Meeting or Teleconference Held Fort Morrow/Port Heiden Investigation Triad Systematic Planning Meeting No. 3 was held. The objectives of this meeting were discussed & include: • Discuss field screening & sampling protocols for Area of Concern C & other AOCs • Discuss the objectives & logistics for the upcoming site visit to Port Heiden in early June Ms. Lee has gone back through all available historical documents to look at data collected from drum storage areas & from the POL spill in AOC K. The maps showing the sampling locations in AOC K were found to be too rough to be of value. She was not able to find much data associated with the drum removal actions, so these areas will have to be sampled as part of the RI. These action items are now closed. • The delineation of the USAF & USACE property boundaries is completed but not the delineation of features. Mr. Smith & Mr. Osgood will assist Ms. Ghebresllassie with obtaining the necessary data from the USAF. The USAF White Alice site is on land leased from AKDOT. The USAF does own some land in the area but leases more than they own. This is action item is ongoing. • The AKDOT has not yet provided the leasing information on the property they own at Port Heiden. This action item remains open. • Ms. Ghebresllassie will work with Ms. Kosbruk to evaluate the responsibility for cleanup of the Village Landfill located in AOC F. If hazardous materials/wastes are not present, it will not be FUDS eligible. What was determined to be FUDS eligible was cleaned up in 2007 & there is no future cleanup work scheduled for this feature. Ms. Kosbruk stated that the Village cleanup the beach in the area of the landfill every spring & usually end up picking up military debris including pipes & drums. They are certain that the debris comes from the landfill. Ms. Annie Christiansen provided a brief history of the landfill. It started as a military dump & then was used by the local villagers as time went by. Now has co-mingled wastes. This site will be a priority during the June 9th site visit. Ms. Hicks stated that drums labeled as US Army still do show up on the beach & in the area of the landfill. Mr. Pflum stated that as of today, this site is not FUDS eligible. This type of waste is considered trash or debris (classified as BDDR) & is not FUDS eligible. Potentially responsible party (PRP) sites will be handled by the USACE lawyers. The upper part of the landfill was just a large drum cache that was removed in 2007. The lower portion of the landfill is a mix of village & government wastes. This action item is closed but it remains a parking lot issue. • A separate meeting was held with the USACE & ADEC Triad members to discuss testing of the roads for PCB contamination. In that meeting it was decided that the roads would not be a separate AOC & only if PCBs are found in features that are located close to a road, would the road be tested. • Road surface sampling—USAF took responsibility for main road. A separate meeting was held with ADEC & the USACE to resolve the sampling of the road issue. Resolution has been reached as discussed above. This parking lot issue is now closed. • The Alaska District & ADEC are to determine the level of the responsibility the USACE has to maintain the cap & cover over Landfill A. This parking lot issue is still open. Field Screening & Sampling Discussion by Triad Members Mr. Bailey of North Wind gave a presentation of the proposed field screening & sampling technical approach & passed out handouts of the associated flowcharts & tables. Ms. Lee asked what the basis for the screening per square footage is. Mr. Bailey answered that 1 field screening (FS) will be collected for every 400 square feet (FT²) or for every 20-ft by 20-ft area. The screening would be conducted using a systemic grid with a random starting point, unless there is obvious contamination. In obvious areas of contamination (staining), a boring would be placed in that area specifically. Ms. Brewer asked if it might be a good idea to use geophysical techniques as a screening tool. Ms. Ghebresllassie stated, in response to Ms. Brewer, that geophysical screening tools can be used at dump sites & areas of mounded dirt. Mr. Bailey will add geophysical survey as a field screening method for the mounded materials, dump site, drum & dump caches, etc. Ms. Brewer asked about underground piping. Ms. Ghebresllassie stated that underground piping at this site is not likely because there were no central heating or fueling plants. Mr. Osgood stated buried drums are a feature type; former drum areas are a surface issue. Ms. Brewer asked if a correlation study would be performed prior to the field screening. Ms. Lee asked that if confirmation samples will be collected – would you need or use a correlation study? For additional information see site file. Louis Howard
6/9/2011 Site Visit CORPS site visit report for June 9, 2011. Fort Morrow Triad members conducted a site visit to the Fort Morrow & Port Heiden area to meet with the project stakeholders & to visit the Areas of Concern (AOCs) to be included in the Fort Morrow Remedial Investigation (RI). The group traveled from Anchorage to Port Heiden aboard an ERA Aviation Beech 1900 aircraft. Ms. Gerda Kosbruk met the group at the Port Heiden Airfield & escorted the group to the Village Administrative Building (known as Ray’s Place). A kickoff meeting was held in the Village Administrative Building prior to heading out to see the affected site features. During the kickoff meeting the following items were discussed: • Logistics and plans for the site tour. • The allocation of limited time on the ground to visit as many features as possible. • Meseret explained that the group must depart Port Heiden before 4:30 pm due to “on-duty” constraints for the ERA flight crew. Following the kickoff meeting, the group traveled to & observed many different site features. The purpose of the visits to these features was to field verify the conditions & logistical constraints that may impact the RI. The following features were some of the features included in the site visits: • The location of the former drum cache located on the beach north of the original village that was removed in 2007. • The current comingled landfill debris adjacent to the removed drum cache. • The original village of Meshik & associated site features in AOC F (e.g. Former chemical storage building & former drum cache). • The location of a former larger drum storage area near the “New Meshik Mall/Jack’s Place”. Gordon Osgood recorded the GPS location of several previously installed monitoring wells located within the former drum storage depression. • The location of the reported PCB soil removal in AOC “D” near James Christensen’s shop. The PCB contamination was reportedly located near an antennae array. James reported that a few days earlier he had located the antennae footings while excavating to the northwest of his shop. Gordon Osgood obtained GPS coordinates for the likely PCB soil excavation. • Several ground scars & “mounded material” along the road as the group traveled to the northwest portion of the former Fort Morrow site where visited & examined. • Defensive fighting positions overlooking the possible enemy approaches from the sea. The visited features were located in AOCs “L” & “K”. • A smaller drum cache depressions located in AOC “K” was visited. A discussion was held to evaluate the difficulties with attempting to move a drill rig into the depressions associated with the fuel caches. • Mr. James Christensen took the group to an area with an abundance of expended brass shell casing located in AOC “K”. • The group then visited a former warehouse foundation. Windblown fine to coarse sand has filled the inside of the foundation walls over the years since the building was removed. • The Triad members visited the site of the landfill near the White Alice site & the location of a material borrow pit. The group searched for a reported white powder that was encountered when the area was being quarried. • The location of the former “fueling station” was visited. No identifying landmarks were observed. • The group then visited the area shown on maps as the “infirmary”. • Mr. Christensen showed the group the type of metal debris that is picked up annually under funding from the NALEMP program. • The area south of the air strip that contained a reported “thousands of drums” was visited. • The group attempted to locate a reported landfill east of the “New Meshik Mall”. The exact area of the landfill was not evident. • The group evaluated an elongated trench structure south of the airfield. It was unclear what the ground scar may represent. • The location of the former shop located south of the airfield was visited. The area contains a comingling of material ranging from DOT airport associated vehicles to private automobiles. The group agreed that the insights gained from the site walk would be beneficial to North Wind for development the RI UFP-QAPP. As discussed in the previous Triad meetings, field screening should be conducted on a 20 by 20-ft. grid. However, ADEC agreed during this visit that if a grid does not fit perfectly into a site feature, the grid layout may be modified to cover the area as applicable. The modified grid should be laid out to maximize the number of screening locations. The actual number of samples that will be collected will be consistent with prior Triad meeting discussions & are as documented in previous meeting minutes. Louis Howard
8/3/2011 Update or Other Action 2011 Draft Final Report Historical Records Review received. Research was conducted at records repositories and archives in the lower 48 states and at the USACE - Alaska District Real Estate office and documented in a Sources Contacted Report (ITSI 2009 Report) that was incorporated into this HRR report. Record searches at all repositories listed in this report were also conducted for other names or designations associated with Port Heiden RRS throughout the history of the installation. Further interviews and clarifications were incorporated into this HRR Report by TLI Solutions. Any additional findings and clarifications identified as a result of the CSE Phase I and II fieldwork will be documented by Sky Research in the CSE Phase I and II Final Report. The objective of this task was to conduct research at the installation and local area repositories and collect all relevant documents in order to refine the history of munitions operations at the previously identified MRAs. All relevant records were copied for potential inclusion in the final document inventory for this project. Potential Munitions Response Area Descriptions The following section describes the operations conducted at the potential MRAs associated with Port Heiden RRS that were identified during the research conducted for the Phase I CSE. No new munitions related sites were identified during the research conducted in support of this HRR. Old Munitions Dump Site The initial research conducted in support of the ITSI 2009 Report identified an Area Use Map of Port Heiden aerial photograph from 1975 on which a 2002 installation map had been overlain. The Old Munitions Dump Site is noted on this map. According to the ITSI 2009 Report, the location of the MRA is noted as being on the coast west of the runways. Review of the map in support of this HRR indicates that the MRA is actually located along the coast approximately 7,000 feet northwest of the northern end of the western runway. The notations on the map prevent viewing of the underlying feature. No supporting information is available to determine how the location on the map was identified as an Old Munitions Dump Site or the types of munitions that may have been disposed in the area (ITSI 2009 Report). Based on a review of documentation located in support of this HRR, the Old Munitions Dump Site is located outside the boundary of Port Heiden RRS. Figure 4-1 depicts the location identified in the 2009 ITSI Report as the location of the Old Munitions Dump Site (AKAF00090). GIS data was received from the installation in support of the HRR that identified the approximate location of the Old Munitions Dump Site. No additional information regarding the Old Munitions Dump Site was identified during this effort. Ordnance Area The initial research conducted in support of the ITSI 2009 Report identified an Ordnance Area at Port Heiden. A map dated October 1943 for the construction of Fort Morrow, Port Heiden, AK listed Building 17 as an Ordnance Storage Igloo. According to the ITSI 2009 Report, the location of Building 17 could not be located on the maps (ITSI 2009 Report). However, a construction report dated October 1943 was reviewed in support of this HRR, and it has been determined through this review that the ordnance storage igloo, identified as item number 17, was to be constructed at Fort Morrow. Although the location of the building can be identified on the historic map, insufficient data is available to accurately map the exact location. Based on a review of documentation located in support of this HRR, the Ordnance Area is located outside the boundary of Port Heiden RRS. GIS data was received from the installation in support of the HRR that identified the approximate location of the Ordnance Storage Igloo. No additional information regarding the Ordnance Area was identified during this effort. The ITSI 2009 Report identified a bermed area south of the east-west runway at the Port Heiden RRS site on the Area Use Map of Port Heiden. It is not clear what purpose this area serves. It may be a rifle range (ITSI 2009 Report). As a result of the research conducted for this HRR, no additional information regarding the Potential Rifle Range 1 was identified. However, based on the period of use at Port Heiden RRS from 1961 until the mid-1970s, it is anticipated that rifles potentially used at the site may include M14s and M16s. Munitions associated with these weapons would include 7.62mm and 5.56mm rounds. Based on a review of documentation located in support of this HRR, the Potential Rifle Range 1 is located outside the boundary of Port Heiden RRS. GIS data was received from the installation in support of the HRR that identified the approximate location of the Potential Rifle Range 1. No additional information regarding the Potential Rifle Range 1 was identified during this effort. See site file for additional information. Louis Howard
9/6/2011 Update or Other Action Draft UFP QAPP received from Army Corps of Engineers contractor for September 14th TRIAD meeting. Approximately 8,000 acres of the Fort Morrow (the “site”) were occupied by the U.S. Army between 1942 & 1945 to support the war effort in the Aleutian Islands. Logistical supplies for the support of the Aleutian campaign, as well as for the support of the nearly 5,000 airmen & soldiers stationed at the site, were shipped to the area & then were stored on site. Thousands of drums of aviation fuel, petroleum, oil, & lubricants (POL), & other maintenance fluids were stored at the site in large drum caches. The amount of these materials released to the environment is not accurately known. Previous limited investigations have indicated contaminated soils are present at the site may exceed 18 Alaska Administrative Code (AAC) 75 Method 2 cleanup levels. The contamination previously identified has included POL, solvents, & PCB contamination above regulatory levels. For the sake of manageability, the site has been divided into 13 Areas of Concern (AOCs) – A through M. Attempts were made to group site features that were associated with a specific company, battalion, or special general type of land usage (e.g., hospital, warehouse, fueling area, airfield operations, etc.). It is likely specific contamination may be associated with each distinct previous land use based on historical documentation & preliminary site investigations; therefore, portions of the site or specific types of site features will require different investigation & ultimately different remediation techniques. At this time, insufficient supporting documentation exists to identify final decision units (DUs). Final delineation of DUs will be made by the Army & regulators once sufficient information is available. A remedial investigation will be conducted to collect analytical data from soil & water samples to assess the presence of contamination. Physical, geotechnical, & chemical screening of features, as well as the analytical data, will be evaluated to determine decision conditions. The following AAs would be considered based on the specific potential hazards present in any given DU: - NFA at any given site feature if screening & confirmation sampling indicates that contamination is not present above regulatory levels. - Possible interim removal/remedial action if specific health based risks are identified. - Include in a removal/remedial action through the RI/FS process. - Collect additional data in order to perform a risk based evaluation of the feature. The selection of one of the AAs for a specific site feature or decision unit & potential hazard may be based on the criteria presented below. The final selection will be made jointly by USACE & ADEC. NFA. This option may be selected when the remedial investigation indicates that a particular DU presents no apparent risk to human health or to the environment. Results of sampling & analysis of environmental media from the suspected area of highest potential contamination should show that no contamination is present or that existing contaminants are below ADEC cleanup levels. Initiate Interim Removal Action (IRA). When the results of a limited field investigation confirm that a chemical release has occurred & the environmental contamination exceeds threshold levels, initiation of an IRA may be recommended. Specific conditions that would support selection of the IRA option include: - The data indicate a need for action to reduce real or potential risk to human health or the environment. - The data adequately describe the nature of contamination & apparently bound the range of concentrations expected to be encountered. - The scope of the problem is well-defined & limited, & the remedy is readily apparent. - The planned discrete action is not inconsistent with or will not preclude implementation of the final expected site remedy. Inclusion in the RI/FS removal/remedial action design. If the results of the field investigation confirm that a chemical release has occurred & that environmental contamination exceeds ADEC cleanup levels, the source area may be recommended for inclusion in the RI/FS removal/remedial action design. Conditions that would support selection of this option are: - The data indicate a need for action to reduce real or potential risk to human health or the environment. - The data adequately describe the nature & extent of contamination at the feature. Collect additional data in order to perform a risk based evaluation of the feature. USACE may decide to collect sufficient data to perform a risk based evaluation of a given site feature, AOC, or the entire site. Conditions that support selection of this option include: - The scope of the problem is not well defined, & the remedy is not readily apparent. - A risk based investigation followed by appropriate removal/remedial action would optimize the design from a cost-benefit standpoint. Louis Howard
9/8/2011 Report or Workplan Review - Other Wayne Crayton CORPS commented on the draft UFP-QAPP & the Systematic Planning Document UFP-QAPP QAPP WS#2, pg. 2, item 5: Suggest eliminating dates in the title, as a date column already exists. QAPP WS#2, pg. 3, item 6: Are the listed stakeholders also signatories for QAPP WS#1? QAPP WS#3, pg. 9: Shouldn’t all stakeholders be listed? QAPP WS#4, pg. 10: Shouldn’t all stakeholders be listed? QAPP WS#9: Pg. 20: Change date-year to 2010 from 2011. Also, change Crayton title to Triad Facilitator. Change Floyd title to NEPA Planner. Pg. 21: Change Crayton title to Triad Facilitator. NOTE: Back-check other planning sessions tables to assure titles are consistent, as they are not. QAPP WS#10: Pg. 27 & 28: Make sure that this section matches what is stated in the finalized Systematic Planning Document. Pg. 29, figure 1: Figure 1’s title should be expanded to (at a minimum) read: Site location map & 13 delineated areas of concern (AOC), Fort Morrow, Port Heiden, Alaska. Pg. 30, table: This is redundant from what is on page 2. Pg. 31 through Pg. 36. Make sure that this section matches what is stated in the finalized Systematic Planning Document. QAPP WS#11: Make sure that this section matches what is stated in the finalized Systematic Planning Document. QAPP WS#12, pg. 40: What about a table for sediment & surface water, as it was mentioned in the draft Systematic Planning Document & in QAPP section 17.6 on page 76? QAPP WS#13, pg. 43: Shouldn’t the team’s site visit in September be listed as a contributing secondary item? It is my understanding that decisions were made during the trip about sampling criteria. QAPP WS#16, pg. 67: Shouldn’t the Systematic Planning Document be listed? QAPP WS#17: Pg. 68: Make sure that this section matches what is stated in the finalized Systematic Planning Document. Pg. 71, Section 17.2: This material appears duplicative…is it really needed again here? QAPP WS#18, pg. 77: Make sure that this section matches what is stated in the finalized Systematic Planning Document. Systematic Planning Document 1.0 Introduction Suggest adding “(see section 1.3)” after “… Method 2 cleanup levels”. NOTE: I think the earlier draft/version I started to review last week, which included Section 1.2 (Previous Investigations & Remedial Actions) & table 1 was informative & helped to put things into context. Should it be added back in, here are some comments on its format: Suggest spelling out abbreviations in the titles. Also, the year-date in the title is redundant with the date column. 1.1 Purpose Suggest revising the opening sentence to read,” The Triad Team has determined that the following questions need to be addressed by this investigation:”. Item 2). Shouldn’t the cleanup levels tables (18 AAC 75 Method 2) be included in this document, maybe as an appendix? Suggest moving the paragraph positioned after the four purpose-questions to the end of the last sentence in the Introduction. 1.2 Organization & Manageability Suggest the beginning of the first sentence read, “To facilitate managing the large investigation area, …”. What are “decision units?” Figure 1’s title should be expanded to (at a minimum) read: Site location map & 13 delineated areas of concern (AOC), Fort Morrow, Port Heiden, Alaska. 1.3 Previous Investigations & Remedial Actions See NOTE in Section 1.0 comments. 2.0 Conceptual Site Model 4th Bullet. Last sentence should read, “…with ADEC & other Triad Team members.” 3.0 Project Decision Conditions 4th Bullet. Is the risk a human health &/or environmental/ecological risk? Please specify. Para. 3. Isn’t the final selection made jointly by the USACE, ADEC & other members of the Triad Team? No Further Action. See previous comment regarding what a “decision unit” is. Next to last para. on page 9. Would both a human health & environmental/ecological risk evaluation be performed? 5.0 Contaminants of Potential Concern Table 2 appears to need some cleaning up. Many of the cells under the Feature Type column unnecessarily textually repeat the feature. What’s the difference between the cells “Defensive-Defensive Position” & “ Defensive-Defensive”, etc. etc. etc.? 6.1 Field Screening. First sentence should read, “The field screening process starts when the screening crew indentifies a specific site feature to be characterized.” Who comprises the “screening crew”? Are the screening & field crews the same? 6.1.4 Screening for Metals. If only lead is to be screened for, why not title this section, Screening for Lead? What about the other metals…any stated concern about them? See site file for additional information. Louis Howard
9/14/2011 Meeting or Teleconference Held TRIAD Meeting with CORPS, ADEC, contractor & members of the public. Mr. John Smith: The USACE Real Estate Department has been researching multiple landowners & has sent out 33 right of entry requests. Of the 33 requests sent out, 4 have been signed & returned & two were returned as undeliverable. Working through the BIA, Mr. Smith was able to locate heirs of deceased original owners of Native Allotments. He has an additional 10 requests ready to send out to the heirs. There are 43 rights of entry total at this time. Ms. Ghebresllassie: The project can’t be awarded unless the signed rights of entry are in place. Ms. Geist: Contracting—from a legal standpoint—needs a majority of landowners to sign the rights of entry before award is made. Discussion & Review of Draft Systematic Planning Document & UFP-QAPP Mr. Crayton: We have received comments from some several Triad members. We need & additional comments from everyone within two weeks. Ms. Kim Kearney: We will need the comments electronically – please email to me & Ms. Ghebresllassie. Mr. Arden Bailey: Let’s start by going through the draft Systematic Planning Document as that contains the rationale & decisions that got us to this point. Mr. Earl Crapps: Schedule—we will need at least one more round of comments on the QAPP before it can be finalized. Ms. Ghebresllassie: We need to separate the finalization of the QAPP from this project. This QAPP at this point is a pre-planning document only, we can’t get into the real detail until after this Triad Planning contract is completed. Mr. Bailey: At this point we need the bigger picture, rather than the SOP level of detail. Mr. Crayton: To clarify for those not involved previously—ultimately we will have a final work plan. These meetings have been to develop the rationale & approach for the investigation that will ultimately feed into a more detailed document. Mr. Bailey: The draft Triad Systematic Planning document is a summation of how we arrived at this point. It will lead to the UFP-QAPP (Draft) which includes the work steps of a WP. The sampling program details such as the sample grids, decontamination processes, sample management, etc. will be detailed in the form of SOPs & will be included in the UFP-QAPP as attachments. There will not be a separate WP per se – the Systematic planning document will have the higher level details & the UFP-QAPP will provide the details in the SOPs. Mr. Crapps: Although the Triad process is “dynamic”, it does not allow for a “free-for-all”. The sampling program still has to follow State regulations. Once the UFP-QAPP gets finalized, each individual SOP will be an addendum. We have to have approval—each AOC will have to be a separate “work plan” or SOP that contains SAP tables, procedures, maps, etc. Mr. Crapps: Mr. Howard will not sign the UFP-QAPP at this point – not enough of the sampling program details have been developed. Ms. Ghebresllassie: We can’t really finalize UFP-QAPP at this point – the project lab needs to be selected first. Mr. Crayton: OK – so we agree - there will be no signature at this point. Ms. Ghebresllassie: Yes - we all agree this will be a “Final Draft” & will have no signatures until it can be finalized. Mr. Bailey: We can’t move forward until we have the basics agreed to—the number of samples, type of samples, screening level vs. definitive level, etc. We have Mr. Howard’s comments on the UFP-QAPP & Systematic Planning Document. We also have Mr. Roth’s & Mr. Crayton’s comments. SUMMARY OF MEETING NO. 5 ACTION ITEMS: 1. Ms. Ghebresllassie indicated the site visit report is complete and she will send out the Site Visit Report to all Triad members. 2. Ms. Ghebresllassie will start an AR for the project and make arrangements for a public meeting. 3. Mr. Osgood will provide BBNC an electronic copy of the GIS database for their records. 4. Mr. Bailey is to remove the “true nones” from Table 1 of the draft Systematic Planning Document and put them into a separate table, add reason or footnote why they are a “none”. 5. Ms. Ghebresllassie will scan and email the groundwater report from NALEMP to Mr. Bailey and Ms. Kearney. It may only contain data from 4 or 5 wells. 6. Mr. Osgood to forward the USAF Remedial Investigation (RI) document to Mr. Bailey and Ms. Kearney so it can be determined if the USAF did a metals background study as part of the RI. 7. Ms. Ghebresllassie to clarify whether roads are to be sampled if PCB contamination is identified near a road. 8. Ms. Amanda Whittier, USACE Project chemist, to provide Mr. Bailey and Ms. Kearney with data from excavations with known PCB contamination. 9. Ms. Kosbruk is to provide Mr. Bailey and Ms. Kearney with well construction data for the wells the village installed or monitors. 10. Ms. Kearney is to send out an email to the entire Triad Group asking that comments be emailed to Ms. Ghebresllassie and herself by the 30th of September. Louis Howard
10/31/2011 Meeting or Teleconference Held TRIAD Meeting with CORPS, ADEC, contractor & members of the public was held on September 14, 2011 received Final version of minutes 10/24/2011. Mr. John Smith: The USACE Real Estate Dept has been researching multiple landowners & has sent out 33 right of entry requests. Of the 33 requests sent out, 4 have been signed & returned & two were returned as undeliverable. Working through the BIA, Mr. Smith was able to locate heirs of deceased original owners of Native Allotments. He has an additional 10 requests ready to send out to the heirs. There are 43 rights of entry total at this time. Ms. Ghebresllassie: The project can’t be awarded unless the signed rights of entry are in place. Ms. Geist: Contracting—from a legal standpoint—needs a majority of landowners to sign the rights of entry before award is made. Discussion & Review of Draft Systematic Planning Document & UFP-QAPP Mr. Crayton: We have received comments from some several Triad members. We need & additional comments from everyone within two weeks. Ms. Kim Kearney: We will need the comments electronically – please email to me & Ms. Ghebresllassie. Mr. Arden Bailey: Let’s start by going through the draft Systematic Planning Document as that contains the rationale & decisions that got us to this point. Mr. Earl Crapps: Schedule—we will need at least one more round of comments on the QAPP before it can be finalized. Ms. Ghebresllassie: We need to separate the finalization of the QAPP from this project. This QAPP at this point is a pre-planning document only, we can’t get into the real detail until after this Triad Planning contract is completed. Mr. Bailey: At this point we need the bigger picture, rather than the SOP level of detail. Mr. Bailey: The draft Triad Systematic Planning document is a summation of how we arrived at this point. It will lead to the UFP-QAPP (Draft) which includes the work steps of a WP. The sampling program details such as the sample grids, decontamination processes, sample management, etc. will be detailed in the form of SOPs & will be included in the UFP-QAPP as attachments. There will not be a separate WP per se – the Systematic planning document will have the higher level details & the UFP-QAPP will provide the details in the SOPs. Mr. Crapps: Although the Triad process is “dynamic”, it does not allow for a “free-for-all”. The sampling program still has to follow State regs. Once the UFP-QAPP gets finalized, each individual SOP will be an addendum. We have to have approval—each AOC will have to be a separate “work plan” or SOP that contains SAP tables, procedures, maps, etc. Mr. Crapps: Mr. Howard will not sign the UFP-QAPP at this point – not enough of the sampling program details have been developed. Ms. Ghebresllassie: We can’t really finalize UFP-QAPP at this point – the project lab needs to be selected first. Mr. Crayton: OK – so we agree - there will be no signature at this point. Ms. Ghebresllassie: Yes - we all agree this will be a “Final Draft” & will have no signatures until it can be finalized. Mr. Bailey: We can’t move forward until we have the basics agreed to—the number of samples, type of samples, screening level vs. definitive level, etc. We have Mr. Howard’s comments on the UFP-QAPP & Systematic Planning Document. We also have Mr. Roth’s & Mr. Crayton’s comments. SUMMARY OF MEETING NO. 5 ACTION ITEMS: 1. Ms. Ghebresllassie indicated the site visit report is complete & she will send out the Site Visit Report to all Triad members. 2. Ms. Ghebresllassie will start an AR for the project & make arrangements for a public meeting. 3. Mr. Osgood will provide BBNC an electronic copy of the GIS database for their records. 4. Mr. Bailey is to remove the “true nones” from Table 1 of the draft Systematic Planning Document & put them into a separate table, add reason or footnote why they are a “none”. 5. Ms. Ghebresllassie will scan & email the GW report from NALEMP to Mr. Bailey & Ms. Kearney. It may only contain data from 4 or 5 wells. 6. Mr. Osgood to forward the USAF Remedial Investigation (RI) document to Mr. Bailey & Ms. Kearney so it can be determined if the USAF did a metals background study as part of the RI. 7. Ms. Ghebresllassie to clarify whether roads are to be sampled if PCB contamination is identified near a road. 8. Ms. Amanda Whittier, USACE Project chemist, to provide Mr. Bailey & Ms. Kearney with data from excavations with known PCB contamination. 9. Ms. Kosbruk is to provide Mr. Bailey & Ms. Kearney with well construction data for the wells the village installed or monitors. 10. Ms. Kearney is to send out an email to the entire Triad Group asking that comments be emailed to Ms. Ghebresllassie & herself by the 30th of September. Louis Howard
2/27/2012 Update or Other Action Draft Fort Morrow Remedial Investigation work plan received. Worksheet#10 The purpose of this remedial investigation is to determine: 1) What areas of the former Fort Morrow have been impacted by Army operations? 2) Does environmental contamination at areas or specific features of the former Fort Morrow exceed the cleanup levels established by 18 AAC 75 Method 2 tables? 3) What is the areal extent & maximum concentration levels of contamination at any areas or site features that exceed the applicable cleanup levels? 4) Does the contamination that may exceed cleanup levels pose unacceptable risks to receptors identified in the CSM [see page 76 & 77 of the PDF]? The possible classes of contaminants & the affected matrices: The foundation for site-related decisions that are both correct & optimized is the CSM. A CSM uses all available historical & current information to estimate where contamination is (or might be) located, how much is (or might be) there, how variable concentrations may be & how much spatial patterning may be present, what is happening to contaminants as far as fate & migration, who might be exposed to contaminants or harmful degradation products, & what might be done to manage risk by mitigating exposure. An accurate CSM will distinguish & delineate different contaminant populations for which decisions about risk & remediation will differ. Distinguishing between different contaminant populations improves the quality & interpretation of data, as well as the confidence & resource effectiveness of project decisions. The CSM may be modified as new data are gathered & evaluated. Project decision conditions (“If..., then...” statements): The purpose of this step is to define the decision statement that combines the key questions the study will attempt to resolve with the alternative actions (AAs) that may be taken in the future. This remedial investigation will be conducted to collect analytical data from soil & water samples to assess the presence of contamination. Physical, geotechnical, & chemical screening of features, as well as the analytical data, will be evaluated to determine decision conditions. The following AAs would be considered based on the specific potential hazards present in any given decision unit: • No further action at any given site feature if screening & confirmation sampling indicates that contamination is not present above regulatory levels. • Possible interim removal/remedial action if specific health based risks are identified. • Include in a removal/remedial action through the RI/FS process. • Collect additional data in order to perform a risk based evaluation of the feature. The selection of one of the AAs for a specific site feature or decision unit & potential hazard may be based on the criteria presented below. The final selection will be made jointly by the USACE & ADEC. No Further Action. This option may be selected when the remedial investigation indicates that a particular Decision Unit presents no apparent risk to human health or to the environment. Results of sampling & analysis of environmental media from the suspected area of highest potential contamination should show that no contamination is present or that existing contaminant concentrations are below ADEC cleanup levels. Initiate Interim Removal Action. When the results of a limited field investigation confirm that a chemical release has occurred & the environmental contamination exceeds threshold concentrations, initiation of an interim removal action may be recommended. Specific conditions that would support selection of the interim action option include: • The data indicate a need for action to reduce real or potential risk to human health or the environment. • The data adequately describe the nature of contamination & apparently bound the range of concentrations expected to be encountered. • The scope of the problem is well-defined & limited, & the remedy is readily apparent. • The planned discrete action is not inconsistent with or will not preclude implementation of the final expected site remedy. Inclusion in the RI/FS removal/remedial action design. If the results of the field investigation confirm that a chemical release has occurred & that environmental contamination exceeds ADEC cleanup concentrations, the source area may be recommended for inclusion in the RI/FS removal/remedial action design. Conditions that would support selection of this option are: • The data indicate a need for action to reduce real or potential risk to human health or the environment. • The data adequately describe the nature & extent of contamination at the feature. See site file for additional information. Louis Howard
3/15/2012 Report or Workplan Review - Other CORPS comments (Amanda Whittier) on the UFP QAPP Wkst #6, page 16: Sample Receipt: please add within 24 hours to procedure. Wkst #11, page 36: The laboratory needs to be ELAP certified as well as Alaska certification. Wkst #11, page 37: Second i.e., list: remove i.e. as the list is general and not specific as it has a etc. Wkst #11, page 37: Surface water and sediment will be taken after soil data is returned from the lab indicating contamination or if field screening indicates or both. Wkst #11, page 38: How will the data be reported? What is meant be periodically? Quarterly, monthly..? Wkst #11, page 38: How will the data be reported? Spell out first EDD (i.e., electronic data deliverable (EDD)). Wkst #12, page 41: DoD QSM requirement needs to be included as well. MS/MSD, one per 20 for each matrix, for each analyte, for each cooler (min. of one). Wkst #14, page 44: Please see comment for worksheet #19. This statement is not supported by the table on worksheet #19. Wkst #14, page 44: Quality Control Task: Field duplicates and MS/MSD are also based on cooler or group of coolers be shipped. Wkst #15, page 46: Why have a compound listed if the project doesn't have a goal or criteria for the compound? Wkst #15, page 53: Why are there no criteria for PCBs? Wkst #18, page 77, Table 6: It is perhaps a good idea to have a table for each AOC and break down the features in it and then "spell out" how many samples (lab confirmation and field screening) will be taken. The example paragraph on page 74 is a good example to set this up, understanding that field conditions may change these plans. Wkst #18, page 77: Building unknown and ground scar sampling frequency is not correct based on the percentage given. Wkst #19, page 80: Parameter – GRO, BTEX and VOCs: EnCore? This should be 4 oz. amber glass, TLC, MeOH and 4+/- 2 preservation with a 28 day hold time for AK101 and 14 days for BTEX or VOCs by SW8260B or SW8260C (see Comment 15). These are discrete samples, so it does not make sense that EnCore is the sampling container (i.e., EnCore make sense for MI sampling for a site that can get the sample into preservation due to the 48 hour hold time). Wkst #19, page 80: SW8260B is listed in previous worksheets. Please make the worksheets consistent (either SW8260B or SW8260C). The same for SW8270. SW8270C is listed on some worksheets and SW8270D on others. Wkst #20, page 83: Or per cooler (see Comment 9). Wkst #21, page 87: Why TestAmerica Denver and not TestAmerica Seattle? Wkst #26, page 100: GoldStreak to Seattle not to Denver? Wkst #27, page 102: The email is incorrect. The email is receipt.cooler@usace.army.mil Wkst #34, page 114: Verification Input – COCs, Sample Receipt Forms and Shipping Forms: Please include the USACE email for these forms (receipt.cooler@usace.army.mil) SOP-02 Table 2: See comments 12 and 13. SOP-02 Page C-24: See comment 2 for laboratory certifications. SOP-05 Page C-44: Second to last paragraph – will a 4-gas meter be utilized during the field effort? SOP-05 Page C-48: Section 5.2.1: second paragraph, the PID lamp should be a 10.6 eV which is standard. Have you replaced the lamp in your PIDs? An 11.7 eV lamp is very fragile doesn’t usually stand up well in the field. SOP-07 Page C-67: Number 7: If temperature is one of the parameters being measured, then four parameters need to be stable per the ADEC guidance. SOP-08 Page C-88: Section 5.5.2.2, Numbers 5 and 6: see comment 25. Louis Howard
3/15/2012 Report or Workplan Review - Other CORPS (Meseret G.) comments on UFP QAPP Page 1, Work sheet # 1 Change the Site Name/Project Name to read: Port Heiden/Fort Morrow Remedial Investigation F10AK002705 Page 2 Work Sheet # 2 Correct Site Number/Code to read F10AK002705 Table under bullet number 5, Please include the FIIP number for all the referenced USACE documents. Page 6 Work Sheet # 2 3rd row, 2.9 Sampling Tasks & 3rd column under Crosswalk to ADEC, scaled site diagram with proposed sampling location include legends & orientation arrow is missing in the planning document. Page 7 Work Sheet # 2 3rd column the last two bullets talk about soil gas & indoor air sampling. Those do not apply to this project, please remove it or otherwise discuss where it applies. Page 38 Work sheet # 11 First paragraph, last sentence remove the statement referring to the defensive positions investigation & correct the percentage of Quartets types of feature for investigation. Page 14 Work Sheet # 4 Please populate the name & contact number of all contractor & subcontractor. Include also the USACE UVOST support team Lead Mr. Folcik, Neil Page 15 Work Sheet # 5 Please list all the subcontractors’ name & affiliation & include the USACE UVOST support team in the organization chart. Please indicate from whom they are getting direction on the field. Page 18, Work Sheet #7 Correct spelling of Lisa Geist. Change responsibility to Contracting Officer’s Representative (COR). Change title to Environmental Engineering Supervisor Page 20 Personal Contact Table Correct or replace the following names: - Replace Pat Riley USACE by John Smith - Remove all the EPA folks from the list - Replace Charles Grosse ATSDR by Joseph Sarcone - Add Michael Schroeder USACE legal - Add Greg Dubois APC Services - Add the names from BBNC Page 22 work Sheet # 9 Please correct John Smith e-mail address or change John’s name to Pat Riley Ramsey as she was the one who attended those meetings. Page 23 -28 Work Sheet # 9 Please correct Jessequa Parker title to Environmental Geologist & her e-mail address. Correct Mr. Patrick Roth 611 AF e-mail address Page 68 Work Sheet #17 On March 15, 2011 triad meeting it was discussed & agreed that for the Work Plan one CSM per AOC shall be developed. Page 69 Work Sheet #17 Figure 4, this indicates that no effort was put in by North Wind to create a site specific CSM diagram. This figure was given to North Wind to use as an example to demonstrate CSM diagrams. Please create a site specific CSM diagram.. page 73 work sheet # 17 Section 17.3.4, according to our last triad meeting on September 14, 2011. Metal screening will be conducted in addition to the sites with elevated GRO from the UVOST screening locations at the site features such as battery site, dump sites & maintenance shop near the airport. page 73 work sheet # 17 Section 17.3.3; please specify what geophysical screening tool will be used & how many site features will be surveyed. page 74 work sheet #17 Please indicate the site features where the radiation screening shall be conducted. page 74 work sheet #17 Section 17.3.6 Depth of screening to 4 ft bgs could miss potential contaminated plume. Depth of screening to groundwater will be appropriate. page 74 work sheet #17 Section 17.4.1, 1st bullet, GRO, DRO & RRO sample will be collected on a frequency of 10% of the field screening. This statement contradicts with Table 6 at frequency of 5%. Please correct. page 77 work sheet #18 Table 6; Fuel Storage total number of features is 42. We discussed & agreed during the March 15, 2011 triad meeting to screen at 2 points & collect 10% confirmation samples from hottest screening location. I don’t understand where grid base screening approach & collection of 100% confirmation samples comes from. Please go back to the meeting minuets & correct it. page 78 work sheet #18 Table 6, Recreational feature type total # of features 16. If only 25% of site feature is screened at two points where doest analytical sampling of 16 comes from. Please correct your calculation. page 115 Work Sheet # 35 Please describe the processes of how UVOST & other field screening data will be Validated. Page 116 Work Sheet # 36 Please provide the name of the subcontractor conducting the data validation & include data qualifiers as specified in the SOW. Work Sheet # 37 This WS concentrates on the analytical laboratory data only. Please describe UVOST & other field data usability assessment. Work Sheet # 38 Bibliography Correct the reference for the USACE, 2011 Alaska District Corps of Engineers Environmental Program Manual For Electronic Deliverables. Why is this document included: CENPD-EN-G-L (90-HM-157c), “Chemical Quality Assurance Report, Ft. Wainwright Basewide Groundwater Monitoring,” Fort Wainwright. See site file for additional information. Louis Howard
3/15/2012 Report or Workplan Review - Other Corps (Gordy Osgood) comments on the UFP QAPP General : This project is a very large RI. It is clearly the largest UVOST project every conducted in Alaska, & it is possibly the largest UVOST project every conducted on the face of this earth. Add to that the inherent logistical challenges posed by the project’s location in remote Alaska. The draft planning document does not reflect the level of planning that is appropriate for this particular project, nor does it reflect the level of planning that would be expected based on the level of effort proposed by Northwind & awarded by USACE. This planning document, as written to date, leaves the impression that Northwind plans to conduct Planning at a later date, & will essentially “wing it” when they get to the field. It does not reflect an appropriate level of planning that should be conducted before mobilizing to the site. Note that it is possible that appropriate planning has been conducted, but is simply not reflected in the deliverable for reasons not known to USACE. However, USACE only has the deliverable with which to gage that factor. General : The review comments reflected here should not be considered complete. Quality Control is first the responsibility of the Contractor; USACE should be expected to provide Quality Assurance only. Additional inadequacies may be identified during further review. There are sufficient inadequacies identified at this time to warrant a re-submittal of the draft planning document. SOP-1 Field Documentation An example of a Northwind boring log was not found in the document. Various other field forms were found throughout the SOP sections. Please provide an example of each field document listed under Section 4 of SOP-1 somewhere in the planning document. QAPP Worksheet #7, Page 17 Under “Responsibilities” column for Gordon Osgood, please remove the word “Supports/” related to contractor GIS specialist. This is a firm fixed price contract without a stated contract obligation of further Government Furnished Materials related to GIS efforts or products. The Government is relying on the contractor to provide all GIS services under contract without further support from the Government. Figure 2, Page 29 Please modify the scale of the large data frame / viewport such that, when printed from .pdf, a standard engineering scale can be used to measure distance. This applies to all map-type figures in the planning documents. QAPP Worksheet #10 During at least three prior Triad meetings it was recommended that existing information from past drilling efforts by the Air Force be reviewed & taken into account in project planning, particularly soil boring logs. Air Force Investigation reports can be downloaded from http://www.adminrec.com/PACAF.asp?Location=Alaska The 2009 Groundwater Investigation report by The Village of Port Heiden & DMC may be helpful. Additionally, the 2003 drinking water quality assessment by Keres includes well logs. I understand this type of documentation was provided to Northwind by Ms. Ghebresellassie. It is unclear if this review effort has occurred; it is not currently documented to have occurred. In the Planning Documents, please provide a detailed description of the results of Northwinds review of past site investigation efforts at Port Heiden to include the following: locations of soil borings & monitoring wells, depths of prior drilling, logged soil types, depths to groundwater over time, drilling methods used, blow counts, problems encountered during drilling, drilling start & stop times or progress rates, etc. Provide a map(s) showing the locations of past site investigation work & summary of results. The information above is fundamental to planning for further work at the site. An appropriate location for this information may be QAPP_WORKSHEET_#10, “Observations from any site reconnaissance reports”. QAPP Worksheet #5, Page 14 Include all subcontractors in the project organization chart. If additional space is needed, then an additional page can be used. Figures & GIS During multiple meetings & conversations over the past year, Northwind indicated that schematic representations of sampling locations for typical types of site features would be generated & included in the planning documents. These schematic diagrams were not provided in the Systematic Planning Document delivered in Fall 2011, nor are they provided in this February 2012 draft planning document deliverable. In order to deliver an acceptable Planning Document for this project, the following deliverables should be provided by Northwind as part of this planning document: See site file for additional information. Louis Howard
3/15/2012 Report or Workplan Review - Other CORPS (Jake Sweet) comments on the UFP QAPP General: Hard to visualize where, why & with what frequency samples are going to be taken. Several tables make it seem like all areas will be analyzed for most compounds, while the text in the document talks about much reduced frequencies. Please clarify all tables & text to indicate sample frequencies & rationales. General : UVOST SOPs & screening information is incomplete. UVOST is a complex way to field screen for POL, & takes a lot of experience to use. If employees expected to operate the UVOST are only trained by Dakota & have no field experience, extremely robust SOPs will be needed to hopefully keep them on the right track. In my opinion, sending inexperienced UVOST operators to the field for a job of this magnitude is not going to work well for the project. General : Which lab is going to be used? There are references throughout that refer to several (from what I can tell it is either Test America Seattle or Denver). Please clarify. Also include ELAP & ADEC certification for any lab used. General : Who is expected to do the fieldwork? Include names & qualifications. General : Who is doing data review? QAPP says one person in one section & one in another. Please send qualifications. UFP-QAPP WS #5: Please indicate who is doing data review & what specific lab will be used on the chart. UFP-QAPP WS #7: There is disagreement on this WS & WS #6 as to who is doing data review. WS #7 says it will be done by Kishor Gala of Northwind, WS6 says Debra Smith of Kestrel. Please clarify & make the rest of the document consistent. No qualifications for anyone are on the WS. Field samplers & qualifications are not present. WS #9 Please include a brief discussion of what was agreed to at each scoping mtg. WS #10 table 2 This is part of my confusion on sample #s, locations, & sampling rationale. This table makes it look like all locations will be sampled for all analyses listed. It may be better to use table 6 here instead. WS # 11: WS talks about field screening for several compounds that are not discussed in the rest of the QAPP or on the SOPs. How will field screening be done for SVOCs, PCBs, Pesticides & Herbicides? There is no complete SOP for the colorimetric test kits or UV test kits in this WP. Please include. WS #11 Data Archive Section Please remove sentence about one or the other (COELT & EDD) data formats being provided. The 2nd sentence of the paragraph is correct, both formats are required. WS # 12 table 5 This table would be a good place to also put MS/MSD requirements. WS #13 Why is data quality unknown for all previous reports? Please elaborate. WS #14 Please include ADEC checklists as part of the documentation & records for data quality reporting. WS #15 DoD QSM requires all results to be reported with LOD & LOQ, not PQL/MDL. MDL/PQL are legacy terms & are not consistent with the way data will be reported. Please remove all references to these terms & ensure that current methodologies are being used. Contact the lab you are using & get current detection limits. Bold text of compounds is not explained anywhere on the table. WS #17 Field screening for SVOC, PCB, Pest, herb & dioxin are not discussed. Field screening for Radium is not discussed. UVOST correlation is not discussed beyond general terms. How will the samples be collected & how, exactly, will the correlation be done? The handling of correlation samples & the methodology will have a huge impact on your correlation study. WS #17 17.3.6 Is this section talking about UVOST pushes? If so, please clarify. Also 4' is not a sufficient depth to characterize the site. UVOST pushes need to go below the water table. 17.4.1 This section need to be cleaned up. It is difficult to figure out sampling rationale. Radiation sampling rationale is not provided here or elsewhere, neither is radiation field screening. This section discussed radionuclide sampling. What methods are proposed? This is not discussed elsewhere in the QAPP. 17.5 What types of wells are going to be used? There is only a SOP for temporary GW monitoring points. Need to clarify well types & procedures for boring, construction, development & sampling if monitoring wells are installed. If temporary points are all that will be used please state. WS 19 Methods are inconsistent across this table & those following. Check with lab to see what methods they can run & which they are certified for. This table seems like the plan is to use EnCore samplers for all VOC analyses. This is not consistent with the Sampling SOP for volatile analysis which calls for methanol preservation in glass jars. Please clarify what will be used. WS 20 Analytical methods are not consistent with previous WS (notably VOC & SVOC analyses). Louis Howard
3/15/2012 Report or Workplan Review - Other CORPS (Neil Folcik) comments on the UFP QAPP Table of Contents Please include an acronym/abbreviation list & executive summary. WS 4 pg. 14 Please identify field personnel. Please provide documentation indicating that field personnel are “qualified” as defined in 18 AAC 78 & 18 AAC 75. WS 9 pg. 28 Please provide a short summary of each scoping meeting. What was the outcome of the meeting? What was decided? Simply providing a sign in sheet provides little value to this document. WS 10 pg. 31 A summary of the previous investigations/removal actions is noticeably missing from the planning document. Please include a summary of each action that was identified in this WS. A data summary table for each investigation would be appropriate. The previous investigation data should be presented & used to identify the COPCs. WS 10 pg. 33 An interim removal action will likely not be performed. The specific conditions listed that would support an interim removal action are not accurate. Please review section 4-4.2 & 4-5 in FUDS ER 200-3-1 for appropriate triggering conditions. WS 10 Table 2 Table 2 gives the perception that analytical samples will be collected from all 1119 site features. Is this the case? What about radium sampling? Or is radium only evaluated by field screening? WS 11 pg. 37 Please list all field screening methods/technologies that will actually be used during this RI & the COPCs they will evaluate. Be specific. WS 11 pg. 37 It is appropriate to collect confirmation samples from locations where field screening indicates contamination is below ADEC cleanup levels. ADEC does not allow the collection of confirmation samples prior to the removal of contaminated soil. Confirmation samples from suspected clean or post excavation. Characterization at suspected dirty locations. WS 11 pg. 38 First paragraph gives the perception that all features will be investigated by field screening & only a percentage will be evaluated by analytical sampling. Is this correct? WS 11 pg. 38 Are these the COPCs? How have they been identified? WS 11 pg. 38 GPS/Survey data needs to be identified & discussed in this section WS 11 pg. 38 How “good” do the data need to be…. Please answer this question for the analytical samples, field screening samples, & survey data. For each field screening method please identify minimum detection limits. (you could reference WS 12, see comment 18) For survey data please identify minimum accuracy requirements WS 11 pg. 38 How much data are needed….. This section should identify or point to the appropriate table/WS that does identify how many analytical samples & field screening samples will be collected during this RI. The Triad/stakeholders have given you their input. You need to take this information & plan this RI. How many samples (field screening/analytical) will be collected & where will they be collected? WS 11 pg. 39 Where, when, & how should the data be collected…..Your text does not answer these questions. Please indicate where, when, & how the analytical, field screening, GIS, & survey data will be collected. Reference other work sheets when applicable. WS 11 pg. 39 How will the data be reported… Please provide a detailed outline of the RI Report. Will the RI report identify the COCs, quantity of impacted media, include figures/tables, etc. How will the UVOST data be used? Will 3-D figures be prepared? Please indicate how the laboratory, GIS, & survey data will be reported. WS 12 pg. 40 It appears that not all analytical methods are identified in Tables 3 & 4. WS 12 pg. 40-41 Please include tables for surface water, sediment, & each of the field screening instruments that will be used. WS 13 pg. 43 Why is the data quality unknown for all of the historic reports? WS 14 pg. 45 Please provide a discussion of mobilization/demobilization, site access, & utility locates. Please discuss the remote camp. Where will it be located, where will water be taken from, how will waste be handled? WS 14 pg. 45 Field screening tasks: Please identify the specific field screening methods/equipment that will be used. Sampling Tasks: Please discuss SW, SD, & GW sampling in addition to soil sampling. Analysis tasks: Are there more analysis being performed than GRO, DRO, RRO, & PCBs? If so please identify. WS 15 pg. 47 Solid is not a matrix. Please include separate tables for soil, SW, SD, & GW. WS 17.1.1 pg. 67 What does the first sentence in this section mean? “The foundation for sample design & rationale are both correct & optimized is the CSM.” WS 17 pg. 69 Is this figure 3 or 4? Remove one of the figure numbers. Please remove the Alaska district logo. The title block is a mess. Flying “subsistence harvesters”? What are the “PCBs-“ connected to? Louis Howard
3/22/2012 Report or Workplan Review - Other ADEC comments on the Draft Fort Morrow, Formerly Used Defense Site Remedial Investigation Port Heiden, Alaska Uniform Federal Policy for Quality Assurance Project Plans (UFP-QAPP) Dated February 2012. The UFP-QAPP reflects a PA/SI approach & not a RI/FS approach as specified in EPA’s Guidance “Guidance for Conducting Remedial Investigations & Feasibility Studies Under CERCLA” EPA/540/G-89/004, OSWER Directive 9355.3-01, October 1988: “The objective of the RI/FS process is not the unobtainable goal of removing all uncertainty, but rather to gather information sufficient to support an informed risk management decision regarding which remedy appears to be most appropriate for a given site. It is important to note that the RI & FS are to be conducted concurrently & that data collected in the RI influence the development of remedial alternatives in the FS, which in turn affects the data needs & scope of treatability studies & additional field investigations.” Neither the schedule, nor proposed data collection is adequate to support a risk assessment in accordance with EPA’s Risk Assessment Guidance for Superfund. Recommend removing all references to risk assessment from the UFP-QAPP. Additionally, the limited data may not be adequate to support an RI/FS, with one “contaminated” point & a couple of “clean” perimeter samples. ADEC requests clarification from the CORPS on whether or not there will be site specific AOC work plans provided (as discussed) with additional information on what percentage of features per AOC will be investigated, how they will be chosen, actual screening & lab sample locations & numbers, etc. If so, add text to reference these in an appropriate appendix. If not, the UFP-QAPP does not provide adequate information to be approved as a work plan. Please provide acronyms table. QAPP Worksheet #1: Title & Approval Page Remove approvals & signature/date line from this page. Lead regulatory agency concurrence will be documented in a letter from ADEC QAPP Identifying Information 1. Identify regulatory program The purpose of this section is to identify the regulatory program this project is being conducted: CERCLA of 1980 &/or 18 AAC 75 Oil & Other Hazardous Substances Pollution Control (2011). DERP & FUDS are not regulatory programs such as: RCRA, TSCA, FIFRA, or the CWA. 2. Identify approval entity USACE- Alaska District is the lead agency at this site. ADEC is the lead regulatory authority at this site. 6.List organizational partners (stakeholders) & their connection with the lead organization: ADEC is the lead regulatory agency. Problem Definition The problem to be addressed by this project: Please be aware that the term site is not limited by property boundaries for the 8,000 acres of the former Fort Morrow site & its 13 Areas of Concern. In accordance with 18 AAC 75.990(115), “site” means an area that is contaminated, including areas contaminated by the migration of hazardous substances from a source area, regardless of property ownership. The text does not explain the listings in Appendix A by AOC on the rationale for site features, e.g. some site features were listed to be field screened but not sampled, or field screened & then sampled or not field screened & not sampled. Please provide text in a table explaining further why site features were presented in Appendix A & the rationale for field screening/sampling by AOC & site feature type. Page 31 A synopsis of secondary data or information from site reports A summary of data from the previous remedial actions & investigations should be included (either here or as an appendix) to determine how COPCs was selected in more detail. Page 32 The possible classes of contaminants & affected matrices 2nd bullet: Add as a potential source of PCB contaminants: “the historical use & disposal practices during the operation of Fort Morrow during 1942-1945.” See page 34, 35 & 36 for likely PCB source areas: five sites with an antennae feature, three sites with a generator shed feature, nine sites with the transformer feature, ten sites with the power house feature, one site with the radar building feature, & one site with the radio power building feature which all potentially could have power transformers associated with them. 2nd Bullet ADEC requests the text regard lead contamination be changed to: “Lead contamination is likely associated with aviation gasoline (AVGAS), leaded automotive gasoline (MOGAS) & lead-acid batteries.” 4th Bullet ADEC requests 18 AAC 78 & the UST Procedure Manual (adopted by reference) be added since the 1st bullet states: fuels or other material may also have been released to subsurface soils from buried drums & USTs. See site file for additional information. Louis Howard
3/22/2012 Report or Workplan Review - Other 611 Project Mgr Pat Roth submits comments on the UFP QAPP Fort Morrow. Worksheet #2 Section 6: On what basis id the USAF listed as a PRP for PCB contamination? This should be deleted. #3 Request USAF, Pat Roth, be added to the distribution list (electronic deliverable is fine). Since USAF is listed in #7, it may help to know what is going on. Page 24, 25, and in general: Use 611 CES or 611th Civil Engineer Squadron; not “Engineering Squadron” Page 32 2nd bullet under Preliminary Exposure: The Corps is not recognizing the real potential for additional PCB-contamination from Fort Morrow activities. By the Corps own previous removal documents, we know other PCB contamination associated with Fort Morrow has been previously identified/removed from Fort Morrow. Furthermore, the Corps’ document “Selected 1942-1944 Photos of life around Port Heiden, Alaska Form “History of Fort Morrow/Port Heiden, Alaska” which was complied by Ben Seid in 1944” shows many pictures of a substantial power line distribution system. I will bring some of these photos to the April meeting. Page 71 First bullet: The Corps is not recognizing the real potential for additional PCB-contamination from Fort Morrow activities. By the Corps own previous removal documents, we know other PCB contamination associated with Fort Morrow has been previously identified/removed from Fort Morrow. Furthermore, the Corps’ document “Selected 1942-1944 Photos of life around Port Heiden, Alaska Form “History of Fort Morrow/Port Heiden, Alaska” which was complied by Ben Seid in 1944” shows many pictures of a substantial power line distribution system. I will bring some of these photos to the April meeting. Louis Howard
4/2/2012 Meeting or Teleconference Held Part I of II TRIAD meeting No. 6 Ms. Meseret Ghebrellassie, USACE, spoke about the project status for 2012. She indicated that due to funding constraints this will be a smaller effort than originally envisioned. The project will be completed in phases to incorporate the available funding & to address the concern of multiple contractors working in Port Heiden in 2012 & the potential for inefficiencies & unintentional interferences with each other. The USACE wants everyone to work effectively & not over tax the local resources. The intent is that North Wind will work primarily in Areas of Concern (AOC) C, D, E, F, G, H, I, J, K, & L & not work in the AOCs surrounding the air field (AOCs B, C, & M) in 2012 where the other contractors will be focusing their efforts. Ms. Ghebrellassie then provided an update of the Real Estate Right of Entry ROE) activities. She stated there are 32 ROE releases have been sent out to local landowners, both corporate/federal government entities as well as private individuals. To date, the USACE has received 20 of 32 ROE requests back. Twenty four (24) of 32 ROE requests are private landowners. There are eight private landowners who have not responded at all or the ROE requests have come back as undeliverable. Two of the private landowners are deceased & their ROEs have been returned as undeliverable. Mr. Emil Christensen offered to contact the local landowners who have not responded &/or have out dated addresses to see if they are willing to sign the ROE requests. Mr. Crayton asked if ADEC had heard of Envirodata. Mr. Earl Crapps indicated that he had not. He asked if ADEC would be granted access to the database. Mr. Bailey indicated that the amount of data to be collected on a daily basis is quite large requiring that the data management system be quite robust. The real time data will have to be evaluated on a daily basis so it can be used to guide the next day’s field efforts. Mr. Crapps stated that since this is a dynamic work process that the Triad will need access to the data. Ms. Kim Kearney stated that the intent is to have pre-approved & pre-determined steps for the field crews to follow for the routine & expected screening & sampling activities. That way the Triad will only have to be involved in instances of completely unexpected scenarios & not on a day to day basis. Mr. Bailey stated that we all need to remember that screening data is not defensible or fully valid but can be used to guide sampling efforts. As agreed to at previous Triad meetings, the list of the screening frequencies for the site features at Fort Morrow is as follows: • 25% of Barracks/Quarters, Administrative/Recreation Buildings, Mess Halls, Quonset Huts, Ground Scars, Building Unknowns, & Tent Areas will be screened. • All other site features will be screened at a frequency of 100%. Mr. Crapps asked if we will step out in the 25% screening frequency sites? Ms. Ghebrellassie indicated that step outs will happen because the intent is to complete each AOC that is investigated in 2012. Mr. Bailey stated that if we find that the 25% screening locations are all clean, then we assume the other 75% are also clean. If we find that some percentage of the 25% screening locations are contaminated, then assume the same percentage of the remaining 75% are contaminated also. Ms. Geist stated that we would do the steps out now at the 25% screening sites & address the remaining 75% later. Mr. Crapps asked if we find that a portion of the 25% screening frequency sites are dirty, do we need to address the other 75%? Mr. Bailey asked for clarification on what a significant portion of the 25% would represent. Mr. Crapps stated that we need to address this issue now so whether the remaining 75% of sites are addressed in Phase I or Phase II of the investigation the approach is the same. Mr. Folcik asked a question about the grid sizes shown on the table on Page 3 of handout for SOP 02. Some grids are 20-ft by 20-ft & some are 35-ft by 35-ft. The grids for former drum areas are shown as 35-ft by 35-ft on the table. The group discussed that for site features such as ground scars, debris areas, & loose storage that if an area exceeds 1,600 square feet that the grid should be changed from 20-ft by 20-ft to 35-ft by 35-ft. Ms. Ghebrellassie indicated that grids should be laid out on the outline of a building. Mr. Crapps stated that there could be two release mechanisms for buildings, one for a spill in the building & one for the scenario where the material is dumped outside of the door. Mr. Folcik indicated that the grid should be laid over the building footprint & extend slightly beyond the edges of the building. Mr. Bailey suggested that we could skew the grid? Louis Howard
4/2/2012 Meeting or Teleconference Held Part II of II TRIAD meeting No. 6 ADEC clarified that for Quonset huts that we are picking the screening & sampling locations at the ends of the structure. Can we move the sample points so they are not in the center of the ends? Mr. Christensen stated the doors on Quonset huts were in the middle of the ends & the stove would be to either side of the door. ADEC asked if we should consider moving the sample locations so they are not in the middle. It was agreed to by the Triad that the screening locations would not be placed in the center of the ends of the Quonset huts. Mr. Bailey stated the site feature percentage will be selected by AOC using a MS Excel random number generator function. They will be sorted by random number & then the top 25% of the features can be identified. Mr. Crayton asked how it would be handled if the crew got in the field & found that one of the selected features was not accessible. Would the next one on the list be screened? It was agreed to by the Triad that if a site feature was not accessible, that the next one on the list would be selected for screening & the selection would be recorded in the site logbook. Lead screening. Should grid spacing be different for battery sites vs. gasoline release sites? ADEC stated for the two battery shops/storage locations we will use a 10 foot grid. Radiation Screening. The radiation screening will be done on a 20 x 20 foot grid. Ms. Ghebrellassie stated screening will be conducted on soils below the vegetative material. ADEC asked how background levels will be established? Mr. Bailey indicated calciferous, granitic or volcanic rocks could have quite different readings. One idea is to select 10 different spots at the site with different soil types to establish a background level. The approach will be laid out in the WP. We do not want to have to use a source to perform calibrations due to shipping restrictions. North Wind will use a low level non-regulated source to calibrate the instrument on a daily basis. A PID will be used for monitoring of the breathing space of the field crew. We could look at using a PID to screen soil if you don’t see a response with the UVOST - it may help with the screening of weathered gasoline. CHANGE IN APPROACH - If you see a reading on the PID of 10 ppm or greater & don’t see anything on the UVOST then that triggers a Triad discussion. Mr. Folcik stated they had found the same thing at Tanaga. They started out with a grid for each building but in the end lumped the buildings together for plume delineation. ADEC stated it is OK with giving flexibility in field. Once the area is delineated, take a lab sample to prove you have found the edge? Will this give you enough information for the FS? Mr. Folcik suggested using the UVOST to identify the boundaries. Then during the removal action, excavate & do confirmation sampling to prove all contamination was removed. ADEC stated that he wants to see laboratory data from both the high & low level screening data. Mr. Folcik stated that collecting samples from low level screening data is not a common practice. ADEC —going back to Mr. Folcik’s comment on screenings locations, I am concerned about rehomogenized soil providing a valid sample. Mr. Folcik we have only had to do a re-homogenized sample three times in 150 sample locations. At the end of the day you want the same soil that is put on the window of UVOST go to laboratory. ADEC asked the WP be clarified to show that all VOC samples (GRO, BTEX, etc.) are preserved. Mr. Bailey agreed & clarified that Encore samplers will not be used on this project. ADEC – ok so if you have 330 Quarters, 80 of them will be screened & 17 will be sampled, & 1 of the samples will be for the full suite of analytes. Mr. Bailey – this is where we could discuss how we want to handle the other 75% if any part of the 25% are significantly contaminated. ADEC asked if all 17 samples come back clean, would we as a group agree that it’s likely that all 330 Quarters are clean? Ms. Ghebrellassie stated that she agrees with that approach. ADEC brought up a concern that if we sample a site feature and the samples come back clean, we will want to use that data to say no further action is necessary at that feature. However, ADEC regulations say that to determine a site is clean, BTEX also needs to be evaluated. ADEC - if the GRO/RRO/DRO data comes back below Method 2 levels we would need BTEX analysis to get clean closure. The highest hit may be for DRO and not GRO, so it may not be valid. CHANGE IN APPROACH: —if the UVOST screening around the perimeter of the feature finds no contamination, then conduct the test pit excavation. —if the UVOST screening around the perimeter finds contamination, then do not excavate the test pit. Louis Howard
5/4/2012 Report or Workplan Review - Other Staff reviewed & provided comments on the draft final UFP-QAPP Fort Morrow Remedial Investigation. WS #7 Personnel Responsibilities, Qualifications, & Contact Tables WS-7 indicates a degree in Biology is not consistent with resume presented in Appendix A Resumes Page A-29. Mr. McGauhey does not meet the definition of a “qualified person*” as detailed in 18 AAC 75.990 (100) despite the years of experience he has working as the primary field lead for delineating heating oil spills, oversight responsibility for installation of wells & soil borings, etc. Unless Mr. McGauhey can demonstrate that he has a bachelor’s degree from a nationally or internationally accredited postsecondary institution, 18 AAC 75 would require that a “qualified person” directly supervise [in accordance with 18 AAC 75.990(125)]** & oversee Mr. McGauhey’s work as a “field technician” at Fort Morrow as part of this project. WS #10 Problem Definition COPCs in Surface Soil Definitions of surface & subsurface soils are inconsistent with Alaska regulations [18 AAC 75.990(123 & 127)]. It is also inconsistent with the project definition of surface soil at the time Ft. Morrow was operational, which could be beneath the vegetative mat or subsequent soil deposition. ADEC requests the USACE revise the definitions to be consistent with Alaska regulations & project objectives. WS #11 How will the data be archived? Chemical data files: The “raw” analytical data, e.g. bench sheets, chromatograms, calibration data, etc., are not required submittals, however, must be retained on file by the laboratory for at least ten years after the analysis date (Laboratory Data: Minimum Requirements for Laboratory Data Reports for Samples, ADEC Technical Memorandum “Environmental Laboratory Data & Quality Assurance Requirements”, March 2009). Comment is still applicable. WS #12 Measurement Performance Criteria Table Table 12-1 & 12-2 – ADEC requests the USACE include surrogates as an Accuracy Measurement for all organic analyses. Table 12-3 – “Less than the practical quantitation limit” is not an appropriate QC criteria for MS/MSD analyses. WS #13 Secondary Data Criteria & Limitations Table ADEC requests the CORPs clarify why data quality is listed as “unknown” if it is used to determine COPCs, especially for the later reports (1996 through 2007). This needs to be addressed in the text of the document. ADEC recalls Teresa Lee (USACE Chemist) saying in earlier TRIAD meetings, she was reviewing old reports, but not that this determination (data quality unknown) was made or documented anywhere. The revised worksheet lists everything as “data quality is unknown,” even the additional 2008-2011 reports. ADEC requests the USACE clarify if Appendix D is supposed to serve as documentation of the data quality being unknown. If so, then it should be referenced. Comment is still applicable. WS #15 Reference Limits & Evaluation Table QL term needs to be replaced in footnotes. The table still does not explain if a PAL is below the LOD (previously were bolded now no formatting or footnote as previously requested). PAL still not defined. “No CL” still used & not discussed in footnote or discussed in text. RSL is in the acronym list but not used anywhere else in main document. Soil & Water – Include ADEC cleanup level for 4-methylphenol (for 3- & 4-methylphenol) & 1,3-Dichloropropene (for cis & trans 1,3-Dichloropropene); List the EPA RSL level for 2-Hexanone & 4-Chlorotoluene (water). ADEC requests the USACE confirm that the listing for 2,2-Dichloropropane is correct – & whether it should be listed as 1,2-Dichoropropane with associated ADEC cleanup levels. Matrix: Soil & Sediment (Methanol Preserved) Analytical Group: Volatiles (SW8260B) Page 62 2-Hexanone CAS 591-78-6 has no ADEC Method Two soil cleanup level. The EPA RSA (November 2011) for residential soil (10-6) should be referenced 210 mg/kg not “no CL”. Matrix: Soil & Sediment Analytical Group: BTEX (SW8021B) Page 64 Project Action Limit for benzene should be 0.025 mg/kg. Matrix: Soil & Sediment Analytical Group: Pesticides (SW8081B) Page 70 Endosulfan CAS 115-29-7 has an ADEC cleanup level in soil of 64 mg/kg. Endosulfan I, Endosulfan II, & Endosulfan sulfate have no ADEC soil Method Two cleanup levels nor EPA RSLs. Matrix: Soil & Sediment Analytical Group: Dioxins (SW8290A) Page 71 ADEC will require that the dioxin TEQ be calculated using the 2005 WHO TEFs & submitted. For non-detects (NDs) the TEQ should be calculated & submitted with ND = 0 & ND = MDL/EDL. Matrix: Groundwater & Surface Water Analytical Group: “Cleanup levels should be attainable, especially for metal waters (Sb, As, Th).” Although values were changed & 6020 referenced - apparently TestAmerica Denver still can’t meet these cleanup levels. Comment is still applicable. See site file for additional information. Louis Howard
6/11/2012 Report or Workplan Review - Other The Alaska Department of Environmental Conservation's Contaminated Sites Program staff (ADEC) received the final documents on June 11, 2012 via an FTP website. ADEC will approve the UFP-QAPP with the caveat that the TCE contamination detected in soil and groundwater may be attributable to the former Fort Morrow and/or the Port Heiden Radio Relay Station, depending on the nature and extent of contamination found as part of the USACE's upcoming investigation. One cannot simply assume all the TCE that is found at Fort Morrow is entirely from the Air Force and not the Army. ADEC review and approval of the UFP-QAPP is to ensure the work is done in accordance with State of Alaska environmental laws and regulations. ADEC's approval of the UFP-QAPP does not relieve the Army Corps of Engineers (USACE) or agents, contractors, subcontractors acting on its behalf from the need to comply with other applicable State or Federal laws and regulations. The USACE is responsible for the actions of contractors, agents, or other persons who perform work to implement the approved UFP-QAPP. For any activity that significantly deviates from the approved UFP-QAPP, the USACE shall notify the ADEC and obtain written approval in the form of a UFP-QAPP amendment before beginning the activity. Any action taken by the USACE, or an agent of the USACE, that increases the project's overall scope or that negates, alters, or minimizes the intent or effectiveness of any stipulation contained in this UFP-QAPP will be deemed a significant deviation from the approved UFP-QAPP. The final determination as to the significance of any deviation and the need for a UFP-QAPP amendment is the responsibility of the ADEC. Therefore, it is recommended that the ADEC be consulted immediately when a significant deviation from the approved UFP-QAPP is being considered. Please provide one hard copy and one electronic copy of the Final signed version of the UFP-QAPP at your convenience for ADEC's files. Louis Howard
9/28/2012 Update or Other Action ADOT letter to Gretchen Pikul ADEC re: runway rehab project. The Alaska Depaument of Transportation and Public Facilities (ADOT&PF) is soliciting comments on a proposed project to rehabilitate the Port Heiden Airport. Port Heiden is located approximately 424 miles southwest of Ancborage and 125 air miles southwest of King Salmon at the mouth of the Meshik River on the north side of die Alaska Peninsula (see Location Map). The project will rehabilate the existing airport facilities and bring the airport up to current Federal Aviation Administration (FAA) airport design Standards. This project is scbeduIed for construction in May 2002. The existing airport facility does not meet the current FAA airport design standards. The airport is deficient with respect to safety areas. The runway lengths are in excess for the types of aircraft tbat use the airport. The surfacing at the Port Heiden Airport is in poor condition. The proposed project will reconfigure and resurface the existing crawl runways, resurface the existing taxiways and apron. replace the runway edge lighting system, relocate the FAA Runway Navigational Aides, and improve the airport safety areas (see Airport Layout). All airport improvements will be constructed within the airport property boundaries, and no additioaal property will be acquired. The proposed project will reduce Runway 5123 from 6,250 feet by 100 feet to 5,000 feet by 100 feet and modify the safety area from 7,050 feet by 200 feet to 6,200 feet by 300 feet Runway 13131 will be reduced &om 4,600 feet by 100 feet to 4,000 feet by 100 feet and the safety area modified from 5,400 feet by 200 feet to 5,200 feet by 300 feet The airport lighting systems, the segmented circle, and the rotating beacon will be replaced. The airport lighting controls will be relocated from the old Reeve Aleutian Airlines building to the ADOT&PF Maintenance/Airport Rescue and Fire Fighting (ARFF) Building. The Port Heiden Airport was previously reviewed for social, enviromnental, and economic impacts related to improvements. An Environmental Assessment and Finding of No Significant Impact (EA/FONSI) for genera1 airport improvements was approved by FAA on June 21, 1991; a Supplemental EAIFONSI for airport fencing was approved by FAA on May 21, 1992. The proposed project is expected to have no impacts on wetlands, since all wort will be contained in areas tbat are uplands. Thae are two material sites in the airport vicinity tbat do not require work in wetlauds, but the Contractor bas 1he option of using GIber material sites (see Material Site Location Map). Any work in wetlands by the Contrac:tor will require an U.S. Army Corps (COE) Permit Gretchen Pikul
9/28/2012 Update or Other Action ADOT Ray De Ley to ADEC Frank Wesser Frank-You requested more information on the waste material we found in the Port Hidden AitpOrt material site. I have consulted with the engineers. I have marked the spot with an X where they found buried waste in our material site. In addition, the engineers have marked a rectangular area that is a ridge where they expect there might be additional buried waste. They have not dug or explored this ridge. In terms of a person to speak to who has first hand knowledge about the sample collection you could call: Rhonda Strocher Project Manager SGS/CTE Environmental Services (907) 562-2343 OR Bryan D. Lund MACTEC Engineering and Consulting 907-563-8102 If you have any.questions give me a call. Tbank you, Rae D. 269-0527 Frank Wesser
2/20/2013 Update or Other Action Draft RI report & appendices received for review. The objectives of the RI were to: • Assess the presence or absence of contaminated surface & subsurface soils, surface water if present, & GW. • Where present, assess the nature & extent of surface & subsurface soil contamination & GW contamination. • Collect sufficient data to develop an ecological & human health conceptual site model (CSM) to evaluate potential exposure pathways. 152 soil samples were collected for full suite analysis, 36 for POL analysis, 103 for PCB analysis, 5 for metals analysis, & 6 for VOC analysis in the 10 AOCs. Results of the soil samples analyzed by the project lab indicate that there is subsurface contamination above 18 AAC 75 Method 2 cleanup levels at 20 site features in 8 of the 10 AOCs investigated in 2012. These AOCs include C, D, E, F, G, H,I, & J. • DRO at 1,500 to 21,000 mg/Kg (PAL = 250 mg/Kg) [MAC 10,250 mg/kg), • RRO at 12,000 to 14,000 mg/Kg (PAL = 10,000 mg/Kg), • Arsenic at 7 to 28 mg/Kg (PAL = 7.05 mg/Kg), • Total chromium at 250 mglKg (PAL = 25 mg/Kg), • Lead at 4,300 mg/kg (PAL = 400 mg/Kg), • Methyl tert-butyl ether (MTBE) at 1.6 to 7.7 mg/Kg (PAL = 1.3 mg/Kg), • Methylene chloride at 0.018 to 0.86 mg/Kg (PAL = 0.3 mg/Kg), • Bromomethane at 0.3 mg/Kg (PAL = 0.16 mg/Kg), & • 2-methylnaphthalene at 18 mg/Kg (PAL= 6.1 mg/Kg). PCB & GRO contamination were not detected above ADEC Method 2 cleanup levels in any of the 10 AOCs. It is likely that the arsenic & chromium detections are naturally occurring & are not from anthropogenic sources. Methylene chloride is a suspected lab contaminant. Radiological screening was conducted at one site feature C-XR-00l. No radiological contamination above background was detected. Almost all the XRF readings were below the (LOD), in addition many metals were not detected in the lab samples. XRF correlation studies were planned to determine if lead contamination associated with lead additives in gasoline or lead/acid storage batteries could be detected and field screened. However, the 2012 field activities were not conducted within AOCs where lead contamination was expected; therefore, lead levels were not detected at a significant number of locations or at levels high enough to perform a complete correlation study. Future correlation evaluations need to be performed at locations where a broad level of low to high detections of lead contamination is present in order to develop a correlation between XRF readings/lab results. In addition, future studies should compare XRF readings of sieved samples to analytical results of sieved samples. Overall, it is expected that sieved samples will contain higher levels of lead contaminants since smaller particles of soil will have more surface area to bind contaminants, as compared to the overall smaller surface areas of larger pieces of soil. Surface water or sediment samples were not collected as no water bodies were found to be closely connected to contaminated GW. The only GW results above Table C, was near site feature C-LT-002.1t was determined that there were no bodies of water of more than 100 sq ft located within 50’ downgradient of this area. 18 wells were installed & sampled & 12 piezometers were installed in to measure elevation & to calculate the flow direction. The results of the sampling indicate that contamination is above Table C, cleanup levels in 4 wells located in 3 AOCs: • C-MW-OO1 in AOC C had a DRO detection 3,500 ug/L (PAL = l,500 ug/L), & manganese at 750 ug/L (PAL = 320 ug/L). • F-MW-OO1 in AOC F had a manganese detection 350 ug/L. • J-MW-002 in AOC J had cobalt detected at 6.7 ug/L (PAL= 4.7 ug/L), iron at 18,000 ug/L (PAL= 11,000 ug/L) & manganese at 370 ug/L. • J-MW-003 in AOC J had arsenic detected at 11 ug/L (PAL = 10 ug/L), cobalt at 12 ug/L, iron at 46,000 ug/L, lead at 24 ug/L (PAL= 15 ug/L) & manganese at 420 ug/L The metals detected above the PALs are believed to be naturally occurring in the area in subsurface soil. A cumulative risk evaluation was performed using the results of the soil and GW sample analyses. There are no risk-contributing or petroleum COPCs in AOCs G, H, I, K, and L. Therefore the remediation of the soil in AOCs G, H, I, K, and L is unnecessary. Arsenic is the sole contributor to risk in AOC E and is believed to be naturally occurring. There are no petroleum COPCs in AOC E, therefore, the remediation of the soil is unnecessary. If the specific areas of petroleum contamination were remediated to meet 18 AAC 7S Method 2 cleanup levels, the cumulative risk would allow for clean closure of the remaining AOCs: C, D, F, and J. The results of soil samples collected up to a depth of 2' bgs were screened against the ADEC ERBSCs. Only metals exceeded the criteria. Therefore, there are no incremental ecological risks above those existing naturally. Further evaluation of the ecological risks is not necessary. Louis Howard
5/24/2013 Report or Workplan Review - Other The Alaska Department of Environmental Conservation (ADEC) has received a draft After Action Report on March 1, 2013 for the Site Road PCB Contaminated Site Removal from the Air Force. During response to comments correspondence and a review of the report, it has come to ADEC's attention that the confirmation sample location (sample ID TU10-L18 E) corresponds with the powerhouse A-PR-2 (Area of Concern "A') at the former Fort Morrow Army Post, located at Port Heiden, Alaska (ADEC CS DB Hazard ID 73). ADEC's review of the information, laboratory data, maps and figures from both the Air Force and Corps of Engineers investigations leads ADEC to determine that the highly elevated PCB contamination is likely associated with the former Fort Morrow site and not the Site Road site being addressed by the Air Force. ADEC requests the Corps of Engineers to make this area the highest priority in its ongoing RI/FS investigation of AOC A based on this recent information provided by the Air Force. The current fencing and signage initially placed by the Air Force needs to remain m place and maintained by the Corps until such time the Corps of Engineers resumes their investigation of AOC A (estimated to be 2014). Louis Howard
3/13/2014 Update or Other Action ADEC received the Phase II UFP-QAPP for review and comment. The purpose of this UFP-QAPP is to provide work plan guidance and applicable information for executing field activities, data analysis and reporting for the Port Heiden/Fort Morrow Remedial Investigation (RI). This work plan was developed by the stakeholders: U.S. Army Corps of Engineers, Alaska District (USACE), Alaska Department of Environmental Conservation (ADEC), U.S. Air Force (USAF), Bureau of Land Management (BLM), Alaska Department of Transportation and Public Facilities (ADOT&PF), the Village of Port Heiden, Alaska Peninsula Corporation (APC), Bristol Bay Native Corporation (BBNC) and private landowners using a Triad systematic planning process that included eight scoping sessions conducted from September 2010 to November 2013. The Fort Morrow site was occupied by the U.S. Army between 1942 and 1945 to support the war effort in the Aleutian Islands. Supplies used as part of this effort included thousands of drums of aviation fuel, petroleum, oil, and lubricants (POL), and other maintenance fluids. The amount of these materials released to the environment is not accurately known. Previous limited investigations have indicated that contaminated soils are present and may exceed 18 Alaska Administrative Code (AAC) 75 Method 2 cleanup levels. For execution of this RI, the Fort Morrow site was divided into 13 Areas of Concern (AOCs). Two AOCs remain to be investigated in 2014; AOC B and AOC M. Using historical information and discussions during the scoping sessions, the site features to be investigated and associated contaminants of potential concern (COPCs) were identified for each AOC. The COPCs include POL, polychlorinated biphenols (PCBs), metals, and a range of volatile organic compounds (VOCs) and semi-volatile organic compounds (SVOCs). Field investigation will begin with soil screening techniques including Ultraviolet Optical Scanning Tool (UVOST) and ultraviolet (UV) fluorescence test kits for POLs, x-ray fluorescence (XRF) for metals and a radiation detector for radionuclides. A total of 1,269 individual possible site features were identified by the Army Geospatial Command (AGS) in the area of the former Fort Morrow. A total of 161 of these features were found to be non HTRW eligible as they are associated with the MMRP. A total of 15 sites from the database are associated with Air Force operations and have been excluded from this RI. Therefore, the total number of identified features to be investigated under this RI is 683. Other features that the RI crew discovers during field operations may be added in the future. The field screening results from UVOST, UV fluorescence test kits and XRF will be used to identify sampling locations for laboratory analysis of gasoline range organics (GRO), diesel range organics (DRO), and residual range organics (RRO), and metals. Collection of samples for laboratory analysis of VOCs, SVOCs, pesticides, metals, and PCBs has been identified for some site features. The combination of soil screening and laboratory analytical results will be used to determine if groundwater, surface water and sediment samples need to be collected to delineate the full extent of contamination. Throughout implementation of the field investigation, communication will be maintained with the stakeholders through biweekly conference calls to provide a summary of completed field activities, data collected and preliminary results. Following completion of the field investigation and receipt of all laboratory analytical data, an RI report will be prepared. Louis Howard
4/8/2014 Report or Workplan Review - Other Staff provided comments on the draft UFP-QAPP Problem Definition Page 41 The problem to be addressed by this project: Please be aware that the term “site” is not limited by property boundaries for the 8,000 acres of the former Fort Morrow site and the thirteen “Areas of Concern”. In accordance with 18 AAC 75.990(115), “site” means an area that is contaminated, including areas contaminated by the migration of hazardous substances from a source area, regardless of property ownership. As noted in 18 AAC 75.325 (g) the risk from hazardous substances should not exceed a cumulative carcinogenic risk standard of 1 in 100,000 across all exposure pathways and does not exceed a cumulative noncarcinogenic risk standard at a hazard index of one across all exposure pathways. Cumulative risk question should also be asked in this section. Page 43 Pesticide is listed as a COPC in Table 17-7 “Contaminants of Potential Concern for the former Fort Morrow by Feature Type”, but not mention in text for COPC. Please correct text. 1,4 dioxane has been discovered at other military sites to be a co-contaminant with trichloroethylene (TCE) in groundwater. 1,4 dioxane is currently not being screened for at Fort Morrow. Please clarify why this is not a COC. The text states: “The use of risk based cleanup levels would only be used in consultation with ADEC and applicable land owners.” The text shall state: “The use of risk based cleanup levels may be developed during later stages of the investigation and used with consent of each landowner affected by the contamination and with ADEC approval.” Landowners will have to consent to risk based cleanup levels being placed on their property, not be consulted with which has a different connotation. The text states: “Although it has been approximately 60 years since Army activities took place, surface water and sediments may have been impacted by releases from drums or other containers that have been more recently damaged or corroded.” While the half-life of the COPC may be less than 60 years in surface water or sediments, having inactivity does not result in no residues for other COPCs due to the fact that drums/ containers housing chemicals are still on site and could have been damaged/corroded over the 60 yr span for release either during that time or in the future if still intact. Page 48 2nd Bullet The text states: “Possible interim removal/remedial action if specific health based risks are identified.” The statement should also include the potential for contaminants to migrate into groundwater and exceed risk based or regulatory values from groundwater. Thus, the interim removal or remedial action would also be used to address source in the soil that has the potential to migrate to groundwater. Initiate Interim Removal Action. The text states: “A removal response is appropriate only when site specific conditions indicate an imminent threat to human health, safety or the environment.” The text should state: “A removal response is appropriate only when site specific conditions indicate an imminent threat to human health, safety or the environment in accordance with 40 C.F. R. § 300.415.” Collect additional data in order to perform a risk based evaluation of the feature. The text states: “USACE may decide to collect sufficient data to perform a risk based evaluation of a given site feature, AOC, or the entire site.” Before USACE decides to collect additional data to perform a risk based evaluation or a Method Four Risk Assessment, it shall obtain consent of each landowner who is affected by the contamination at the site that a cleanup level less stringent than a cleanup level appropriate to residential land use is appropriate for the site [18 AAC 75.340(e)(3)(D)]. If USACE cannot obtain written landowner consent to less stringent cleanup and the required institutional controls which will be appurtenant to and run with the land so that the control is binding on each future owner of the site, there is no reason to consider a any other cleanup level beyond Method Two soil cleanup levels and Table C for groundwater cleanup levels. The investigation proposed by this UFP-QAPP and the data generated from the 2014 field work will not meet the data needs that would allow for the development of alternative cleanup levels through a Method Four (risk assessment). Louis Howard
5/7/2014 Report or Workplan Review - Other RTCs to ADEC's comments on the Draft UFP-QAPP approved. Louis Howard
10/6/2014 Update or Other Action ATSDR Health Consultation for Evaluation of PCBs Associated with the Former Radio Relay Station Area, Former Fort Morrow, & Other Former Use Areas, Port Heiden, AK. The community petitioned ATSDR with health & environmental concerns associated with the former radio relay station (RRS). RRS’s are known for their use of PCBs as an insulator. Long after the Air Force (USAF) stopped using the RRS they & the Army Corps of Engineers (USACE) collected environmental samples. We consolidate & evaluate that data here. The purpose of this Health Consultation is to give community members the information they need to protect their health. Its purpose also is to recommend actions that Defense & other agencies can take where known contamination exists to protect the community’s health. ATSDR evaluated the possible ways people could have contacted PCBs from the site; then evaluated the exposure doses using the data collected by Defense; filled in some data gaps using what is provided in literature; & then compared the doses with studies used to evaluate harmful effects. Recommendations: Although total Aroclors (only Aroclor 1260 was detected) in soil is sufficient for an estimate of PCB concentrations & to determine soil removals & areas to remediate, congener-specific data for plants & animals is preferable. In particular, congener-specific data are preferable for evaluating human health & are recommended. We recommend filling as many data gaps as possible. 1. To minimize any additional exposure, the USAF & USACE should ensure that workers, especially local contractors, are adequately protected & educated about exposures before they handle PCB-contaminated soils. 2. The USAF, USACE, or U.S. EPA should sample for PCBs in the soil within the Village of Port Heiden. Potential is identifiable for the redistribution of soils from the former WACS/RRS, possible use of PCBs oils for dust suppression, as well as other sources. 3. The USAF or Corps of Engineers should sample the remaining roads on which PCBs might have been used for dust suppression. Testing of the borrow landfill sites (particularly drainages) & transportation routes for PCBs is recommended. Additionally, any remaining PCB hot spot areas in soil should be removed (including any associated with the old Army Power Plant, especially if access isn’t restricted to people. 4. ATSDR through its memorandum of understanding could work through Superfund Community Action through Nutrition (SCAN) or a similar program to help the community improve its overall health status to include a focus on local contaminants. A program designed to identify which foods contain the highest levels of PCBs & ways of preparing food or finding substitutes that could reduce exposure is recommended. 5. Should the above studies indicate PCB exposures, further investigation of food sources should be conducted. PCB data are unavailable for clams, sculpins, walruses & other marine mammals, & other animals in the Bristol Bay area near Port Heiden near shore & marine birds & their eggs are also food sources of some of the community. 6. Sample cockles in Bristol Bay for PCBs. Such sampling is warranted due to the vicinity of the RRS site (within 5 km of Bristol Bay), the recently eroding landfill adjacent to the bay, & potential riverine (Reindeer & Abbott Creeks) inputs of PCBs into the bay. & most residents consume cockles. While we expect some PCBs from worldwide sources, we want to make sure that they are not unusually higher than elsewhere in the region. 7. Residents need to follow the instructions on the posted signs that advise not to collect subsistence food at the radio relay station site. 8. Residents who want to lower their PCB body burdens could limit consumption of the Arctic subsistence foods that tend to have higher PCB concentrations. Such reduction would also reduce their risk of cancer & adverse health effects, such as learning problems. 9. Residents could also reduce their exposure to PCBs in soil & dust by washing food, clothing, hands, & other items that have come in contact with PCBs. 10. Residents can help reduce some PCB risk by eating more fruits & vegetables. The USAF plans to conduct further removals at the RRS (such as at the RRS Landfill, pad grid 1, Black Lagoon Outfall/Septic System Outfall, etc.) & along the roadway from the airport to the RRS area. Removal of approximately 20,000 cy of PCB-contaminated soil was planned for 2013. As of December of 2013, some soils were removed, other areas were fenced, & tarps were placed over soils. The USACE began Fort Morrow investigations in 2012. A recent report found that 10 of the 13 Corps areas contained PCBs at levels below 1 mg/kg. Louis Howard
5/9/2016 Update or Other Action Updated ETM ranking. Louis Howard
5/9/2016 Update or Other Action Draft Phase II RI report received for review and comment. Exceedances for POL in surface & subsurface soils were for DRO exclusively at 11 features (6.6%) of those sampled. Exceedances were observed in former Drum Area, Building Unknown, Power House, Shop, Storage, Transformer, & “Unknown” feature types. Exceedances for lead screening in surface soil were confirmed at a Shop feature type, or 11% of those screened. The largest screening detections were in Shop features exclusively. Some VOC or SVOC contaminants exceeded PALs in many samples but are not considered to be contributable to environmental contamination; they are common lab contaminants-methylene chloride & methyl tert-butyl ether. Methylene chloride is a suspected laboratory contaminant not associated with activities at Fort Morrow. Many detections of arsenic & chromium above the PAL are likely naturally occurring & are not from anthropogenic sources with the exception of sample results from a test pit in E-DS-001. At this location, both arsenic & chromium levels are above the UTL set by the 2015 background study as well as the 2006 Air Force Metals Background Study at the Port Heiden Radio Relay Station (USAF, 2006) & the PALs. Contamination in M-PR-005 was detected at a depth of 25 feet bgs associated with an organic rich layer, & may be due to biogenic interference rather than actual POL contamination. No POL exceedances were confirmed in any of the other nine features at depths greater than 12 feet bgs. No exceedances for POL were confirmed in Quarters features. 31 features were screened with roughly half screened inside the discernable recessed area & half immediately outside the perimeter. Two potential POL detections were noted; one at M-QT-039 on the outside perimeter & one at M-QT-101 inside the recessed area. For metals analyses in AOC M, exceedances for arsenic do not appear to be associated with any specific feature type, except possibly mounded material features where four of the four features sampled exceeded the PAL & one of the four features exceeded the 2015 UTL. Exceedances of manganese & molybdenum above 2015 UTLs appear to occur in latrine, mounded material, & warehouse type features at a higher ratio of features sampled than in other features types (with multiple features). Exceedances for POL in groundwater were confirmed in four monitoring wells. Three of the wells were installed in locations of known highest contamination. One downgradient well was impacted. Exceedance of POL in one downgradient well may be due to migration of the contaminant plume or the well’s proximity to another source of contamination. No other downgradient wells were impacted. Eight wells analyzed for total & dissolved metals had exceedances for metals. Exceedances were for iron, manganese, dissolved manganese, or cobalt. No exceedances for lead were observed. Groundwater occurrence in AOC M was not consistently documented at features with confirmed contamination in soils above PALs. Depth to the groundwater surface was not clearly defined at features M-ST-006, M-UN-002, & M-PR-005. Feature M-ST-006 had confirmed contamination at 6 feet bgs. This feature is located on terrain above the elevation of the adjacent maintained road near feature M-ST-008 by approximately 10 feet. Depth to water was measured in M-ST-008 at 17 feet bgs, so it is unlikely that contamination at M-ST-006 is within 5 feet of the groundwater surface. Feature M-UN-002 had confirmed contamination at 12 feet bgs. The elevation of this feature is approximately 30 feet higher than monitoring well M-MW-002 located in feature M-SH-002. It is unlikely that contamination at M-UN-002 is within 5 feet of the groundwater surface. Two piezometers installed at M-PR-005 did not provide consistent information regarding the occurrence of groundwater in & around this feature. Water was detected in one piezometer but not the other one just 50 feet away, suggesting possible isolated perched zones with no lateral continuity. See site file for additional information. Louis Howard
5/23/2016 Report or Workplan Review - Other Staff provided comments on the draft phase II RI Report. Interpretation of the sample chromatogram must be done by an experienced analyst for qualitative match of the chromatograph pattern to known sources of fuel product and/or biogenic interference. Please submit the chromatograms to ADEC for those samples with contamination in M-PR-005 which biogenic interference is being presumed by the United States Corps of Engineers (USACE). Once biogenic interference has been determined by ADEC’s chemist, the laboratory procedure as listed in ADEC Tech Memo 06-001 May 2006 for silica gel cleanup may be used as an analytical tool to evaluate the contribution of biogenic interference to the original sample results in accordance with the memo. Merely stating or observing an organic layer does not make it automatically a case for biogenic interference which ADEC will approve. Please provide reference to the ADEC approval for transport/disposal of the soil by ELM Solutions to Columbia Ridge Landfill in Arlington, Oregon. ADEC has no record in any 2014 emails or formal requests from the USACE using the ADEC’s “Transport, Treatment, & Disposal Approval Form for Contaminated Media” for this “incidental soil” to be disposed of at Columbia Ridge Landfill. According to 18 AAC 75.325 Site cleanup rules: purpose, applicability, and general provisions (i) A responsible person shall obtain approval before disposing of soil or groundwater from a site 1. that is subject to the site cleanup rules. This applies to any project in the State of Alaska which requires disposal of contaminated soil and/or groundwater (in-state or out of state). It appears the correlation value for LIF set at 1.6% did not correlate well for DRO exceedance of 3,000 mg/kg at this UVOST probe locations (LIF values: 0.295%. Based on the Table 6-5 results for %LIF and laboratory results, there may not be as good a correlation between a LIF value of 1.6% and DRO exceedances as mentioned on Page 4-3 Section 4.3.1 Screening for Petroleum, Oils, and Lubricants . C-GS-004 had a LIF value of 4.547% and a DRO result of ND (2.7 mg/kg) and K-ST-001 had a LIF value of 1.692% and a DRO result of ND (2.2 mg/kg). Please state that several UVOST probe locations had a DRO results above the project action limit of 250 mg/kg even though they did not exceed the correlation LIF value of 1.6%. Site feature MP-PR-05 had DRO detected at 6,900 mg/kg associated with an effective LIF value of 0.949%, site feature M-SH-002 had DRO detected at 8,700 mg/kg with an effective LIF value of 0.224%, site feature M-ST-006 had DRO detected at 960 mg/kg (QL) with an effective LIF value of 0.010% and site feature M-TF-001 had DRO detected at 2,400 mg/kg with an effective LIF value of 1.44%. Also state that there were four locations where the LIF values were above the 1.6% correlation value (2.16 2.05, 2.40 and 2.10%), but DRO was below the project action limit of 250 mg/kg. See site file for additional information. Louis Howard

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