Action Date |
Action |
Description |
DEC Staff |
3/31/1989 |
Update or Other Action |
Work plan for Remedial Investigation/Feasibility Study (RI/FS) stage 1 received. 5.3,1 Removals
5.3.1.1 Waste AccumulationArea No. 1 (ROM-3)
Description - At this site, which has in the past and is presently used as a staging and temporary storage area, various containerized materials were noted in 1987, and included open partially-filed containers of toluene, lubricating oils and grease, other solvents and paints. Some containers that were not open were leaking or crushed. There were fresh stains on the Soil under and alongside these containers.
Setting - The containerized materials are stored on a gravel pad, which has been placed on top of the natural surface cover and subsurfacesoils. These conditions are further characterized in Section 5.3.2.1.
Recommended Action - It is recommended that the contaminated materials be removed. Prior to any removal, all containers will be identified and inventoried. Removal will consist of overpacking all containers and properly labelling the overpacks according to DOT regulations. Disposition of the overpacks will be coordinated with the DPD Office at Elmendorf AFB. Removal of the overpacks will be initiated during the 1989 field effort in accordance with applicable disposal protocols and requirements.
Because of the up-gradient location of the waste accumulation area with respect to the drinking-water supply well, this well will be sampled. Further, to assist in identifying the source of contamination in the any well, the small lake upgradient of the well and the soil in the natural
drainage channel leading from the waste accumulation area to the well location will be sampled. Sample analysis from all three sample localities will include volatile organics, semi-volatile organics, PCB, total petroleum hydrocarbons and metals. |
Louis Howard |
3/1/1991 |
Update or Other Action |
USFWS Letter to Lt. Col. William Lamb USAF 11 Tactical Control Wing/LG regarding discovered contaminants of concern in selected fish and wildlife resources at the facility which lies in the Yukon Delta National Wildlife Refuge. The investigation was conducted in 1987 and 1988, and was specifically designed to determine if Site generated contaminants have entered the Refuge's resources.
Analytical results indicate that elevated levels of some polycyclic aromatic hydrocarbons (PAHs), organochlorines and trace elements are accumulating in wildlife tissue. Most notable were PCBs and DDT-related compounds in vole, fox and fish samples. Pathways of uptake include contact, ingestion, or inhalation of contaminated soil, sediment, water, waste or prey.
The U.S. Fish and Wildlife Service's Environmental Contaminant Specialists have determined that the elevated contaminant levels may pose a threat to the Refuge's wildlife resources. Furthermore, sediment samples collected by the Service and water and sediment samples collected by your contractor Woodward-Clyde Consultants indicate that an abandoned Landfill is a significant contributor of PAHs, PCBs, chlordane, lead and cadmium contamination. A copy of our "Report of Findings is enclosed for
your reference.
In conclusion, Service concerns appear to be adequately addressed under the U.S. Air Force's Installation Restoration Program. We believe Woodward-Clyde Consultants' remedial recommendations should be seriously considered. Therefore, we recommend, that:
1. the U.S. Air Force select remediation alternatives in consultation with the U.S. Environmental Protection Agency, Alaska Department of Environmental Conservation, and U.S. Fish and Wildlife Service;
2. the State of Alaska's Department of Environmental Conservation interim standard of i00 mg/kg (ppm) for Total Petroleum Hydrocarbons in soil be adopted by the U.S. Air Force as a cleanup level for the Cape Romanzof Long Range Radar Site;
3. the Environmental Protection Agency's "Polychlorinated Biphenyls Spill Cleanup Policy" (52 FR 10688. April 2, 1987) be used as a guide to remediate affected sites; and
4. the abandoned landfill's contents be excavated and disposed off-site to ensure permanent protection of the area's fish and wildlife resources. |
Louis Howard |
3/11/1991 |
Update or Other Action |
Woodward Clyde Remedial Investigation/Feasibility Study (RI/FS) 06/1990 stage 1 received by ADEC for work conducted 7/89-9/89. ROM-3 Former Shop Area: location where oils, hydraulic fluids, solvents, toluene, paints, and ethylene glycol had been stored, leaked and spilled. The site is the former shop area at Lower Camp east of ROM-10 (Spill site 3 POL Fill Stand or ST09). The site also includes the groundwater of the installation supply well and the surface water of the lake behind Huson Dam.
Partially filled containers of waste and stained soils noted by the 1987 reconnaissance team were no longer present at this site. Because the buildings had been demolished by the 5099th CEOS, there was no point of reference to indicate the exact location of the former shop.
A soil gas survey was performed here to better define locations to be investigated further by soil sampling. Seventeen soil gas probes were installed and sampled, from depths of 2.0 to 4.5 feet. Not all locations were possible for dual sampling due to subsurface conditions that inhibited the probe from penetrating to the greater depth. Soils are fill material composed of sandy silt with boulders. At location number 12, a sample was not collected due to running mud that clogged the tee and the needle of the syringe (WCC 1989a). Based on soil gas results, four soil samples were collected from locations shown to be contaminated.
In addition, several samples of soil and water were collected from the area southwest of and mostly downgradient from the former shop area. For convenience, these samples were included in the ROM-3 study. One sediment sample (3-5) was collected from a small drainage downslope (in the tundra) from the area of the soil gas survey. One surface water sample (3-7) was collected from the small lake formed behind the small earth-filled dam. One groundwater sample (3-6) was collected from the LRRS water supply well. It was not possible to obtain a water level measurement for the water supply well at ROM-3 because no port existed.
The base water supply well was pumped for 8 minutes. Water level was measured from the ground surface at 29.00 feet for ROM-3 Well no. 1. All soil sample results indicated the presence of TPH ranging from 2,400 mg/kg to 35,000 mg/kg. Groundwater TPH contamination was found in a sample at 2 mg/L. Estimates of contamination in square footage was calculated to be 12, 600 sq. ft. and contaminated soil was estimated to be 2,104 cubic yards (assuming 4.5 ft. depth of contamination). |
Vic Vickaryous |
2/25/1992 |
Document, Report, or Work plan Review - other |
Staff reviewed and commented on the Draft Installation Restoration Program (IRP) Remedial Investigation/Feasability Study (RI/FS) Stage 1 Tech Report Addendum March 1991 and 2nd draft report June 1990. ROM-3 Former Shop Area-Capping as a remedial alternative for this site is not a preferred method for eliminating the potential contamination of the station's drinking water supply 100 yards southwest of ROM-3. Total petroleum hydrocarbons (TPH) was detected in soils as high as 35,000 ppm at the 4.5 foot depth & total depth or lateral extent of contamination is unknown (page 4-22 sect. 4.1.4.6 WCC June 1990).
These levels are above ADEC's cleanup levels & must be addressed. ADEC concurs that the tundra area undergo remediation for TPH in conjunction with remediation of ROM-lS Fuel Spill soil. ADEC also concurs that further investigation is needed to adequately define the geologic and hydrogeologic subsurface conditions in the ROM-3/ROM-lS areas, and the extent of contamination. |
Louis Howard |
4/9/1992 |
Update or Other Action |
EPA Memorandum April 9, 1992 Reply to the ATTN of ES-098. Subject Toxicity of Fuels. From Carol Sweeney Toxicologist Health and Environmental Assessment Section. To Wayne Pierre Federal Facilities Superfuend Branch (HW-124). A response has been provided to the frequently-asked question of whether a reference dose or other toxicity information can be provided for fuel mixtures so that these mixtures can be addressed quantitatively in Superfund risk assessments. The memo from ECAO Cincinnati is attached (last attachment). They have developed reference doses for gasoline, JP-5/kerosene, and JP-4, and a cancer potency factor for gasoline. The memo emphasizes that these are provisional numbers and that considerable uncertainty is involved in this quantitative assessment, because of data limitations, and because inhalation studies were used to calculate oral reference doses.
I typed up a summary table showing the numbers (first attachment) and calculated some risk-based concentrations (second attachment). On the risk-based concentration table, I also
included ordnance compounds, because I hadn't made a table of those before that I can remember. The risk-based concentrations were calculated the same way as table II-1 and II-2 of the Region
10 Supplemental guidance; for soil, the same limitations apply, that the numbers presented do not consider pathways other than soil ingestion.
Toxicity Reference Vaules for Fuel Mixtures EPA Region 10 4/9/1992 Non-cancer effects-Gasoline (unleaded) RfD (mg/kg-day) Oral: 2.0E-1, Uncertainty Factor-Oral:1000, Level of Confidence-Oral: Low. Toxicity Data Source-Oral RfD: Memo 3/92. Carcinogenicity-Cancer Potency/(mg/kg/day): Oral 1.7E-3, Unit Risk (/ug/m3) 4.8E-7, Cancer Weight Of Evidence-C, Toxicity Data Source-Oral SF and Inhal. SF: Memo 3/1992.
Kerosene/JP-5 RfD2.0E-2, UF Oral: 10,000, LOC Oral: low, TDS Oral RfD: Memo 3/92
JP-4 RfD 8.0E-2, UF Oral: 10,000, LOC Oral: low, TDS Oral RfD: memo 3/92.
Screening Values for Water RBCs based on Ingestion, Residential
Gasoline-Risk = 10-6 (ug/L) 50, 10-4=5000 HI=1 (ug/L) 7000
JP-5 Kerosene Risk 10-6 10-4=NA HI = 1 (ug/L) 700
JP-4 Risk 10-6 10-4 = NA, HI = 1 (ug/L) = 3,000
Screening Values for Soils- RBCs Based on Soil Ingestion Residential
Gasoline-Risk = 10-6 (mg/kg) 400, 10-4 (mg/kg) 40,000, HQ = 1 (mg/kg) 50,000
JP-5 Kerosene Risk 10-6 10-4 NA, HQ =1 5,000
JP-4 Risk 10-6 10-4 NA, HQ = 20,000
IARC concluded that gasoline is possibly carcinogenic to humans (Group 2B). IARC concluded that marine diesel fuel is possibly carcinogenic to humans (Group 2B), but light diesel fuels and jet fuels are not classifiable as to their carcinogenicity in humans (Group 3). |
Louis Howard |
7/13/1992 |
Preliminary Assessment Approved |
Letter from EPA Region 10 stating that the Preliminary Site Assessment for the purposes of ranking under the Hazard Ranking System used to evaluate federal facilities for inclusion on the National Priorities List (NPL). Review of the documents indicate the site (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 the federal agency hazardous waste compliance docket tracking system. If new or additional information becomes available that suggests the facility may score high enough to be proposed for the NPL, EPA will reevaluate the facility accordingly. The Facility is not relieved from complying with appropriate Alaska state regulations and SARA 1986(a) (4) requires federal facilities to comply with state cleanup requirements and standards when not listed on the NPL. |
Jennifer Roberts |
9/9/1992 |
Update or Other Action |
The Department of Environmental Conservation has been informed by the 11 CEOS on August 31, 1992 that the sampling for Cape Romanzof was delayed until next field season-1993. The Department requests in writing a schedule outlining next year's start date for the RI/FS work at Cape Romanzof's spill SS15 Site. Investigative work must proceed expediently as possible due to the potential effects of this spill may have on this sole source aquifer.
Any further delays in investigative work may lead to a compliance advisory from the Department. The State of Alaska's Oil and Hazardous Substances Pollution Control regulations 18 AAC 75.327-337 state that "Immediately upon becoming aware of a discharge of a hazardous substance to land or waters of the state, any person responsible for that discharge shall contain, clean up, and dispose of the material collected, using methods for which approval has been given by the department. The discharge must be cleaned up to the Department's satisfaction." Currently, investigative efforts for this spill have not been adequate in delineating and containing the contamination at Cape Romanzof.
The Department requests a written response within 14 (fourteen) days of receipt of this letter outlining what actions will be taken. |
Louis Howard |
2/10/1993 |
Document, Report, or Work plan Review - other |
Vickaryous provided comments on RI/FS technical report. ROM-3 a.k.a. SS07 Former Shop Area. Samples indicate 35,000 mg/kg TPH at 4 1/2 feet which is above ADEC cleanup levels as noted in the Interim Guidance for NON-UST contaminated soil cleanup levels (July 17, 1991). Further sampling is needed to determine depth, extent and map the contamination. Document recommends excavation with landfarming as the preferred method of remediation. ADEC requested workplan submittal detailing schedule for proposed further sampling and remediation at site. All excavation, sampling, and remediation must be done under a workplan that has prior approval by DEC. |
Vic Vickaryous |
4/28/1994 |
Site Added to Database |
TPH contamination in soil and groundwater. |
Louis Howard |
2/14/1995 |
Update or Other Action |
Scope of Work CR LRRS DBWT-92-79902 Biopile Construction. Background: In FY93 the 611 CES/CEOR observed 3 areas obviously contaminated and stained with POL products. These areas are located between the old POL Fill Stand (ST09) and the beaver pond near the beach area. The old POL Fill Stand (ST09) and the Drum Storage Area (SS14) near the beach area were included into the FY93 work plan. The two areas which are contaminated with POL were to be stockpiled in Cell No. 1 and Cell No. 2 which were constructed in FY93. The extent of POL contamination from the Drum Storage Area (SSI4) was delineated in FY94 and approximately 1152 cubic yards of soils was placed into Cell No. I. The extent of contamination at the POL Fill Stand area (ST09) was delineated during FY94, but was not excavated due the expanded scope of the project. The original estimate of contaminated soil was approximately 20 cubic yards. The new estimate of POL contaminated soils is approximately 1000 cubic yards.
The 900 cubic yards of diesel contaminated soil associated with the UST @ Lower Camp (SS15) had been stockpiled after the removal of the UST in 1991. These soils were taken out of the temporary stockpile and placed into Cell No. 3. In addition, the POL contaminated soil associated with Waste Accumulation Area No. 3 (SS08) was also placed in Cell No. 3.
The excavation and stockpiling of POL contaminated soils is detailed in the Cape Romanzof LRRS Investigation, Delineation, and Excavation of Contaminated Soil Report prepared by the 611 CES/CEOR (Feb 95). In addition to the contaminated soil which was excavated and stockpiled from the Drum Storage Area (SS14), Waste Accumulation Area No. 3 (SS08), and the soils associated with the UST @ Lower Camp (SS15), include the Installation Restoration Program (IRP) sites listed below in the FY95 soil stockpiling/soil remediation (biopile) field work. The soils at these sites were found to be contaminated with POL above Alaska Department of Environmental Conservation (ADEC) cleanup standards.
ST09 Truck Fill Stand-1,000 cubic yards, SS07 Waste Accumulation Area No. 1-2,100 cubic yards.
The Waste Accumulation Area No. l (SS07) and the POL Truck Fill Stand (ST09) will be excavated by the 6ll CES/CEOR. The soils will be field screened for PCBs before excavation and then screened for POL. If PCBs are detected in the soils, a sampling grid will be set up to determine the extent of PCB contamination. Soils found to be contaminated with PCBs above regulatory limits will be stockpiled separately and will not be included in the biopile. Excavation will continue until field screening indicates all contaminated soil has been removed. Confirmation samples will also be taken from the limit of the excavation by the contractor and analyzed for Alaska Method AKI01 (GRO), AKI02 (DRO), and EPA Method 8020 (BTEX), 7000 (metals), and 8080 (organochlorine pesticides and PCBs).
Two passive type biopiles will be designed and constructed near the beach area for the remediation of POL contaminated soils from the Drum Storage Area (SS14) and the POL Truck Fill Stand (ST09). These biopiles may utilize a wind generated blower system due to the lack of electrical power. Two biopiles will be designed and constructed at the Lower Camp area. One new cell (Cell No. 4) will be constructed adjacent to Cell No. 3. The contaminated soil from Cell No. 3 will be placed in Cell No. 4. Cell No. 3 will be retrofitted as a biopile. These two biopiles will use an electrical powered blower system. These biopiles will include soils from the diesel contaminated soil associated with spill site SS15, Waste Accumulation Area No. 1 (SS07), and Waste Accumulation Area No. 3 (SS08). |
Louis Howard |
6/16/1995 |
Site Ranked Using the AHRM |
Initial ranking. Action code added because it wasn't when the site was originally ranked. |
John Halverson |
8/20/1995 |
Cleanup Plan Approved |
Ray Burger approved ex-situ treatment in a biocell for contaminated soils from SS15, ROM-12 (SS14), and ROM-1 (SS08). The contaminated soil originated from five areas. These areas are: SS07 Waste Accumulation Area No 1 (Lower Camp),
SS08 Waste Accumulation Area No 3 (Lower Camp), ST09 POL Fill Stand (Beach area), SS14A Drum Storage Area (Beach area), and SSl5 Old UST Site (Lower Camp).
Soil from SS08 and SS15 has already been excavated and is being stored in Cell #3. Soil from SS14A has already been excavated and is being stored in Cell #1. Soil from SS07 and ST09 will be excavated under this project. An additional Cell #2 has already been constructed, but not yet filled. The contractor will construct an additional bioremediatlon Cell #4.
The cells will be converted into ex-situ bioremediation cells and cell existing one new constructed. Soils will be bioremediated for two years. At that time, closure sampling will take place If the sampling results are below the Alaska Department of Environmental Conservation (ADEC) matrix level A, they will be returned to the land surface within the LRRS. NOTE: Level A= 50 mg/kg gasoline range organics, 100 mg/kg diesel range organics, 2000 mg/kg residual range organics, 0.1 mg/kg benzene, and 10 mg/kg total BTEX.
If the sampling reveals levels above the level A, the Air Force will reevaluated the project This reevaluation may include continual operation of the biocells, alternate technology, or negotiation of alternate cleanup levels.
Introduction: In the fall of 17%, Elmendorf AFB contracted construction of a biopile treatment facility to evaluate effectiveness of using that technology to treat petroleum contaminated soils, The 11 CEOS proposed biopile is based on this study. Construction: Current soil containment cells and future soil containment cells statewide will be constructed to provide a double-lined cell with secondary containment, leachate detection, leachate collection systems, and vent piping.
Vacuum extraction piping, water/nutrient addition piping, thermocouples (to record core temperature), and tensiometers (to measure soil moisture content) will be placed in each cell as they are constructed. Access ports will be constructed to allow sampling. An equipment unit housing (similar to a connex box) will be constructed to house vacuum/air injection equipment and water/nutrient addition equipment which will in turn be connected to perforated piping within the pile.
Sampling: Monthly inspections will evaluate biopile performance. They will include operating the vacuum extraction/injection system and collecting LEL, 02, and C02 measurements from sampling points. Total volatile organics will be measured at the vent tubes during periods of air injection. Temperature and moisture content will be monitored.
Design:
(1) Biopiles (soil piles with mechanical addition of air, water, and nutrients) are used to treat soil when available space is limited. Soil is stockpiled onto a non-reactive liner and an internal piping system introduces water, nutrients, and oxygen. Soil is sometimes mixed with an organic bulking agent such as sawdust, gypsum, or clean soil to improve soil texture and moisture potential and to provide a carbon and nutrient source.
(2) A vapor extraction/venting system provides oxygen to the bacteria and can remove
nondegradable organics in the vapor phase that can be easily removed via an air emission treatment system in a short period of time. Biopiles require no mechanical tilling or agitation. Monitoring of biopile systems will be largely automated.
(3) The design is based on a successful biopile system in Montreal, Canada. This technology was used to create a biopile system at Elmendorf AFB where it was observed for four months. Microbial biodegradation of contaminants in the soil is accomplished through using forced air as an oxygen source. This process provides oxygen to indigenous soil microorganisms, promoting aerobic mineralization of organics and simultaneously stripping some volatile compounds from the soil. |
Ray Burger |
11/11/1995 |
Update or Other Action |
Engineering Evaluation/Cost Analysis for Soil Remediation at CR LRRS prepared by the US Army Corps of Engineers. The U S Air Force is preparing to bioremediate petroleum contaminated soils (about 5500 cubic yards total) at the Cape Romanzof Long Range Radar Site (LRRS). After a review of feasible alternatives, ex-situ bioremediation was selected for this project The main contaminants are diesel range petroleum hydrocarbons and gasoline range petroleum hydrocarbons BTEX is also present along with minor amounts (<5 mg/kg) of PCBs. The intent of the bioremediation is to treat the DRO, GRO, and BTEX components in the soil. No treatment will be performed on the PCBs or lead. Testing for PCBs and lead will only be performed to ensure that the levels in the soil do not exceed regulatory requirements.
PCB treatment is not within the scope of this project. It is assumed, based on past sampling, that any PCBs will be under the regulatory limit of 10 mg/kg. If testing reveals PCB levels over 10 mg/kg, the soil will be left in the ground and addressed under a separate contract action.
The contaminated soil originated from five areas. These are:
SS07 Waste Accumulation Area No 1 (Lower Camp), SS08 Waste Accumulation Area No 3 (Lower Camp), ST09 POL Fill Stand (Beach area), SS14A Drum Storage Area (Beach area), SSl5 Old UST Site (Lower Camp).
Soil from SS08 and SS15 has already been excavated and is being stored in Cell #3. Soil from SS14A has already been excavated and is being stored in Cell #1. Soil from SS07 and ST09 will be excavated under this project. An additional Cell #2 has already been constructed, but not yet filled. The contractor will construct an additional bioremediatlon Cell #4.
The cells will be converted into ex-situ bioremediation cells and cell existing one new constructed. Soils will be bioremediated for two years. At that time, closure sampling will take place If the sampling results are below the Alaska Department of Environmental Conservation (ADEC) matrix level A, they will be returned to the land surface within the LRRS. NOTE: Level A - DRO 100 mg/kg, GRO, 50 mg/kg, BTEX 10 mg/kg, benzene 0.1 mg/kg, RRO 2,000 mg/kg.
If the sampling reveals levels above the level A, the Air Force will reevaluated the project This reevaluation may include continual operation of the biocells, alternate technology, or negotiation of alternate cleanup levels. |
Ray Burger |
3/18/1996 |
Update or Other Action |
Decision Document Declaration received for SS07, SS08, ST09, SS14, SS15 Ex-situ Bioremediation of POL Soils. The document presents the selected removal action for the ex-situ bioremediation of soil contaminated with petroleum, oils, and lubricants (POL) at Cape Romanzof LRRS. The Alaska Department of Environmental Conservation has participated in the scoping and review of the EE/CA and concurs with the selected ex-situ bioremediatlon alternative. All comments have been addressed, and a copy of them are enclosed in Appendix E of the EE/CA. The final EE/CA revealed ex-situ cell bioremediation of POL contaminated soil as the most protective of human health and the environment as well as the most cost effective.
ASSESSMENT OF THE SITE
The 611 CES performed a Removal Action to remove soil contaminated with POL at three IRP sites ±n FY94. The contaminated soil from SS08, SS14,and SS15 was placed In two soil containment cells. The contaminated soil from SS07 and ST09 will be excavated as part of this RA. One cell is located at the Lower Camp and the other is located near the beach. The cell near the beach contains contaminated soil excavated from SS14, while the cell at the Lower Camp contains soil from SS08 and SS15. A potential long-term health risk to humans and the environment exists. The petroleum contaminated soil poses a threat to on-site workers and visitors through ingestion and dermal contact. This removal action will reduce the concentrations of contaminants in the soil and therefore eliminate the risk of future exposure to human and ecological receptors.
DESCRIPTION OF THE SELECTED REMEDY
The removal action alternative chosen was excavation and ex-situ bioremediation. Contaminated soil at the Truck Fill Stand (ST09) and at Waste Accumulation Area No. 1 (SS07} will be excavated. The contaminated soils will be transported to the treatment site for bioremediation. The excavated soils will be sampled and analyzed for levels of Polychlorinated Biphenyls, Diesel Range Organics, Gasoline Range Organics, total and individual Benzene, Toluene, Ethylbenzene, Xylenes, and lead prior to being placed in the treatment cells. Contaminated soil currently stored in the containment cells will be removed and treated by ex-situ bioremediation. Signed by David Peters, Lt Col, USAF, Commander, 611th CES/CC March 18, 1996. |
Ray Burger |
1/9/1998 |
Update or Other Action |
Management Action Plan: Currently there are several ongoing or planned remedial actions (RAs), including: In 1998, a drum collection and removal program is planned as SS07 (WAA No. 1 - Spill/Leak No. 1 and 2).
Response Schedules: The schedule for the various sites at Cape Romanzof LRRS include the following activities: A drum removal will take place at SS07 (WAA No. 1 - Spill/Leak No. 1 and 2) in 1998 and a no further remedial action planned (NFRAP) is anticipated in 1999. |
Louis Howard |
10/16/2000 |
Meeting or Teleconference Held |
Staff met with communities of Chevak, Scammon Bay, Hooper Bay, Paimuit in Anchorage. Also present were the 611 CES-Environmental project manager, Community relations staff and the 611 CES Environmental Program Chief, U.S. Fish and Wildlife Service, Alaska Community Action on Toxics, Yukon-Kusko Health staff. Community members called for the meeting to be updated on what has happened at the facility, present and future work. Also they wished to be informed on any possible effects of contamination 15 miles upriver from their seasonal fish camps on the beach below the facility and the contamination present at the facility. |
Louis Howard |
5/23/2001 |
Update or Other Action |
Staff reviewed and commented on the draft proposed plan which covers 10 sites which includes this one. Staff concurred with the removal of drums and monitored natural attenuation as the preferred alternative listed in the document. DP11: Add text which states ADEC concurrence regarding the Air Force's request for no further action was granted by ADEC in a 1993 letter. This document (Proposed Plan) formalizes that no further action decision. LF02: Add text which states ADEC concurrence regarding the Air Force's request for no further action was granted by ADEC in a 1993 letter. This document (Proposed Plan) formalizes that no further action decision. LF12: Add text which states ADEC concurrence regarding the Air Force's request for no further action was granted by ADEC in a 1993 letter. This document (Proposed Plan) formalizes that no further action decision.
OT06: Please clarify where the asbestos came from in the asbestos landfill that was observed, staked and placarded. Add text which states ADEC concurrence regarding the Air Force's request for no further action was granted by ADEC in a 1993 letter. This document (Proposed Plan) formalizes that no further action decision. SS01: Add text which states ADEC concurrence regarding the Air Force's request for no further action was granted by ADEC in a 1993 letter. This document (Proposed Plan) formalizes that no further action decision. SS10: Change text to state: The rationale for this alternative is that cleanup levels were not exceeded in the groundwater, which would allow for it to be used for drinking water. Add text which states ADEC concurrence regarding the Air Force's request for no further action was granted by ADEC in a 1993 letter. This document (Proposed Plan) formalizes that no further action decision. OT05 :Add text which states ADEC concurrence regarding the Air Force's request for no further action was granted by ADEC in a 1993 letter. This document (Proposed Plan) formalizes that no further action decision.
For SS07, SS08 and LF12: Please conduct a detailed analysis of alternatives for each site. This analysis would consist of an assessment of individual alternatives against each of nine evaluation criteria and a comparative analysis that focuses upon the relative performance of each alternative against those criteria. The nine evaluation criteria are as follows:
(A) Overall protection of human health and the environment.
Alternatives shall be assessed to determine whether they can adequately protect human health and the environment, in both the short- and long-term, from unacceptable risks posed by hazardous substances, pollutants, or contaminants present at the site by eliminating, reducing, or controlling exposures to levels established during development of remediation goals consistent with Sec. 300.430(e)(2)(i).
(B) Compliance with ARARs. The alternatives shall be assessed to determine whether they attain applicable or relevant and appropriate requirements under federal environmental laws and state environmental or facility siting laws or provide grounds for invoking one of the waivers under paragraph (f)(1)(ii)(C) of this section.
(C) Long-term effectiveness and permanence. Alternatives shall be assessed for the long-term effectiveness and permanence they afford, along with the degree of certainty that the alternative will prove successful.
D) Reduction of toxicity, mobility, or volume through treatment. The degree to which alternatives employ recycling or treatment that reduces toxicity, mobility, or volume shall be assessed, including how treatment is used to address the principal threats posed by the site.
(E) Short-term effectiveness. The short-term impacts of alternatives shall be assessed.
(F) Implementability. The ease or difficulty of implementing the alternatives shall be assessed.
(G) Cost.
(H) State acceptance. Assessment of state concerns may not be completed until comments on the RI/FS are received but may be discussed in the proposed plan issued for public comment. The state concerns that shall be assessed include the following: (1) The state's position and key concerns related to the preferred alternative and other alternatives; and (2) State comments on ARARs or the proposed use of waivers.
(I) Community acceptance. This assessment includes determining which components of the alternatives interested persons in the community support, have reservations about, or oppose. |
Louis Howard |
9/23/2002 |
Update or Other Action |
Clean Sweep Remedial Action Report received for work performed under contract#F41624-01-C-8072.
Project information indicated that 55 gallon drums and other sized containers were originally stored at Waste Accumulation Area No. 1 (SSO7). The drums were subsequently scattered across the tundra throughout the Fowler Creek drainage area. During a previous site inspection in August of 2001, a total of 177 drums were identified both within and adjacent to the Fowler Creek Drainage Area.
Cape Romnanzof drum recovery activities were conducted in September and October 2001. The
project scope of work included recovery, screening, and disposal of drums and containers from within the Fowler Creek Drainage area, and to collect representative environmental samples to
characterize and delineate potential impacts from contaminants. Previous site inspections
identified approximately 177 drums and containers located within and adjacent to the Fowler Creek Drainage Area. Drum counts were approximated because some drums were partially
intact, partially buried and/or covered with snow.
The drum recovery crew consisted of 8 local residents of Paimniut and Scammon Bay and a
supervisor from Anchorage. During this project 183 drums and containers were identified. This included 167 drums located within the Fowler Creek Drainage Area and 16 drums determined to be located outside the drainage area.
Of the 167 drums within the drainage area, a total of 148 drums and containers were located and
marked, screened, recovered and disposed of at the Cape Romnanzof landfill. A total of 16 drums
and containers were located and marked but could not be removed by hand. Drums and containers that required machinery for removal were not part of this scope of work.
Of the 148 drums and containers that were removable by hand, 140 were determined to be empty
or only held vegetation, sediment or water, and were disposed of on-site. Eight drums contained
a small amount of water with sheen. The contents of these eight drums were consolidated into
one new recovery drum. The eight empty drums were disposed of on-site.
The consolidated liquid in the recovery drum, approximately 30 gallons, was sampled and analyzed for Oil Burning Specifications. Two separate samples were collected and submitted to
the laboratory for analysis and each time the laboratory could not conduct the analysis because the samples contained too much water. The recovery drum and contents were processed by Energy Recovery Services Inc. I ~~Environmental assessment samples were collected from drum location areas to evaluate potential contaminants. A total of 27 samples, including 3 duplicate samples, were collected and analyzed for fuel and metal analytes.
Representative soil samples were collected randomly from drum location areas to determine levels of various contaminants of concern. Sampling areas included locations visible container indentations, areas with no indentations, and areas adjacent to surface water. A total of 27 soil samples, including 3 duplicates, were submitted to CT&E Laboratory in Anchorage AK.
DRO and RRO compounds were detected at all sample locations. DRO levels ranged from 40 to 2,500 mg/Kg. RRO compounds ranged from 144 to 9,320 mg/Kg.
A total of 68 semi-volatile hydrocarbon compounds were analyzed for SVOCs per EPA method 8270. No SVOC compounds were detected in any of the samples.
Sample #CR4 had a GRO level of 14 mg/Kg. None of the other samples had detectable levels of GRO compounds. Note: the most stringent ADEC cleanup level for GRO is 50 mg/Kg.
Toluene was detected in sample CR4 at a level of 0.041 mg/Kg. The most stringent ADEC soil cleanup level for Toluene is 69 mg/Kg. Xylene was detected in sample #CR14S at 0.055 mg/KG. The most stringent ADEC soil cleanup level for Xylene is 69 mg/Kg.
Sample #CR148 had detectable levels of Naphthalene, sec-Butylbenzene, l,2,4-Trimethylbenzene, and 1,3,5-Trimethylbenzene. There are no published ADEC soil standards for sec-Butylbenzene, 1 ,2,4-Trimethylbenzene, or 1,3,5-Trimethylbenzene. Napthalene was detected at 0.28 mg/Kg. The most stringent ADEC soil cleanup level for Napthlene is 38 mg/Kg.
No metals were detected above detection limits in any of the samples except for Barium. The RCRA allowable TCLP for Barium is 100 mg/L. The highest Barium level measured was from sample
#CR22 at 0.59 mg/L.
Total lead levels at two locations exceeded the HUD soil lead guidelines of 400 mg/Kg for residential and 1,000 mg/Kg for industrial. Sample #CR55 had a lead level of 418 mg/Kg; sample #CR1 18 had a lead level of 4,460 mg/Kg. Total lead concentrations for all other samples ranged from 2.7 to 151 mg/kg.
No PCB compounds were detected in any of the samples. |
Louis Howard |
7/21/2004 |
Update or Other Action |
Solid Waste Program SiteID: 1651, Permit: SWG0307004 issued 7/21/2004 expires 1/31/2008. Wastes: Inert, municipal, ash, RACM asbestos, non-RACM asbestos, sludge. Category: Class 3 (camp), Application received for renewal under GP SWG0307000. |
Louis Howard |
11/16/2004 |
Update or Other Action |
File number issued 2526.38.005 |
Aggie Blandford |
3/15/2006 |
Update or Other Action |
2005 Supplemental Investigation Report for SS007 dated February 2006 received. Work planned for SS07 in 2005 consisted of collecting approximately 10 co-located soil samples at 5 locations within the area that had elevated TPH levels in 1990 to assess the
nature and level of contamination present. The samples were to be collected at/or near surface and at least 1 foot below ground surface at each sample site in order to determine the extent of any possible contamination. The samples were to be analyzed for
DRO/RRO and PAHs.
Deviations from work plan. Initial site inspection in the fall of 2005 revealed that the site of the historic fuel spills at SS07 had been extensively reworked and covered over. Heavy equipment tracks were still visible along the surface where the soil had been
reworked According to site personnel, the sampling area of SS07 had become a solid waste disposal area for building debris in 2004. A placard at the site confirms the existence of the disposal area and date of its inception.
An estimated 15-25 feet of material now covers SS07. The debris/soil lift extends laterally approximately 40-100 feet from the sampling site. The amount and extent of material now covering SS07 precluded the collection of any soil samples at the 5 predetermined locations. 4 soil samples were collected at the toe of the disposal area and down gradient of SS07.
Site Summary and Recommendations The 4 samples collected at the toe of the disposal area were analyzed for DRO and PAHS. DRO was detected in the 4 samples and 2 of the samples had concentrations above 250 mg/kg the ADEC regulatory limit for migration to groundwater (Sample 001 301 mg/kg and 002 479 mg/kg). The potential sources for further contamination (fuel tanks and drums) have been removed. SS07 is also a debris disposal site and has been surveyed, designated a disposal site, and is managed and maintained by the 611 CES/CEVQC according to applicable solid waste regulations.
Recommendations include allowing the existing low levels of DRO contamination to naturally attenuate without monitoring and a No Further Response Action Planned (NFRAP) decision with ADEC’s standard caveat: "ADEC reserves all of its rights, under AS 46.03 (and where applicable : 18 AAC 78 &/or 18 AAC 60), and 18 AAC 75 to require the Air Force to conduct additional site assessment, remediation, and/or other necessary actions at SS07 if information becomes available that contamination is present which poses a risk to human health or safety, welfare, or the environment." |
Louis Howard |
4/4/2007 |
Update or Other Action |
The Alaska Department of Environmental Conservation (ADEC), Contaminated Sites Federal Facilities Restoration Program, received the draft Proposed Plan on March 21, 2007 via electronic mail for review and comment. ADEC has the following comments described below.
General Comments-Unless it is demonstrated that the ingestion pathway for soil is completely eliminated, the use of inhalation cleanup levels may be inappropriate. ADEC requests clarification on why the Air Force is not using ingestion cleanup levels (i.e. diesel range organics-DRO 10,250 mg/kg) since it has identified potential complete exposure pathways (i.e. ingestion and dermal contact from SURFACE SOIL) for several sites where use of inhalation cleanup levels (i.e. DRO 12,500 mg/kg) are used. ADEC requests the Proposed Plan include definitions for surface soil (means soil that extends no more than two (2) feet below the surface) and subsurface soil (soil that is more than two feet below the surface).
ADEC requests the Air Force change the text to read: “Petroleum detections at the four subject sites do not pose unacceptable risk to human health or the environment. However, because petroleum detections at three of the sites (ST009, SS014, and DP011) are above levels allowing unrestricted use under Alaska’s contaminated site regulations, institutional controls (ICs) are proposed for these sites. The final actions proposed by USAF under Alaska’s contaminated site regulations are: conditional closure with groundwater/surface water monitoring for ST009, conditional closure with ICs for SS014 and DP011, and unconditional closure for SS007.”
The text states: "The State of Alaska concurs with the actions proposed in this Plan." ADEC requests the Air Force revise the text to read: "The State of Alaska’s final acceptance of the actions proposed in this Plan will be evaluated following public comment.”
Page 9 - The text states: “If the cleanup level applied to a site is higher than the ADEC Method Two soil cleanup level or Table C groundwater cleanup level, the State of Alaska may require ICs to restrict the site from unprotected uses.” ADEC requests the Air Force change the text to state: “If the cleanup level applied to a site is higher than the ADEC Method Two soil cleanup level or Table C groundwater cleanup level, the State of Alaska will require ICs to restrict the site from unprotected uses and ensure that any excavated contaminated soil is properly managed.”
Surface Water and Sediments Page 9 - The text states: “Although there are no sediment cleanup levels established in regulation, Alaska water quality regulations (18 AAC 70) state that sediment contamination may not cause adverse effects on aquatic life.” ADEC requests the Air Force change the text to read: “Although there are no sediment cleanup levels established in the State’s contaminated site regulations, Alaska water quality regulations (18 AAC 70) state that sediment contamination may not cause adverse effects on aquatic life.”
Institutional Controls Pages 9 and 10 - The text states: “USAF will implement, monitor, maintain, and enforce the ICs identified below in accordance with Alaska state regulations.” ADEC requests the Air Force change the text to read: “USAF will implement, monitor, maintain, and enforce the ICs identified below in accordance with Alaska’s contaminated site regulations.”
The text states: “The purpose of the ICs is to help prevent the future handling of petroleum-contaminated soil inconsistent with State of Alaska regulations.” ADEC requests the Air Force change the text to read: “The purpose of the ICs is to help prevent the future handling of petroleum-contaminated soil inconsistent with State of Alaska’s contaminated site regulations.”
Proposed Remedy Page 15 - The text states: “Under Alaska State regulations, unconditional site closure is proposed for Site SS007, because contamination at the site is below levels allowed in Alaska State regulations, and the site does not pose unacceptable potential risk to human health or the environment.” ADEC requests the Air Force change the text to read: “Under Alaska’s contaminated site regulations, unconditional site closure is proposed for Site SS007, because contamination at the site is below levels allowed in Alaska’s contaminated site regulations, and the site does not pose unacceptable potential risk to human health or the environment.”
|
Louis Howard |
12/18/2007 |
Update or Other Action |
Draft Record of Decision received for Spill/Leak 1 & 2 (SS007),
Spill/Leak 3 (ST009), Drum Storage Area (SS014), and Dump Area (DP011). There are no CERCLA hazardous substances identified as chemicals of concern (COCs) at the four subject sites of this ROD. The only COCs are constituents of petroleum products (i.e.,
diesel-range organics [DRO] and gasoline-range organics [GRO]) and are therefore excluded as CERCLA hazardous substances under the CERCLA petroleum exclusion. As there are no
CERCLA COCs, a no action response is the appropriate and selected remedy for these sites under CERCLA.
This ROD is issued by the United States Department of the Air Force (USAF) in accordance with and satisfying the requirements of the Defense Environmental Restoration Program (ERP),
10 United States Code (USC) 2701 et seq.; CERCLA 42 USC 9601 et seq.; Executive Order 12580, 52 Federal Register 2923 (23 January 1987); National Contingency Plan (NCP), 40 Code
of Federal Regulations 300. The U.S. Environmental Protection Agency (EPA) has been consulted consistent with the requirements of 10 USC 2705 and has chosen to defer to the Alaska Department of Environmental Conservation (ADEC) for regulatory oversight at Cape Romanzof LRRS.
Because petroleum substances are COCs under State of Alaska laws and regulations, the four subject sites are being addressed under those applicable laws and regulations, including but not
limited to Title 46 of the Alaska Statutes and regulations promulgated thereunder.
This ROD is issued by the USAF in accordance with the regulations promulgated under the Alaska Oil and Hazardous Substance Pollution Control Act, 18 Alaska Administrative Code
(AAC) 75 (as amended through December 30, 2006). By signing this Declaration, the State of Alaska concurs with the selected remedies.
In 2005 a focused Remedial Investigation showed that Site SS007 is covered by approximately 15 to 25 feet of disposal material, and DRO is present in soil (at the toe of the disposal area) at concentrations slightly above the ADEC Method Two cleanup level. However, the detected concentrations do not pose unacceptable potential risk to human health or the environment.
DRO were detected in all four samples at concentrations between 38 mg/Kg (Sample 004) and 479 mg/Kg (Sample 002). Two of the four DRO detections were slightly above the ADEC Method Two cleanup level of 250 mg/Kg (protective of the migration to
groundwater pathway) (479 mg/Kg in Sample 002 and 301 mg/kg in Sample 001). However, all DRO detections were significantly below the cleanup levels protective of inhalation and ingestion (10,250 mg/Kg).
Risk calculations were not performed for SS007, because no COPCs have been identified at SS007. Although it is not known whether DRO levels in the soil at Site SS007 itself exceed Method Two inhalation or ingestion cleanup levels, the site is buried under
15 to 25 feet of disposal material so there would be no complete exposure pathway to any contamination, even if it were present.
SS007 became a solid waste disposal area for building debris in 2004. As such, it is being managed by the Air Force in accordance with 18 AAC 60. Solid Waste regulations with all the required monitoring and institutional controls.
Spill/Leak 1 & 2 (SS007) Unconditional Site Closure-No action is necessary under State of Alaska Regulations at Site SS007. There are no COCs at this site. Unconditional closure will be noted in ADEC and USAF records. The land is available for unrestricted use. |
Louis Howard |
12/27/2007 |
Document, Report, or Work plan Review - other |
Staff reviewed and commented on the Draft Record of Decision SS007, ST009, SS014, DP011, Cape Romanzof LRRS dated December 2007. 1.4.2 Remedies Selected Under State of Alaska Regulations Spill/Leak 3 (ST009) Conditional Site Closure with Groundwater/Surface Water Monitoring and ICs
Page 1-6
ADEC requests adding another Remedial Action Objective (RAO) which describes land use restrictions at ST009: d) Land use at the facility will remain as the current land use (minimally-attended radar system) with temporary residents only. (Same comment applies to Drum Storage Area (SS014) Conditional Site Closure with ICs Page 1-7, Dump Area (DP011) Conditional Site Closure with ICs Page 1-9.)
2. Institutional Controls (ICs) Page 1-6
ADEC requests adding an additional bullet for implementing ICs at ST009: • Future land use will remain the same as the current land use at the facility which is industrial use with temporary residents.
(Same comment applies to ST009, DP011 and SS014).
Sect 2.7.4.1 Cleanup Levels Page 2-16
(SS09) Text states that a site-specific ADEC Method Three cleanup level of 12,500 mg/kg was selected for DRO based on the maximum allowable cleanup levels and that it is protective of ingestion/inhalation. ADEC requests the text describe the land use scenario/assumptions associated with the cleanup level accordingly.
Example language: "The Method Three cleanup level represents the maximum allowable DRO cleanup levels under Alaska regulations; the cleanup level is protective of the ingestion and inhalation pathways at ST009, based on industrial land use with temporary residents."
Page 2-18
The second bullet item states: DRO were detected in three of the five groundwater samples at concentrations of 4.14 mg/L (MW-9), 3.09 mg/L (MW-7), and 0.635 mg/L (MW-8). All of the detections were below the ten times Table C cleanup level of 15 mg/L, but the MW-7 and MW-8 concentrations exceeded the Table C cleanup level of 1.5 mg/L.
ADEC requests the text to reflect MW-9 and MW-7 concentrations exceeded the Table C cleanup level of 1.5 mg/L. MW-8 DRO concentrations at 0.635 mg/L do not exceed the Table C cleanup level of 1.5 mg/L.
Sect 2.7.5.1 Cleanup Levels Page 2-19
(SS14) Text refers to the maximum allowable levels for DRO/GRO as the cleanup levels and states they are protective of ingestion/inhalation pathways. ADEC requests the text specify the land use scenario/assumptions (i.e. based on industrial use with temporary residents).
Example language: "The Method Three cleanup levels represent the maximum allowable DRO and GRO cleanup levels under Alaska regulations; these cleanup levels are protective of the ingestion and inhalation pathways at SS014 based on industrial land use with temporary residents."
Sect 2.7.6.1 Cleanup Levels Page 2-21
(DP011) Text refers to a site specific ADEC Method Three cleanup level of 1,200 mg/kg for DRO was calculated and selected for soil at DP011. The text also states the levels are protective of ingestion/inhalation pathways at DP011. ADEC requests the text specify the land use scenario/assumptions (i.e. based on industrial use with temporary residents).
Example language: "This cleanup level is protective of the ingestion and inhalation pathways at DP011 based on industrial land use with temporary residents."
2.15.2.1 Protection of Human Health and the Environment Page 2-40
The text states: “However, ICs are required and selected to restrict land use at ST009 and SS014 to ensure compliance with the exposure assumptions in the risk assessment (i.e., no subsurface activities that would allow exposure to subsurface soil and no groundwater use for water supply at ST009).”
ADEC requests adding text as follows: “However, ICs are required to restrict land use at ST009 and SS014 to industrial use with temporary residents to ensure compliance with the exposure assumptions in the risk assessment….”
|
Louis Howard |
2/1/2008 |
Update or Other Action |
Solid Waste Permit Number SWGPLRRS-13 issued on 02/01/2008 expires on 01/31/2013. |
Louis Howard |
2/20/2008 |
Exposure Tracking Model Ranking |
Initial ranking with ETM completed. |
Louis Howard |
2/27/2008 |
Record of Decision |
John Halverson (ADEC) signed the final version of the Record of Decision (ROD) for 4 sites: Spill/Leak 1 & 2 (SS007), Spill/Leak 3 (ST009), Drum Storage Area (SS014), and Dump Area (DP011) at the Cape Romanzof Long Range Radar Site (LRRS). Spill/Leak 1 & 2 (SS007): Spill/Leak 1 & 2 is located at a former waste accumulation area (Waste Accumulation Area No. 1) near the shop area adjacent to the power plant for Lower Camp. This site has also been known as Waste Accumulation Area No. 1 and ROM-3. All of the buildings have since been removed from this area. Some of the waste materials reportedly stored at the waste accumulation area included oils, hydraulic fluids, toluene, paints, and ethylene glycol.
Site investigation activities discovered petroleum contamination in the soil at this site. The
source of the petroleum contamination is probably drum leakage and a large diesel fuel spill that reportedly occurred but was not well-documented.
Remedies Selected Under CERCLA-
No action is necessary under CERCLA to protect public health or welfare or the environment at
Spill/Leak 1 & 2 (SS007), Spill/Leak 3 (ST009), Drum Storage Area (SS014), and Dump Area
(DP011).
No action is necessary under State of Alaska Regulations at Site SS007. There are no COCs at
this site. Unconditional closure will be noted in ADEC and USAF records. The land is available
for unrestricted use.
This ROD documents the decision made for Four ERP sites: Spill/Leak 1 & 2 (SS007),
Spill/Leak 3 (ST009), Drum Storage Area (SS014), and Dump Area (DP011), located at Cape
Romanzof LRRS, Alaska. By signing this declaration the ADEC concurs with the Air Force's
selected remedies.
The decision may be reviewed and modified in the future if new information becomes available
that indicates the presence of contaminants or exposures that may cause unacceptable risk to
human health or the environment. If additional contaminants are discovered, USAF and ADEC
will determine the compliance levels for soil and groundwater cleanup actions. |
John Halverson |
2/27/2008 |
Cleanup Complete Determination Issued |
John Halverson (ADEC) signed the final version of the Record of Decision (ROD) for 4 sites: Spill/Leak 1 & 2 (SS007), Spill/Leak 3 (ST009), Drum Storage Area (SS014), and Dump Area (DP011) at the Cape Romanzof Long Range Radar Site (LRRS). No action is necessary under CERCLA to protect public health or welfare or the environment at Spill/Leak 1 & 2 (SS007), Spill/Leak 3 (ST009), Drum Storage Area (SS014), and Dump Area (DP011).
No action is necessary under State of Alaska Regulations at Site SS007. There are no COCs at
this site. Unconditional closure will be noted in ADEC and USAF records. The land is available
for unrestricted use.
This ROD documents the decision made for Four ERP sites: Spill/Leak 1 & 2 (SS007),
Spill/Leak 3 (ST009), Drum Storage Area (SS014), and Dump Area (DP011), located at Cape
Romanzof LRRS, Alaska. By signing this declaration the ADEC concurs with the Air Force's
selected remedies.
The decision may be reviewed and modified in the future if new information becomes available
that indicates the presence of contaminants or exposures that may cause unacceptable risk to
human health or the environment. If additional contaminants are discovered, USAF and ADEC
will determine the compliance levels for soil and groundwater cleanup actions. |
Louis Howard |
11/6/2009 |
Update or Other Action |
Note: If you are looking for information about this site prior to 2004, check file number 2526.38.000, marked Cape Romanzof General Inormation/Correspondence. This file contains documents that may pertain to all of the Cape Romanof sites before they were established as individual sites. |
Natalie Loescher |