| Action Date |
Action |
Description |
DEC Staff |
| 3/30/2006 |
Update or Other Action |
Factsheet for Military Munitions Response Program (MMRP) on EAFB received. The Air Force (AF) is evaluating three locations on Elmendorf Air Force Base (EAFB) under the Military Munitions Response Program (MMRP). We are seeking any information the public may have regarding the history of these locations in an effort to learn more about possible past uses that may not have been documented. We are particularly interested in information regarding munitions at any of these three sites or other locations on Elmendorf AFB. In order for us to use information provided by the public during a field investigation scheduled for late May, we would like to receive all information by May 15, 2006.
The MMRP is a comprehensive program that will address the potential health, safety, and
environmental hazards present at former munitions response sites that were in operation through
the year 2002. Munitions response sites are areas the Department of Defense (DoD) has
historically used for munitions-related activities and are now closed or inactive. All designated MMRP sites have been found to contain or are suspected of containing unexploded ordnance (UXO), discarded military munitions (DMM), or munitions constituents (MC). The program
focuses on how potential munitions remaining on a site could affect people or the environment
The overall goals of the MMRP are to identify location, type, and to what extent munitions are
present; determine the hazards to human health and the environment; establish goals and
metrics to track progress; prioritize which sites require response actions before others; conduct necessary response actions; and transfer land consistent with the munitions response completed.
The first step in the MMRP is the Comprehensive Site Evaluation (CSE) which is conducted in
two phases. Phase I consists of historical record reviews, visual surveys, limited geophysical
surveys, and personal interviews; and Phase II involves a thorough site investigation with soil
and water sampling. We are currently initiating Phase I of the CSE in order to prioritize sites in Alaska for future work. Field work is scheduled for May of this year.
Elmendorf AFB is one of several military installations in Alaska included in the MMRP. There
are three suspected sites:
• B-26 Crash Site: this crash site is approximately one acre in size and contains airplane
wreckage. This site is remote and access is limited. Suspected munitions include .50 caliber
and larger ordnance.
• Small Arms Range: this site is approximately 10 acres in size and was used as a small
arms and grenade training range. The site is in a remote location in the northern portion of
the base and has limited access. Suspected munitions include small arms and grenades.
• Suspected Skeet Range: this site is approximately one acre in size and may have been
used as a skeet range. This site is remote with limited public access allowed. No evidence
of munitions of any type has been found at this location.
|
Louis Howard |
| 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 |
| 12/28/2006 |
Update or Other Action |
NOTE TO FILE:
DoD applies the environmental restoration process set forth by CERCLA and its implementing legislation, the National Oil and Hazardous Substance Pollution Contingency Plan, to address cleanup at MRSs.
CSE: The Cornerstone of the MMRP
The two-phased CSE approach is the foundation of the AF MMRP.
The Air Force is following the Comprehensive Environmental Response, Compensation, & Liability Act (CERCLA) process in addressing its MMRP sites; therefore, the CSE Phase I & Phase II are equivalent to the CERCLA phases Preliminary Assessment (PA) & Site Inspection (SI), respectively.
The CSE was designed to
• Identify munitions response sites (MRSs) & evaluate the extent & distribution of munitions & explosives of concern (MEC) at each site
• Define future military munitions response actions with a high degree of confidence
• Provide sufficient site information to help estimate the costs of future military munitions response actions
(Air Force Military Munitions Response Program MMRP Spotlight February 2007).
Comprehensive Site Evaluation (CSE) Phase I – same as
CERCLA PA
? Historical records review, visual surveys, interviews
? CSE Phase II – same as CERCLA SI
? Conduct environmental sampling and limited geophysical
surveys
? Has greater data requirements to support:
? MRSPP scoring
? Conceptual Site Model (CSM)
? Updated phase schedules in tracking databases
? Better cost estimates for environmental liabilities
? Upfront work expedites future responses by streamlining RIs
Possible Outcomes from CSE
? Site meets (UU/UE) and no further action is appropriate –
proceed to NFA decision memo
? Further investigation is required – proceed to RI
? A response action is required, and the site is sufficiently
characterized to perform a removal action – proceed to a
time critical/non-time critical removal action
? The site does not meet UU/UE, further investigation is not
warranted, but an IC will be required |
Louis Howard |
| 12/29/2006 |
Update or Other Action |
Final Supplemental Comprehensive Site Evaluation (CSE) Phase I Findings Report Revision 02 October 2008 received. This Supplemental Comprehensive Site Evaluation (CSE) Phase I, conducted under the Military Munitions Response Program (MMRP), was performed for Elmendorf Air Force Base (AFB) in Anchorage, AK. The purpose of this effort is to supplement previous CSE Phase I efforts by performing an extensive munitions response historical records review (MRHRR) to determine if any previously unknown munitions response areas (MRAs) exist. The Findings Report presented herein pertains specifically to Elmendorf AFB, AK.
A person who responded with anecdotal information indicated that a small arms range was formerly located at the recent location of the Defense Reutilization & Marketing Office (DRMO). The person stated that he was stationed at EAFB during the Vietnam War era. A review of the 1962 aerial photograph with the title ending with 60_a (see Appendix E) shows that the DRMO was in place at that time & no small arms ranges are present on EAFB in the vicinity. However, historical maps of Fort Richardson do indicate that several small arms ranges were present to the east of the DRMO within the boundaries of Fort Richardson. Based on this information, it appears that 1 of these may be the small arms range he was discussing. Therefore, this information does not represent a new potential MRA.
Elmendorf Site SR001 (MRA2001) is a former small arms & grenade range encompassing about 10 acres in an undeveloped northern area of the Base, with the nearest buildings (less than 1,250 feet) used on a temporary basis for training purposes. The area has low grass & few shrubs. Access to the area is controlled by a gated road with a warning sign & a security patrol.
The former firing range is suspected to have historically been used for small arms training. No evidence of small arms munitions were found during the visual inspection. Due to a high number of grenades found during the visual inspection, the probability exists that the inactive range has also been used for munitions other than small arms. Grenades found may also be attributed to ricochet & misfires from the neighboring grenade launcher training area.
The Small arms range site is undeveloped & contains open areas of gravel/sand interspersed with grass & some shrubs. An active grenade launcher training area is immediately adjacent to the Small arms range. There are no additional land use restrictions outlined in the Base General Plan.
The MRA was found to contain open areas of gravel/sand interspersed with grass & some shrubs. The open area approaching the range appeared to be maintained & may still be used to access areas surrounding the small arms range site. The topography was primarily flat with some rolling hills. There was no evidence of stained soil or stressed vegetation. There are vehicles shown parked on the road dividing the two ranges.
There was no small arms ammunition found on the small arms range during the investigation. However, approximately twenty 40mm grenade base plates were found during the visual inspection of the approach area to the small arms range. Within the boundaries of the small arms range, 40mm smoke grenade & M781 practice grenade parts were found. Intact 40mm grenades that had apparently ricocheted from the adjacent grenade launcher training range were found scattered around the target area, the center road, & into the small arms range itself. In addition, there were several scatterings of debris from 40mm plastic grenades.
Geophysical mapping was conducted over five grids covering an area of approximately one acre at the former firing range. The grids included: one grid on the road between the small arms range & the active grenade training range; one grid covering the 100-yard target line; one grid covering the 50-yard target line; one grid covering a slope behind the 100-yard target line; & one grid covering an area just in front of the backstop. The anomaly density in the grids ranged from medium to low (from 30 anomalies per acre to less than ten anomalies per acre). The highest density of anomalies was detected on the road between the two ranges. Some of the anomalies detected in all grids were surface debris visually confirmed to be grenade components or scrap metal.
However, many were subsurface & may be MEC related, such as concentrations of small arms ammunition projectiles. The anomalies detected during the investigation are depicted overlying an aerial photo of the site. There was no small arms ammunition visually identified during the 2006 survey of the site, indicating that the range was likely routinely cleared. Geophysical results, however, indicate that there may be concentrations of small arms projectiles in down-range backstops.
See site file for additional information. |
Louis Howard |
| 1/8/2007 |
Document, Report, or Work plan Review - other |
Staff reviewed & commented on the Comprehensive Site Evaluation Elmendorf Air Force Base December 2006.
General: A detailed description of each interview conducted should be included either in the text or as an appendix. In addition a more detailed description of the Archival research should be included including a description of important documents.
4.0 General: Please include a section detailing the historical aerial photo coverage reviewed as part of this investigation. Please include the years reviewed, frames, flight line, & indicate extent of coverage & source. The result of the site specific evaluation of aerial photography should be included in each section. While some interpretation is included in Section 7.0 it is not present in other section.
5.3.4.1, 6.3.4.1 & 8.3.4.1: The last sentence is a little confusing & appears to indicate that Multi incremental sampling will help in identifying contaminant “Hotspots”. Please revise to state that “The sampling approach including a combination of discrete & composite (MI) soils samples will help in identifying …….”.
Figure 6-1: Please include the outline of the 40mm grenade range & the small arms range on the figure. Also indicate the location of the firing point & target areas for the 40mm range. The location of the 100-yard target line, 50-yard target line, the slope behind the 100-yard target line & the back stop should be depicted on the figure (Discussed in section 6.1.6.3). Some of these features should also be identified on Figure 6-2 where their presence won’t interfere with the evaluation of the Geophysical data.
6.1.6.1: Were any berms or other physical features visible that could indicate the presence of a small arms range? Please include a discussion in the text & if not please state so. Section 6.1.6.3 suggests that these features are present.
6.1.6.4: The text states that the presence of the 40mm projectile grenade range may negate any remediation efforts performed at the site. Remediation of Lead in soil & removal of target berms will not be affected by ricochets or misfires from the grenade range.
6.2.4: This section discusses the possibility that live 40mm (HE or HEDP) may have been used at the range. What interviews of historical documentation (training records) have been conducted/investigated to confirm or refute this possibility? This is a very important safety concern due to the unstable nature of fired (unexploded) 40mm projectile grenades.
In addition this section fails to address penetration estimates for small arms projectiles at the small arms range.
6.3.4.1: Please review the ITRC “Characterization & Remediation of Soils at Closed Small Arms Firing Ranges” for guidance on characterizing the extent & magnitude of metals contamination in the impact berms. Multi-incremental sampling is appropriate for the range floor. Please revise section accordingly.
6.3.4.2 & 6.3.4.3: This section presents a general discussion of Field analytical methods but does not contain any specific recommendations as the section header indicates.
The following section makes recommendations for EPA Method 1312 (SPLP) but no clear recommendations for metals analysis or explosive compounds are made. It is not clear in these sections if sampling for explosives compounds is being recommended.
8.1.6.3 & 8.1.6.3: The text states that many anomalies were surface debris consisting of scrap metal & grenade components. These items should have been removed prior to conducting the survey. If the items could not be removed for safety reasons or physical/equipment limitations they should have been surveyed & an overlay of the figure should be included show which anomalies resulted from this debris. A figure should be included.
Appendix G Note: Individual MRA’s that have been divided into more than one MRS should have scoring sheets completed for each designated MRS.
MRSPP work sheets Firing Range: Table 4 should have been scored “Barrier to Access is incomplete. Text indicates there is a gate at the road but no barrier to pedestrian access.
MRSPP worksheet for Skeet Range: Table 1, 2, & 3 “Small Arms” should be selected. Table 10 the EHE module total should be 23 (10+13=23) not 24 (reported as 24 In text. Will change with other corrections. Table 29 You either score the module with a letter rating or an alternative module rating not both.
Note: Individual MRA’s that have been divided into more than one MRS should have scoring sheets completed for each designated MRS.
RACER Work Sheet for Small Arms Range: Range Types Description for other states “Practice Grenade Launcher Range. Adjacent to other grenade range.” There is not description of another grenade range in this vicinity only the small arms range & the practice grenade range. Please revise or explain this second grenade range in the text. Depth to GW comment above. |
Guy Warren |
| 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 |
| 8/29/2008 |
Document, Report, or Work plan Review - other |
Staff reviewed the Draft Final of CSE Supplemental Phase I Site Evaluation Findings Report and MMRP CSE Phase II Work Plan Elmendorf AFB Contract W91238-06-D-0019 Task Order DK01. ADEC has no comments on the Draft Final Supplemental Comprehensive Site Evaluation (CSE) Phase I Findings Report Revision 01 July 2008.
General Comments
1. Lack of continuity between CSE Phase I report recommendations and CSE Military Munitions Response Program (MMRP) Phase II work plan
2. Lack of specificity regarding visual survey procedures, and Digital Geophysical Mapping (DGM) procedures (What they are and where they will be used). Also number and proposed location of samples is not provided. Nor is a general procedure for characterizing Small Arms Ranges (SAR).
3. The investigation proposed does not address potential sub-surface impacts from munitions use and/or disposal.
Figure 1-2 Installation Overview and Site Layout Page 3
The “C” battery appears to be located off Base. ADEC requests clarification from the Air Force on whether this site correlates with one of the formerly used defense sites (FUDS) AAA sites in Anchorage.
3.0 Interim Conceptual Site Model and Exposure Pathway Analysis Page 23
The text states the conceptual site model describes MC sources and possible receptors, and the interactions that link them. ADEC requests the Air Force change the text regarding the ICSM to state:
“It describes sources of MEC and/or MC at a site; actual, potentially complete, or incomplete exposure pathways (sediment, surface water, and groundwater); current or reasonably anticipated future land use; and potential receptors. The source-receptor interaction is a descriptive output of the ICSM.”
Section 4.5 Project Schedule
Table 4-1 Page 47
ADEC requests the Air Force provide the meeting notes from the Kick-off meeting and a list of all participants that attended the June 2008 meeting.
Section 5.4 Visual Survey Page 52
The section contains no specifics regarding the proposed visual surveys. ADEC requests the Air Force provide clarification on whether handheld detectors will be used and whether GPS tracking will be implemented during these surveys. ADEC requests the Air Force provide additional information on what percentage of the sites of interest will be visually surveyed. Since the Air Force is relying totally on visual surveys for sites of interest, this work plan should include a better description of the procedures that will be used.
Table 5-1 Non-Intrusive Surveys Page 61
If the “Munitions Known/Suspected” is “None Anticipated”, then ADEC requests the Air Force provide information on why these sites with this information are MMRP sites. It would seem appropriate to include what is suspected to be at the sites.
Table 5-5 Proposed Analytical Sampling Page 64
ADEC requests the Air Force check the information provided in the table with the CSE Phase I recommendations. This table should be consistent with the recommendations from CSE Phase I.
Section 5.5.1 XRF Survey and Surface Soil/Subsurface Soil Sampling Page 65
The text states “the soil will be further prepared by squeezing a representative aliquot through coffee filter papers to remove moisture.” This statement does not make much sense. ADEC recommends the Air Force delete the text and provide additional detail what will be done in the event saturated soil is located in the sampling area.
Table 9-4 Data Quality Objectives for Various Ordnance Sites
Comments apply to “Develop a decision rule” sections in Table 9-4. If no MEC are observed NFA is recommended. If MEC is observed a presumptive remedy may be recommended.” There are several problems with this decision rule. MEC is specifically defined as UXO, DMM, and explosive soil. Munitions debris is specifically not included in this definition. MD on the surface of the site should be cause for additional action. Also this totally ignores the subsurface of the site. This investigation is focused on visual surface surveys and therefore does not address potential sub-surface munition items. Therefore it is not possible to make any determinations regarding potential sub-surface conditions based on this investigation.
Section 9.8.2.2 Explosives Page 110
ADEC requests analysis include laboratory sub-sampling following air drying, grinding and mixing.
|
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 |
| 2/25/2009 |
Document, Report, or Work plan Review - other |
Review of the Final Work Plan MMRP CSE Phase II Work Plan Elmendorf AFB, January 2009. 2.12.12 Special Considerations (Chemical Warfare Materiel, Depleted Uranium, etc.) Page 17 ADEC requests the Air Force provide a statement regarding the presence or absence of DU should be included in this section. ADEC requests confirmation from the Air Force that “Bioenvironmental Engineering” will notify the Tech Escort Unit in the event that CWM is identified.
Table 5-2 Non-Intrusive Surveys Page 51
See comment 1. Ammo Area B site is no longer shown on Figure 1-2. Also Munitions Known/Suspected should probably be the same as for Former Explosives Storage Area. Also not mentioned anywhere else in the report.
5.5.1 Visual Survey Page 61
Chemical Corps Building and Storage Area (CW006): Reconnaissance should not be limited to concrete building pads. Storage pads and internal roads should be identified from historical aerial photography and ADEC requests the Air Force include them in the investigation.
5.8 Analytical Program Page 68
This list does not include all analytes proposed for sampling as indicated in Table 5-6. ADEC requests the Air Force include references to the analytes. This comment is relevant for many subsequent sections and tables (e.g. Section 7.2, Table 7-1, Table 9-8, Section 9.8.2, etc.)
|
Louis Howard |
| 5/6/2010 |
Document, Report, or Work plan Review - other |
Review comments on the Draft Final Work Plan MMRP CSE Phase II Report Elmendorf AFB, April 2010. 14.5 Future Response Actions and Objectives Page 14-3 ADEC concurs with the removal action at the Small Arms Range (MRA 2001) (MRSR001) and the Suspected Skeet Range (MRA 2003) (MRS TS003). ADEC is issuing a written determination no further military munitions response actions are needed at the remainder of the MRAs on Elmendorf Air Force Base. This determination may be reviewed and modified in the future if new information becomes available that indicates the presence of contaminants or exposures that may cause an unacceptable risk to human health or the environment.
|
Louis Howard |
| 8/4/2010 |
Document, Report, or Work plan Review - other |
Review comments of the Final Report MMRP CSE Phase II Report EAFB July 2010.
The Alaska Department of Environmental Conservation (ADEC) has received the above document for review on July 26, 2010. ADEC has no further comments on the document and concurs with Section 14.5 Future Response Actions and Objectives Page 14-3 proposed removal action at the Small Arms Range (MRA 2001) (MRSR001) and the Suspected Skeet Range (MRA 2003) (MRS TS003). ADEC is issuing a written determination no further military munitions response actions are needed at the remainder of the MRAs on Elmendorf Air Force Base. This determination may be reviewed and modified in the future if new information becomes available that indicates the presence of contaminants or exposures that may cause an unacceptable risk to human health or the environment.
|
Louis Howard |
| 9/14/2011 |
Update or Other Action |
Draft-Final Non-Time Critical Removal Action Work Plan for the Small Arms Range (MRA 2001/MRS SR001) and Suspected Skeet Range (MRA 2003/MRS TS003) dated September 2011 received for review and comment. The purpose of this Work Plan is to provide site-specific procedures that will be utilized in completing the NTCRA for contaminated soil at the identified munitions response sites (MRSs) that pose potential human health and environmental risks at Elmendorf Air Force Base (AFB).
Removal Action Objectives (RAOs) for the Small Arms Range (MRS SR001) and the Suspected Skeet Range (MRS TS003) are as follows:
· Determine the appropriate screening criteria to apply for nitroglycerin at the Small Arms
Range by delineating the concentrations and extent of nitroglycerin in soil;
· Delineate the extent of polycyclic aromatic hydrocarbons (PAH) contamination in soil at the Skeet Range;
· Reduce the risk to human health and the environment through the removal of contaminated soil; and
· Obtain a No Further Action status for the Sites.
In 2006, a CSE Phase I was performed at JBER-Elmendorf to compile and evaluate information
on JBER-Elmendorf relating to the possible presence of potentially explosive munitions, site
physical and environmental conditions, conceptual site model information, identification of new
MRAs and eligibility for presumptive remedies, and gathering data to support setting priorities
and developing future munitions response action cost estimates. Small Arms Range (MRS SR001), which was included in MRA2001 along with the adjacent active grenade range, was recommended to continue in the MMRP and CSE Phase II. The grenade range was recommended to be removed for consideration under the MMRP.
A CSE Phase II was conducted in support of the MMRP at JBER-Elmendorf in 2009 as a followup
to the CSE Phase I and supplemental Phase I investigations. The CSE Phase II was
performed to further determine whether individual MRAs and potential MRAs within JBERElmendorf
warranted additional munitions response actions or if NFA was warranted. Small Arms Range
(MRA 2001/MRS SR001), MEC Results: No evidence of MEC or MD. MC Results: Lead, antimony, and nitroglycerin detected above background concentrations (when available) and human health screening criteria. MRSPP Score: 6. Recommendations: Removal action for small arms
ranges to mitigate risk associated with impacted soil.
In addition to the XRF sampling, ten analytical surface soil samples were analyzed for lead, six
surface soil samples were collected for select metals, and one analytical surface soil sample
was collected for explosives. Lead and antimony were detected above background and the most conservative human health screening criteria. The antimony detected above screening criteria is collocated with the lead-contaminated soil. Lead was found at a maximum concentration of up to 42,000 mg/kg and Antimony was found at 180 mg/kg.
Nitroglycerin was detected above the most conservative human health screening criteria in the one sample collected for explosives analysis (a background concentration is not established for nitroglycerin). The concentration of nitroglycerin detected (5.7 milligrams per kilogram [mg/kg]) is above the Alaska Department of Environmental Conservation (ADEC) Soil Migration to Groundwater cleanup level (0.22 mg/kg), but is below the USEPA Residential Regional Screening Level ([RSL], 6.1 mg/kg) and the ADEC Soil Under 40 Inch Zone cleanup level (300 mg/kg). The source of the nitroglycerin detected in sample SAR-SS-26 is unknown.
Analytical samples for nitroglycerin will be collected at the Small Arms Range to determine the horizontal and vertical extent of nitroglycerin in soil. Based on the sample results, the project team will assess the appropriate screening criteria to apply to the MRA (i.e., the ADEC Under 40 Inch Zone Soil Cleanup Level or the ADEC Migration to Groundwater Soil Cleanup Level). This will be conducted prior to mobilization for excavation activities.
Small arms ammunition (SAA) and casings, as well as any practice grenades (from the adjoining practice grenade training area) within the Small Arms Range will be removed by hand. All visible SAA will be picked up from the ground surface. All SAA, casings, and practice grenades removed will be staged until transportation and disposal have been arranged.
Impacted soils (approximately 3,500 bank cubic yards [BCY]) will be removed to below cleanup levels and stabilized. Excavated soil will be transported for disposal at a preapproved facility.
Analytical samples for lead, antimony, and nitroglycerin (if retained as a Contaminant of
Concern) will be collected from the excavation floor and sidewalls to confirm RAOs have
been met.
See site file for additional information. |
Louis Howard |
| 9/14/2011 |
Update or Other Action |
ENGINEERING EVALUATION/COST ANALYSIS SEPTEMBER 2011 SMALL ARMS RANGE (MRA 2001/MRS SR001) and SUSPECTED SKEET RANGE (MRA 2003/MRS TS003) received. In support of the Military Munitions Response Program (MMRP), this engineering estimate and cost analysis (EE/CA) has been prepared to evaluate Non-Time Critical Removal Actions (NTCRA) at Small Arms Range (Munitions Response Area [MRA] 2001/Munitions Response Site [MRS] SR001) and the Suspected Skeet Range (MRA2003/MRS TS003) at the JBER Elmendorf Air Force Base (AFB) in Alaska.
Previous investigations of Small Arms Range (MRS SR001) found no evidence of unexploded ordnance (UXO), discarded military munitions (DMM), or munitions debris (MD) observed at any
location on the Small Arms Range. Several inert 40 millimeter (mm) practice grenades from the
adjacent active practice grenade training range were found within the boundary of the site. Soil
sample results indicate that lead, antimony, and nitroglycerin are present at concentrations
exceeding the most conservative human health screening criteria in one large area just west of
the target line and two small areas on the second backstop at the northwest end of the site. The
CSE Phase II report recommended that the volume of impacted soil be removed from the site to
eliminate further potential contamination to the site.
Previous investigations of the Suspected Skeet Range (MRS TS003) found no evidence of UXO, DMM, or MD observed at any location at the Suspected Skeet Range. Soil sample results indicate that lead was detected below the human health screening criteria but above the ecological screening criteria. Polycyclic aromatic hydrocarbons (PAHs) exceeded the human health and ecological screening criteria. Small amounts of skeet debris and the PAH exceedances were present in soil primarily in the western portion of the site. The Comprehensive Site Evaluation (CSE) Phase II report recommended that the volume of impacted soil be removed from the site to eliminate further potential contamination to the site.
The EE/CA provides for evaluation of the Response Action Alternatives (RAAs) to mitigate the
site hazards. This EE/CA was prepared in general accordance with U.S Environmental
Protection Agency (USEPA) Presumptive Remedy for Metals-in-soil Sites (September 1999);
United States Army Corps of Engineers (USACE) Engineering Pamphlet 1110-1-18 (USACE,
2006); and the National Oil and Hazardous Substances Pollution Contingency Plan (NCP) 40
Code of Federal Regulations (CFR) §300.415.
Constituents at the Small Arms Range (MRS SR001) consist of lead and antimony from
expended SAA and nitroglycerin from an unknown source.
Twenty-one correlation samples were split for off-site laboratory analysis of lead. These
included a sample taken from one of the XRF hotspots (SAR-SS-30E) in the center of the backstop (re-graded area) from 2.5 to 3 ft bgs. The off-site laboratory correlation samples for lead correlated to the XRF samples within quality control limits and all lead-contaminated soil is
delineated by the XRF results. Six of these off-site laboratory samples were also analyzed for
total metals and one was analyzed for explosives due to the proximity to the practice grenade
training area.
Lead was detected above the BSV and human health and ecological screening criteria. There
was no BSV with which to compare the antimony sample results, but the concentration of one
sample (SAR-SS-86C) exceeded the human health and ecological screening criteria. Nitroglycerin was detected in the one explosives sample. No other explosives were detected. As described in Section 2.4.2, the concentration of nitroglycerin detected is above the ADEC Migration to Groundwater soil cleanup level.
This EE/CA was developed in accordance with requirement under CERCLA as amended and consistent with the NCP, Section 300.415. A comparative analysis was performed to evaluate alternatives to mitigate contaminant-associated hazards at the Small Arms Range (MRS SR001) and the Suspected Skeet Range (MRS TS003) at JBER-Elmendorf, Alaska. The preferred alternative was Contaminated Soil Removal and Off-site Disposal.
Contaminated soil removal best meets the RAOs for the Small Arms Range (MRS SR001) and
the Suspected Skeet Range (MRS TS003) at JBER-Elmendorf, Alaska. The total project cost is
estimated to be $3,393,650. |
Louis Howard |
| 9/20/2011 |
Site Added to Database |
A new site has been added to the database |
Mitzi Read |
| 9/21/2011 |
Exposure Tracking Model Ranking |
Initial ranking with ETM completed for source area id: 79162 name: JBER-Elmendorf Small Arms Range MMRP |
Louis Howard |
| 9/23/2011 |
Document, Report, or Work plan Review - other |
Staff provided comments on the NTCRA draft work plan.
1.2 Add text, such as the following: “The USAF is undertaking the proposed removal action, as lead agency pursuant to CERCLA, Section 104(a). In accordance with 40 CFR 300.415(j), removal actions conducted under CERCLA are required to abate, prevent, minimize, stabilize, mitigate, or eliminate the release or threat of release of substances hazardous to public health, welfare, and the environment.”
4.1 Small Arms Range (MRS SR001)
First bullet
The appropriate cleanup level for nitroglycerin in soil at the site is Table B1, Method Two, Under 40 Inch Zone, migration to groundwater cleanup level of 0.22 mg/kg unless ADEC approves a site-specific alternative cleanup level under Method Three; or ADEC determines the groundwater is not a drinking water source; or JBER demonstrates it is not a drinking water source per the requirements listed at 18 AAC 75.350. The nitroglycerin soil contamination is already above migration to groundwater cleanup levels at 5.7 mg/kg (J flagged: Re-extraction outside of holding time, so the detect was flagged as estimated).
Please note, the other referenced soil cleanup level (i.e. the ADEC Under 40 Inch Zone Cleanup Level) is the Method Two Soil Cleanup Level for direct contact. Text should state: (i.e. the ADEC Under 40 Inch Zone Direct Contact Cleanup Level)
Per notes to Tables B1 and B2: “migration to groundwater” means the potential for hazardous substances to leach to groundwater where they may result in a completed human exposure pathway through direct ingestion of contaminants at or above levels listed in Table C at 18 AAC 75.345(b)(1); soil cleanup levels protective of migration to surface water must be determined on a site-specific
basis.
“Direct contact” means exposure through both incidental ingestion of soil and through dermal absorption of the contaminant from soil.
4.2.8 All loads will be covered during transport to its disposal facility (18 AAC 60.015. Transport. (a) A person who transports solid waste shall keep the waste contained during transport.)
Table 4-3
JBER must ensure that they full comply with § 300.440 “Procedures for planning and implementing off-site response actions”, also known as the “Off-Site Rule” when transporting wastes to an off-site disposal facility.
5.1 18 AAC 75.990 (123) “subsurface soil” means soil that is more than two feet below the surface defines subsurface soil.
A-14 5.1 TestAmerica and any other corporate laboratory/backup laboratory will need to be currently certified/approved for the proposed analyses mentioned in this work plan. Please identify which TestAmerica laboratory will be utilized for this project on JBER since there are multiple laboratories listed on ADEC’s approved laboratory list.
|
Louis Howard |
| 6/24/2013 |
Update or Other Action |
Final Report for Small Arms Range & Suspected Skeet Range received for review and comment.
Removal actions were successfully completed at the two subject MRSs, the SAR (MRS SR001)
and the SSR (MRS TS003), located at JBER-Elmendorf. These sites were selected for interim
removal actions based on the results of the CSE Phase I and CSE Phase II. The EE/CA
determined that the best alternative to address the contamination at these sites was excavation.
A Technical Memorandum was prepared discussing nitroglycerin mobility in soil based on the
results of soil samples collected at SAR (MRS SR001).
The Technical Memorandum concluded that, based on current site conditions and analytical sampling conducted at the SAR, NG levels do not pose a risk to human health and the environment and that NFA was warranted for NG at the SAR. ADEC and the USEPA agreed that NFA was warranted for NG at the SAR.
A total of 2,881 tons of stabilized soil was removed from the SAR (MRS SR001) and a total
2,953 tons of soil was removed from the SSR (MRS TS003). Soil excavated from the SAR was
stabilized using Free Flow® 200. Excavated soil from both sites was characterized and
disposed of at the appropriate facilities.
COC concentrations in confirmation samples collected at each site were less than ADEC soil
cleanup levels with the exception of one sample, ELRA-SSR-S42-1. ELRA-SSR-S42-1 was
collected at the SSR (MRS TS003). The concentration of one PAH constituent, (benzo(a)pyrene), in ELRA-SSR-SAR-1 was greater than the ADEC (under 40 inch zone) cleanup level of 0.49 mg/kg. It was not possible to excavate further past ELRA-SSR-S42-1 due to its close proximity to an adjacent building.
The remaining soil with benzo(a)pyrene contamination is primarily under the building’s foundation and inaccessible. However, based on the preliminary risk screening, the 95% UCL, exposure point concentration of benzo(a)pyrene is 0.206 mg/kg, which is below the ADEC cleanup level of 0.49 mg/kg.
The MRSPP modules for each MRS were revised following the removal actions and both MRSs
now have an overall MRSPP score of “Prioritization No Longer Required.” The removal actions at the SAR and the SSR have been completed and the objectives outlined in the Final Removal Action Work Plan have been satisfied. It is recommended that the data obtained during the removal actions be used to support an NFA determination at the SAR (MRS SR001) and the SSR (MRS TS003) located at JBER-Elmendorf, Alaska. |
Louis Howard |
| 7/2/2013 |
Document, Report, or Work plan Review - other |
Staff reviewed and commented on the site specific Final Report Small Arms Range (MRS SR001) and Suspected Skeet Range (MRS TS003).
2.4.3 Potential Human and Ecological Exposure
The text states: “For the SSR (MRS TS003), the EPC was calculated for benzo(a)pyrene, which was the only constituent detected above ADEC cleanup level following the excavation. All SSR confirmation sample results for benzo(a)pyrene were used in the 95% UCL calculation. The resulting EPC, calculated using the 95% UCL, is 0.206 mg/kg, which is less than the ADEC soil (under 40 inch zone) cleanup level of 0.49 mg/kg.”
ADEC will require JBER provide both the hard copies and electronic copies of the input and output data from ProUCL to ADEC as part of the written site characterization report. JBER is requested to provide supporting documentation for the ProUCL input values and whether or not inputs included the “J” flagged data = Estimated: The analyte was positively identified; the quantitation is an estimate or “U” flagged data = The constituent was analyzed for, but not detected at or above the method detection limit (MDL) concentration or “UJ” flagged data = The constituent was analyzed for, but not detected at or above the reported concentration. The associated concentration value for the affected constituent is an estimated laboratory reporting limit (RL) due to QC exceedances.
There were 17 “J” flagged results, 1 “U” flagged result, 1 “UJ” flagged result and 24 results without any data flags.
|
Louis Howard |
| 11/1/2013 |
Update or Other Action |
Staff received the draft site closure report (MMRP) for several sites which also included the Small Arms Range MRS SR001.
This site closure report has been prepared by the USAF to present documentation that exemplifies how the following JBER–Elmendorf MMRP sites are eligible for site closeout/no
further action: B-26 Crash Site (munitions response site [MRS] DA002); Susitna Gunnery Range Firing Point MRS FR004; Mortar Range 1A MRS FR005; Former Chemical Corps Building and Storage Area MRS CW006; Former Explosives Storage Area MRS XU007; Anti-Aircraft (AA) Batteries A, B, D, G, H West, H East and HQ MRS ML922; AA Battery South West MRS ML923; Four - Former 40-millimeter (mm) Gun Positions MRS ML924; AA Battery North of North-South Runway MRS ML925; Airplane Target Butts North of East-West Runway MRS ML926; Small Arms Range MRS SR001; and Suspected Skeet Range MRS TS003.
The results of several site investigations concluded that these sites meet the following State of Alaska (State) and CERCLA criteria for site closure, in that each site: 1) is protective of human health and the environment; and 2) meets State and CERCLA requirements that are applicable or relevant and appropriate.
This report was developed in accordance with the DERP protocol, CERCLA requirements and
guidance, and 18 AAC 75.380 final reporting requirements for site closure. This is the
comprehensive site closure report for the above-listed 12 MRSs, providing an overall summary
of the eligibility of the sites for closure.
The JBER-Elmendorf MRS SR001 is a former SAR located at Northing 6799393 and Easting 350821 (Universal Transverse Mercator, Zone 6 North, World Geodetic Zone 84 meters). The site encompasses about 5.5 acres in an undeveloped area of the Base, with the nearest buildings (less than 0.47 miles away) used on a temporary basis for training purposes.
In a small (1,200-square-foot) area in the southeastern portion of the site, nitroglycerin (NG) extends to a depth of 12 inches below the surface. At one location (SS-26) with an NG surface
concentration of 5.7 mg/kg, a surface sample (0-6 inch) was analyzed by synthetic precipitation
leaching procedure. NG was not detected in the leachate. The results of the NG soil sampling at
the SAR (MRS SR001) confirm that NG has been attenuated in the surface soils, and therefore is
not leaching into the groundwater. Based on current site conditions *(which includes current land use) and analytical sampling conducted at the Small Arms Range, the ADEC and the EPA have agreed that NG levels do not pose a risk to human health and the environment and that no further action was warranted for NG at the Small Arms Range.
After completion of the 2012 Non-Time Critical Removal Action (NTCRA), there was no MEC hazard or MC risk to human health and the environment. Based on analytical results, confirmation samples collected at the site showed results were below ADEC cleanup levels in the remaining soil. Stockpiled soil was transported offsite after being characterized to ensure legal compliance in the areas of profiling, transporting, and disposal. Contaminated soil was then transported to an appropriate facility. With the approval from the ADEC and the EPA, and agreement that the site does not present a significant threat to human health and the environment, SR001 is eligible for site closure. |
Louis Howard |
| 11/25/2013 |
Cleanup Complete Determination Issued |
The Alaska Department of Environmental Conservation (ADEC) has received the above document for review and comment on November 1, 2013. ADEC has reviewed the information provided and concurs with the site closure for the following: B-26 Crash Site (DA002), Susitna Gunnery Range Firing Point MRS FR004, Mortar Range 1A MRS FR005, Small Arms Range MRS SR001, Former Chemical Corps Building and Storage Area MRS CW006, Former Explosives Storage Area MRS XU007, AA Batteries A, B, D, G, H West, H East, and HQ MRS ML922, AA Battery South West MRS ML923, Four Former 40-mm Gun Positions MRS ML924, AA Battery North of North-South Runway MRS ML925, and the Airplane Target Butts North of East/West Runway MRS ML926.
After completion of the 2012 NTCRA, there was no MEC hazard or MC risk to human health and the environment. Based on analytical results, confirmation samples collected at the site showed results below ADEC cleanup levels in the remaining soil at MRS SR001 (Small Arms Range). Stockpiled soil was transported offsite after being characterized to ensure legal compliance in the areas of profiling, transporting, and disposal. Contaminated soil was then transported to an appropriate facility.
Based on the information available, ADEC has determined the sites have been adequately characterized under 18 AAC 75.335 and have achieved the applicable requirements under the site cleanup rules. This decision is subject to a future ADEC determination that the cleanup is not protective of human health, safety, or welfare, or of the environment, and further site characterizations and cleanup may be necessary under 18 AAC 75.325-.390. |
Louis Howard |
| 12/9/2013 |
Document, Report, or Work plan Review - other |
ADEC has reviewed the Air Force's responses to ADEC's comments (on sites where action was required) and finds the responses adequate. Please finalize the document. |
Louis Howard |
