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Site Report: Kulis ANG - Basewide PFAS

Site Name: Kulis ANG - Basewide PFAS
Address: 6000 Air Guard Road; Former Kulis Air National Guard Base, Anchorage, AK 99502
File Number: 2100.38.559
Hazard ID: 26531
Status: Active
Staff: Ginna Quesada, 9074515960 ginna.quesada@alaska.gov
Latitude: 61.163819
Longitude: -149.973978
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

Confirmed perfluorinated compounds (PFCs) released during KULIS Air National Guard Base (ANGB) operations (1955-2011). Aqueous film forming foam (AFFF), containing PFCs, was used at the former Kulis ANGB for extinguishing petroleum fires and in fire suppression systems at several of the installation buildings. Based on the research conducted, ten potential AFFF areas were identified at former Kulis ANGB and may potentially require further action. Soil and groundwater are confirmed to be contaminated with PFCs above cleanup levels. Groundwater is contaminated in one monitoring well. While not listed on the NPL, investigation at the former Kulis Air National Guard Base must follow CERCLA process per E.O. 12580 [e.g. CERCLA Sections 104(a), (b), and (c)(4), 113(k), 117(a), and (c), 119, and 121) with respect to releases or threatened releases where either the release is on or the sole source of the release is from any facility or vessel under the jurisdiction, custody, or control of their departments. These functions must be exercised consistent with CERCLA Section 120 Federal Facilities. State laws. -- State laws concerning removal and remedial action, including State laws regarding enforcement, shall apply to removal and remedial action at facilities owned or operated by a department, agency, or instrumentality of the United States when such facilities are not included on the National Priorities List. The preceding sentence shall not apply to the extent a State law would apply any standard or requirement to such facilities which is more stringent than the standards and requirements applicable to facilities which are not owned or operated by any such department, agency, or instrumentality.].

Action Information

Action Date Action Description DEC Staff
8/31/1984 Update or Other Action KANG Drainage Study received. Recommendations A new storm sewer should be constructed. The drainage ditch should be regraded between Nodes H and L in Basin IV. We recommend that steam thaw pipes be installed in culverts in major drainage ways. As a general drainage scheme, large ditches (such as extend around the flight line) are very effective in that they provide an area for winter snow disposal which readily drains during break-up. We recommend that the culvert inlet at Node R be modified such that the large drainage ditch around the perimeter of the flight line in Sub-basin IV-E could serve as a surge basin. Low areas and swamps which exist in undeveloped areas of the study area provide a natural solution to runoff water quantity and quality problems. New facilities should provide 515 cf runoff storage at Node A in Sub-basin IV-A. In sidehill areas, ditches constructed in kiess silt should be lined with gravel or rock to protect the invert from erosion. At the outlet of Basin V a cutoff ditch should be constructed to capture future overland flow. A culvert should be installed in the perimeter road at the outfall of Basin II. See site file for additional information. Louis Howard
7/31/1995 Update or Other Action Base Master Plan received. The major goal of the Kulis Air National Guard (ANG) Base Master Plan is to identify opportunities for improving the mission capabilities, readiness, and environment of Kulis ANG Base and the 176th Group. Results of these initiatives are expected to enhance the base's image as an excellent installation to support airlift, rescue, and training requirements into the next century. This plan looks forward 20 years and provides a framework for daily decision making in regard to facility needs and sitings. This plan is a tool used to achieve the base objectives and goals that have been established as necessary to mission fulfillment. As a tool, this plan must be reviewed and updated on an annual basis to keep the plan abreast of changing needs and goals. Outlined in this plan is the mission expansion from the existing 16 aircraft to a long-range mission of 30 aircraft. To fulfill this mission, short- and long-range installation plans have been developed in a manner that will maximize mission accomplishment, optimize existing facilities, and provide the most efficient and professional environment possible. The existing total land area of 129.47 acres is leased from the AlA. Significant potential still exists for future development within the existing installation boundary. See site file for additional information. Louis Howard
9/29/2000 Update or Other Action EA for Proposed short term construction projects at KANGB. This environmental assessment (EA) evaluates potential environmental impacts associated with proposed short-term construction projects at Kulis Air National Guard Base (ANGB). The purpose of the proposed action is to implement eleven short-term construction projects that are critical for maintaining efficient base operations and enhancing the orderly development of Kulis ANGB. These projects are needed to consolidate common or compatible organizational and facility uses to maximize land use compatibility and facility efficiency. Implementation of the proposed action would help accomplish this by providing enhanced development, thereby reducing existing facility utilization inefficiencies and circulation problems at Kulis ANGB. The primary goal of the proposed short-term construction projects at Kulis ANGB is to improve the unit's mission capabilities and readiness in order to support airlift, rescue, and training requirements. In order to meet these requirements, eleven construction projects, including the expansion of the existing apron/taxiway and the demolition of four facilities would be implemented and completed within the next 5 years. Proposed demolition is necessary in order to replace outdated facilities or to facilitate new construction. New facilities would be located in areas more compatible from a land-use efficiency perspective. See site file for additional information. Louis Howard
5/29/2009 Update or Other Action Environmental Baseline Study received. The majority of the 129-acre property of Kulis ANGB proposed for transfer is classified as a Category 1 site (i.e., areas with no releases of hazardous substances) and will be referred to as one site. Smaller areas within the property boundaries have been separated from this classification as follows: eight (8) Category 2 sites (i.e., areas with only petroleum releases), no Category 3 sites (i.e., areas with releases that do not require remediation), four (4) Category 4 sites (i.e., areas where releases have occurred and all remedial actions have been completed), one (1) Category 5 site (i.e., areas where releases have occurred and all remedial actions are underway), no Category 6 sites (i.e., areas where releases have occurred, but remedial actions have not been implemented), and no Category 7 sites (i.e., areas requiring further investigation). These specific sites are listed as follows: • Category 1 Sites—The 129- acres of Kulis ANGB property (except as noted below). • Category 2 Sites—Buildings 00002 (Helicopter Maintenance); 00014 (Refueler Parking Canopy); 00023 (Supply & Equipment Warehouse - parking lot); 00046 (Corrosion Control Facility); 00047 (Aerospace Ground Equipment); east of 00050 (Civil Engineer Squadron); and Former Refueling Station (year 2000 location); Roundabout Road (southern intersection with Denali View Drive). • Category 3 Sites—None identified. • Category 4 Sites—Site 00117, A.K.A. Site 1; Site 00012, A.K.A. Site 2; POL Yard (specifically footprint of former ASTs 1, 2 and 3; Aircraft Parking Apron. • Category 5 Sites—Building 00042 (Fire Rescue Station). • Category 6 Sites—None identified. • Category 7 Sites—None identified. Corrective actions are recommended as follows to eliminate items of concern: • Base personnel have indicated that the closure report has been submitted to ADEC, however, the site is not officially closed until approval is received from the state. Once the site has been closed by the state, this will no longer be an item of concern. • Based on the assumed use of the buildings (airport administration), corrective actions are not needed at this time. Future owners/occupants should be aware that the older buildings might contain lead-based paint. If the paint begins to deteriorate or if children will frequent a building, the paint should be tested. No further study or assessment of the surveyed parcels is recommended at this time. Therefore, it is recommended that the planned property transfer proceed as proposed. See site file for additional information. Louis Howard
6/26/2015 Update or Other Action While not listed on the NPL, the Air Force must follow CERCLA process per E.O. 12580 [e.g. CERCLA Sections 104(a), (b), and (c)(4), 113(k), 117(a), and (c), 119, and 121) with respect to releases or threatened releases where either the release is on or the sole source of the release is from any facility or vessel under the jurisdiction, custody, or control of their departments. These functions must be exercised consistent with CERCLA Section 120 Federal Facilities. State laws. -- State laws concerning removal and remedial action, including State laws regarding enforcement, shall apply to removal and remedial action at facilities owned or operated by a department, agency, or instrumentality of the United States when such facilities are not included on the National Priorities List. The preceding sentence shall not apply to the extent a State law would apply any standard or requirement to such facilities which is more stringent than the standards and requirements applicable to facilities which are not owned or operated by any such department, agency, or instrumentality]. Louis Howard
7/30/2015 CERCLA PA Preliminary Assessment received. This Perfluorinated Compounds (PFCs) Preliminary Assessment (PA) provides findings from research conducted to determine whether and where aqueous film forming foam (AFFF), containing PFCs, was stored, handled, used or released at the former Kulis Air National Guard Base (ANGB), located in Anchorage, Alaska. Research was conducted for the years 1970 through the installation closure in 2011 using: 1) personnel interviews; 2) online research; and, 3) archival research at the Air Force Historical Research Agency (AFHRA) and the Air Force Safety Center (AFSEC). AFFF, containing PFCs, was used at the former Kulis ANGB for extinguishing petroleum fires and in fire suppression systems at several of the installation buildings. Based on the research conducted, ten potential AFFF areas were identified 1 at former Kulis ANGB and may potentially require further action. Building 2 (Helicopter Maintenance), Building 3 (Aerial Port and Hangar), Building 9 (Former Vehicle Maintenance/Fire Station), Building 42 (Fire Rescue Station), Building 45 (Fuel Systems Hangar), Roundabout Road, Building 1005 (Fire Rescue Storage), T-1003 or T-1004, North Aircraft Apron, West Aircraft Apron. See site file for additional information. Louis Howard
9/25/2015 Document, Report, or Work plan Review - other Staff commented on the draft Preliminary Assessment for PFCs. The Alaska Department of Environmental Conservation is not obligated to follow or comply with the DoD Instruction nor the subsequent Air Force Interim Guidance (with attachment) on Perfluorinated Compounds (Mark A. Correll, SES, P.E., USAF), September 2012. ADEC requests that the nearest wells (i.e. there are 76 inactive USGS wells within one mile radius of property) be utilized to determine groundwater flow and gradient in the vicinity of the former Kulis ANGB. In addition, ADEC has identified at least 50 or more private wells or subsurface water rights locations and two drinking water protection areas within a one mile radius of the former Kulis ANGB. See site file for additional information. Louis Howard
3/11/2016 Site Added to Database A new site has been added to the database Mitzi Read
7/6/2016 Update or Other Action Draft Installation-Specific Uniform Federal Policy – Quality Assurance Project Plan Addendum Site Inspection of PFC Release Areas at Multiple BRAC Installations: Former Kulis Air National Guard Base received for review and comment. The primary objective of the SI at the former Kulis ANGB is to conduct an investigation of AFFF Areas 1 through 10 (Figures 2, 3, and 4), previously identified as part of the PA (AMEC Foster Wheeler Environment and Infrastructure, Inc. [AMEC], 2016) to determine if PFCs are present in groundwater, soil, and/or surface water, determine if concentrations of PFOS, PFOA or a sum of both in groundwater, exceed 0.07 micrograms per liter (µg/L). identify potential human health pathways and receptors, and where there is a reasonable expectation that PFCs may be present, determine if drinking water wells are impacted. While not listed on the NPL, Kulis ANGB must follow CERCLA process per E.O. 12580 [e.g. CERCLA Sections 104(a), (b), and (c)(4), 113(k), 117(a), and (c), 119, and 121) with respect to releases or threatened releases where either the release is on or the sole source of the release is from any facility or vessel under the jurisdiction, custody, or control of their departments. These functions must be exercised consistent with CERCLA Section 120 Federal Facilities. State laws. -- State laws concerning removal and remedial action, including State laws regarding enforcement, shall apply to removal and remedial action at facilities owned or operated by a department, agency, or instrumentality of the United States when such facilities are not included on the National Priorities List. The preceding sentence shall not apply to the extent a State law would apply any standard or requirement to such facilities which is more stringent than the standards and requirements applicable to facilities which are not owned or operated by any such department, agency, or instrumentality.]. See site file for additional information. Louis Howard
7/6/2016 Update or Other Action Final Quality Program Plan for Site Inspection of Potential Perfluorinated Compound Release Areas at Multiple BRAC Installations Contract No. FA8903-08-D-8785 Task Order No. 0017 received along with site-specific UFP QAPP Addendum for field work on PFCs at the former facility. Perfluorinated Compound (PFC) Release Areas at Multiple Base Realignment and Closure (BRAC) Installations. This is a general QPP designed to provide program-level information for investigation and release determination activities at Aqueous Film Forming Foam (AFFF) areas that will be conducted at 17 United States Air Force (USAF) BRAC installations including Kulis ANGB. The primary objective of the SI is to conduct investigations of potential AFFF areas previously identified in the PA conducted across 17 BRAC installations to 1. determine if PFCs are present in groundwater, soil, surface water, sediment, and/or other environmental media as necessary, 2. determine if concentrations of PFOS, PFOA or the sum of both exceed 0.07 µg/L in groundwater, 3. identify potential human health receptors and pathways, and 4. where there is a reasonable expectation that PFCs are present, determine if drinking water wells are impacted. State-specific screening criteria or action levels for PFCs will be included in the Installation-Specific UFP QAPP Addenda as appropriate. Background samples are not proposed to be collected during SI activities. However, if results of the field sampling program indicate that additional investigation is warranted, then background sampling will be conducted during the remedial investigation as appropriate. Inhalation has not been identified as a potential exposure pathway for PFCs; therefore air sampling will not be conducted. The SI field investigations will be documented in Installation-Specific SI Reports, which will include revised conceptual site models (CSMs), exposure pathways and potential receptors, and an evaluation of data at each AFFF area and recommendations for • no further action, • remedial investigation, or • implementation of mitigation measures (time critical or non-time critical removal action). See site file for additional information. Louis Howard
7/13/2016 Document, Report, or Work plan Review - other Staff reviewed the Draft Installation-Specific UFP-QAPP Addendum SI of PFCs releases. Main comments were regarding the need to complete ecoscoping forms on the seven areas being investigated for PFCs and that ADEC has calculated cleanup levels for PFOS and PFOA that are lower than the AFCEE/TDV soil screening levels being proposed for use. Finally, staff requested that soil borings be sampled at 0-2' bgs and 13'-15' bgs instead of 0-2' and 10-12' bgs and that well surveys include researching of information from ADEC's Drinking Water Program, Municipality of Anchorage's On-Site Water & Wastewater Program as well as Alaska Department of Natural Resources Well Log Tracking System (WELTS). See site file for additional comments. Louis Howard
8/15/2016 Site Characterization Workplan Approved On July 28, 2016, ADEC received the response to comments for the “Installation-Specific UFP-QAPP Addendum Site Inspection of PFC Release Areas” work plan. ADEC conditionally approves the responses to comments and the UFP-QAPP may be finalized. The PFOS/PFOA cleanup levels (included in the Draft work plan) used by AFCEC, to determine presence or absence, are greater than what ADEC will be adopting into 18 AAC 75 this fall/winter 2016 [actually on 11/06/2016]. The PFOS and PFOA cleanup levels in the draft 18 AAC 75 regulations will be used by ADEC staff when reviewing the report for the PFC inspection at the Former KANGB. If the levels of PFOS and PFOA detected at the site exceed ADEC cleanup levels listed in 18 AAC 75 (as revised), then ADEC will require additional work delineating the nature and extent of contamination. Proceeding with the work using the higher screening levels or presence/absence thresholds than ADEC’s draft cleanup levels is at AFCEC’s risk. Louis Howard
4/7/2017 Document, Report, or Work plan Review - other Letter work plan addendum received and approved by ADEC for implementation The proposed supplemental investigation activities include the following: 1) Installation of five groundwater monitoring wells to better define groundwater flow directions and concentrations of PFCs that may be migrating on or off-site. The attached Figure 1 illustrates the proposed well locations. Well depths will correspond to first water encountered, historically 75-85 feet below ground surface (bgs). Boreholes for each well will be advanced to penetrate up to five feet into the top of the reported confining clay layer beneath the former ANGB or determine if the confining unit is absent. The borehole will be backfilled with bentonite to the top of the clay and the monitoring well set above the confining clay layer. Based on lithologic observations from new monitoring wells KULPMW 0l0, -11, -13, and 14, if the confining clay unit is absent along the former eastern boundary, monitoring well KULPMWO 12 will be advanced and installed to depths up to 140 ft bgs. All well screens will be 10 feet long. Each new monitoring well will be surveyed by a professional land surveyor to determine top of casing elevation to support potentiometric mapping. 2) Groundwater samples will be collected from each of the nine monitoring wells installed in 2016 to confirm previous results as well as the five newly installed wells. Samples will be analyzed for PFCs on an expedited turnaround time. One of the duplicate samples will be collected from well KULPMW007. 3) Collect a complete round of water levels from the 14 wells (nine existing and five new) to determine groundwater flow direction. 4) The drainage ditch along the south side of Tug Road (Figure 1) will be visually investigated to determine potential contributions and discharge points. Louis Howard
8/14/2017 Offsite Soil or Groundwater Disposal Approved Granted approval to transport IDW PFC-contaminated media to permitted disposal facility: Clean Harbors Grassy Mountain LLC in Utah. Louis Howard
8/14/2017 Exposure Tracking Model Ranking Initial ranking with ETM completed for source area id: 80112 name: PFC Contamination Louis Howard
5/23/2018 Document, Report, or Work plan Review - other Staff reviewed and commented on the draft site investigation report for AFFF areas on the former Kulis Air National Guard Bases. Main comment was the use of Table C cleanup levels for surface water samples with exceedances of perfluorinated compounds that flow in ditches and some into wetlands leading to surface water bodies. Additional comments were to include surface water in any additional remedial investigation under CERCLA at the site. See site file for additional information. Louis Howard
9/17/2018 Document, Report, or Work plan Review - other A letter was sent regarding the 2018 ADEC tech memo which establishes drinking water action levels for six PFAS when detected in groundwater or surface water used for drinking at Former Kulis Air National Guard Site. The tech memo establishes drinking water action levels for six PFAS when detected in groundwater or surface water used for drinking. These compounds, selected in accordance with the U.S. Environmental Protection Agency’s third Unregulated Contaminant Monitoring Rule (UCMR3) under the Safe Drinking Water Act, include: perfluorooctane sulfonate, also known as perfluorooctane sulfonic acid (PFOS), perfluorooctanoic acid, also known as perfluorooctanoate (PFOA), perfluorononanoic acid (PFNA), Perfluorohexanesulfonic acid (PFHxS), Perfluoroheptanoic acid (PFHpA), and perfluorobutane sulfonate (PFBS). Based on review of available information, DEC considers these six UCMR3 compounds to be hazardous substances under state law. See site file for additional information. Louis Howard
9/17/2018 Document, Report, or Work plan Review - other Staff sent a letter notifying Air Force of Action Levels for PFAS in Water and Guidance on Sampling Groundwater and Drinking Water Technical Memorandum dated August 20, 2018. Action levels for UCMR3 PFAS compounds in groundwater and surface water used as drinking water are as follows: Where one or more of the PFAS compounds, PFOS, PFOA, PFNA, PFHxS, or PFHpA are detected in a water sample analytical result, the sum of the concentrations for all detected compounds will be compared to an action level of 0.07 µg/L. Where PFBS is present in a water sample analytical result, the detected concentration will be compared to an action level of 2.0 µg/L. Please note that all future sampling results for PFAS-impacted groundwater, surface water, and pore water must include results for all six UCMR3 PFAS compounds. See site file for additional information. Louis Howard
11/20/2018 Meeting or Teleconference Held Teleconference held with Air Force project manager regarding sampling of drinking water wells adjacent to former KANGB site. Upper level management review of the site was conducted and the result was not to continue with adding additional monitoring wells at the site, but instead to concentrate on the drinking water well sampling in the easterly direction within a one mile radius of the site. A contractor will be chosen by Fall 2019 timeframe and coordination with ADEC staff will be forthcoming on the sampling design issues and public outreach before, during and after of the proposed drinking water wells. Louis Howard
9/6/2019 Workplan Requested Staff requested the U.S. Air Force sample potable water wells potentially impacted by contamination from KANGB that were identified in the “Final Site Inspection for Aqueous Film Forming Foam Areas at Former Kulis Air National Guard Base” dated March 2019 (the SI). ADEC is concerned the sampling of the wells identified in the SI has not yet occurred, and receptors are potentially exposed to unacceptable levels of PFOA/PFOS. As of August 6, 2019, the U.S Air Force indicated it plans to sample the wells for PFOA/PFOS in April 2020. ADEC requests the U.S. Air Force sample the wells for PFOA/PFOS as soon as possible. Louis Howard
3/28/2020 Update or Other Action [Drinking] Water Well Survey to Supplement the Site Inspection of Per-& Polyfluoroalkyl Substance (PFAS) Release Areas received for review & comment. The well survey will focus on the eastern residential area adjacent to the former Kulis Air National Guard Base (ANGB) base boundary. Although this area appears to be upgradient of the contaminated AFFF Areas identified in the NE corner of the former ANGB in the SI, there is uncertainty regarding groundwater flow direction & properties are less than 100 feet from the base boundary. The well survey & sampling drinking activities will determine if active water wells are located on these properties & if PFOS & PFOA are present in drinking water. The Air Force will provide ADEC with updates on the responses to well survey forms, door to door survey, & sampling as necessary. If sampling is performed, drinking water sample results will be supplied to the well owners in individual letters after data have been validated. The results will also be provided to ADEC with recommendations for additional sampling as necessary. See site file for additional information. Louis Howard
4/6/2020 Document, Report, or Work plan Review - other Staff provided comments on the water well survey at the former Kulis Air National Guard Base (FKANGB). Main comments were to request further sampling of water wells to the south as well as the proposed east side of the FKANGB boundaries. ADEC will require that future sampling of drinking water wells will encompass a one mile radius of the site for PFAS contamination. Sampling, analysis and reporting of PFAS contamination will be required for all analytes of the Method 537.1 rev. 1.1/537.1 and not just the 14 proposed in the letter work plan. Finally, ADEC will require the use of updated regulations, updated or new guidance documents that are now in effect since the UFP-QAPP work plan was finalized in 2016. See site file for additional information. Louis Howard
12/17/2020 Update or Other Action The USAF provided the results of sampling two private drinking water wells along Air Guard Road on 18 November 2020, downgradient of Kulis Air National Guard Base, for per- and polyfluoroalkyl substances (PFAS) including PFOA and PFOS. No PFAS were detected, and the limits of detection for the analyses were sufficiently low to meet DEC's cleanup level and EPA's lifetime health advisory number for PFOA+PFOS. Melinda Brunner
4/8/2021 Meeting or Teleconference Held DEC staff met with the U.S. Air Forces' (USAF's) representative to discuss the draft "Relative Risk Site Evaluation" (RRSE) completed by the USAF for CAT56P, due to the presence of PFOA and PFOS. The RRSE is used by the USAF to help prioritize its sites for work, based on risk. Kulis has an "overall site category" of "high" because there is unrestricted access to contamination in soil, and there are drinking water wells within four miles downgradient of known groundwater contamination. Sampling to date has not located any drinking water wells are impacted. Melinda Brunner
11/23/2021 Document, Report, or Work plan Review - other DEC reviewed and provided comments on soil stockpile work plan associated with apron updates. William Schmaltz
12/9/2021 Document, Report, or Work plan Review - other DEC approved work plan summarizing methodology to sample stockpiles that will be constructed from soil removed from the site as part of apron upgrades. William Schmaltz
1/31/2022 Offsite Soil or Groundwater Disposal Approved DEC approved disposal of 70 cubic yards of soil at Columbia Ridge Landfill in Arlington, Oregon. William Schmaltz
5/2/2022 Document, Report, or Work plan Review - other DEC approves RI QAPP for soil PFAS specific soil and groundwater investigation at the site. William Schmaltz
1/19/2023 Risk Assessment Workplan Approved DEC reviewed and approved Risk Assessment Work Plan for data gathered during the 2023 RI at the site. William Schmaltz
3/28/2024 Document, Report, or Work plan Review - other DEC reviewed the Technical Memorandum Draft 2024 Remedial Investigation Sampling Plan CERCLA Remedial Investigation at Former Kulis Air National Guard Base (ANGB), Alaska, Dated March 6, 2024. The sampling plan describes the supplemental remedial investigation activities to be conducted at the Former Kulis Air National Guard Base, in Anchorage, Alaska. Per and polyfluoroalkyl substances (PFAS) will be investigated in surface water, groundwater, and soil to define the nature and extent of contamination at the site. Ginna Quesada
4/4/2024 Document, Report, or Work plan Review - other DEC approved the Technical Memorandum Final 2024 Remedial Investigation Sampling Plan CERCLA Remedial Investigation at Former Kulis Air National Guard Base (ANGB), Alaska, Dated April 4, 2024. Ginna Quesada

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