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Site Report: Wildwood AFS Operations Building Facility Former ASTs/USTs Area

Site Name: Wildwood AFS Operations Building Facility Former ASTs/USTs Area
Address: 3.5 Mile North Kenai Road, Wildwood Drive, Kenai, AK 99611
File Number: 2320.38.051
Hazard ID: 25213
Status: Active
Staff: Erica Blake, 9074512182 erica.blake@alaska.gov
Latitude: 60.606809
Longitude: -151.286961
Horizontal Datum:WGS84

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

Problems/Comments

Two 15,000 gallon ASTs and two 15,000 gallon USTs previously existed at the Operations Building Facility east and southeast of Building 101 . The tanks were used to supply diesel fuel to the facility's generator, and were removed prior to the start of the RI.During 1997, approximately 345 cubic yards of petroleum contaminated soil was removed from the former AST/UST area. The work was conducted in two excavation phases, and was directed based on interim sampling results. Final excavation dimensions were approximately 45 feet by 26 feet by 8 feet deep. The excavation was backfilled with clean fill. Confirmation soil samples were collected from the excavation. DRO remained in soil at the base of the excavation at 8 feet bgs; concentrations ranged from 1,210 to 3,770 mg/kg.Based on available information, DRO contaminated soil exceeding the cleanup target was removed down to the groundwater table. DRO contamination above the cleanup target remained in the smear zone in 1997. DRO contamination in groundwater exceeded the cleanup target. Contaminants of Concern: The contaminant of concern remaining in soil at this source area is DRO. Contaminants of concern remaining in groundwater at this source area are DRO and TRPH.

Action Information

Action Date Action Description DEC Staff
4/18/1996 Site Added to Database (Date adjusted from 11/10/1999 for report/query consistency. (Reese)) John Halverson
4/18/1996 Proposed Plan The Corps finalized the proposed plan. Preferred alternatives included: Main Complex tank farm and USTs 5-1 and 5-2 - vapor extraction and air sparging; Maintenance Building, ACS MARS, Quonset Hut and Disposal Trench Area Burn Pit - soil excavation and off-site treatment followed by no further action; Operations Building - excavation and off-site treatment followed by natural attenuation and institutional controls; Landfill and Disposal Trenches - capping, natural attenuation (landfill area only) and institutional controls. John Halverson
6/3/1996 Update or Other Action Received a groundwater monitoring report for tank farm area from sampling in August 1995. It covered the main complex area tank farm and USTs (significant fuel contamination), ACS/MARS facility (low level DRO), Operations Building (DRO and low TEX), Landfill (low level VOCs) and Trench disposal areas (DRO and benzene at burn pit area). John Halverson
8/27/1996 Update or Other Action Received the December 1995 groundwater monitoring event report. The Operation Building area contained DRO up to 20 mg/l and low level TEX in GW. John Halverson
12/9/1997 Update or Other Action Received the groundwater monitoring report for sampling done in July 1997. Groundwater levels have dropped significantly, some MWs have gone dry. Operations Building (up to 6 mg/l DRO) in groundwater. John Halverson
5/15/1999 Update or Other Action Received groundwater monitoring report for sampling done in July 1998. Operations building (DRO low levels, need new wells in better locations). John Halverson
9/3/1999 Interim Removal Action Approved ADEC received "Remedial Action Report, Phase II Remediation" by Harding and Lawson/Wilder, dated August 25, 1999. The report documents cleanup work done between June 1997 and November 1998. Operations Building - transformer area and drum storage area have residual DRO contamination; transformer casing and concrete sent to landfill. John Halverson
9/3/1999 Update or Other Action ADEC received "Remedial Action Report, Phase II Remediation" by Harding and Lawson/Wilder, dated August 25, 1999. The report documents cleanup work done between June 1997 and November 1998. Operations Building - transformer area and drum storage area have residual DRO contamination, former AST/UST area has residual fuel contamination; transformer casing and concrete sent to landfill. John Halverson
2/24/2000 Site Ranked Using the AHRM Initially ranked as High Priority however, the actual AHRM scores comes up Low Priority. John Halverson
2/3/2005 Update or Other Action File number issued 2320.38.051 Aggie Blandford
6/2/2005 Site Characterization Workplan Approved A work plan for Site Characterization and Attenuation Monitoring was approved with minor comments. The work plan describes the planned investigation to delineate further the locations of remaining NAPL at the various source areas within the former Wildwood AFS using the Rapid Optical Screening Tool (ROST), Laser-Induced Fluorescence (LIF). It includes sampling and analysis to calibrate the results of the ROST LIF work and to further characterize contaminant nature and obtain data with which to evaluate the status of each source area using current Method II and III tools, and possibly a 4-phase partitioning model. Sampling and analysis will also obtain data with which to evaluate natural attenuation occurrence at each source area. Debra Caillouet
6/21/2005 Meeting or Teleconference Held Staff visited all of the Wildwood sites with the new project manager and the environmental engineer for the site. Staff also observed the ROST/LIF in operation. Debra Caillouet
6/15/2007 Update or Other Action The Declaration of Project Closure Decison for the CON/HTRW project at Wildwood was signed. Debra Caillouet
9/5/2007 Update or Other Action Staff reviewed and prepared comment on No DOD Action Indicated Report, Wildwood AFS, F10AK0251 HTRW Project 03, Draft July 07 The report summarizes the actions and data for twelve areas of concern at the former Wildwood Air Force station that are located at the High Frequency Facility, ACS MARS facility, Operations Building Facility, Rifle Range, Firing Range, Main Complex, and the Main Drum Storage Area. Comments on the draft document are being provided on the attached table. In general, DEC agrees with the conclusions to close these sites after the appropriate public comment period with the exception of the High Frequency Facility where the data supports a Conditional Closure. Debra Caillouet
9/5/2007 Site Characterization Report Approved The ROST/LIF Investigation, Former Wildwood Air Force Station, Revision 1, April 2007 Report was reviewed and approved. The report presents the results of the investigation at multiple areas within the former Wildwood AFS during the summer of 2005. The logs from the ROST/LIF are presented along with laboratory analysis results. The report provides valuable site characterization data to support future decisions and generally meets the requirements of 18 AAC 75.335 Site Characterization. Debra Caillouet
9/25/2008 Site Added to Database A new site has been added to the database Mitzi Read
9/26/2008 Exposure Tracking Model Ranking Initial ranking with ETM completed for source area id: 78528 name: Former ASTs/USTs Area Debra Caillouet
11/16/2009 Site Characterization Workplan Approved Final Work Plan, Soil Assessment and Groundwater Monitoring of Non-Tank Farm Sites, Former Wildwood Air Force Station, Kenai, November 2009 will sample soil and groundwater at the site. Debra Caillouet
6/4/2010 Document, Report, or Work plan Review - other 2009 Report Soil Assessment and Groundwater Monitoring of Non-Tank Farm Sites Former Wildwood Air Force Station, FUDS The results of the chemical analyses were compared to Table C of the ADEC 18 AAC 75.345, Oil and Hazardous Substances Pollution Control. DRO and GRO results reported in the 1995 RI (field-laboratory results) and the results from the 2009 sampling event are compared in Figure 5-1. Complete analytical results (Table B7) and a sample tracking table (Table B1) are presented in Appendix B. Groundwater sample results are summarized below. • DRO was detected in one well, AST-MW10 (AP-503), at a concentration (3,800 µg/L) that exceeded the ADEC cleanup level (1,500 µg/L), located directly downgradient of the former ASTs. The two wells located further downgradiant had DRO concentrations detected below the cleanup level. • GRO was detected in all wells one to two orders of magnitude less than the ADEC cleanup level (2,200 µg/L). Although the DRO concentration in well AST-MW10 (3,800 µg/L) exceeds the groundwater cleanup level (1,500 µg/L), it has decreased significantly since the removal of 345 cubic yards of POL-contaminated soil from the AST area in 1997. The DRO concentration measured in 2009 was two orders of magnitude less than the concentration identified in the nearby RI sample location (AP-503). It is presumed that the concentration will continue to decrease over time through natural attenuation processes. Furthermore, the two downgradient wells, AST-MW8 (AP-446) and AST-MW9 (AP-507), were below the DRO cleanup level in the 2009 groundwater sampling event, which indicates limited contamination migration. Debra Caillouet
4/20/2015 Site Characterization Workplan Approved Follow-up Investigation Work Plan, Additional UVOST Delineation, Soil Sampling and Well Installation, Wildwood Partly Mitigated Sites Project 04 was approved. Additional characterization will be performed to support site closure decisions. Debra Caillouet
7/20/2015 Site Characterization Report Approved Follow-Up Investigation Report, Additional UVOST Delineation, Soil Sampling, and Well Installation, Wildwood AFS Partly Mitigated Sites Project 04, Formerly Used Defense Site, F10AK-25104, Kenai Alaska, Draft June 2015 ADEC approves the report as additional site characterization. Debra Caillouet
7/10/2017 Document, Report, or Work plan Review - other Received the Summer 2016 Groundwater Sampling Report, dated January 2017 for the Wildwood Former Air Force Station Operation Facility Formerly Used Defense Site – F10AK025104. The described field effort was completed in August 2016 and generally consisted of collecting water samples from three monitoring wells (MW-1, MW-2, and MW-3). The sample collected from Well MW-2 exhibited a concentration of diesel range organics (DRO) at 2.3 mg/l, which exceeds the Table C groundwater cleanup level of 1.5 mg/l. Samples results from all other wells were either not detected above laboratory method detection limits, or were present at concentrations below Table C levels. Revised report requested by September 2017. Joshua Barsis
7/10/2017 Document, Report, or Work plan Review - other Reviewed the Groundwater Sampling Work Plan Addendum, dated June 2017. This work plan covers the planned groundwater monitoring at the Wildwood Former Air Force Station Tank Farm Formerly Used Defense Site – F10AK025105 and the Wildwood Former Air Force Station Operation Facility Formerly Used Defense Site – F10AK025104. Proposed activities mainly include sampling nine wells (MW-3, MW-4, MW-6, MW-11, MW-16, MW-23, MW-24, MW-30, and AP-397) at the tank farm site and three wells (MW01, MW02, and MW03) at the operations building facility former storage tanks location. Joshua Barsis
9/12/2017 Document, Report, or Work plan Review - other Reviewed the Soil Removal and Confirmation Sampling Plan, dated September 6, 2017 for the Wildwood AFS Operations Building Facility Former ASTs/USTs Area. Proposed activities generally consist of additional source area excavation. ADEC has some concerns about the effectiveness of this proposed event. ADEC requested a revised work plan by October 15, 2017 Joshua Barsis
10/10/2017 Document, Report, or Work plan Review - other Reviewed the Soil Removal and Confirmation Sampling Plan, dated October 10, 2017 for the Wildwood AFS Operations Building Facility Former ASTs/USTs Area. This work plan is a revised version to the September 6, 2017 plan. Issued approval letter. Joshua Barsis
10/25/2017 Document, Report, or Work plan Review - other Received the final versions of two reports; the Annual 2016 Groundwater Sampling Report for the Operations Facility (F10AK025104) and the Annual 2016 Groundwater Sampling Report for the Tank Farm (F10AK025105), both dated October 2017. Joshua Barsis
1/17/2018 Document, Report, or Work plan Review - other Reviewed the Soil Removal and Confirmation Sampling Report, dated January 10, 2018 for the Wildwood AFS Operations Building Facility Former ASTs/USTs Area. Activities completed during the 2017 effort included excavating test pits in the AST/UST areas and collected a total of three analytical soil samples; Samples AST1-2 and AST1-3 from the former AST area, and Sample UST-NE from the former UST area. All samples were collected from just above or at the smear zone. Sample AST1-2 was collected from 2 feet below ground surface (bgs), just above the smear zone and had a DRO concentration of 831 mg/kg. Sample AST1-3 was collected from the same hole as AST1-2, but from 3 feet bgs (closer to the water table) and exhibited a concentration of DRO at 40,400 mg/kg. Sample UST-NE was collected from 2 feet bgs, just above the smear zone, and had a DRO level of 772 mg/kg. Although planned for the 2017 season, excavation, stockpiling, confirmation soil sampling, and offsite disposal were not completed because of the high water level. Final version of report is dated March 16, 2018. Joshua Barsis
2/6/2018 Document, Report, or Work plan Review - other Reviewed the 2017 Groundwater Sampling Report, dated December 2017 for the Wildwood Former Air Force Station Operation Facility Formerly Used Defense Site – F10AK025104. The report described field effort was completed in August 2017 and consisted of collecting water samples from three monitoring wells (MW-1, MW-2, and MW-3). The sample collected from Well MW-3 exhibited a concentration of diesel range organics (DRO) at 3.9 mg/l, which exceeds the Table C groundwater cleanup level of 1.5 mg/l. Samples results from all other wells were either not detected above laboratory method detection limits, or were present at concentrations at or below Table C levels. ADEC requested a revised report by May 1, 2018. Joshua Barsis
2/12/2018 Document, Report, or Work plan Review - other Reviewed the Groundwater Sampling Work Plan Addendum, dated February 2018. This work plan covers the planned groundwater monitoring at the Wildwood Former Air Force Station Tank Farm Formerly Used Defense Site – F10AK025105 and the Wildwood Former Air Force Station Operation Facility Formerly Used Defense Site – F10AK025104. Proposed activities mainly include sampling nine wells (MW-3, MW-4, MW-6, MW-11, MW-16, MW-23, MW-24, MW-30, and AP-397) at the tank farm site and three wells (MW01, MW02, and MW03) at the operations building facility former storage tanks location. Joshua Barsis
7/11/2018 Document, Report, or Work plan Review - other Reviewed the Groundwater Sampling Work Plan Addendum, dated February 2018. This work plan covers the planned groundwater monitoring at the Wildwood Former Air Force Station Tank Farm Formerly Used Defense Site – F10AK025105 and the Wildwood Former Air Force Station Operation Facility Formerly Used Defense Site – F10AK025104. Proposed activities mainly include sampling nine wells (MW-3, MW-4, MW-6, MW-11, MW-16, MW-23, MW-24, MW-30, and AP-397) at the tank farm site and three wells (MW01, MW02, and MW03) at the operations building facility former storage tanks location. Joshua Barsis
8/6/2018 Document, Report, or Work plan Review - other Reviewed the 2018 Soil Removal and Confirmation Sampling Plan Amendment, dated August 2, 2018 for the Wildwood AFS Operations Building Facility Former ASTs/USTs Area. This plan is an amendment to the last version of the plan, the Soil Removal and Confirmation Sampling Plan, dated October 10, 2017. The 2018 plan includes provisions for dewatering. ADEC submitted comments on the plan, requesting additional info, on August 6, 2018. The final plan was approved on August 22, 2018. Joshua Barsis
11/14/2018 Document, Report, or Work plan Review - other Reviewed the 2018 Groundwater Sampling Report, dated September 2018 for the Wildwood Former Air Force Station Operation Facility Formerly Used Defense Site – F10AK025104. The report described field effort was completed in August 2018, and consisted of collecting water samples from three monitoring wells (MW-1, MW-2, and MW-3). The sample collected from Well MW-2 exhibited a concentration of diesel range organics (DRO) at 2.2 mg/l, which exceeds the Table C groundwater cleanup level of 1.5 mg/l. Sample results from all other wells were either not detected above laboratory method detection limits, or were present at concentrations below Table C levels. Joshua Barsis
2/25/2020 Document, Report, or Work plan Review - other Reviewed the 2019 Groundwater Sampling Report, dated July 2019 for the Wildwood Former Air Force Station Operation Facility Formerly Used Defense Site – F10AK025104. The report described field effort was completed in June 2019, and consisted of collecting water samples from three monitoring wells (MW-1, MW-2, and MW-3). The sample collected from Well MW-2 exhibited a concentration of diesel range organics (DRO) at 1.24 mg/l, which is slightly below the Table C groundwater cleanup level of 1.5 mg/l. Sample results from all other wells were either not detected above laboratory method detection limits, or were present at concentrations below Table C levels. This report is approved. ADEC agrees with the recommendation for continued groundwater monitoring at this site. Joshua Barsis
6/16/2020 Site Characterization Workplan Approved The department approved a workplan to conduct annual groundwater sampling at the Former Tank Farm and Operations Building AST/UST, and to install two new monitoring wells in the 12-acre landfill and 1 new monitoring well at UST 502-1. Three wells MW-1, MW-2, and MW-3 from the Operations Building Facility Former ASTs/USTs area will be sampled and the samples will be analyzed for BTEX, GRO, and DRO. Lisa Krebs-Barsis
6/16/2020 Site Characterization Workplan Approved The department approved a workplan to conduct groundwater sampling at the Former Tank Farm and Operations Building AST/UST, 12-acre landfill, and UST 502-1. Three wells installed during the 2015 field effort (MW-1, MW-2 and MW-3) will be sampled and analyzed for BTEX, GRO, and DRO. Lisa Krebs-Barsis
7/28/2021 Document, Report, or Work plan Review - other Reviewed work plan to remove 100 cubic yards of material from the former ASTs/USTs area. Comments sent on 7-28-21. NALEMP project. Lisa Krebs-Barsis
8/20/2021 Site Characterization Report Approved ADEC reviewed the 2020 Groundwater Sampling Report for the Former Tank Farm, Operations Building Former ASTs/USTs, 12-acre landfill, and UST 502-1. At the Operations Building Former ASTs/USTs, MW-1, MW-2, and MW-3 were sampled for GRO, DRO, and BTEX. DRO was detected in MW-1 at a concentration of 3.46 mg/L significantly above the Decision Document criteria of 1.5 mg/L. DRO was also detected in MW-2 at a concentration of 1.82 mg/L slightly above Decision Document criteria. For MW-3, the DRO concentration detected was of 1.11 mg/L slightly below the Decision Document criteria. No other compounds were detected above Decision Document criteria in any well. Lisa Krebs-Barsis
8/26/2021 Site Characterization Workplan Approved The 2021 and 2022 Groundwater Sampling Work Plan Addendum for the Former Tank Farm, Operations Building Former ASTs/USTs, 12-acre Landfill and UST 502-1 received on August 25, 2021 is approved.In 2021 at the Operations Building Former ASTs/USTs MW-1, MW-2and MW-3 will be sampled and analyzed for DRO after the 2021 NALEMP removal action occurs. In 2022 MW-1, MW-2 and MW-3 will be sampled and analyzed for DRO. Lisa Krebs-Barsis
9/2/2021 Site Characterization Workplan Approved Approved Kenaitze Indian Tribe NALEMP work plan to remove up to 100 cy of contaminated soil from this site east and southeast of the former Building 101. Soil will be sampled for lead and DRO. Soil will be sampled for GRO and DRO. If appropriate soil waste will be transported to ASR. Lisa Krebs-Barsis
8/3/2022 Document, Report, or Work plan Review - other A NALEMP Draft Report for the Removal of Contaminated Soil at the Operations Building Former ASTs/USTs was reviewed. The report included work done at other hazard id. Approximately 140 cubic yards of material was excavated and segregated into 4 stockpiles. Groundwater was found at 6 ft bgs in the excavation. Excavation sidewalls were sampled and analyzed for DRO, GRO, and VOC. Contamination remained in situ at up to 5,980 mg/Kg and GRO at 473 mg/Kg. Napthalene, 1,2,4-trimethylbenzene, and 1,3,5-trimethylbenzene exceeded cleanup levels as well. Two stockpiles comprising 20 cubic yards were determined to be clean by sampling and were left on site for reuse. Two stockpiles comprising 119 cubic yards were dirty and were transported to Soil Treatment Technologies in Nikiski. Lisa Krebs-Barsis
12/30/2022 Document, Report, or Work plan Review - other DEC reviewed the 2021 Groundwater Sampling Report, Wildwood AFS Formerly Used Defense Site (FUDS), Property F10AK0251, Dated October 2022. Comments were sent to USACE. Daniela Fawcett
5/25/2023 Document, Report, or Work plan Review - other DEC approved the Final Groundwater Sampling Work Plan Addendum, Wildwood AFS Former Tank Farm, Operations Building Former ASTs/USTs, 12-acre Landfill, and UST 502-1-, and Third-Party Waiver Request, dated April 2023. The work plan describes the scope of work for the sampling of groundwater monitoring wells at the Former Wildwood Air Force Station (AFS) Operations Facility, 12-acre Landfill, and Underground Storage Tank (UST) 502-1. Groundwater will be analyzed for diesel-range organics (DRO) at the Operations Facility and at the at the former UST 502-1. At the 12-acre landfill groundwater will be sampled for vinyl chloride. The work plan included a waiver request under 18 AAC 75.390(b) for the requirement in 18 AAC 75.333(b)(1) that a qualified environmental professional (QEP) be an impartial third party. DEC approved the Third-Party Waiver Request. Ginna Quesada
7/12/2023 Document, Report, or Work plan Review - other DEC provided comments for the Draft Work Plan Subsurface Soil Investigation at the Operations Building Former ASTs/USTs Wildwood Remediation FUDS# F10AK0251 Kenai, Alaska, dated June 2023. The work plan describes the subsurface investigation activities planned at the Former Wildwood Air Force Station (AFS) Operations Facility located in Kenai, Alaska. The investigation will be focused on defining the extent of remaining contamination around the sidewalls of a 2021 excavation. Soil will be analyzed for diesel-range organics (DRO), volatile organic compounds (VOCs) and 1,2,4- and 1,3,5- trimethylbenzene (TMB). Ginna Quesada
7/20/2023 Document, Report, or Work plan Review - other DEC approved the Final Work Plan Subsurface Soil Investigation at the Operations Building Former ASTs/USTs Wildwood Remediation FUDS# F10AK0251 Kenai, Alaska, dated July 2023. The work plan describes the subsurface investigation activities planned at the Former Wildwood Air Force Station (AFS) Operations Facility located in Kenai, Alaska. The investigation will be focused on defining the extent of remaining contamination around the sidewalls of a 2021 excavation. Soil will be analyzed for diesel-range organics (DRO), volatile organic compounds (VOCs) and 1,2,4- and 1,3,5- trimethylbenzene (TMB). Ginna Quesada
9/11/2023 Document, Report, or Work plan Review - other DEC submitted responses to comments for the Draft Work Plan Removal of Contaminated Soil at the Operations Building Former ASTs/USTs, Wildwood Remediation FUDS# F10AK0251 Kenai, Alaska, dated August 2023. Ginna Quesada
2/23/2024 Document, Report, or Work plan Review - other DEC reviewed the 2022 Groundwater Sampling Report Wildwood AFS Formerly Used Defense Site (FUDS) Property F10AK0251 HTRW Project -05 Former Tank Farm, CON/HTRW Project -06 Operations Building Former ASTs/USTs, HTRW Project -07 12-acre Landfill, and CON/HTRW Project -08 UST 502-1 Kenai, AK, dated June 2023. The report describes the 2022 groundwater monitoring event at the former Tank Farm, 12-acre Landfill, UST 502-1, and at the Operations Building Former ASTs/USTs sites located at the Wildwood Air Force Station, Alaska. The report recommends continued monitoring at the Operations Building and 12-acre Landfill and project closeout after the remaining sampling events. Reduced sampling frequency is proposed at the Tank Farm and the decommissioning of groundwater monitoring wells and project close out for the UST 502-1 site. Ginna Quesada
4/5/2024 Document, Report, or Work plan Review - other DEC has reviewed and approved the 2022 Groundwater Sampling Report Wildwood AFS Formerly Used Defense Site (FUDS) Property F10AK0251 HTRW Project -05 Former Tank Farm, CON/HTRW Project -06 Operations Building Former ASTs/USTs, HTRW Project -07 12-acre Landfill, and CON/HTRW Project -08 UST 502-1 Kenai, AK, dated June 2023. The report describes the 2022 groundwater monitoring event at the former Tank Farm, 12-acre Landfill, Underground Storage Tank (UST) 502-1, and at the Operations Building Former Aboveground Storage Tanks (ASTs) /USTs sites located at the Wildwood Air Force Station, Alaska. The report recommends continued monitoring at the Operations Facility and 12-acre Landfill and project closeout for the UST-502-1 site. Brian Watts
7/9/2024 Site Visit DEC staff conducted a site visit to the Wildwood AFS area in Kenai, Alaska. The purpose of the site visit was to inspect multiple sites within the Wildwood Air Force Station and observe groundwater monitoring fieldwork. Sites inspected were; 12-acre Landfill, disposal trench area, Underground Storage Tank (UST) area near the Correctional Facility, and the Operations Maintenance Building. U.S. Army Corp of Engineers staff accompanied DEC staff around the facility for the inspection. Peter Campbell
7/29/2024 Update or Other Action DEC provided the U.S. Army Corp of Engineers with a letter summarizing site inspection notes from a July 9, 2024 site visit at various Wildwood AFS sites. The letter described several deviations from the approved work plans (dated 2016 and 2023), and requested USACE discuss impacts of the deviations and issues in the reporting. Erica Blake

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