| 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 AK Department of Environmental Conservation (ADEC) wishes to thank you for the opportunity to participate in the application of the Munitions Response Site Prioritization Protocol (MRSPP) to Military Munitions Response Program (MMRP) sites throughout AK. We feel that active participation & cooperation between DOD, ADEC, EPA & other stakeholders is critical to ensuring the success of the program. The MRSPP is a congressionally mandated rule developed by the DOD to prioritize munitions response sites for cleanup under the DERP & BRAC acts. As such, we understand DOD is the lead agency responsible for cleanup & that ADEC involvement in application of the protocol is primarily a support role. However, the closure of sites under CERCLA & state environmental regulations will require ADEC &/or the US EPA concurrence.
To this end, ADEC is requesting that you & your contractors submit for review & comment the various work plans & documents used in the MRSPP process that correspond to applicable CERCLA documentation requirements (i.e. PA, SI, RI, FS, EECA, etc.). This request applies to all documents already generated in implementing the initial stages of the protocol as well as those that are yet to be generated under the MRSPP process.
We are making this request to provide for credible, legally defensible site characterization & evaluation in the MRSPP process while at the same time providing for efficient & timely ADEC review. Review of historical records, work plans & reports & other supporting documents will allow the project team to ensure that the information gathered is consistent throughout the installations & ADEC & that the appropriate information is gathered to make informed decisions. As sites are investigated, it is likely that several will require additional sampling due to unexpected circumstances. Review & approval of documents as the process moves forward will help minimize information or data gaps that may otherwise develop.
In the long run, concurrent review & approval of various documents will help reduce costs to DOD through a collaborative decision making process which ensures that site characterization, remedial assessment, & remedial actions are consistent with state & federal regulations. As these documents would need to be reviewed prior to “NFA” decisions, review during the MRSPP process will allow remedial action &/or final status decisions to be made in an expedited manner. Likewise, up-front regulatory acceptance should lead to faster agreement on site prioritization & appropriate, timely implementation of remedial actions.
Signed
John Halverson, Environmental Program Manager |
John Halverson |
| 8/14/2007 |
Update or Other Action |
ADEC John Halverson sent letter to Lt. Col. Hodges - 3 CES RE: Reporting discovery of Munitions & Explosives of Concern (MEC) & EOD response activities to DEC
The Alaska Department of Environmental Conservation (DEC) requests that DOD components establish & implement reporting procedures for discovery of Munitions & Explosives of Concern (MEC) & Explosive Ordnance Disposal (EOD) response activities that occur outside active military ranges within Alaska. In the past, numerous ordnance items have been found & EOD response actions implemented without proper reporting to & 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 & cleaned up in a manner & to a degree that are protective of human health, safety, welfare & the environment. To accomplish this mission, laws have been created requiring hazardous substance releases be reported to, & 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) & 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 & 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, & Liability Act of 1980)”.
Additionally, Alaska laws require containment & 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 & 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 & coordination on response to MEC discoveries outside the boundaries of active military ranges.
Specific topics for discussion & agreement include:
1. Timely reporting of Munitions & Explosives of Concern (MEC) discovery.
2. Roles & 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) & number of items discovered, photographs of the items, proximity to populated areas, & response actions taken.
4. Consultation with DEC regarding additional response activities including land use controls, historical records reviews, site characterization & cleanup workplans.
I propose holding a meeting / teleconference it at 10:00 AM, Wednesday August 22nd in our office at 555 Cordova Street & setting up a dial in number for those that cannot 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 & availability at the proposed time & 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 & I, along with the other Military Services, work with environmental & natural resource agencies to exchange information on environmental topics, coordinate related projects & initiatives, avoid conflicts when possible, & 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 & effective manner to explosives & munitions emergencies. DoD provides this support to ensure the public safety of Alaskans & the environment. 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 of this 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 of whether 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 & perhaps pursue a written agreement between the DEC & DoD that delineates the roles & responsibilities of each party.
I would appreciate the opportunity to further discuss our concerns with you & your staff, & so I have asked my points of contact for this issue, Ms. Aubrey Baure & 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 |
| 1/20/2011 |
Update or Other Action |
DSMOA modification adding several Air Force MMRP sites and National Guard MMRP sites to our cooperative agreement. Staff can now start work on the sites. |
Louis Howard |
| 1/21/2011 |
Update or Other Action |
Draft Final Work Plan MMRP CSE Phase I/II PACAF Multisite received which Cape Romanzof LRRS is one of the sites. Two sites exist at Romanzof: Ammunition Storage (No ID) and Training Exercise (No ID). The CSE Phase I/II WP for the USAF MMRP MRAs is a living document. A living document is one that can be modified, as necessary, in order to best achieve the goals and objectives stated within. Based on field observations, site conditions, and other unforeseen circumstances or conditions, the approach described in this document may be modified in order to best achieve the objectives of the CSE Phase I/II.
This CSE Phase I/II project for the AF MMRP MRAs is being completed by the SKY Team, Sky Research, Inc. (SKY) (Prime Contractor), and TLI Solutions, Inc. (TLI) (Subcontractor to SKY) under United States Army Corps of Engineers (USACE) Omaha District Contract W9128F-07-D-0006, Delivery Order 007 to support the United States Air Force (USAF) MMRP. The USAF MMRP MRAs are associated with Cape Romanzof LRRS.
Training Exercise: "Brim Frost" Exercise; possible small arms is the MEC Types and Activities, 100 acres in size, operated in 1989. Closed.
Training Exercise - Under BRIM FROST 89, Cape Romanzof 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”
Ammunition Storage: Unknown MEC Types and Activities, 10 acres in size, Approximate dates of Operation-September 1951 to April 1976. Closed.
Ammunition Storage – According to the Quarterly History Report for Period of Second Quarter FY 76 (1 April – 30 June 76) for the 795th ACWS at Cape Romanzof, as of 30 September 1951 the ammunition storage was 42% complete. The location is unknown.
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 110 acres, will be visually surveyed during the CSE Phase I/II activities at Cape Romanzof 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.
See site file for additional information.
|
Louis Howard |
| 1/24/2011 |
Document, Report, or Work plan Review - other |
Staff provided comments on the draft final CSE Phase I/II Work plan which will be part of a letter incorporating other project managers' comments on the document.
1.3 Purpose & Scope Page 1-2 It is the AF’s responsibility to ensure that the work plan(s) are prepared by a “qualified person ” in accordance with: 18 AAC 75.335. Site characterization. (a) Before proceeding with site cleanup under the site cleanup rules, a responsible person shall characterize the extent of hazardous substance contamination at the site. (b) A responsible person shall submit a site characterization workplan to the department for approval before beginning site characterization work. The department will approve the site characterization workplan if the workplan is (1) prepared by a qualified person The AF shall verify preparer meets qualified person criteria according to the definition in 18 AAC 75.990(100).
1.4 Overview of the PACAF Multisite CSE Phase I/II Page 1-2 ADEC does not accept field screening data as definitive data. The XRF results are not definitive & will not be accepted in lieu of analytical lab results (e.g. EPA Methods-6010C, 6020A, or 7000 series with the appropriate container. (100mL Widemouth HDPE jar, TLC. HDPE: High Density Polyethylene sample collection bottles, critically cleaned for trace metals analysis.). Only definitive data from lab analysis will be accepted for determining if the presence of lead exceeds regulatory action levels. Currently the action level for unrestricted land use (e.g. residential) is 400 mg/kg. For commercial or industrial land use, as applied in 18 AAC 75.340(e)(3), the soil cleanup level is 800 mg/kg. For soils contaminated with lead more than 15 feet below ground surface, lead cleanup levels will be determined (by ADEC) on a site-specific basis.
2.2.4 CSE Field Lead/Site Safety & Health Officer Page 2-1 ADEC will require the Field Lead/Site Safety & Health Officer to meet the definition of a “qualified person” as defined by 18 AAC 75.990 (100). The “qualified person” will also be required to supervise, oversee or coordinate field team activities as required by18 AAC 75.990 (125).
2.6.4 CSE Phase I/II Report Page 2-3 ADEC will require the AF to have the report prepared by a “qualified person”.
4.2.1 Personnel Page 4-2 The AF shall ensure that the four-person field team will have a minimum of one person that meets the definition of “qualified person” as found at 18 AAC 75.990 (100). ADEC will require the “qualified person” to be on-site & either directly conduct all the field screening & sampling activities or supervise other field team members on-site as defined by 18 AAC 75.990(125).
4.3.1 UXO Avoidance Page 4-4 ADEC requests the AF PACAF RPM report the incident to ADEC. ADEC's concern on being notified of the discovery of military munitions or explosives is in ensuring former ranges, training areas, & munitions storage & disposal areas where these items may remain are identified & addressed, as necessary, to help ensure protection of human health & safety.
See site file for additional information.
|
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 |
2011 Final Historical Records Research report 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.
The initial research conducted in support of the ITSI Sources Contacted Report identified one MMRP site that was to be used during a biennial joint readiness exercise named Brim Frost 89. During the exercise, an area at the Cape Romanzof 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 (ITSI 2009 Report).
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 Cape Romanzof 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 Cape Romanzof LRRS.
Summary of MRAs Identified at Cape Romanzof LRRS:
Ammunition Storage Facility-HRR Acreage = NA, Munitions Used: Small Arms 5.56 mm (M16).
Conclusions: Information regarding an Ammunition Storage Facility at Cape Romanzof LRRS was identified. However, the location of the site is unknown and no information was identified to suggest a release of MEC or MC occurred at this location.
Training Exercise Area: HRR Acreage-TBD, Munitions Used: Small arms, blanks, pyrotechnics,
Conclusions: No additional information was obtained regarding the specific operations conducted during use of the Training Exercise Area. The location of the site is unknown.
See site file for additional information.
|
Louis Howard |
| 8/2/2013 |
Update or Other Action |
Draft Final Phase I/II report received.
The potential Ammunition Storage Area MRA & potential Training Exercise Area MRA were not located nor confirmed to exist based on findings from the visual reconnaissance, visual surveys, & interviews with site personnel conducted during the CSE Phase I/II investigation. Therefore, as described in Section 4.5, because there was no evidence of any munitions related activities, the two potential MRAs are not eligible to be investigated as MRAs in the CSE Phase II portion of the Cape Romanzof LRRS investigation. The investigation findings included evidence of munitions related activities for one additional field identified MRA, the Open Burn Area MRA.
Additional findings of munitions related activities for a recreational small arms use area, discovered during the field investigation, are included in this report; however, the small arms use was recreational in nature & the area is not classified as a non-operational (or operational) range. The small arms use area is not eligible for investigation under the USAF MMRP. The data provided in this report regarding the recreational small arms use area is for informational purposes only.
Open Burn Area (No ID) Munitions Response Area
Visual reconnaissance & visual surveys were conducted in & around the Open Burn Area MRS. The location of a former open burn area was found near the road in the Lower Camp. The open burn area is 0.98 acres. Rusted 55-gallon drums & more than 100 0.50-cal. & 0.30 cal. shells were found within the apparent burn location; ‘kickout’ debris were found nearby. The condition of some of the debris & shells indicated that intact rounds had been burned & exploded from the heat since they appeared to be shredded or otherwise blown apart as opposed to having been fired before being burned. The presence of ‘kickout’ rounds found near the apparent burn pile locations, further suggests that the rounds had been burned.
Seven surface soil samples (including one field duplicate) were collected & analyzed for lead & antimony. Due to the potential of buried munitions, no additional samples were collected. No samples for other analyses were collected because small arms debris was the only potential source of MC. Lead was detected in all surface soil lead samples at concentrations ranging from 7.3 mg/kg to 13 mg/kg. Antimony was not detected in any of the samples. Release of MC associated with small arms debris is likely due to evidence of open burn activities.
Potential Future Actions
Further munitions response action.
The Open Burn Area is being recommended for further action based on the identification of possible buried munitions.
The results of the MRSPP assessment for the MRS indicated the following (note that Priority 1 indicates the highest potential hazard & Priority 8 indicates the lowest potential hazard).
• Priority 8: Open Burn Area MRS
Recreational Small Arms Use Area
Evidence of an abandoned recreational small arms use area was found approximately 300 feet south of the road in the Lower Camp. Features included a deteriorated wooden firing platform, targets, & a bermed area. No munitions-related debris such as small arms casings was observed. Transects were surveyed in the vicinity of the site.
The small arms use was recreational in nature & is not considered a non-operational (or operational) range, & therefore is not eligible under the USAF MMRP. The data provided are for informational use only.
See site file for additional information.
|
Louis Howard |
| 8/23/2013 |
Document, Report, or Work plan Review - other |
The Alaska Department of Environmental Conservation (ADEC) Contaminated Sites Program has received the draft Final Report CSE Phase I/II Cape Romanzof LRRS dated August 2013 for review and comment on August 2, 2013 for CS DB Hazard ID 26504. ADEC has reviewed the document and based on a review of the information provided agrees with the Phase I and Phase II conclusions that further munitions response is warranted at the MRS (No ID) Open Burn Area (0.98 acres). ADEC has no further comments and the document may be finalized. |
Louis Howard |
| 11/6/2013 |
Document, Report, or Work plan Review - other |
The Alaska Department of Environmental Conservation (ADEC) Contaminated Sites Program has received the Final Report CSE Phase I/II MMRP, Cape Romanzof LRRS dated October 2013
on October 29, 2013 for CS DB Hazard ID 26504. While the recreational small arms use area is not classified as a non-operational (or operational) range and is not eligible for investigation under the MMRP, ADEC expects the Air Force to conduct additional investigation/remediation under 18 AAC 75. The Air Force must address the contamination found in soil: lead at 2,400 mg/kg and antimony at 4.4 mg/kg (C-LS-CR-04-SS-107) and lead at 800 mg/kg (C-LS-CR-04-SB1-107). ADEC looks forward to reviewing the draft work plan for this site to address the inorganic contaminants present in soil above applicable cleanup levels. |
Louis Howard |
| 1/12/2015 |
Update or Other Action |
Draft Feasability Study received for review & comment.
Although antimony was identified as a COPC in the CSE Phase I/II & evaluated as a potential contributor to overall risk, levels are below state & federal cleanup levels. Because antimony is collocated with lead, most treatments addressing lead will also address antimony.
All alternatives screened were retained for detailed analysis. These include the following:
• Alternative 1: No Action
• Alternative 2: Land-Use Controls (LUCs) & Long-Term Monitoring (LTM)
• Alternative 3: Capping, LUCs, & LTM
• Alternative 4: Debris Removal, In Situ Soil Treatment, Capping, & LUCs
• Alternative 5: Removal & Offsite Disposal
Threshold Criteria
Alternative 1 fails to comply with the threshold criteria. Because this alternative lacks both LUCs & active treatment, humans could be exposed to lead above the ADEC Method Two cleanup level. The remaining alternatives are protective of HHE & could be implemented in a manner that complies with all chemical-, location-, & action specific ARARs.
Because Alternative 1 fails to attain the threshold criteria, it will not be considered further.
Primary Balancing Criteria
Alternatives 2 through 5 would be effective. Alternatives 2, 3, & 4 would require extra costs due to the maintenance of LUCs indefinitely. In contrast, Alternative 5 would not require any LUCs or LTM & has a lower cost than Alternative 4; however, Alternative 5 results in greater greenhouse gas emissions relative to the other alternatives due to additional mobilization & demobilization flights.
Alternative 4 satisfies the statutory preference for a reduction in toxicity, mobility, & volume through treatment. Under Alternative 4, a chemical stabilizer would be applied to limit the mobility & leachability of residual lead contamination in soil. The lead would remain in the soil, though it would become less available & thus be less hazardous. Alternatives 4 & 5 are most effective but have higher difficulties in implementability & cost. Alternative 2 is the easiest to implement but does not significantly lower risk compared to Alternatives 3, 4, & 5.
See site file for additional information.
|
Louis Howard |
| 1/26/2015 |
Document, Report, or Work plan Review - other |
Staff provided comments on the draft FS.
Alternative 3: Capping, Land-Use Controls, & Long-Term Monitoring
ADEC requests the text state: “LTM would be implemented to ensure the integrity of the cap & inspections would occur once a year for the first five years, then every five years thereafter, indefinitely.”
Primary Balancing Criteria
Short-Term Effectiveness
ADEC is unaware changes to NCP (40 CFR 300) & the “Nine Criteria for Evaluation”: specifically, the primary balancing criteria of Short-Term Effectiveness to include a review of potential harm to the environment from increased fossil fuels & greenhouse gas emissions. It can be discussed in general, but ADEC does not consider increased fossil fuel usage & greenhouse gas emissions primary balancing criteria (comment also applies to Alternatives 3, 4, & 5 & Section 4.4.2).
The NCP defines Short-Term Effectiveness as: “The short-term impacts of alternatives shall be assessed considering the following:
(1) Short-term risks that might be posed to the community during implementation of an alternative;
(2) Potential impacts on workers during remedial action & the effectiveness & reliability of protective measures;
(3) Potential environmental impacts of the remedial action & the effectiveness & reliability of mitigative measures during implementation; &
(4) Time until protection is achieved.”
Chemical-Specific Applicable or Relevant & Appropriate Requirements
18 AAC 57.340 Soil cleanup levels; general requirements (A)
18 AAC 75.341. Soil cleanup levels; tables. (A)
Description: Establishes cleanup goals for soil.
Rationale: Cleanup levels for soil (18 AAC 75.340-341); methods for determination & application of cleanup levels.
Location-Specific Applicable or Relevant & Appropriate Requirements
18 AAC 60.410 Location Standards (A)
Description: lists the requirements for location standards of storage of solid wastes.
Rationale: Applicable if excavation options require solid waste storage locations on site.
See site file for action-specific ARARs, location-specific ARARs and additional information
|
Louis Howard |
| 1/26/2015 |
Exposure Tracking Model Ranking |
Initial ranking with ETM completed for source area id: 79034 name: Training Exercise Area |
Louis Howard |
| 2/11/2015 |
CERCLA FS |
ADEC has reviewed the Air Force's responses to ADEC's comments and finds them acceptable. Please finalize the Feasibility Study (FS).
NOTE to File: While not a CERCLA NPL site, DoD is expected to follow CERCLA process during the investigation of hazardous substances in accordance with the NCP and Executive Order 12580 Superfund Implementation. Executive Order (EO) 12580, Superfund Implementation, as amended by EO 13016, Amendment to EO 12580, delegates authority and responsibility to the Secretary of Defense (re-delegated to the Secretary of the Air Force) to respond to releases or threatened releases “where either the release is on or the sole source of the release is from any facility or vessel under the jurisdiction, custody, or control” of the Air Force. The Air Force is the “lead agency” with delegated authority to plan and implement response actions under CERCLA and the NCP.
DERP, 10 USC §§ 2700-2711. 10 USC § 2701(a) states “The Secretary of Defense shall carry out a program of environmental restoration at facilities under the jurisdiction of the Secretary.” The scope of the DERP is defined in 10 USC § 2701(b), which states “Goals of the program shall include the following: (1) identification, investigation, research and development, and cleanup of contamination from hazardous substances, pollutants or contaminants; (2) correction of other environmental damage (such as detection and disposal of UXO) which creates an imminent and substantial endangerment to the public health or welfare or to the environment; (3) demolition and removal of unsafe buildings and structures, including buildings and structures of the DOD at sites formerly used by or under the jurisdiction of the Secretary.”
Under 10 USC § 2701(a)(2) and (c)(1), response actions (i.e., site identification, investigation, removal actions, remedial actions, or a combination of removal and remedial actions) taken under the DERP to address releases of hazardous substances, pollutants or contaminants (as defined under CERCLA) shall be carried out subject to, and in a manner consistent with, 42 USC § 9620.
Demolition and removal of unsafe buildings and structures are not subject to CERCLA unless the demolition or removal involves the need for, or is an integral part of, a response action to address releases to the environment of CERCLA hazardous substances. |
Louis Howard |
| 7/23/2015 |
Update or Other Action |
Draft Proposed Plan received for SR018.
Remedial Action Objectives: Prevent direct contact of humans to soil containing lead in excess of 400 mg/kg, Minimize or eliminate direct ecological exposure to COCs, Reduce the poten??al for COCs to migrate from site soil to any groundwater, surface water, and/or sediments where human receptors could be exposed.
The preferred alternative for SR018 is Removal and Offsite Disposal. Under this alternative, munitions debris at the site and soil contaminated with lead greater than 400 mg/kg would be excavated, staged, manifested, and transported offsite for disposal at a Resource Conservation and Recovery Act (RCRA)permitted chemical waste landfill capable of managing RCRA-regulated lead contaminated soil.
Soil would be excavated and staged onsite prior to transport. Approximately 8.3 cubic yards (12.5 tons) of lead-contaminated soil remain at the site; when excavated, the amount of soil to be disposed equates to approximately 10 cubic yards (15 tons) when adjusting for bulk factor. |
Louis Howard |
| 8/31/2015 |
Document, Report, or Work plan Review - other |
ADEC requested that the Comprehensive Site Evaluation Phase I/II (October 2013) be added to the site as well as a Site designation for SR018 in the list of sites as well as any agency comments. The user might not know to do a keyword search for SR018 to pull up the sole document (the FS) for SR018. |
Louis Howard |
| 4/22/2016 |
Update or Other Action |
Staff received the draft ROD for review and comment. Based on the regulator and support agency comments received during the development of the Proposed Plan, the USAF selected Removal and Offsite Disposal as the overall site remedy.
Munitions debris and soil contaminated with lead above the ADEC Method Two cleanup level (400 mg/kg) would be excavated, staged, manifested, and transported for disposal to a Resource Conservation and Recovery Act (RCRA)-permitted chemical waste landfill capable of managing RCRA-regulated lead-contaminated soil. Soil would be excavated and staged onsite prior to transport. Approximately 8.3 cubic yards (cy) (12.5 tons) of lead-contaminated soil remain at the site. Analytical samples would be collected from the staged soil for waste profiling. It is anticipated that excavation activities would focus on surface soil to an 18-inch depth.
Confirmation sampling of the excavation would be required to ensure lead is no longer present at concentrations above the ADEC cleanup level. Once analytical results from confirmation samples indicate that all contaminated soil has been removed, the excavation would be backfilled. If properly implemented at SR018, Removal and Offsite Disposal will then be protective of human health and the environment. The site would be restored for unlimited use and unrestricted exposure (UU/UE). CERCLA five-year reviews would not be required.
See site file for additional information. |
Louis Howard |
| 5/18/2016 |
Document, Report, or Work plan Review - other |
Staff provided comments on the Draft ROD for SR018.
Main comments were clarifying the no action alternative does not meet the criterion on most of the 9 criteria for evaluation of alternatives under CERCLA and updates to references.
See site file for additional information. |
Louis Howard |
| 3/3/2017 |
Update or Other Action |
Draft Remedial Action-Construction Completion and Site Closure Report SR018 Recreational Small Arms Use Area received for review and comment. Based on the analytical results of the SR018 RA-C post-excavation confirmation soil samples, no lead concentrations above the ADEC Method Two Human Health Soil Cleanup Criteria of 400 mg/Kg were exceeded or remain at the SR018 backstop berm. Based upon these findings, the RAs associated with this restoration effort meet the objectives of
the 2016 ROD as well as meet the criteria for requesting regulatory closure of SR018 per 18 AAC 75. |
Louis Howard |
| 3/22/2017 |
Cleanup Complete Determination Issued |
The Alaska Department of Environmental Conservation, Contaminated Sites Program (ADEC) has completed a review of the environmental records associated with the Small Arms Use Area (SR018) at Cape Romanzof Long Range Radar Site. Based on the information provided to date, it has been determined that the contaminant concentrations remaining on site do not pose an unacceptable risk to human health or the environment and no further remedial action will be required unless new information becomes available that indicates residual contaminants may pose an unacceptable risk.
This Cleanup Complete determination is based on the administrative record for the SR018 Small Arms Use Area, which is located in the ADEC office in Anchorage, Alaska. This determination is in accordance with 18 AAC 75.380 and does not preclude ADEC from requiring additional assessment and/or cleanup action if future information indicates that contaminants at this site may pose an unacceptable risk to human health, safety, or welfare or to the environment.
See site file for additional information. |
Louis Howard |
