| Action Date |
Action |
Description |
DEC Staff |
| 4/3/2006 |
Update or Other Action |
Letter from ADEC to DOD re: State of Alaska Department of Environmental Conservation's Expectations of the Munitions Response Site Prioritization Protocol Program.
The Alaska Department of Environmental Conservation (ADEC) wishes to thank you for the opportunity to participate in the application of the Munitions Response Site Prioritization Protocol (MRSPP) to Military Munitions Response Program (MMRP) sites throughout Alaska. We feel that active participation and cooperation between DOD, ADEC, EPA and other stakeholders is critical to ensuring the success of the program.
The MRSPP is a congressionally mandated rule developed by the Department of Defense (DOD) to prioritize munitions response sites for cleanup under the Defense Environmental Restoration Program and Base Realignment and Closure acts. As such, we understand DOD is the lead agency responsible for cleanup and that State involvement in application of the protocol is primarily a support role. However, the closure of sites under CERCLA and state environmental regulations will require State and/or the US Environmental Protection Agency (EP A) concurrence.
To this end, ADEC is requesting that you and your contractors submit for review and comment the various work plans and documents used in the MRSPP process that correspond to applicable CERCLA documentation requirements (i.e. Preliminary Assessment, Site Investigation, Remedial Investigation, Feasibility Study, Engineering Evaluation/Cost Analysis, etc.). This request applies to all documents already generated in implementing the initial stages of the protocol as well as those that are yet to be generated under the MRSPP process.
We are making this request to provide for credible, legally defensible site characterization and evaluation in the MRSPP process while at the same time providing for efficient and timely State review. Review of historical records, work plans and reports and other supporting documents will allow the project team to ensure that the information gathered is consistent throughout the installations and State and that the appropriate information is gathered to make informed decisions. As sites are investigated, it is likely that several will require additional sampling due to unexpected circumstances. Review and approval of documents as the process moves forward will help minimize information or data gaps that may otherwise develop.
In the long run, concurrent review and approval of various documents will help reduce costs to DOD through a collaborative decision making process which ensures that site characterization, remedial assessment, and remedial actions are consistent with state and federal regulations. As these documents would need to be reviewed prior to 'no further action' decisions, review during the MRSPP process will allow remedial action and/or final status decisions to be made in an expedited manner. Likewise, up-front regulatory acceptance should lead to faster agreement on site prioritization and appropriate, timely implementation of remedial actions.
The final MRSPP rule requires DOD to notify stakeholders of the opportunity to participate in the application of the protocol. For those that have notified us and begun the process, we again thank you for the opportunity to assist with the application of the MRSPP in Alaska and look forward to working with you toward its completion. For those that have not started the process, this letter serves as a reminder of this requirement and gives you some idea of what the State of Alaska will be expecting out of this process.
Signed
John Halverson, Environmental Program Manager
|
John Halverson |
| 8/14/2007 |
Update or Other Action |
ADEC John Halverson sent letter to Lt. Col. Hodges - 3 CES RE: Reporting discovery of Munitions and Explosives of Concern (MEC) and EOD response activities to DEC
The Alaska Department of Environmental Conservation (DEC) requests that DOD components establish and implement reporting procedures for discovery of Munitions and Explosives of Concern (MEC) and Explosive Ordnance Disposal (EOD) response activities that occur outside active military ranges within Alaska. In the past, numerous ordnance items have been found and EOD response actions implemented without proper reporting to and coordination with DEC. Most recently, an article appeared in the Fairbanks News Miner regarding an unexploded munitions item discovered along the Swede Lake Trail near Paxton. The article indicates clearance activities are ongoing to determine if additional munitions items remain in the area. DEC should not have to rely on local media reports to bring these incidents to our attention.
DEC is responsible for ensuring releases of hazardous substances are adequately contained, characterized and cleaned up in a manner and to a degree that are protective of human health, safety, welfare and the environment. To accomplish this mission, laws have been created requiring hazardous substance releases be reported to, and that response actions be approved by, DEC.
Alaska laws (AS 46.09.010 / 18 AAC 75) require discharges or releases of hazardous substances be reported to DEC as soon as the person in charge of an operation or facility has knowledge of a release. Improper disposal is considered a release (46.09.900(6)).
MEC, including unexploded ordnance (UXO) and discarded military munitions, are considered hazardous substances under Alaska laws. Per Alaska statute (AS 46.09.900), "hazardous substance" means (A) an element or compound that, when it enters into or on the surface or subsurface land or water of the state, presents an imminent and substantial danger to the public health or welfare, or to fish, animals, vegetation, or any part of the natural habitat in which fish, animals, or wildlife may be found; or (B) a substance defined as a hazardous substance under 42 U.S.C. 9601 - 9657 (Comprehensive Environmental Response, Compensation, and Liability Act of 1980)”.
Additionally, Alaska laws require containment and cleanup of released hazardous substances through initial response actions (18 AAC 75.310-.320). Based on the results of initial response, DEC may require additional site characterization and cleanup under the site cleanup rules (18 AAC 75.325 - .380).
DEC recommends holding a meeting/teleconference with the appropriate DOD representatives to help establish adequate reporting procedures and coordination on response to MEC discoveries outside the boundaries of active military ranges.
Specific topics for discussion and agreement include:
1. Timely reporting of Munitions and Explosives of Concern (MEC) discovery.
2. Roles and responsibilities of entities that should be involved.
3. Submittal of Explosive Ordnance Incident Reports including information on the location of discovery, property ownership, environmental restoration program status (FUDS, active installation) if applicable, type(s) and number of items discovered, photographs of the items, proximity to populated areas, and response actions taken.
4. Consultation with DEC regarding additional response activities including land use controls, historical records reviews, site characterization and cleanup workplans.
I propose holding a meeting / teleconference it at 10:00 AM, Wednesday August 22nd in our office at 555 Cordova Street and setting up a dial in number for those that can not participate in person. Please contact me at (907) 269-7545 or john.halverson@alaska.gov or Guy Warren at (907) 269-7528 or guy.warren1@alaska.gov regarding your interest and availability at the proposed time and whether you think other people should be involved. |
John Halverson |
| 2/4/2008 |
Update or Other Action |
Letter from DOD Regional Environmental Coordinator Region 10 to ADEC Jennifer Roberts RE: Reporting on DOD Support of Explosives or Munitions Emergencies.
As the Department of Defense (DoD) Regional Environmental Coordinator (REC) for Region
10, my staff and I, along with the other Military Services, work with envITonmental and natural
resource agencies to exchange information on envITonmental topics, coordinate related projects
and initiatives, avoid cor.i!icts when possible, and help resolve issues efficiently. Our REC team appreciated the opportunity to discuss your request for notification of DoD explosives or
munitions emergency responses in support of civil authorities.
The DoD is firmly committed to assisting civil authorities, primarily those in law enforcement,
in responding in a timely and effective manner to explosives and munitions emergencies. DoD
provides this support to ensure the public safety of Alaskans and the envITonment. To continue to provide this support, we would like clarification on a couple of important issues.
First, although the DoD Explosive Ordnance Disposal (EOD) team's mission is generally limited to responding to military munitions, these teams often provide support to civil authorities when non-military explosives or munitions are encountered. When supporting requests by civil authorities, we do not believe DoD personnel are the "person in charge" pursuant to Alaska regulations for the purposes of notifying DEC. (See, e.g., 18 AAC 75.300 & 75.990(86).)
Nevertheless, as a matter of comity, but without relinquishing any legal arguments, rights or
defenses, DoD is voluntarily providing DEC the attached summary of DoD explosives or
munitions emergency responses from January through December 2007. The DoD is also willing
to discuss, if necessary, any additional reporting requests that you may have regarding DoD
explosives or munitions emergency responses in support of civil authorities. As part ofthis
discussion, DoD would like to know whether the notifications requested of DoD are the same as
those requested of other federal, state, or local emergency response personnel. (See, 42 USC
6961.)
Second, the DoD is also concerned about a provision in 18 AAC 75.315(b) that appears
to require a person who is not a responsible person, but who voluntarily undertakes an initial
response action, to perform a comprehensive cleanup. This provision is of concern to us because
DoD EOD teams voluntarily respond to all requests from civil authorities for support of an
explosives or munitions emergency regardless ofwhether a military munitions is involved,
although they are not legally required to do so.
This regulation may impose cleanup liability on DoD for its voluntary response. We would like to discuss this concern with your office and perhaps pursue a written agreement between the DEC and DoD that delineates the roles and responsibilities of each party.
I would appreciate the opportunity to further discllss our concerns with you and your
staff, and so I have asked my points of contact for this issue, Ms. Aubrey Baure and Maj Judith
Walker, to contact you in the near future.
Signed
Clare Mendelsohn DoD Regional Environmental Coordinator Region 10. |
Jennifer Roberts |
| 9/15/2008 |
Update or Other Action |
Letter from Jennifer Roberts ADEC to Ms. Clare Mendelsohn, DoD Regional Environmental Coordinator. RE: Reporting on DoD Support for Explosives or Munitions Emergencies
I received your February 4,2008 letter and apologize for not responding sooner. The Alaska
Department of Environmental Conservation (ADEC) has a long and positive working
relationship with the Department of Defense (DoD). We understand DoD's primary mission is
national defense and appreciate the emergency response support DoD voluntarily provides to
civil authorities and the public. One such area of support is responding to discoveries of
munitions or explosives.
ADEC agrees that when Explosive Ordnance Disposal (EOD) teams respond to non-military
munitions or explosives, off military lands, DOD's response personnel are not considered the
"person in charge" with respect to Alaska hazardous substance reporting and response
requirements. When conducting voluntary responses under these circumstances, ADEC does
not consider DoD to be incurring liability for complete cleanup under 18 AAC 75 .315(b). We
hope this addresses your concerns with respect to this matter. If not, we are open to pursuing a
written agreement between ADEC and DOD delineating roles and responsibilities in these
cases.
With respect to your question of whether the notifications requested of DoD are the same as
those requested of other federal, state, or local emergency response personnel, the answer is
yes. In the event of a discovery of a release on a property, the property owner, for example, the federal agency, state agency, or other owner of that property, is required to notify ADEC. In addition, ADEC's Prevention and Emergency Response Program guidance has been amended
to include cross program coordination with the Contaminated Sites Program staff whenever
such reports are received.
The 2007 EOD emergency response summary for Alaska was helpful in better understating the
scope of these actions. ADEC's concern on being notified of the discovery of military
munitions or explosives is in ensuring former ranges, training areas, and munitions storage and
disposal areas where these items may remain are identified and addressed, as necessary, to help ensure protection of human health and safety. We would like additional information on a few
ofthe responses to help determine whether further investigation is warranted and will followup
on those via email. We also are interested in receiving similar periodic (semi-annual)
summaries of EOD responses. |
Jennifer Roberts |
| 1/21/2011 |
Update or Other Action |
Draft Final Work Plan MMRP CSE Phase I/II received of which one is Tatalina LRRS. There are two areas: Training Exercise (No ID) and Unknown Area (clearing) (No ID). The Training Exercise area has unknown MEC types and activities may have included small arms, 100 acres in size, unknown dates of operation and is closed. The Unknown Area contains and unknown clearing, 50 acres in size, Approximate dates of operation was in the mid-1970s and is closed.
During the visual surveys, the field teams walk transects at a pre-determined spacing, recording
visual observations. All evidence of Munitions and Explosives of Concern (MEC) and other items of interest will be documented with photographs and GPS technology during the surveys. Two MRAs, approximately 150 acres, will be visually surveyed during the CSE Phase I/II activities at Tatalina LRRS.
XRF instruments will provide an analytical method used to detect lead in soil. A portable XRF unit will be used to analyze samples as they are collected in the field. The goal of the XRF sampling and on-site analysis is to define the vertical and horizontal extent of lead contamination in soil during the CSE Phase I/II field work. Soil sampling for lead is planned for the Training Exercise MRA, approximately 100 acres.
The final field portion of the Phase I/II consists of soil sample collection for off-site laboratory analysis. Samples will potentially be collected at the Unknown Area MRA from areas where evidence of munitions use is confirmed during the Phase I/II field visual surveys and will be analyzed dependent on the composition of the historical munitions used at the MRA. Sample locations within the MRA will be determined after all the data gathered during the field
visual surveys are evaluated. |
Louis Howard |
| 1/24/2011 |
Update or Other Action |
Staff reviewed and commented on the Draft Final CSE Phase I/II Work plan which will become merged with other project managers' comments on their facilities.
ADEC requests the AF identify the lab or laboratories it will be using for this project. ADEC also requests the AF have the lab supply a copy of their current ADEC approval letter. These letters detail the methods, matrices, & dates for which the lab has approval. Labs must renew their approval & pass performance evaluation samples annually.
4.3.5.3 Sample Identification Pages 4-13, 4-14, & 4-15
Absence of positive field screening results or those field screening results below an arbitrary threshold (field action level) cannot be used alone as justification for not taking the associated number of lab analytical samples.
ADEC does not recognize field screening data as definitive data for demonstrating compliance with cleanup levels listed in site cleanup rules (e.g. 18 AAC 75.341 Table B1 Method Two). ADEC will only accept confirmation sampling which is verified by lab analyses.
4.5 Analytical Program Page 4-17
ADEC does not support the AF skipping the required multi-incremental sampling in the field when implementing Method 8330B. ADEC requests the AF to develop site specific work plans for each MRA at each PACAF Site where multi-incremental sampling will be conducted. ADEC will require the AF to follow the ADEC Draft Guidance on Multi Increment Soil Sampling (March 2009) when developing these site-specific work plans.
7.2 Generation of Data Page 7-1
ADEC will require the Air Force to ensure that the report is prepared by a “qualified person” in accordance with 18 AAC 75.335(c).
Characterizing Metals in Soil Utilizing X-Ray Fluorescence (XRF) Spectrometry SOP SKY-100 Revision 4 (6-3-2009)
5.4.1 Page 6 of 10
ADEC will require the Air Force ensure the XRF field lead is a “qualified person” in accordance with 18 AAC 75.990(100).
Characterizing Metals in Soil Utilizing X-Ray Fluorescence (XRF) Spectrometry
SOP SKY-100 Revision 4 (6-3-2009)
2 Reference Documents Page 2 of 10
ADEC requests the Air Force incorporate and use the following guidance documents for an appropriate strategy on characterizing the extent and magnitude of lead contamination at former DoD small arms ranges.
Alaska Department of Environmental Conservation, Small Arms Range Characterization, Technical Memorandum, March 2008.
Interstate Technology and Regulatory Council, Characterization and Remediation of Soils at Closed Small Arms Firing Ranges, January 2003.
Visual Surveys
SOP SKY-200 Revision 1.0 (11/05/2008)
6. Quality Assurance and Quality Control (QA/QC)
6.1. Page 8 of 10
See comments above regarding the field lead meeting the definition of a “qualified person” in accordance with 18 AAC 75.990(100) and will supervise, in accordance with 18 AAC 75.990(125), the data collection teams.
Quality Assurance Project Plan for The Pacific Air Forces Sites in Alaska (November 2010)
Soil Sampling
SOP SKY-300 Revision 0 (11-17-2009)
5.1 Project Manager Page 3 of 7
ADEC will require the Project Manager meet the definition of a “qualified person” in accordance with 18 AAC 75.990(100) and also recognizes the PM as one who will directly supervise personnel/field team members in accordance with 18 AAC 75.990(125).
5.2 Project Scientist Page 3 of 7
and other technical standards associated with environmental sampling.” ADEC will require the Project Scientist to also meet the definition of a “qualified person” in accordance with 18 AAC 75.990(100).
5.3 Field Lead Page 3 of 7
ADEC will require the Air Force ensure the Field Lead meets the definition of a “qualified person” in accordance with 18 AAC 75.990(100). The “qualified person” is responsible for adherence to this SOP, the project specific work plan(s).
6.2.4 Incremental Samples (Composite) Page 4 of 7
ADEC will require the Air Force to conduct incremental sampling in accordance with ADEC Draft Guidance on Multi Increment Soil Sampling (March 2009). Work plans shall be site specific for each area at a PACAF Site where incremental sampling is being proposed.
Quality Assurance Project Plan for the Pacific Air Forces Sites in Alaska
QAPP Worksheet #3
Distribution List Page 7 of 67
The worksheet lists Peter Dalyrmple as the Project Sample Team Leader for Sky Research.
QAPP Worksheet #6
Communication Pathways Page 10 of 65
The worksheet lists Peter Dalyrmple as the Sampling Team Leader who will provide Daily Field Progress Reports to Suzie Kaufman and will notify him of any work stoppages.
QAPP Worksheet #7
Personnel Responsibilities and Qualifications Table Page 11 of 65
The following lists reference to personnel which duties are to oversee field activities or fulfill the duties of a “qualified person” as described in 18 AAC 75.990 (100). |
Louis Howard |
| 1/25/2011 |
Site Added to Database |
A new site has been added to the database |
Mitzi Read |
| 8/3/2011 |
Update or Other Action |
2009 Final Historical Records Research Report received. The HRR evaluated historical documents associated with the historical boundaries of Tatalina LRRS including areas that may be outside of the current boundaries of the installation.
USACE Alaska District – Anchorage, AK – The USACE Alaska District in Anchorage, AK was contacted as a possible source of information. Two documents were found that were related to Tatalina LRRS. The map Real Estate, Tatalina Long Range Radar Site, Military Reservation did not contain MMRP information. A second document Environmental Assessment for Brim Frost 89 Exercise Specified Areas of Alaska was obtained. It was undated; however, it appears to reference a training exercise for forces in Alaska. BRIM FROST 89 was one in a series of biennial joint readiness exercises conducted in Alaska to ensure the combat readiness of forces based in Alaska and the continental United States. The following information was obtained:
- Training Exercise – Under BRIM FROST 89, Tatalina LRRS was an area which “will be used for three days by approximately 300 troops with tents, 6 snow machines, and two tracked vehicles. C-130 aircraft will be used for insertion and extraction of troops. Small units will perform patrols in the area of the radar site and personnel will establish site defense positions that will be removed prior to departure. No live ammunition will be used, blanks and pyrotechnics only.”
Aerial Photographs
• Aerial photographs from 1976 and 2000 were obtained and reviewed. In the September 1976 and July 1983 aerial photographs, a clearing is visible southeast of the lower camp, north of the road. By the time of the 2000 aerial photograph, two rectangular features are visible within the clearing. Although this feature does not correspond with any landfills identified in the Administrative Record, it displays features similar to areas that have been identified as landfills. Therefore, this area is not included as a feature of interest. The features of interest found on the historic aerial photographs include:
- Unknown Area 1 – In the September 1976 and July 1983 aerial photographs, a clearing is visible southeast of the lower camp, south of the road. This feature does not correspond with any landfills (as identified in the Administrative Record) and appears to contain a structure at the southern end. The feature appears to be the location of a small arms range. By the time of the 2000 aerial photograph, the apparent structure has been removed and the clearing is becoming overgrown.
The HRR identified potential MRAs that are not associated with the FUDS Program. As a result,
a CSE Phase I should be completed to determine if additional MRAs are present at Tatalina
LRRS. The following table summarizes the MMRP areas for Tatalina LRRS based on a review
of the documents collected for this HRR-SC Report:
Potential MMRP Site Estimated Acreage Comments
Training Exercise To be Determined (TBD) (Location Unknown): Under BRIM FROST 89, Tatalina LRRS was an area which “small units will perform patrols in the area of the radar site and personnel will establish site defense positions that will be removed prior to departure. No live ammunition will be used, blanks and pyrotechnics only.”
Unknown Area 1 TBD In the September 1976 aerial photograph, a clearing is visible southeast of the lower camp, south of the road. This feature does not correspond with any landfills (as identified in the Administrative Record) and appears to contain a structure at the southern end. The feature appears to be the location of a small arms range. By the time of the 2000 aerial photograph, the apparent structure has been removed and the clearing is becoming overgrown.
TOTAL ACRES TBD
Figure 3 presents the location of the potential MRA, Unknown Area 1. The location of the
potential MRA (Training Exercise) was not known and therefore, was not included in Figure 3. |
Louis Howard |
| 8/3/2011 |
Update or Other Action |
2011 Draft Final Historical Records Review received. 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.
Training Exercise Area
The initial research conducted in support of the ITSI 2009 Report identified one MMRP site that was to be used during a biennial joint readiness exercise named Brim Frost 89. Under Brim Frost 89, Tatalina LRRS was to be used for three days by approximately 300 troops with tents, six snow machines, and two tracked vehicles. C-130 aircraft were to be used for the insertion and extraction of troops. Small units were to perform patrols in the area of the radar site and personnel were to establish site defense positions that would be removed prior to departure. No live ammunition was to be used; however, blanks and pyrotechnics were to be used. The exact location of the use of the blank ammunition and pyrotechnics is unknown.
Additional research regarding Brim Frost 89 was conducted in support of this HRR. However, no specific information regarding the operations that may have been conducted at Tatalina LRRS was found. Brim Frost 89 was scheduled to involve 26,000 troops, 120 aircraft, and 1,000 vehicles from the U.S. Army, Air Force, Marines, Coast Guard, National Guard, and reserve units. In addition, Canadian Forces were scheduled to participate. However, the Canadian Forces withdrew following the crash of one of their transport planes in which nine servicemen were killed (AKAF00079). In addition, extreme cold temperatures forced the cancellation of some activities (AKAF00080). As a result of these changes, it is not known if the planned operations actually took place at Tatalina LRRS.
Unknown Area 1
The initial research conducted in support of the ITSI 2009 Report identified an area referred to as Unknown Area 1. Review of aerial photographs from September 1976 and July 1983 identified a clearing southeast of the Lower Camp, south of the road. This feature did not correspond with any landfills (as identified in the Administrative Record) and appeared to contain a structure at the southern end. The feature appeared to be the location of a small arms range. By the time of the 2000 aerial photograph, the apparent structure had been removed and the clearing was overgrown (ITSI 2009 Report). Figure 4-1 depicts the location of Unknown Area 1 (AKAF00093).
No additional information regarding the use of Unknown Area 1 was identified, and there
is no indication that there was a release of MEC or MC at this location.
Summary of MRAs Identified at Tatalina LRRS
Potential Munitions Response Area
Training Exercise Area: HRR Acreage-TBD, munitions used: Small arms blanks, pyrotechnics
No additional information was obtained regarding the specific operations conducted during use of the Training Exercise Area. The location of the site is unknown. Further munitions response
activity may be required.
Unknown Area 1 HRR Acreage: TBD Munitions Used: Small arms, No further information was
obtained regarding the specific operations conducted at Unknown Area 1. Further
munitions response activity may be required. |
Louis Howard |
| 5/31/2013 |
Update or Other Action |
Draft CSE Phase I/II received.
The Training Exercise Area was not located or confirmed to exist based on actual findings during fieldwork activities. No potential future actions
There was no evidence of any munitions related activities associated with the Training Exercise Area and it is no longer considered as a potential MRA
The small arms use at the recreational small arms use area is recreational in nature and the area is not classified as a non-operational (or operational) range; therefore, it is not eligible for investigation under the USAF MMRP. The data provided in this report regarding the recreational small arms use area are for informational purposes only.
Based on the results of the CSE Phase I/II investigation, the Unknown Area 1 would have been split into two MRSs. Most of the Unknown Area 1 would have been recommended for NFA. The southern extent of the Unknown Area 1 would have been recommended for further action due to the elevated levels of lead present in the soil, if the area was eligible for investigation under the USAF MMRP.
Information was collected to support completion of the MRSPP; however, MRSPP worksheets were not completed because the Unknown Area 1 was not eligible for investigation under the USAF MMRP.
Thirty-two soil samples were collected and analyzed at an off-site analytical laboratory, using USEPA methods for lead and antimony, as warranted, at Unknown Area 1. The samples were distributed as follows: 19 soil samples (0-6 inches), 12 soil samples (6-12 inches), and one soil sample (12-18 inches). Lead was detected in all of the soil samples with concentrations ranging from 9.5 mg/kg to 1,200 mg/kg. Antimony was detected in seven soil samples with concentrations ranging from 0.47 mg/kg to 2.7 mg/kg. Individual lead detected values were compared to the ADEC and USEPA human health soil screening values.
The soil sample with a lead concentration of 1,200 mg/kg appears to be an isolated occurrence with adjacent samples, including one deeper sample from the same location, all showing concentrations less than 400 mg/kg. It is possible that the high concentration was caused by a small lead fragment that was entrained in the sample, and the reported result may not represent a larger area of contamination.
No surface water or groundwater sampling was conducted, because there were no surface water features at Unknown Area 1 that could represent an exposure pathway, nor were there any apparent surface water to groundwater communication features present. No seeps or springs or other aquatic features potentially associated with groundwater were observed. |
Louis Howard |
| 5/31/2013 |
Exposure Tracking Model Ranking |
Initial ranking with ETM completed for source area id: 79027 name: Small Arms Firing Range |
Louis Howard |
| 6/13/2013 |
Document, Report, or Work plan Review - other |
ADEC concurs with the conclusions regarding no potential future action under the MMRP for Training Exercise Area since it was not located or confirmed to exist. ADEC also agrees the small arms use is recreational in nature and the Unknown Area 1 is not classified as a non-operational (or operational) range; therefore, it is not eligible for investigation under the USAF MMRP. ADEC reserves the right to require the Air Force to conduct additional investigation, assessment, monitoring, or remediation if new information regarding conditions at the sites indicate that further actions are necessary to protect human health, welfare, safety or the environment. |
Louis Howard |
| 8/27/2014 |
Update or Other Action |
Draft Feasibility Study received.
Through further records review, field reconnaissance, & visual surveys of Site SR001 during the CSE Phase I/II, it was concluded that Site SR001 is a former recreational small arms use area & not eligible for investigation under the USAF Military Munitions Response Program (MMRP). However, SR001 instead falls under the Compliance Restoration Program for further action.
This Feasibility Study (FS) evaluates potential remedial technologies to address metals contamination in soil at SR001. The alternatives were screened based on site-specific effectiveness, implementability, & cost.
Following final approval of this FS, the U.S. Air Force will issue a Proposed Plan, including the 5 alternatives based on the evaluations performed in this FS. Comments on the Proposed Plan will be solicited from the community & state. Following receipt of comments, the alternatives will be further evaluated based on the modifying criteria (state acceptance & community acceptance), & then a remedy will be selected for the site. The selected remedy will be documented in the Record of Decision for the site.
Alternative, Description, Cost Estimate:
Alternative 1 No Action $0
Alternative 2 Land-Use Controls & Long-Term Monitoring $263,491
Alternative 3 Capping, Land-Use Controls, & Long-Term Monitoring $972,233
Alternative 4 Debris Removal, In Situ Soil Treatment, Capping, & Land-Use Controls $1,205,488
Alternative 5 Removal & Offsite disposal $1,860,860
Soil was sampled for lead & antimony. Analytical results indicated that there is lead & antimony in surface & subsurface soil associated with activities conducted at Site SR001. Samples exhibited lead exceeding the soil cleanup level for residential areas (400 milligrams per kilogram [mg/kg]) in three locations in the berm/impact area. All results for antimony were less than the most stringent cleanup criterion. Although antimony was identified as a chemical of potential concern in the CSE Phase I/II & evaluated as a potential contributor to overall risk, site concentrations are well below both state & federal cleanup levels; the antimony results were collocated with lead.
The primary COC is lead. At this site, lead-contaminated soil is located at the firing range berm/impact area. This area measures approximately 45’ by 30’ & extends an estimated 1 foot below ground surface (bgs); it is estimated that approximately 50 cubic yards of soil are contaminated with lead. The affected volume of soil was estimated based on the ADEC Method Two cleanup criterion of 400 mg/kg for lead in residential areas.
See site file for additional information. |
Louis Howard |
| 9/17/2014 |
Document, Report, or Work plan Review - other |
Staff provided comments on the draft FS for SR001.
ADEC believes the Air Force should rewrite the document as an engineering evaluation/cost analysis (EE/CA) and conduct a non-time critical removal action under the Air Force’s CERCLA authority. This would eliminate the need to do a full Proposed Plan, Record of Decision, remedial design/remedial action. |
Louis Howard |
| 4/9/2015 |
Update or Other Action |
Draft Proposed Plan received for review and comment.
The primary chemicals of concern at SR001 are metals associated with small caliber ammunition (lead and antimony).
The antimony results were collocated with lead. Lead-contaminated soil is located at the firing range berm/impact area. This area measures approximately 45 feet by 30 feet and extends an estimated 1 foot below ground surface; it is estimated that approximately 50 cubic yards of soil are contaminated with lead.
The affected volume of soil was estimated based on the ADEC soil cleanup level for lead. There was no evidence of historical use of explosives and no munitions and explosives of concern were observed during the CSE Phase I/II; only “small arms debris” was observed during the visual survey.
Based on the information currently available, it is the Air Force’s judgment that the response actions proposed under Alternative 3, Capping, Land-Use Controls, and Long-Term Monitoring, are necessary to protect public health, welfare, and the environment from actual or threatened releases of pollutants or contaminants at SR001.
Alternative 3 offers better protection of human health and the environment than Alternative 1 (No
Action) and it has similar effectiveness, is easier to implement, and will cost less than Alternative 5 (Excavation and Offsite Disposal). Therefore, Alternative 3 meets all the RAOs outlined in this Proposed Plan. |
Louis Howard |
| 4/28/2015 |
Document, Report, or Work plan Review - other |
Staff provided comments on the proposed plan. Main comments were on the request to the Air Force to make the SR001 documents & proposed plan available electronically for those living near Tatalina LRRS. Additional comments were made regarding choosing a remedy for removing the contaminated soil and disposing of it on-site at a historical landfill/dump instead of capping it where it is currently at and having another site with land use controls. Lastly, comments were made regarding the lack document comparing each of the alternatives separately to the nine criteria: 1 Overall Protection of Human Health and the Environment, 2 Compliance with ARARs (Or justification of a Waiver), 3 Long-Term Effectiveness and Permanence, 4, Reduction of Toxicity, Mobility, or Volume Through Treatment, 5 Short-Term Effectiveness, 6, Implementability, 7 Cost, 8 State Acceptance, and 9 Community Acceptance. See site file for additional information. |
Louis Howard |
| 3/25/2016 |
Document, Report, or Work plan Review - other |
Staff provided comments on the draft ROD for SR001. Main comments were clarifying that all groundwater is a potential drinking water source regardless if it is being used or not for drinking. Other comments clarified that the excavation of lead contaminated soil will not cease at 12 inches if there is lead contamination present above 400 mg/kg just because there is a contract limit on the depth of excavation.
See site file for additional information. |
Louis Howard |
| 4/8/2016 |
Update or Other Action |
Draft WP for remedial activities at SS003, SS008, SS011, SR001 received for review and comment.
Surface munitions debris will be removed by hand, placed in drums or Super Sacks®, and
transported offsite for disposal at an appropriate facility.
Approximately 75 cubic yards of soil at locations containing lead above 400 mg/kg will be treated in-situ with a chemical stabilization product to a 12-inch depth. Analytical samples will be collected from the soil before and after treatment and analyzed for TCLP lead. This will determine whether soil should be managed and transported offsite for disposal as RCRA hazardous waste (i.e., TCLP lead results = 5 mg/L). Treated soil characterized as non-hazardous waste (i.e., TCLP lead results < 5 mg/L) will be excavated and disposed of onsite at the Tatalina LRRS permitted landfill at LF004. Treated soil characterized as hazardous waste will be excavated, placed in drums or Super Sacks®, and transported offsite for disposal at a permitted RCRA TSD facility.
Excavation will continue until analytical results from confirmation soil samples collected from
the floor and sidewalls of each excavation indicate remaining concentrations of lead are below
the ADEC cleanup level (< 400 mg/kg) or until the proposed soil volume of 75 cubic yards has
been removed (whichever is completed first). Excavations will then be backfilled with locally
available clean fill. Drums or Super Sacks® containing lead-contaminated soil will be transported to Sterling Landing and staged in a lined containment area prior to being loaded onto barges for transportation to the offsite disposal facility.
See site file for additional information. |
Louis Howard |
| 4/13/2016 |
Document, Report, or Work plan Review - other |
Staff provided comments on the draft RA CA WP for Remedial Activites at SS003, SS008, SS011, SR001.
Executive Summary
SR001 does not have a signed decision document, therefore, the work plan will be commented on and may be finalized, but it is not approved for implementation until there is a signed decision document.
SR001 – Former Recreation Small Arms Use Area
The text here will serve as a placeholder until such time the final 2016 ROD is signed. While it is not anticipated that the selected remedy in the final version will differ from what is presented here, in cases where the final ROD for SR001 and this work plan differ, the final ROD will be followed, not the work plan.
ADEC may approve the QAPP for implementation at source areas: SS003, SS008 and SS011 without holding up work awaiting the final ROD for SR001 to be signed before the QAPP is approved for
source area SR001 by ADEC to implement the selected remedy.
If unrestricted use is the goal for land use at the site, then if contamination is greater than 400 mg/kg in confirmation samples after 75 CY have been removed, then continue digging until cleanup levels are met. This comment is similar to ADEC’s comments (See ADEC March 25, 2016 letter to AFCEC) regarding depth limitation for excavation of lead contaminated soil). If the volume of lead contaminated soil is significantly greater than 50 cubic yards estimated in the Draft 2015 ROD and this results in a substantial cost increase, then an explanation of significant differences (ESD) may be warranted or institutional controls or land use controls would be required after the contractual limit of 75 cubic yards is reached with lead contamination > 400 m/kg still present at SR001.
Approximately 50 cy of lead-contaminated soil remain at the site; when excavated, the amount of soil to be disposed equates to approximately 61 cy of soil when adjusting for bulk factor (2014 Feasibility Study Section 3.1.5).
See site file for additional information. |
Louis Howard |
| 7/6/2016 |
CERCLA ROD Approved |
Kim DeRuyter signed the ROD for SR001. The remedy selected in this ROD is Alternative 6, which includes Debris Removal, In Situ Soil Treatment, and Onsite Disposal. This remedy satisfies overall protectiveness; complies with ARAR criteria; and was the most favorable alternative with respect to short-term effectiveness, implementability, and cost. The selected remedy meets the RAOs for SR001.
The selected remedy presented herein is to remove munitions debris and lead-contaminated
soil. The remedial actions conducted under the selected remedy will eliminate the potential
for human/ecological exposure and future contaminant migration of munitions debris constituents and lead-contaminated soil associated with prior site activities at SR001. Debris will be scraped from the surface and transported to an appropriate disposal facility outside of the Tatalina LRRS. Soil will be treated in situ, then excavated for disposal at LF004, an existing landfill at the Tatalina LRRS.
See site file for additional information. |
Kim DeRuyter |
| 8/28/2017 |
Update or Other Action |
In 2016, Free Flow 300® , a lead immobilization product, was added to the surface of the excavation areas associated with SR001 and mixed to 1-foot bgs with an excavator. Waste characterization samples were collected from the treated areas and were submitted for Toxic Characteristic Leaching Procedure (TCLP) for lead. All results were less than the regulated level of U.S. Environmental Protection Agency-regulated level of 5 mg/l.
Pursuant to 18 AAC 75.325(g), when detectable contamination remains on-site following a cleanup, a cumulative risk determination must be made that the risk from hazardous substances does 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.
Soil contamination at the site has been cleaned up to concentrations below the approved cleanup levels suitable for residential land use. This site will receive a “Cleanup Complete” designation.
See site file for additional information. |
Louis Howard |
| 8/28/2017 |
Cleanup Complete Determination Issued |
Soil contamination at the site has been cleaned up to concentrations below the approved cleanup levels suitable for residential land use. Based on the information provided to date, ADEC has been determined the contaminant concentrations remaining on site do not pose an unacceptable risk to human health or the environment. No further remedial action will be required unless new information becomes available that indicates residual contaminants may pose an unacceptable risk to human health, welfare, safety or the environment.
This cleanup complete determination is based on the administrative record for the SR001, which is located in the ADEC office in Anchorage, Alaska. This decision letter summarizes the site history, cleanup actions and levels, and standard site closure conditions that apply.
See site file for additional information. |
Louis Howard |
| 2/3/2021 |
Update or Other Action |
Bulk action entry - all Tatalina LRRS sites x-referenced with the general file, 2655.38.001, on this date. |
Cascade Galasso-Irish |
