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Site Report: Cape Romanzof LRRS OB942 Open Burn Area

Site Name: Cape Romanzof LRRS OB942 Open Burn Area
Address: Cape Romanzof, ~0.6 Mile E of N End of Airstrip; ~100 Ft S of Access Rd, Scammon Bay, AK 99662
File Number: 2526.38.021
Hazard ID: 26372
Status: Active
Staff: Axl LeVan, 9074512156 axl.levan@alaska.gov
Latitude: 61.785673
Longitude: -166.016690
Horizontal Datum:WGS84

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

Problems/Comments

The Cape Romanzof OB942 Open Burn Area was discovered during the Comprehensive Site Evaluation Phase I/II field investigation in September 2011. Evidence for the Open Burn Area Munitions Response Area was observed in the form of burned 0.50-caliber and 0.30-caliber rounds. The Open Burn Area may have been used to destroy ammunition that was stored for defensive purposes. In 2017 the record of decision was signed with the chosen alternative being Institutional and Land Use Controls. With potential anomalies potentially related to munitions left in place at two feet below ground surface. Additionally, a 2017 Site Investigation focused on potential petroleum contaminants of concern determined that no petroleum contaminants above ADEC Human Health Clean-up levels were present. (Updated 11/30/2021).

Action Information

Action Date Action Description DEC Staff
10/31/2013 Update or Other Action Open Burn Area – The Open Burn Area was discovered during the CSE Phase I/II field investigation visual reconnaissance. Evidence for the MRA was observed in the form of burned 0.50-cal. & 0.30-cal. rounds. The area may have been used to destroy ammunition that was stored for defensive purposes. Representative surface soil samples were collected & analyzed to determine if MC had been released to the environment at the MRA. Based on field observations from reconnaissance & visual surveys, small arms projectiles were determined to be present in quantities that may constitute a source at the newly discovered MRA. No MEC or MD related items were found that would constitute a MC release, therefore no explosives sampling was conducted. The MRA is located near the road between the Lower & Upper Camps, just south of the road (Figure 6-1). The MRA is 0.98 acres. Features include evidence of 1 or more burn piles with more than 100 0.50-cal. & 0.30-cal. shell casings & projectiles found scattered on the open ground & among the rocks & vegetation. Several rusting metal drums were also present. The area is in open, rocky tundra. The area was partially clear of vegetation or had sparse vegetation relative to the immediately adjacent area. An additional contaminant of concern at the MRA is antimony from small arms projectiles. COPCs (e.g. PAHs, Diesel & Gasoline Range Organics) associated with the burning activities may be present within the MRA & will be evaluated during subsequent munitions response activities because sampling criteria for these activities were not included in the approved work plan or the UFP-QAPP for MC sampling. Eight surface soil samples (including one field duplicate) were collected from eight locations & analyzed for lead & antimony. Lead ranged from 7.3 mg/kg to 13 mg/kg (detection frequency [DF] = 100%). Antimony was not detected in any of the surface soil samples (DF=0%). No subsurface (greater than 2’ bgs) sampling was conducted due to the large amount of small arms debris & the unknown nature of the subsurface. No sampling & analysis for PAHs was conducted because there were no observations of clay targets or debris that could be a source of PAHs (i.e. repetitive use as a range for skeet or trap shooting). The food chain exposure pathways are complete though likely insignificant. The dust inhalation pathway is complete though likely insignificant for all human receptors due to the moist nature of the tundra soils. Depth to GW at the MRA was estimated to be between 0 & 60’. For this reason, the GW pathway is potentially complete though likely insignificant. Surface water & sediment pathways are also potentially complete though likely insignificant. Both lead & antimony were retained as COECs for the MRA since there were low Eco-SSL exceedances & possible underestimation of antimony concentrations. Although lead & antimony were retained as COECs at this MRA, unacceptable risks are unlikely to terrestrial mammals, birds, soil invertebrates, & plants from exposure to soil through any exposure pathway at the MRA. For additional information see site file. Louis Howard
3/27/2015 Update or Other Action Draft Feasibility Study received for review and comment. Remedial options in this section are evaluated assuming approximately 3 cy of munitions debris and approximately 400 cy of debris mixed with the top 3 inches of soil at the site. Based on the screening, all the alternatives were retained for detailed analysis. These include the following: • Alternative 1: No Action • Alternative 2: LUCs • Alternative 3: Capping, LUCs, and LTM • Alternative 4: Removal and Offsite Disposal Chemical-specific ARARs provide numerical cleanup values that establish acceptable contaminant concentrations that may remain following a remedial response. RCRA of 1976 as amended by the hazardous and solid waste amendments of 1984, Subtitles C and D, other than corrective action requirements (U.S. Code, Title 42, Section 6901 [42 USC 6901]) Establishes protections and protocols for the creation and recycling of waste including cradle to grave manifesting Applicable. Excavated materials designated as waste (e.g., contaminated soils) are subject to the requirements of RCRA. Alaska Oil and Other Hazardous Substance Pollution Control regulations (18 AAC 75) Governs discharge of oil and hazardous substances and state cleanup requirements. Also establishes soil cleanup levels. Applicable Cleanup levels for soil (18 AAC 75.340-341); methods for determination and application of cleanup levels. The site is known to be affected by a release of metals constituents. Alternative soil cleanup levels may be applied. U.S. Environmental Protection Agency Regional Screening Levels for Chemical Contaminants at Superfund Sites (Code of Federal Regulations, Title 20, Section 141.61 [20 CFR 141.61]) RSLs for residential soil. TBC Used as a more conservative guideline for delineating potential lead and antimony contamination. U.S. Environmental Protection Agency Ecological Soil Screening Levels (Eco-SSL) Office of Solid Waste and Emergency Response (OSWER) Directives 9285.7-70 and 9285.7-61 Ecological soil screening levels. TBC Concentrations of contaminants in soil that are protective of ecological receptors that commonly come into contact with and/or consume biota that live in or on soil. Lead levels exceeded the Eco-SSL at OB942. See document for Location Specific ARARs, Action Specific ARARs and additional information. Louis Howard
3/31/2015 Site Added to Database A new site has been added to the database Mitzi Read
4/1/2015 Exposure Tracking Model Ranking Initial ranking with ETM completed for source area id: 79755 name: OB942 Open Burn Area Louis Howard
4/20/2015 Document, Report, or Work plan Review - other Staff provided comments on the draft Feasibility Study. Main issues were regarding analyzing for petroleum contaminants used in burning of munitions that were mentioned in previous documents as a data gap, but dropped from the document. Other issues raised were the need for permit for off-site remedial actions but not for on-site remedial actions which only need to meet the substantive portions of a permit for the remedial action. Staff requested clarification on whether fencing would be used as part of land-use controls or not and why greenhouse gas emissions are considered as part of the "Nine-Criteria for Evaluation" by EPA under CERCLA. See site file for additional information. Louis Howard
6/2/2015 Document, Report, or Work plan Review - other The Alaska Department of Environmental Conservation (ADEC) has received the final Feasibility Study for OB942 (CS DB Hazard ID 26372). ADEC has no further comments on the final version of the document and approves the document. Louis Howard
9/25/2015 Update or Other Action Draft Proposed Plan received for review & comment. The remedy proposed at OB942 is land-use controls (LUCs). Munitions constituents associated with small arms debris – explosives residues in high enough amounts or concentrations to pose an explosive hazard, or any chemical compound or element originating from small arms such as fragments, shell casings, projectiles, etc. military munitions includes explosives; pyrotechnics; artillery ammunition; small arms ammunition; grenades; & devices & components of the above. Additional analytes including diesel-range organics; gasoline-range organics; polycyclic aromatic hydrocarbons; & benzene, toluene, ethylbenzene, & xylenes will be sampled in site soils in 2015. The following environmental remedial action objective (RAO) was established for OB942 based on regulatory guidance & the findings of previous investigations, actions, & assessments: Minimize or eliminate the potential for site worker exposure to munitions constituents associated with small arms debris, which could present a physical hazard Achievement of this RAO will be necessary to protect human health & the environment, allowing continued use of the site for the Air Force mission. Lead & antimony concentrations onsite are already below the ADEC Method Two soil cleanup levels (400 mg/kg & 41 mg/kg, respectively, for direct contact/ingestion that are protective of human health). Munitions constituents associated with small arms debris will remain onsite for more than five years; therefore, CERCLA five-year reviews would be required. Administrative approval should be possible, though more challenging than containment or complete removal because munitions constituents associated with small arms debris remains onsite. The effectiveness of this remedy is dependent upon adequate enforcement, & continued protectiveness must be verified through regular monitoring. Louis Howard
1/13/2016 Update or Other Action AFCEC Response to ADEC comments on the Draft Proposed Plan The Air Force would like to proceed with the proposed plan under the MMRP. Non-munitions related analytes will be sampled under the ERP in accordance with the State of AK regulations because they fall under the CERCLA petroleum exclusion rule. The proposed plan will be revised as follows to clarify the intentions of the site under the MMRP: Page 1, Title, add “Military Munitions Response Program.” 1st sentence, revise as follows: “This Proposed Plan, developed for the U.S. Department of Defense Military Munitions Response Program (MMRP), proposes a remedy for OB942, Open Burn Area, located at the Cape Romanzof Long-Range Radar Site (LRRS), Alaska.” 3rd paragraph, end, add the following sentence: Note that the most recent site investigation at OB942 recommended sampling for various fuel constituents. Fuel characterization will be conducted separately & presented under a separate cover as fuels do not constitute CERCLA hazardous substances as defined under the Petroleum Exclusion Rule [§101(14) (A) through (F)], & are therefore regulated by the State of AK & fall under a separate Department of Defense program (ERP). Page 3, CSE Phase I/II, revise last sentence: “Results for both lead & antimony were below the ADEC Method Two soil cleanup levels. Sampling for fuel constituents was recommended, & will be conducted under the ERP in 2016 or 2017. If fuel contamination exceeds acceptable levels as defined by ADEC, the need for additional remediation or measures to protect human health & the environment will be evaluated pursuant to State of AK regulations & guidance.” Page 5, “What is the Chemical of Concern”, revise the last paragraph as follows: “Additional analytes, including DRO; GRO; PAHs; & BTEX will be sampled as part of the ERP in 2016 or 2017. If these analytes are detected in concentrations that exceed ADEC cleanup levels, they will be addressed under the ERP in accordance with State of AK regulations & guidance. A separate decision document will be prepared for any additional analytes that are identified as part of ERP sampling planned for the future.” See site file for additional information. Louis Howard
2/17/2016 Update or Other Action ADEC has reviewed the responses to its comments on the Proposed Plan for OB942 and finds the responses acceptable. Please finalize the document. 1 hard copy and 1 electronic of the final version requested by ADEC for its files. Louis Howard
3/1/2016 CERCLA Proposed Plan Final Proposed Plan received for OB942. The Air Force has identified munitions constituents as the main contaminant that poses potential risk to human health and the environment at OB942. Munitions constituents are materials originating from unexploded ordnance, discarded military munitions, or other military munitions, including explosive and nonexplosive materials, and emission, degradation, or breakdown elements of such ordnance or munitions. Additional analytes including diesel-range organics; gasoline-range organics; polycyclic aromatic hydrocarbons; and benzene, toluene, ethylbenzene, and xylenes will be sampled as part of the ERP in 2016 or 2017. If these analytes are detected in concentrations that exceed ADEC cleanup levels, they will be addressed under the ERP in accordance with State of Alaska regulations and guidance. A separate decision document will be prepared for any additional analytes that are identified as part of ERP sampling planned for the future. The preferred alternative for OB942 is land-use controls. Under this alternative, land-use controls would be implemented to protect human health from exposure to munitions constituents associated with small arms debris. Land-use controls would be implemented to restrict invasive and residential activities and protect human health from exposure to munitions constituents associated with small arms debris. Land-use controls would include dig restrictions and signage, and the Air Force would file a notice of contamination with the Air Force real property office and in Alaska state land records. Additionally, the site would be added to the Land-Use Control Management Plan for Pacific Air Forces Regional Support Center Installations. Munitions constituents associated with small arms debris will remain onsite for more than five years; therefore, CERCLA five-year reviews would be required. The effectiveness of this remedy is dependent upon adequate enforcement, and continued protectiveness must be verified through regular monitoring. See site file for additional information. Louis Howard
4/13/2016 Update or Other Action Email from USFWS (T. Plucinski)on the draft PP for OB942: As for my review, I do not have any formal comments on the Proposed Plan since this site potentially poses more of a physical human health risk than anything, and the site is currently on Air Force property. The only comment I would make is that DoD agencies have made a pretty big push recently to downsize the property for which they are responsible in order to reduce their liability. Assuming that sometime in the future the Air Force would like to incorporate portions of the property into the Yukon Delta NWR, please note the USFWS will not accept the responsibilities associated properties with land-use or institutional controls. Therefore, the USFWS would suggest the Air Force address the hazards related to the munitions and remove contaminated material at the site in order to eliminate all human and environmental risk. Louis Howard
4/20/2016 Document, Report, or Work plan Review - other Staff approved the UFP-QAPP and Site-Specific Work Plans for LF003, SS016, SS017 and OB942 at Cape Romanzof LRRS, Alaska. ADEC is withholding its approval of SR018 site-specific work plan pending a signed Record of Decision. Louis Howard
10/6/2016 Update or Other Action OB942 Draft ROD received for review and comment. Selected remedy is land use controls (LUCs). The remedy will leave MCs and debris in place but put signage and dig restrictions on the premises. The LUCs will mitigate the potential for human exposure, remain protective of human health and the environment, and satisfy the RAO for OB942. This alternative passes threshold criteria, is protective of human health and the environment over the long-term, and is more implementable and less costly than capping or removal and offsite disposal. • No MCs or debris would be removed. • LUCs would be implemented to restrict land use and prevent the removal and transportation of MCs and debris. Signage would be installed to prevent unauthorized access. The USAF dig permitting system would be utilized. No unauthorized transport or disposal of soil or unauthorized digging/excavation would occur without ADEC notification and approval. The LUCs at OB942 would be incorporated into the USAF LUC Management Plan. • CERCLA five-year reviews would be required to evaluate the long-term protectiveness of the remedy. • The approximate cost for this alternative is $0.43 million; the estimated project duration would be 0 days. • This alternative would comply with all chemical-, location-, and action-specific ARARs, including RCRA, the Alaska Oil and Other Hazardous Substances Pollution Control regulations (18 AAC 75), the Clean Water Act (33 USC 1251 et seq; Section 404: 33 USC 1344; 40 CFR 230), and the Migratory Bird Treaty Act (16 USC 703-712; 50 CFR Parts 10, 20, 21). See site file for additional information. Louis Howard
10/26/2016 Document, Report, or Work plan Review - other Comments provided on the draft ROD. Main comments were for MC not being above levels that allow for UU/UE. The reason for the ICs is the potential (low) for MEC in the uninvestigated anomalies remaining on the site. Other comments were regarding the surface water, sediment and GW pathways for human receptors being incomplete and the ecological receptors are potentially incomplete. See site file for additional information. Louis Howard
4/14/2017 Update or Other Action Site Investigation (draft) received for review and comment. The purpose of this SI was to further investigate soil quality at Site OB942 and determine whether the conceptual site model and the remedial alternatives proposed in the FS remained valid for the site. Discrete soil samples were field screened and submitted for laboratory analysis to evaluate whether petroleum constituents typically associated with accelerants (gasoline or diesel), commonly utilized to burn small arms munitions, were present in surface and subsurface soils of the site at concentrations that exceeded their respective ADEC Method Two Human Health Soil Cleanup Levels, for locations within the under 40-inch precipitation zone per 18 AAC 75. Response to Comment No. 1 included in Appendix C of the 2015 FS noted that if petroleum constituents were identified in exceedance of ADEC regulatory standards, OB942 would be transferred into the AFCEC ERP and the FS would be amended. Based on the analytical results of the 70 discrete soil samples collected and analyzed during the implementation of this SI at Site OB942, DRO, GRO, RRO, BTEX, and PAHs are not present in surface and subsurface soils at concentrations that exceed their respective ADEC Method Two Soil Cleanup Levels. Based upon these findings, no additional investigation for hydrocarbons is warranted for Site OB942 and it is recommended that the site be considered for regulatory Site Closure. See site file for additional information. Louis Howard
4/25/2017 Document, Report, or Work plan Review - other Staff provided comments on the draft Site Investigation for OB942. A PID does not report concentrations of contaminants in mg/kg, but instead PIDs typically report results in total organic vapors in ppm (or in some cases ppb) units. Unless AFCEC has documentation that it has confirmed there are not buried small arms or anomalies at depths greater than two (2) feet below ground surface and has subsequently dealt with any anomalies appropriately, then the most OB942 could be eligible for is “cleanup complete with institutional controls”. See site file for additional information. Louis Howard
9/13/2022 CERCLA SI On 9/13/2022 ADEC approved the FINAL Quality Assurance Project Plan, Off-Base Drinking Water Site Inspections and Miscellaneous Tasks, Three U.S. AF Long Range Radar Stations, Alaska, Dated September 2022. The objective of the Quality Assurance Project Plan (QAPP) is to provide a response action for per- and polyfluoroalkyl substances (PFAS)-impacted drinking water for areas surrounding three remote U.S. Air Force (USAF) Installations, Cape Romanzof Long Range Radar Station (LRRS), Indian Mountain LRRS and Sparrevohn LRRS. The project goals are to determine if off-site migration of polyfluoroalkyl substances (PFAS) has potentially impacted off-site groundwater and surface water used as drinking water used by residences or commercial businesses, and if a response action will be needed and required for applicable PFAS impacted drinking water sources. The USEPA Lifetime Health Advisory levels for perfluorooctane sulfonate (PFOS) and perfluorooctanoic acid (PFOA), and the sum of the concentrations (PFOS+PFOA) of 70 nanograms per liter (ng/L) will be used as the action level for drinking water sources (both groundwater and surface water). Axl LeVan
5/16/2023 CERCLA SI DEC reviewed and approved the "Final Site Inspection and No Further Response Action Planned Report for Per and Polyfluoroalkyl Substances at Cape Romanzof Long Range Radar Station, Alaska, May 2023." The Site Inspection (SI) report for Cape Romanzof Long Range Radar Station (LRRS) has been prepared to report the results of activities performed as part of the SI and recommend future activities at the installation. The report recommended an Remedial investigation at FTA #1, Non-FTA No.4 – Landfill No. 4, and Non-FTA No.6 – Biocell 3. It also recommended No Further Response Action Planned at Non-FTA No. 1 – Spill/Leak No. 7, Non-FTA No. 2 – Landfill No. 2, Non-FTA No. 3 – Landfill No. 3, and Non-FTA No. 5 – Landfill No. 5. DEC agreed with the recommendations. Axl LeVan
12/8/2023 CERCLA ROD Periodic Review DEC reviewed and provided comments on the "Draft 2023 Five-Year Review Report for DP011, LF003, SS010, SS013, SS014, SS015, SS016, SS017, ST009, and OB942 at Cape Romanzof Long Range Radar Station, Alaska, November 2023". The purpose of a Five-Year Review (FYR) is to evaluate the implementation and performance of a remedy in order to determine if the remedy is and will continue to be protective of human health and the environment. This report is the first FYR for OB942. Axl LeVan
1/30/2024 CERCLA ROD Periodic Review DEC reviewed and approved the "Final 2023 Five-Year Review Report for DP011, LF003, SS010, SS013, SS014, SS015, SS016, SS017, ST009, and OB942 at Cape Romanzof Long Range Radar Station, Alaska, January 2024". All DEC comments were addressed by the revised version of the document. Axl LeVan

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