| Action Date |
Action |
Description |
DEC Staff |
| 9/26/1942 |
Update or Other Action |
Areas Used by the Chemical Warfare Service During the 1900s (historical division U.S. Army Chemical & Biological Defense Command compiled by Kathy Ciolfi). Fort Morrow Alaska Ltr. (Letter) 470.6 (CWS), 1st Lt. J.A. Romanczuk, Asst. AG., to C CWS., 28 Sep 42., Subj: Toxic Agents for Alaska Defense Command. 1. The Commanding General, Alaska Defense Command has requested the shipment of vesicant agent and airplane spray tanks to stations of his command. He is fully cognizant of the War Department instruction, April 25, 1942, prescribing approval of War Department prior to use of toxic chemicals. 2. Recommend early shipment to stations in Alaska as Follows:
Station HS Tons Airplane Spray Tanks M-10 & filling lines, complete Pump Fort Glenn 50 100 6 Fort Randall 50 100 6 Longview 50 100 6 (Adak-Longview Army Airfield: Although this operational area was initially named "Longview Army Airfield," by early 1943, it was renamed Davis Army Airfield.") Fort Greely 30 75 4 Fort Richardson 30 200 16 3. Recommend for future planning but not immediate delivery, for stations as follows: Station HS Tons Airplane Spray Tanks M-10 & filling lines, complete Pump Fort Morrow 15 50 4 Naknek 15 50 4 Bethel 15 50 4 Cordova 15 50 4 Annette 15 50 4 |
Louis Howard |
| 1/18/2006 |
Meeting or Teleconference Held |
January 18, 2006 stakeholder kickoff meeting held for the military munitons program. Representatives from the organizations listed above met at Fort Richardson in Anchorage, Alaska. Mr. Gene Barber of TechLaw, Inc. (TechLaw) presented an overview of the three phases of the MMRP & explained that the program only addresses closed, transferred, or transferring ranges with releases that occurred prior to 30 September 2002. Releases include explosive safety hazards, as well as media contamination resulting from unexploded ordnance, discarded military munitions, & munitions constituents. The MMRP excludes operational ranges, operating storage/manufacturing facilities, & permitted treatment or disposal facilities.
Mr. Barber explained that the MMRP protocol generally follows the phased Comprehensive Environmental Response, Compensation, & Liability Act (CERCLA) process. The Phase 3 Range Inventory constitutes the completion of the CERCLA Preliminary Assessment (PA) Phase.
Mr. Barber introduced the Final Phase 3 Inventory Report completed for Fort Richardson, the Site Inspection (SI) Project Team, & the MMRP SI goals. The goals of the MMRP SI include collecting the appropriate amount of data necessary to make a decision on whether sites warrant further action, such as a RI/FS, Interim Removal Action, or NFA. The secondary goal involves collecting information that helps develop more effective costs to complete & to complete the Munitions Response Site Prioritization Protocols.
Ms. Cheryl Mahoney of TechLaw outlined the twelve Munitions Response Sites at Fort Richardson. She explained the historical use & site conditions for each of the following sites: Davis Range A, Davis Range B, Grezelka Machine Gun Range, Mahon Machine Gun Range, McGee Machine Gun Range, Mortar Range 1A, Mortar Range 1B, Mortar Range 1C, Mortar Range 2A, Mortar Range 2B, the Pistol Range, & the Rifle Range.
Discussion regarding the ranges identified at Fort Richardson began with Ms. Cristal Fosbrook informing the meeting attendees that the Army is in the process of trying to reacquire both Davis Ranges A & B. Further discussion indicated that work would not need to be conducted at these 2 ranges since it is the Army’s intention to reacquire the areas for use as a training area. During the discussion, it was noted that the Army would also like to reacquire all of the range fans located outside of Fort Richardson’s eastern boundary, which would include Grezelka Machine Gun Range, Mahon Machine Gun Range, & McGee Machine Gun Range. Discussion continued regarding these ranges & the importance of whether or not they would be reacquired by the Army. It was noted that an SI will not need to be conducted at these ranges if they will be utilized by the Army for training. Mr. Mark Prieksat stated the issue with the range fans located outside Fort Richardson’s boundary is that they currently comprise Chugach State Park, & that the Bureau of Land Management (BLM) may not issue another permit to the Army for its use.
Mr. Barber then described the SI process. He explained that the Technical Project Planning (TPP) process will involve the stakeholder group in the development of: 1) project objectives, 2) data quality objectives & the conceptual site model, 3) sampling & analysis approaches, & 4) additional data collection options that meet the facilities short & long term goals.
Field work activities were then discussed within the stakeholder group. TechLaw asked when the best time to conduct the field work is in Anchorage. The group indicated that generally May through October is the best time period. Snow can arrive as early as mid-October & remain as late as May. It was noted that the vegetation in the area generally dies off in the spring & fall, & might be the best time to conduct field activities. During the summer, Fort Richardson is extremely overgrown with vegetation, & it was noted that visual surveys would probably be more successful during the spring & fall. It was also noted that in Alaska a combination of geophysics & ground penetrating radar is best for field investigations.
Mr. Kevin Gardner suggested that Public Affairs be notified, specifically for sampling work being conducted this summer. Ms. Young Chong informed the meeting attendees that their will be two informational sessions regarding field work activities; an established RAB & informational meetings. Further discussion indicated that Fort Richardson does have an RAB & their next meeting will be in April. Mr. Barber stated that the Public Affairs office would be notified about field work activities depending upon the installation’s desire.
Mr. Prieksat stated that sampling has been conducted around Mortar Range 2B by the railroad during the railroad realignment. He suggested that TechLaw try & obtain the sampling results &/or report. |
Louis Howard |
| 4/27/2006 |
Document, Report, or Work plan Review - other |
Staff reviewed and commented on the Draft Historical Records Review for Fort Richardson, AK March 31, 2006 Contract# W91238-05-F-0153.
ADEC requests the Alaska Department of Natural Resources (ADNR) be provided copies of all reports, documents (draft and final) which are being provided to other stakeholders. In addition ADEC strongly suggests that a letter be sent and phone contacts be made to both of ADNR’s Division of Parks and Division of Mining, Land & Water requesting staff participation and comment on future documents.
Suggested contacts to send a request for ADNR staff participants:
Director's Office
Division of Parks and Outdoor Recreation
Alaska Department of Natural Resources
550 W 7th Ave, Suite 1380
Anchorage, AK 99501-3561
(907) 269-8700 Fax: (907) 269-8907
Director’s Office
Division of Mining, Land & Water
Alaska Department of Natural Resources
Robert A. Atwood Building
550 W. 7th Ave., Suite 1070
Anchorage, AK 99501-3579
Without ADNR participation, it is uncertain whether the MMRP site inspections, which will be conducted (or not conducted based on current stakeholder involvement) at the various sites, will be satisfactory to ADNR to accept transfer of federal land from BLM to ADNR (Chugach State Park). In addition, there are some sites which educational or informational signage is being proposed in lieu of conducting a MMRP site inspection. This may or may not be acceptable to ADNR as sufficient to accept transfer of land associated with a particular MMRP site.
The MMRP sites which have potential for being affected are: Davis Ranges A & B, Grezelka Machine Gun Range, Mahon Machine Gun Range, McGee Machine Gun Range, and the Anti-Aircraft Range – TD MR Site. |
Louis Howard |
| 7/31/2006 |
Update or Other Action |
Final Historical Records Review dated July 2006 received. The purpose of the HRR is to perform a records search to document historical & other known information for the MMRP sites at Fort Richardson to supplement the inventory information, & to support the Technical Project Planning (TPP) process, which will facilitate decisions to focus on those areas where more information is needed to determine the next steps in the CERCLA process.
Phase 3 of the Range Inventory identified twelve MMRP sites - five closed & seven transferred ranges (Figure 2-2). The closed ranges include Mortar Ranges 1B, 1C, 2B, the Pistol Range, & the Rifle Range. Mortar Range 2B (AEDB-R Site ID FTRS-008-R-01) is estimated to be 201 acres in size.
Grezelka Machine Gun Range
The firing point for this transferred range was located within the operational range area & the range continued southeast with the end extending on to property that is owned by BLM. This property was used under permit with BLM. The permits have expired & at the time of the Inventory, the Army considered the property to be released. According to interviewees, the BLM did not want to accept the return of the property because it had not been cleared to BLM’s satisfaction. It was noted that there is the possibility that the Army will decide to renew the permit for this property. It is estimated that the range was used from the 1960s to the early 1980s. A smaller version of this range is still in use. This area is open range that was understood to be part of Chugach State Park. The size of this range was estimated at 92 acres.
Mahon Machine Gun Range
The firing point for this transferred range was located within the operational range area & the range continued southeast with the end extending on to property that is owned by the BLM. This property was used under permit with BLM. The permits have expired & at the time of the Inventory, the Army considered the property to be released.
According to interviewees, the BLM did not want to accept the return of the property because it had not been cleared to BLM’s satisfaction. It was noted that there is the possibility that the Army will decide to renew the permit for this property. It is estimated that the range was used from the 1960s to the early 1980s. Based on the label on a 1983 map, this range may also have been used for 81mm mortar & M-31 rifle grenades. A smaller version of the range is still in use. This area is open range that was understood to be part of Chugach State Park. The size of this range was estimated at 1,205 acres.
McGee Machine Gun Range
The firing point for this transferred range was located within the operational range area & the range continued southeast with the end extending on to property that is owned by the BLM. This property was used under permit with BLM. The permits have expired & at the time of the Inventory, the Army considered the property to be released. According to interviewees, the BLM did not want to accept the return of the property because it had not been cleared to BLM’s satisfaction. It was noted that there is the possibility that the Army will decide to renew the permit for this property. It is estimated that the range was used from the 1960s to the early 1980s. A smaller version of the range is still in use. This area is open range that was understood to be part of Chugach State Park. The size of this range was estimated at 49 acres.
Mortar Range 1A
This transferred range is a combination of two mortar ranges that overlap. The firing points for both of these ranges are within the operational range area. One range fan extends north with an impact area that falls partially within the operational range area & partially in the water of Knik Arm. The second range fan extends to the northwest & covers the majority of the first range fan. A small portion of this second range fan extends over the northern end of Elmendorf & was excluded from the Phase 3 CTT Inventory. It is estimated that the range was used between 1960 & 1984. The range remains an open waterway. The size of this range was estimated at 12,161 acres.
See site file for additional information. |
Louis Howard |
| 4/10/2007 |
Document, Report, or Work plan Review - other |
Staff reviewed & commented on the Draft Site Inspection Work Plan for Fort Richardson, Alaska dated March 2007 General Services Schedule Number GS-10F-0168J, Delivery Order No. W91238-05-F-0153.
2.2 Mortar Range 1A
To ensure consistency please include a subsection titled “Site Recommendations” at the end of this section and each subsequent section to be consistent with section 2.1. Please include the statement “The site is not scheduled for field activities as part of this SI” (from section 2.2.1) in this new subsection with an explanation for why this site is not scheduled for filed activities.
2.2.2 Previous investigations at Mortar Range 1A
The statement “The results tend to indicate that there is no contamination at Eagle River Flats resulting from munitions use.” is misleading and incorrect. It is not appropriate to draw conclusions regarding contaminants at Eagle River Flats based on water samples collected from Eagle Bay and Goose Bay. In addition, active remediation of white phosphorus contamination is on going in the Eagle River Flats. Please revise for accuracy. A similar statement is included in section 2.2.3.5 and 2.4.2.
2.4 Mortar Range 2A
The text includes an explanation of the rationale used for reducing the size of the range fan. It appears the primary evidence for this decision is a lack of reported munition incidents. However, the text also indicates that a thorough investigation to identify these incidents did not occur. This appears to be very weak evidence to support this decision. ADEC recommends plotting the maximum range for the various ordnance types, suspected of being used at Mortar Range 2A, from the firing point. This may support the decision and provide stronger evidence to support the decision to reduce the size of the range fan.
4.0 Data Gaps
Text states “It is unclear if munitions may have impacted the Grezelka, Mahon, or Mcgee Machine gun Ranges.” However these ranges have been removed from consideration due to the topographic evaluation presented in figure 4. If this is indeed a data gap then why have these ranges been removed from consideration as MR sites? Please clarify this statement.
Table 3-1
This table indicates that if MC sampling does not indicate the presence of MC then NFA for MC will be required. Regardless of the findings of the initial MC sampling additional sampling may be required as the project progresses & additional source areas are identified. The table includes two entries for the “Anti-Aircraft Range” & is missing an entry for “Anti-Aircraft Range No.1”.
5.0 Data Quality Objectives
ADEC has developed cleanup regulations for oil & other hazardous substances under the site cleanup rules, 18 AAC 75 Article 3. 18 AAC 78 contains regs specific to LUST & associated site cleanup. The UST Procedures Manual, adopted by reference in 18 AAC 78.007, contains specific requirements for lab QA. However, QA requirements are not as explicit in 18 AAC 75. The CS program oversees characterization & cleanup of sites under both 18 AAC 75 & 78.
In order to ensure consistency in data quality across the CS program, a technical memo (06-002 dated October 9, 2006) was issued which summarizes the minimum requirements for both lab data packages & QA Summaries (data reduction, verification, evaluation, etc.) that must be included in all reports containing analytical data submitted to the CS program under the 18 AAC 75 & 18 AAC 78 regs. ADEC has determined that the QA submittals described below are necessary to meet requirements of 18 AAC 75.335 (b) (2) (B) & (G), 75.335 (c) (3) & (4), 75.355 (a), 75.360 (2) & 18 AAC 78.007. This technical memo & additional information can be found at http://www.dec.state.ak.us/spar/guidance.htm#csp under the Analytical Methods & Quality Assurance section.
Laboratory Data Verification & Quality Assurance Summary
All reports submitted to ADEC containing analytical lab sample results (i.e. soil sample results generated to determine the presence or absence of contamination from previous military munition activities) need to contain a completed Laboratory Data Review Checklist & a Quality Assurance (QA) Summary. The Lab Data Review Checklist is located online at
http://www.dec.state.ak.us/spar/guidance.htm#methods & must be completed, signed & dated by the firm submitting the report to ADEC. It is not to be completed by the analytical lab that performed the sample analysis.
|
Louis Howard |
| 8/14/2007 |
Update or Other Action |
Letter sent to 3 CES which was not applicable at the time. However, due to 2005 BRAC Program and the merger of Ft. Richardson into Elmendorf AFB = JBER, the letter is applicable now for the 673 CES/CEANR which Richardson is now a part of as of October 2010 (fully functional).
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 |
| 3/5/2008 |
Meeting or Teleconference Held |
A Technical Project Planning (TPP) meeting for the Site Inspection (SI) of Fort Richardson was held at the Fort Richardson Directorate of Public Works Conference Room on 5 March 2008 to discuss the findings & recommendations resulting from the SI field activities related to the Military Munitions Response Program (MMRP).
It was noted that an attempt was made to bias the sample locations near signs of military activity, such as munitions items/debris & fighting positions. In addition, samples were collected down slope from the military activity.
It was determined that the analytical data tables will be updated to include reporting limits.
There was some discussion about the small amounts of RDX that were found in areas where RDX would not be expected based on historic use of the ranges. Mr. King stated that it is an Army-wide problem & they are finding traces of RDX at sites where RDX was never used. There has been some discussion that the results are based on something present when the samples were collected.
Mortar Ranges 1A, 1B, 1C, & 2A, Pistol Range, Rifle Range, Anti-Aircraft Range, Anti-Aircraft Range (TD) – The results of the field activities, conclusions, & recommendations for these sites were presented by Mr. Barber & Mr. Ahlborn. No significant issues were raised during this meeting.
Davis Ranges A & B – BLM raised concerns about the difference between the total acreage documented in the original Special Land Use Permit (SLUP) for use as the Davis Ranges A & B MR sites & the MR site acreage presented in the Draft SI report. It was noted that the MR site acreage is limited to the acreage covered by the range fan, as opposed to the entire acreage withdrawn under the SLUP. It was agreed that the boundary of the property as described in the SLUP will be added to the report figures for the Final SI report. It will be noted that the MR site does not encompass the entire SLUP acreage.
There was additional discussion regarding the status of the Davis Range A & B MR sites. The State of Alaska has requested the property from BLM, but it has not been officially released as an agreement has not been reached between BLM & the Army regarding the level of clearance of the property. Ms. Fosbrook stated that this issue is being addressed by the Army’s attorneys & BLM & is a separate issue from the MMRP; however, data from the MMRP will be used to determine how best to reach an agreement as to an acceptable level of clearance. It was further noted that neither area is impacted by current activities at the operational Davis Range. The operational Davis Range is used for small arms training only & is completely contained within the installation.
Anti-Aircraft Range No. 1 – Mr. Ahlborn explained that samples were generally collected in drainages because it was felt that if there had been constituents present at the site, they would have accumulated in the drainage areas. One sample was collected in a drainage area that was outside of the site boundary to evaluate if MC had migrated off the site.
The group discussed MRSPP notification process, including the steps that need to be taken by the installation to solicit input from the stakeholders & general public. The installation will send a notification letter to the lead regulatory agency (ADEC) requesting their input on the MRSPP scores that are included in the Draft SI Report. The stakeholders can request an additional meeting at which time the MRSPP scores can be reviewed. The installation is also required to publish a public notice in the local newspaper soliciting additional information regarding the MR sites from the community.
There was a question regarding the blank Health Hazard Evaluation (HHE) tables in the MMRP. Mr. Barber explained that the tables in the HHE module of the MRSPP incorporate all media; however, only the forms that include the media actually sampled are marked. In addition, the term “Evaluation Pending” is used for those MR sites where field work was not completed (i.e., water sites).
Ms. Chong asked that the stakeholders notify her if they would like additional time to review the Draft SI Report. She also noted that the SI report can not be finalized until 30 days from the date the MRSPP notifications are posted. It was also noted that a conference call or web based meeting could be arranged if any stakeholders would like to discuss the report further after they have had time to draft their comments.
For those sites recommended for further evaluation, it is anticipated that funding will be available in approximately 2012. For the water sites, further evaluation will be dependent on the development of new technology. Mr. Rodeffer stated that after 2010 the USAEC plans decentralize the program & it is probable that the funding will be sent to the installations to run the program. |
Louis Howard |
| 4/2/2008 |
Document, Report, or Work plan Review - other |
Staff reviewed & commented on the General Services Administrative Schedule No. GS-10F-0168J, Delivery Order No. W91238-05-F-1053; Draft Site Inspection Report for Fort Richardson, Alaska dated February 2008.
Table 1: Fort Richardson SI Recommendations
Davis Range A
The site is recommended for RI/FS. Based on the information presented in the document, ADEC concurs with this recommendation.Grezelka Machille Gun Range
The site is recommended for listing as "Response Complete in the AEDB-R." Based on the information presented in the document, ADEC concurs.
Mahon Machine Gun Range
The site is recommended for listing as "Response Complete in the AEDB-R." Based on the information presented in the document, ADEC concurs.
McGee Machine Gun Range
The site is recommended for listing as "Response Complete in the AEDB-R." Based on the information presented in the document, ADEC concurs.
To ensure consistency please include a subsection titled "Site Recommendations" at the end of this section & each subsequent section to be consistent with section 2.1. Please include the statement "The site is not scheduled for field activities as part ofthis SI" (from section 2.2.1) in this new subsection with an explanation for why this site is not scheduled for filed activities.
Mortar Range lA
The Table 1 lists this site's recommendations as activities including an educational program & the posting of signs be implemented for recreational users of this area & in the communities associated with this site." Text at Section 3.6 states this range lies entirely over open water & would be difficult to assess utilizing conventional methods of data collection & surveying. In addition, the lack of human inhabitants & activity in close proximity to this site warrant a recommendation of no further action (NF A). ADEC request the Table 1 be corrected to include the NF A recommendation. ADEC also requests this area be recorded this area may be contaminated with MEC/MC & this contamination may make itself apparent from future human activities or environmental conditions. If this occurs, then investigation & remediation may be required.
Mortar Range 1B
The text includes an explanation of the rationale used for reducing the size of the range fan. It appears the primary evidence for this decision is a lack of reported munition incidents. However, the text also indicates that a thorough investigation to identify these incidents did not occur. This appears to be very weak evidence to support this decision. ADEC recommends plotting the maximum range for the various ordnance types, suspected of being used at Mortar Range 2A, from the firing point. This may support the decision & provide stronger evidence to support the decision to reduce the size of the range fan.
Mortar Range 1C
The site is recommended for NF A in Table 1. ADEC concurs for the MEC at the site. However, low level amounts of RDX, TNT & tetryl were detected in the majority of samples collected at the site. The presence of explosive compounds being present in the soil indicates further investigation of this site for MC is recommended. ADEC requests whatever action for any MC discovered at Mortar Range 2B for MC be applied to Mortar Range 1C.
Mortar Range 2A
The site is recommended that "activities including an educational program & the posting of signs be implemented for recreational users of this area." ADEC requests a better evaluation of the areas previously identified in another document, which showed range fans on land in the Knik area be conducted. The document does not address the portion of Knik which may be impacted. Figure 3-1 conveniently takes a "jog" away from Knik to avoid any portion of the firing fan for Mortar Range 2a being on land which is in contrast to the figures in the final Historical Records Review (Figure 2-2, Figure 4-9, Figure 4-9A & especially Figure 4-10)
The text in Section 3.9 Mortar Range 2A & Section 7.9 Mortar Range 2A makes no mention of the fact the range is under water despite being mentioned in Table 1 & Section 8.9 Mortar Range 2A. ADEC also requests this area be recorded this area may be contaminated with MEC/MC & this contamination may make itself apparent from future human activities or environmental conditions. If this occurs, then investigation & remediation may be required.
Pistol Range
The site is recommended for NF A in Table 1. Based on the information presented in the document, ADEC concurs.
Rifle Range
The site is recommended for NF A in Table 1. Based on the information presented in the document, ADEC concurs. |
Louis Howard |
| 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 |
| 10/31/2008 |
Update or Other Action |
Final Site Inspection Report received. The primary goal of the MMRP SI is to collect the appropriate amount of information necessary to make one of the following decisions:
1) Whether further investigation, such as a Remedial Investigation/Feasibility Study (RI/FS), is required at a site;
2) Whether an immediate response is needed; or
3) Whether the site qualifies for No Further Action (NFA).
SI field activities were conducted at the following MR sites:
-Davis Range B (FTRS-012-R-01) – Approximately 163 acres of land located south & west of the northwest corner of the installation, & to the north & east of Campbell Creek Canyon.
-Mortar Range 1C (FTRS-010-R-01) – Approximately 10 acres of land encompassing a triangular-shaped area at the base of one of the historic range fans comprising Mortar Range 1A.
-Pistol Range (FTRS-011-R-01) – Approximately 3 acres of land located in the southeast area of the Fort Richardson cantonment area. It is located southeast of the former Rifle Range.
-Rifle Range (FTRS-007-R-01) – Approximately 111 acres of land located in the southeast area of the Fort Richardson cantonment area. It is located northwest of the former Pistol Range.
-Anti-Aircraft Range (FTRS-013-R-01) – This MR site is divided into three non-contiguous portions divided by operational range area. The two closed sections located on the installation comprise approximately 509 acres & are located in the central portion of Fort Richardson. A third section is located in Chugach State Park & is the Anti-Aircraft Range – TD MR site. The Anti- Aircraft Range is bisected by Glenn Highway, which extends from the southwest to the northeast. Arctic Valley Road extends northwest to southeast near the eastern boundary of the northern area.
-Anti-Aircraft Range – TD (FTRS-014-R-01) – This MR site forms the third piece of the three non-contiguous portions of the Anti-Aircraft range. This transferred section encompasses approximately 2,336 acres & is located in Chugach State Park outside & adjacent to the southeast corner of Fort Richardson. It is also adjacent to Davis Range A & the installation boundary.
-Anti-Aircraft Range No. 1 (FTRS-016-R-01) – This MR site forms the transferred portion of historic Anti-Aircraft Range No. 1. The remainder of the range fan is contained within the operational range area of Fort Richardson. This transferred section encompasses approximately 9,197 acres & is located in Chugach State Park outside & adjacent to the southern boundary of Fort Richardson. It is also adjacent to Davis Range B & the installation boundary.
Analytical results indicate that no explosives were detected in any of the samples collected at the Davis Range B MR site with the following exceptions:
• Hexahydro-1,3,5-trinitro-1,3,5-triazine (RDX) was detected in two of the sediment samples (Samples FR-DRB-SED003 ( 0.39 mg/kg) valid (v) & FRDRB-SED004 (0.22 mg/kg*)). This amount is well below the screening criteria of 4.4 mg/kg.
* No problems with compound quantitation were identified with the exception of RDX in sample FR-DRB-SED004. As part of the Level III review, quantitative results as well as lab qualifiers were evaluated. No problems with compound quantitation were identified with the exception of RDX in sample FR-DRB-SED004. Field sample FRDRB-SED004 had RDX reported at 0.22 mg/Kg. This result was qualified by the lab with a PZ (the % difference between original & confirmation analyses is greater than 25% & co-elution occurred).
Mortar Range 1C
Analytical results indicate that RDX, methyl-2,4,6-trinitrophenylnitramine (tetryl), & 2,4,6-trinitrotoluene were detected in three samples as noted below. All results were well below screening criteria.
-FR-MR1C-SO002 indicated a detection of RDX of 0.65 mg/kg (v)
-FR-MR1C-SO003 indicated a detection of 2,4,6-trinitrotoluene of 0.27 mg/kg(P, J*)
-FR-MR1C-SO004 indicated a detection of tetryl of 0.21 mg/kg (P, J*)
* As part of the Level III review, quantitative results as well as lab qualifiers were evaluated. The results for samples FR-MR1C-SO003 & FR-MR1C-SO004 were qualified indicating that the associated numerical value is an estimated quantity. There is a greater than a 40% difference between the two HPLC columns for the detected concentrations. The lower of the two values was reported. (J) Indicates that the value was estimated because the analyte was positively identified, but the reported concentration was estimated due to QC failure or data quality limitations. (P) Indicates analytes which demonstrated greater than 40% difference in concentration between analytical columns. Generally, in these situations the lower value is reported.
See site file for additional information.
|
Louis Howard |
| 4/30/2010 |
Update or Other Action |
The Alaska Department of Environmental Conservation (ADEC) has received the final Site Inspection (SI) Report for review and comment. After conducting a review of the document, ADEC no additional comments and will grant its approval of the report. |
Louis Howard |
| 3/16/2011 |
Update or Other Action |
Remedial Investigation & Expanded Site Inspection Work Plan for Various Sites draft January 2011 received.
ESI activities are planned for Davis Range A, Mortar Range 2A, Mortar Range 1A, Anti-Aircraft Range TD, & Anti-Aircraft Range No. 1. These activities include further research & analysis to determine whether the sites may be closed for No Further Action. The fieldwork for this effort is anticipated to begin on 6 July & extend through 4 August 2011. The goals for the fieldwork are to characterize contamination at Mortar Range 2B & Davis Range B & collect enough information to determine whether further action is required at the site. The goal for the ESI sites is to determine whether a NFA determination can be achieved.
Multiple areas of FTR are expected to contain MD, MC, or MEC due to possible munitions activity. The nature of military activities that occurred at the sites is unclear, or if any activity occurred at all. The following sites have not been cleared for NFA & will be the focus of an ESI:
-Davis Range A
-Mortar Range 1A
-Mortar Range 2A
-Anti-Aircraft Range No. 1
-Anti-Aircraft Range TD
The ESI will consist of a records review to determine the nature & extent, if any, of
military activities that occurred at each site. The following archived resources should be
used to conduct the study:
-Historical land usage
-Historical photo analysis of the site
-Past incident reports in & around the area
-Other DoD support activities
Mortar Range 1A lies entirely over open water & is a combination of two overlapping ranges comprising approximately 13,119 acres. This range lies entirely over open water & would be difficult to assess utilizing conventional methods of data collection & surveying. In addition, the lack of human inhabitants & activity in close proximity to this site warrant a recommendation of No Further Action for this site. Mortar Range 2A is a combination of several former ranges & includes two ranges called the McLaughlin Range, which varied in shape over the years, a tank training range (Cole Range), & the Moore Range Anti-Aircraft Range TD/No. 1. The Moore firing point was located due east of Otter Lake & extended north-northeast across the operational range & into Knik Arm.
The Cole Range had a firing point E of ERF with a wide range fan that extended north. The McLaughlin Ranges shared a single firing point east-northeast of ERF. In the early 1960s one of them became a tank range, & the impact area was lengthened to include land on the other side of Knik Arm. All of the range fans extended north across the operational range area & over the Knik Arm
See site file for additional information. |
Louis Howard |
| 4/5/2011 |
Site Added to Database |
A new site has been added to the database |
Mitzi Read |
| 4/5/2011 |
Exposure Tracking Model Ranking |
Initial ranking with ETM completed for source area id: 79068 name: JBER-Ft. Rich MMRP |
Mitzi Read |
| 1/11/2013 |
Update or Other Action |
MMRP RI report received.
Rifle Range and Anti-Aircraft Range: In 2011, one sample was collected using the MULTI INCREMENT sampling approach at one location at each site where discrete samples collected in 2007 had detected explosive contamination (USACE 2008). The results showed that explosives contamination was not present above ADEC Method Two migration to groundwater cleanup levels.
The sample grid at the Rifle Range (Figure A-3) needed to be relocated due to interfering site
features. The site was located 1.5 meters outside of the fence surrounding the elementary
school; therefore, the grid was oriented to fit alongside the fence while still positioned over
the previous discrete sample location. The resulting grid was consistently spaced, but the
discrete sample location was approximately 1-meter offset from the center of the plot.
|
Louis Howard |
| 7/25/2016 |
Update or Other Action |
RIFS Mortar Range 1A & 2A received for review and comment.
Due to the hazards and difficulties posed by the exposed mudflats and the extreme tides in the Knik Arm, no field investigations have been conducted to characterize the nature and extent of MEC in Mortar Range 1A (FR002) or Mortar Range 2A (FR001). Information presented in the HRR and SI Reports, Knik Arm sedimentation studies, and other publicly available data, were used to determine the nature and extent of potential MEC within the Mortar Range 1A (FR002) and Mortar Range 2A (FR001) MRSs.
The project objectives were met with the determination of the nature and extent of any MEC hazards and MC risks associated with historical military munitions use at the Mortar Range 1A (FR002) and Mortar Range 2A (FR001) MRSs. In conclusion, the RI identified the presence of potential MEC hazards throughout the MRSs with a moderate potential explosive hazard condition identified from the MHAT.
The data evaluated during the RI risk assessments indicates that MC does not present unacceptable risks to human and ecological receptors. Based upon the findings of the RI, the Mortar Range 1A (FR002) and Mortar Range 2A (FR001) MRSs were further evaluated in the FS for develop remedial alternatives for addressing MEC hazards to humans and sensitive ecological receptors under the current and future land use scenarios.
The three alternatives presented in the feasibility study are:
• Alternative 1: No Action
• Alternative 2: LUCs
• Alternative 3: Removal of MEC
See site file for additional information. |
Louis Howard |
| 8/30/2016 |
Document, Report, or Work plan Review - other |
Staff commented on the RI/FS for Mortar Ranges 1A and 2A. Main comments were regarding Beach Lake Park 13.73 acres (on land) being excluded from and impact area for Mortar Range 2A and if land use restrictions are part of the remedy for Range 2A, they need to be coordinated and approved by the Municipality of Anchorage. Other comments were on the need to include a reference to the fish tissue sample results from Eagle River and Eagle Bay and to update reference to the EPA RSLs to the most current version available. Finally, staff recommended that the DoD provide training on LUCs not just materials and information.
See site file for additional information. |
Louis Howard |
| 5/19/2017 |
Meeting or Teleconference Held |
Meeting for discussion of implementation of land use controls for Mortar Ranges 1A and 2A.
The meeting topics for the April 12, 2017 meeting were a status update of the Desktop RI/FS, potential remedial alternatives identified in the FS, and willingness of stakeholders to implement land use controls (LUCs) on areas that are not managed by the Department of Defense (DoD).
Action items include:
a. Ms. Halstead will provide contact information to the team for hunting and fishing regulation research for similar LUCs at Fort Wainwright.
- A representative from DNR indicated that she would get back to the USEPA/team regarding her POC at Fort Wainwright.
- AFCEC/JBER to determine requirements for recreational permit restrictions through
iSportsman and hunting/fishing regulations with ADF&G (or POC at Fort Wainwright).
b. AFCEC/JBER to discuss possible access agreement and operations and maintenance activities with MOA for LUCs at Beach Lake Park and Ship Creek boat launch area, as well as with ADF&G at the Goose Bay boat launch.
c. AFCEC/JBER to contact the Native Village of Eklutna for possible information on activities within the MRS boundaries.
d. AFCEC/JBER to contact DNR for input.
e. GSI to evaluate MEC migration study; however, based on the preliminary information
available, only a qualitative analysis can be performed. A quantitative analysis cannot be
completed without field data. |
Louis Howard |
| 8/31/2018 |
Update or Other Action |
Final RI/FS received for Mortar Ranges 1A, 2A & 2C. The RI identified the presence of potential MEC hazards throughout both the Mortar Range 1A and Mortar Range 2A MRSs with a moderate potential explosive hazard condition identified from the Munitions and Explosives of Concern Hazard Assessment Tool (MHAT). Both MRSs were further evaluated in the FS. The General Response Actions (GRAs) and technologies that may be applicable for the MRSs were identified and screened then developed into remedial alternatives which were screened for effectiveness, cost, and implementability. Three alternatives were determined to be feasible based on these factors (and the need for a permanent solution in compliance with the NCP), and were further evaluated and compared against the nine NCP criteria. The three alternatives were as follows:
• Alternative #1 – No Action
• Alternative #2 – Land Use Controls (LUCs)
• Alternative #3 – Removal of MEC from Sediment
A 13.73-acre portion of Mortar Range 2A (FR001) was determined to be located on land during the RI. In August 2016, a GSIP field team conducted an instrument assisted visual survey of the acreage. No MEC, small arms, or other evidence of historical military use was documented. No subsurface anomalies were identified with the metal detectors. The land-based acreage of Mortar Range 2A were recommended to be split from Mortar Range 2A (FR001) as a separate MRS (Mortar Range 2C based on the difference in physical features and the results of the investigation. There is no known or suspected explosive or health hazard from Mortar Range 2C and therefore no further action is the likely preferred alternative.
See site file for additional information.
|
Louis Howard |
| 11/26/2018 |
Update or Other Action |
Draft Proposed Plan receive for review and comment for sites Mortar Ranges-1A, 2A & 2C. Preferred alternative for 1A & 2A is land use controls (LUCs). Signage would be implemented to alert users of the history, nature of munitions present, and provide public safety information (e.g., recognize, retreat, and report [3Rs]). At Mortar Range 2C, no munitions or explosives of concern were found, therefore the preferred alternative is no further action.
See site file for additional information. |
Louis Howard |
| 1/16/2019 |
Document, Report, or Work plan Review - other |
Staff provided comments on the draft proposed plan. Main comment was to requests a notice be placed in state land records regarding the hazards of munitions present and land use controls being implemented for Mortar Ranges 1A and 2A. Comments were made also on the time period of long term management of the site be specified.
See site file for additional information. |
Louis Howard |
