| Action Date |
Action |
Description |
DEC Staff |
| 5/1/1939 |
Update or Other Action |
In 1939, increasing world tensions caused the establishment of Elmendorf Field just outside of Anchorage. One year later, the name Fort Richardson was adopted by the US War Department in memory of Brigadier General Wilde P. Richardson, a Texas engineer and 1884 West Point graduate who served three tours of duty in the rugged Alaska Territory between 1897 and 1917. During this time, General Richardson commanded troops along the Yukon, supervised construction of Fort Egbert near Eagle and Fort William H. Seward near Haines, and served as commander of the American Expeditionary Force, North Russia. As head of the War Department’s Alaska Road Commission during 1905–1917, he was responsible for much of the surveying and building of early railroads, roads and bridges that helped the state’s settlement and growth. The Valdez-Fairbanks trail, surveyed under his direction in 1904, was named the Richardson Highway also in his memory.
Between 1939 to 1945, approximately 151,180 acres of land were withdrawn for military use. Fort Richardson originally resided on land that Elmendorf AFB currently occupies. When the Japanese attacked Pearl Harbor in 1941, Fort Richardson was charged with defending Alaska from invasion and coordinating the Alaskan war effort. Before the outbreak of World War II, military strength in Alaska was less than 3,000; it soon grew to 7,800 troops stationed at Fort Richardson alone, including the 4th Infantry, 81st Field Artillery, and 75th Coast Artillery (Anti-Aircraft). As the war progressed, Fort Richardson’s mission expanded significantly as the logistics base for numerous Army garrisons and the Air Corps.
Nevertheless, Fort Richardson relinquished much of its training lands, with over 80,000 acres of training and maneuver lands, and over one million acres of bombing ranges being excessed. In addition, approximately 13,000 acres was transferred to the Air Force. Army troops were redesignated as the United States Army Alaska (USARAL) on November 15, 1947, and assigned to the Alaskan Command, the nation’s first unified command staffed jointly by Army, Navy, and Air Force officers. Headquarters for USARAL were established at Fort Richardson. At that time the post was located on what is now Elmendorf Air Force Base. After the establishment of the Air Force as a separate service in 1947, the Army post was rebuilt on its present location in 1950.
In 1950, Fort Richardson was moved east to its current location, and 9,042 acres were transferred to the Air Force, which later became Elmendorf AFB.
From 1945 to 1955, the military returned approximately 85,000 acres to the Department of the Interior. Many EOs stipulated the return of these lands following the end of World War II. A letter from the Secretary of the Interior, dated Oct. 27, 1952, granted permission for the military to retain jurisdiction over withdrawn lands until they were not needed for military use. From 1955 to 1965, the Department of the Army released approximately 10,000 acres to various entities such as the US Air Force, State of Alaska, and the Bureau of Land Management (BLM), and acquired approximately 6,000 for Army use. From 1966 to the present, Fort Richardson’s boundaries have remained fairly stable. Leases from the BLM have expanded the boundary to the east and in the south. |
Jennifer Roberts |
| 5/7/1941 |
Update or Other Action |
HQ 81st Field Artillery Battalion Fort Richardson, Alaska. Subject: Acquistion of land in the vicinity of Anchorage for Defense and Training Purposes. To: The Commanding General, Alaska Defense Command, Fort Richardson, Alaska. Thru: The Commanding Officer, Fort Richardson, Alaska.
1. It is believed necessary to the land defense of the Fort Richardson area that the War Department obtain or regain COMPLETE CONTROL of the following areas as shown on the map of Fort Richardson and vicinity, scale 1/40,000, dated January 1941 by the 75th Coast Artillery (AA): Pt. Woronzof Military Reserve, Pt. MacKenzie Military Reserve, and Fire Island Military Reserve. It is understood that this would involve only the purchase of property from two individuals. A totally unimproved tract known as lot 3, sec. 21 on Pt. Woronzof from one Laura Elvig and a plot in Pt. MacKenzie held by one Zabaglio. Enclosed herewith is a description of the properties involved.
It is believed that a defense against invasion by water necessitates installations involving the use of the three areas mentioned. It is also proposed to use the Pt. Woronzof area for TRAINING Purposes for fire against both fixed and moving targets in the water for problems involving defense against possible landing operations in this area.
2. It is further requested that a study be made to the feasibility of acquiring all of the land due South and due East of, and to include, Section 21 of the Township 13N-R3W, including all unsurveyed public domain to the crest of the Chugach Mountains from the line of the Alaskan Railroad on the south to Ship Creek Canyon on the north. This land would be used for maneuver purposes and for a Field Artillery firing range. A preliminary survey of this area indicates that this would involve the purchase of only two proven homesteads and the improvements on about fifteen others. It is believed that this area offers the best possibilities for a field artillery range in the vicinity of Fort Richardson. |
Jennifer Roberts |
| 11/11/1980 |
Update or Other Action |
Original documentation of the migratory bird die-off on the Flats, Fort Richardson, Alaska, occurred in 1980 when aerial overflights noted dead swans. |
Jennifer Roberts |
| 11/11/1981 |
Update or Other Action |
In the late summer and fall of 1981 Army biologist, Alan Bennett, discovered what he considered an unusually high number of duck carcasses in a sector of the Eagle River Flats, which also included several dead swans. Subsequent, random searches by the Army, U.S. Fish and Wildlife Service (USFWS), and Alaska Department of Fish and Game (ADFG) discovered abnormally high numbers of dead waterfowl, indicating a serious problem. |
Jennifer Roberts |
| 7/19/1982 |
Site Visit |
DRXTH-AS-IA-82328A Installation Assessment of the Headquarters, 172d Infantry Brigade (Alaska), Fort Richardson. An onsite installation assessment was conducted by USATHAMA July 19-23, 1982 at Headquarters, 172d Infantry Brigade (Alaska), Fort Richardson (FR), Alaska, to determine the presence of any toxic or hazardous materials and to assess the potential for offpost migration. Based on the findings of this assessment, a field survey, was not recommended.
The Eagle River Flats Impact Area, located on the Eagle River delta in the northwestern section of the reservation, serves .50-caliber (cal) machinegun and M-60 machinegunranges, 40-mm/90-mm ranges used for 90-mm recoilless rifles (RR), M-203 grenade launchers, rockets, and missiles. The Eagle River Flats delta has been the primary impact area since prior to 1944 (FR, 1977a). A second impact area, the Davis Range, is located southeast of Bunker Hill. This impact area receives M-60,M-6, 90-mm RR, M-203 grenade launcher, and bangalore torpedoes.
Currently, 105-mm artillery and 81-mm mortar rounds are the largest rounds fired. Explosive ordnance disposal (EOD) records and reports indicate the previous use of l55-mm artillery; possibly 8-in mortars; tube-launched, optically-tracked, wire-command link (TOW) missiles;
light anti-tank weapon (LAW) rockets; and Improved Conventional Munitions (ICM) rounds, consisting of 105 mm rounds filled with HE bomblets.
No depleted uranium (DU) rounds or biological agents have been used. Chemical rounds used include riot control agents CS and CN, white phosphorus (WP), smoke, and incendiary rounds. |
Jennifer Roberts |
| 8/1/1983 |
Preliminary Assessment Approved |
Waterfowl Mortality Eagle River Flats (ERF), August 16, 1984 by Alan Bennett, U.S. Fish and Wildlife Service (USFWS) Biologist. Results 1500 to 2000 waterfowl carcasses were estimated in Eagle River Flats (ERF) on Fort Richardson. Suspected that toxic chemicals released from artillery firing was somehow the cause of the mortalities. |
Jennifer Roberts |
| 8/1/1983 |
Update or Other Action |
Investigation of Waterfowl Mortality at ERF, February 1988 by Alaska Fish and Wildlife Research Center and National Wildlife Health Research Center; Reviewed the 1983 through 1985 test results on the carcasses of 60 birds but not conclusive as to cause of death. |
Jennifer Roberts |
| 11/11/1983 |
Update or Other Action |
Ground searches conducted in September 1983 found 368 waterfowl carcasses, including about 35 fresh carcasses. |
Jennifer Roberts |
| 11/11/1984 |
Update or Other Action |
In August and September 1984, about 175 carcasses were discovered. At that time, the Army estimated the number of waterfowl deaths to be between 1,500 and 2,000 per year. |
Jennifer Roberts |
| 2/7/1986 |
Update or Other Action |
Water Quality Biological Study Number 32-24-1371-86, Waterfowl Die-off Investigation, Eagle River Flats (ERF), February 7, 1986, by U.S. AEHA 17-22 June 1985. Purpose: To investigate & locate possible causes of recurring waterfowl die-offs in the ERF impact area on Fort Richardson.
Study Area & Methods: Sample locations were selected to provide insight where possible contamination may be entering the ERF (sample sites 1 through 3). Sample site 1 was located at a landfill leachate site along the Eagle River & site 2 was located at a sewage treatment discharge site on the Eagle River. Additional sample sites were located in the ERF where waterfowl die-offs were known to have occurred (sample sites 4 through 7).
Also, control areas (Goose Bay, sample sites 8 & 9) were selected to determine natural background levels of potential contaminants. 3-day composite water samples were taken at each sample location. Water samples were preserved & returned to USAEHA for analysis. Composite sediment samples were taken at all sample sites except site 1, where the rocky substrate prevented sediment sampling. Macroinvertebrate species diversity was determined for sampling sites 4 through 9.
Invertebrates were allowed to colonize artificial substrates (Hester-Dendy Plates) for 6 to 8 wks. Invertebrates were collected & preserved by Fort Richardson personnel & sent to the USAEHA contractor for species identification.
Water Analyses. Results from water chemistry indicate that the Eagle River, ERF, & control areas were free of tested pollutants. Purgeable, base/neutral, & acid extractable organics, pesticides, & explosives were not detected at any sample site. Metals detected in sample waters included antimony, arsenic, beryllium, cadmium, chromium, copper, lead, nickel & zinc, but were not at levels considered toxic to wildlife. However, cadmium & lead levels detected in water from sites 1, 2, 3, 6, 7, 8, 9 & 6, 7, 8, 9, respectively, slightly exceeded aquatic life criteria.
It should be noted that levels of chromium, lead, & other metals detected in the control areas (sites 8 & 9) were similar to those levels detected on the ERF (sites 4 through 7) & Eagle River (sites 1 through 3). Therefore, metal levels detected in waters from the ERF appear to reflect natural background levels. Also, inorganic & physical water quality parameters were similar at ERF as compared with control areas.
Sediment Analyses. Pesticides, PCBs & explosives were not detected in sediments from any sample site. Metals were detected in sediments from all sample sites, but did not exceed levels beyond expected natural background & were similar to levels detected in control areas.
Macroinvertebrate Analysis. Analysis of invertebrate species diversity indicated poor quality habitat in the ERF & control areas. However, the invertebrate data is probably not representative of actual invertebrate populations in the ERF or control areas. Aquatic habitat exclusive of the Eagle River is more suited for invertebrate sampling using dredge techniques. However, this information was unknown during the planning & development of the study. Additional invertebrate sampling using dredge sampling techniques would provide more accurate data for analysis of invertebrate populations.
d. Waterfowl Analysis. No sick or recently dead waterfowl were observed or collected during this study. Previous waterfowl necropsy results were inconclusive in determining cause of death. Collection & analysis of tissue & blood serum is an essential element in determining the actual cause of the die-offs. Analyses of water, sediment, & macroinvertebrates provide needed background information, but do not determine the actual cause of waterfowl die-offs.
Significant die-offs were not observed during 1985. which may be related to small numbers of waterfowl using the ERF for reasons previously discussed (paragraph 4d). However, this should not be construed that waterfowl die-offs will not reoccur if populations using the ERF return to previous levels.
CONCLUSIONS.
a. Purgeable, base/neutral, & acid extractable organics, pesticides, & explosives were not detected in water samples.
b. Metals detected in water & sediments were not found in concentrations considered to be toxic to waterfowl.
C. Explosives & pesticides were not detected in sediment samples.
d. Macroinvertebrate diversities indicate poor environmental quality but should be resampled using dredge sampling techniques to provide further insight into invertebrate populations.
e. Essential waterfowl tissue & blood serum analyses are missing & are needed to determine actual cause of die-offs.
7. RECOMMENDATIONS. The following are based on good scientific practices.
a. Resample macroinvertebrates on the ERF & control areas using dredge sampling techniques.
b. Analyze waterfowl tissue & blood serum from sick & recently dead birds to determine actual cause of death to include botulism. |
Jennifer Roberts |
| 11/11/1987 |
Update or Other Action |
In late 1987, an interagency task force was formed to identify the cause of waterfowl deaths and recommend remedial alternatives. The Eagle River Flats (ERF) Task Force consisted of representatives from the U.S. Army Alaska, USEPA, USFWS, ADFG, and ADEC. After the formation of the ERF Task Force, several studies and investigations were conducted to identify contaminants of concern, characterize the nature and extent of contamination, and evaluate potential remedial alternatives.
The approach to determining the cause of waterfowl mortality included a review of physical and chemical data and an evaluation of waterfowl behavior based on biological data. The studies initiated to assess waterfowl behavior included bird utilization of habitat and bird mortality studies. Based on the initial bird utilization and mortality studies results, ERF was originally divided into four Areas: A, B, C, and D. Over time, four other areas of potential concern were identified: Area C/D (between Areas C and D), Bread Truck Pond, Pond Beyond, and the mud flats. Additional research throughout ERF eventually led to the following designated areas, which were the focus for RI and feasibility study (FS) activities: A, B, C, C/D, D, Coastal East, Coastal West, Bread Truck, and Racine Island. Appendix B shows the locations and approximate boundaries for the ERF areas. |
Jennifer Roberts |
| 1/25/1988 |
Update or Other Action |
USEPA Assistant Administrator J. Winston Porter (OSWER) Memorandum for the record to Regional Administrators I-X Subj: Enforcement Actions under RCRA and CERCLA at Federal Facilities. Statutory language makes it clear that Federal facilities must comply both procedurally and substantively with RCRA and CERCLA in the same manner as any non-Federal entity. The purpose of this memo is to lay out the statutory authorities under RCRA and CERCLA that EPA may use at Federal facilities to achieve compliance and expeditious cleanup.
EPA (The Agency) is viewing the Section 120 Interagency agreement as a comprehensive document to address hazardous substance response activities at a Federal facility from the remedial investigation/ feasibility study (RI/FS) through the implementation of the remedial action. All such interagency agreements must comply with the public participation requirements
of Section 117. The timetables and deadlines associated with the RI/FS and all terms and conditions associated with the remedial actions (including operable units or interim actions) are enforceable by citizens and the States through the citizen suit provisions of Section 310 of CERCLA. In addition, Section 122(1) of CERCLA authorizes the imposition of civil penalties against Federal agencies for failure to comply with interagency agreements under Section 120. Procedures for imposing these penalties are provided for in Section 109 of CERCLA.
Executive Order 12580 clarifies that EPA is authorized to issue Section 104 and Section 106 administrative orders to other Federal agencies, with the concurrence of the Department of
Justice. Section 4(e) of the Executive Order provides that: Notwithstanding any other provision of this Order, the authority under Section 104(e)(5)(A) and Section 106(a) of the Act to seek information, entry, inspection, samples or response action from Executive Departments and agencies may be exercised only with the concurrence of the Attorney General.
States also have a variety of enforcement authorities under CERCLA, so the exercise of EPA's enforcement authorities should be closely coordinated with the States.
First, Section 121(e) (2) of CERCLA authorizes States to enforce ANY Federal or state standard, requirement, criteria or limitation to which the remedial action must conform under CERCLA.
Second, Section 310 authorizes citizen suits to require Federal agencies to comply with the standards, regulations, conditions, requirements, or orders which have become effective pursuant to CERCLA including IAGs under Section 120 of the Act.
Third, Section 120(a)(4) clarifies that State laws concerning removal and remedial action, including State laws regarding enforcement, are applicable at Federal facilities not included on the NP. In addition, Section 120(i) states that nothing in CERCLA Section 120 shall affect or impair the obligation of the Federal agency to comply with the requirements of RCRA, including corrective action requirements (see section IV.C., "Importance of the States as a Party to the IAG"). EPA enforcement actions against Federal agencies should therefore be carefully coordinated with States to avoid potentially duplicative or conflicting exercises of authority.
All RCRA Subtitle C permits issued after November 8, 1984, will contain provisions for implementing the corrective action requirements of 40 CFR Part 264 Subpart F (or authorized state requirements), and Section 3004(u) and (v) of RCRA. For facilities that have or are seeking a RCRA permit, the requirements for a "CERCLA" remedial investigation and cleanup could be met by implementing these requirements through RCRA corrective action. It is important to keep in mind, however, that the extent of coverage of the RCRA permit is generally limited to hazardous wastes/constituents (e.g., some CERCLA hazardous substances such as radionuclides are not RCRA hazardous constituents and, therefore, the permit may not be able to address all of the releases at a facility).
The corrective action authority under Section 3008(h) of RCRA can be used at RCRA interim status facilities to address releases from RCRA regulated units and other solid waste management units. At a Federal facility that has interim status, a RCRA corrective action order could address the investigation and clean-up of releases in. lieu of a "CERCLA" response action or as an interim measure. Again, the extent of coverage in the RCRA corrective action order is limited to RCRA hazardous wastes/constituents.)
CERCLA Section 106 can be used to address releases from RCRA units or CERCLA sites when an "imminent and substantial endangerment" is shown. A Section 120 IAG could be drafted to incorporate all RCRA corrective action requirements and CERCLA statutory requirements. Where some or all of a Federal installation has been listed on the NPL, the CERCLA Section 120 IAG is required for remedial action by statute. |
Jennifer Roberts |
| 2/9/1988 |
Update or Other Action |
Memorandum of Understanding (MOU) between: Department of the Army, Department of the Interior U.S. F&WS, EPA, Department of Fish and Game, and the Department of Environmental Conservation. The purpose of the MOU is to promote interagency and intergovernmental coordination in assessing the extent of and causes of the migratory bird die-off on the Eagle River Flats, Fort Richardson, Alaska, and to identify and recommend corrective actions to mitigate the losses while accommodating the military mission. The listed agencies agree to designate a representative(s) to serve as a member of the ERF migratory bird die-off task force, referred throughout in this MOU as Task Force. Each member will: Participate in the development and completion of the General Study Plan and its Detailed Work Plan components by February 1, 1988.
Commit resources, as appropriate and available to fulfill each participating agency's responsibilities for implementing the General Study Plan. Coordinated activities, share information with Task Force members and support appropriate information releases to the public as jointly developed and approved by the Task Force. Sign a "Hold Harmless Agreement" ((Attachments I-IV). All parties recognize the inherent danger of conducting a field study in the ERF because it is an impact area for Army ordnance. The flats contain many unexploded (duds) rounds that are capable of exploding at any time, or upon the slightest impact. As a result, only the portion of the flats designated for entry as shown on the map attached to this agreement may be entered by the employees of any agency participating in this study. Individuals who proceed outside the designated safety area, do so in violation of this agreement and proceed at their own risk. |
Bill Lamoreaux |
| 2/9/1988 |
Update or Other Action |
HOLD HARMLESS Agreement signed by agencies. Bill Lamoreaux Southcentral Regional Supervisor Department of Environmental Conservation signes a hold harmless agreement (Attachment IV) of a memorandum of understanding at a meeting with various agencies working on the Eagle River Flats Migratory Bird Die-Off.
In consideration of permission granted by the United States Army to use Army facilities, ranges, equipment, and personnel, the user named below hereby agrees:
To release the United States Army, its agencies, and personnel from all liability arising out of the use of Army facilities, ranges, supplies, or services while located on, or in direct vicinity of, Eagle River flats and engaging in an activity directly related to this field study.
This includes, but is not limited to,
all activities conducted on Fort Richardson associated with investigating the Eagle River flats migratory bird die-off, whether, individual or group in nature. The user will defend, pay or settle all. claims or suits against the United States Army, its agencies, or personnel by agents or employees of the user or persons claiming through them, or by third parties, and will hold the United States Army, its agencies, and personnel, harmless against every such claim or suit,. including attorney fees, costs, and expenses, services, arising out of the use of any Army facilities, ranges, supplies, or by the user.
EXCEPT THAT, this agreement is not operative where death, injury, loss or damage to persons or property results solely from the willful misconduct or gross negligence of United States Army personnel.
Signed by Ted Medley Colonel, Field Artillery, Garrison Commander, U.S. Army Garrison, Alaska, Fort Richardson, Alaska dated 9 February, 1988 and Bill Lamoreaux SCRO Regional Supervisor DEC Anchorage, AK February 9, 1988. |
Bill Lamoreaux |
| 5/17/1988 |
Update or Other Action |
Report received from the Army regarding a fuel spill reported by Range Control, Keith 864-1195 1300 hours. Spill was estimated to have occurred some time during the month of November 1987. 40 gallons was estimated to have been released to a gravel parking area near the new building between the Zero Range and Record Fire Range. Source was a leaking above ground storage tank in the parking area. Spill number assigned was 88-2-1-1-131-3. |
Bruce Erickson |
| 11/11/1988 |
Update or Other Action |
Study shows a series of aerial and ground surveys conducted in 1988 documented more than 900 waterfowl carcasses and feather piles in one area of ERF. |
Jennifer Roberts |
| 5/1/1989 |
Update or Other Action |
ERF Expanded Site Investigation, Draft Sampling Design Plan; Final Sampling Design Plan dated July, 1989 by Hunter/ESE, Inc. |
Jennifer Roberts |
| 7/1/1989 |
Update or Other Action |
ERF Expanded Site Investigation, March 1990, Hunter/ESE, Inc. - 2 reports: Quality Control Recovery Data Report and Draft Technical Report. Eagle River Flats (ERF) Expanded Site Investigation Fort Richardson Draft Technical Report Data Item A011 prepared for the U.S. Army Toxic and Hazardous Materials Agency Installation Restoration Division. Surface sediment samples ERF-8 had PETN at 17.5 ug/g or ppm and ERF-17 detected PETN at 34.7 ug/g or ppm. 1,1,2,2-Tetrachloroethane was found in water samples from ERF. Maximum water concentration was 20 ug/L. 1,1,2-Trichloroethane was detected in water samples from ERF. Maximum water concentration was 10 ug/L.
Conclusions
One of the most obvious potential causes of wildlife mortality at an active artillery range is concussion caused by mortar and artillery fire. Waterfowl within the impact zone of an explosive artillery round could experience a traumatic injury caused by shrapnel, concussion or impact with the ground due to concussion. During the investigation of waterfowl mortality at ERF, no evidence of traumatic injury in gross necropsy of 10 dead or moribund wild ducks collected from ERF. In fact, ducks feeding in close proximity to mortar and artillery impacts displayed little reaction to the munitions. Mortality caused by concussion would indiscriminately affect all wildlife within the impact area at the time of firing, whereas mortality on ERF is primarily confined to waterfowl, specifically dabbling ducks of the genus Anas. Waterfowl also continued to die on ERF more than 10 days after the cessation of all firing on the flats, leading to the conclusion that concussion caused by artillery undoubtedly results in some wildlife mortality on ERF, but it is not a major cause of the waterfowl mortality evident on ERF.
There is no evidence to support the hypothesis that smoke inhalation is the cause of mortality for waterfowl at ERF. During the course of the 1989 study, rounds were not fired into the flats for a period of up to 3 weeks. Mortalities continued despite the fact that no rounds were being fired into ERF.
The metals elevated at ERF are probably due to Army activities, as many detections are much higher than would be expected naturally. Antimony, iron, magnesium, and sodium occurred at high enough levels in the water so the estimated avian dose was approximately one order of magnitude less than toxic doses. This is not a wide margin of safety considering the uncertainties involved in estimating dose. Behavioral observations indicated less alert behaviors in the ERF waterfowl populations as compared to controls at Cottonwood Slough. Alert behaviors were lower in the migratory population at ERF than expected. While these data may not be significant, they may also indicate an early stage of the adverse effects such as slight lethargy or a narcotic type of effect. Nitroaromatics can produce narcotic effects in mammals.
Results indicate death of waterfowl probably due to toxins of artillery shells in water and sediment but recommended further studies. Waterfowl census data for 1988 and 1989 indicated that dabbling ducks comprised the majority of the affected waterfowl and the ducks were continuing to die. The following 1990 field season focused on finding the cause of mortality based on the assumptions that the contaminant(s) resided in sediment, were distributed heterogeneously at ERF, and were slow to degrade. |
Jennifer Roberts |
| 9/5/1989 |
Update or Other Action |
Bruce Baldwin Plaintiff summons the U.S. Government: U.S. EPA, Department of Interior-US Fish and Wildlife Service, Department of the Army, 6th Infantry Division (Light) and U.S. Army Garrison Fort Richardson Alaska. State of Alaska: Department of Environmental Conservation and Department of Fish and Game. Case Number A89-371 (D. Alaska). Mr. Baldwin alleged that ADF&G and ADEC had not complied with federal statutes and requested that the waterfowl season be closed by injunction until cause is discovered and ADEC be required to enforce the provisions of the Federal Water Pollution Control Act. Defendants have known since 1980 that at the 2500 acre complex known as Eagle River Flats, significant numbers of migratory waterfowl have died of unknown causes. Extensive military firing exercises conducted on ERF throughout the year pose a threat to fish and wildlife resources of the area.
The chemical composition of the artillery shells used on this range contain toxic, highly toxic, and carcinogenic compounds which have been accumulating over the years. The composition of the artillery shells used by the military on this range comports to hazardous substance releases under 42 USC 9601 (14). Plaintiff alleges that the migratory waterfowl utilizing this tidal wetlands may be diseases or contain toxic chemicals which may be harmful to humans if ingested. Plaintiff is concerned that the toxic chemical compounds used by the military at ERF has contaminated the ground water supply in violation of the Clean Water Act 33 USCS 1251 and that the migratory waterfowl using this important staging area may be diseased or contaminated and the ingestion of these birds by sport hunters may be harmful to their health. |
Jennifer Roberts |
| 10/24/1989 |
Update or Other Action |
Court Case Number A89-371 Civil order of dismissal granted and the complaint is dismissed with prejudice. |
Jennifer Roberts |
| 11/13/1989 |
Update or Other Action |
Factsheet re: Poleline Road Disposal Area discoverd through search for a link to a dump site to the Eagle RIver Flats (ERF) mortalities of waterfowl.
SUBJECT: Poleline Road Chemical Disposal Area
BACKGROUND: Records on past (before the mid-1970s) landfills or "dumps" are poor with usually no documentation of material
deposited into them. A dump site location, an acknowledgement that such a site existed and was properly closed, or something similar is usually the best file information available. It is
unlikely that any more information on the Poleline Road Chemical Dump site will be uncovered in the files.
FACTS BEARING ON THE SUBJECT: a. Facts. In late September of 1989, Anchorage Mayor Tom Fink informed MG Fields, Commanding General of the 6th Inf Div (L) and U.S. Army Garrison, Alaska, of an Anchorage citizen who was stationed on Fort Richardson in the 1950s and remembered chemicals being buried in an area close to Eagle River Flats Impact Area (ERFIA). The Mayor indicated this might be connected to the Eagle River Flats Waterfowl Mortality (ERFWM) problem under Army investigation in the ERFIA. This project will be handled separately from the ERFWM project unless/until a link between the two is found because it is likely that they are unrelated (they are separated by about five kilometers).
b. Action Taken. The informant spent an afternoon with 6th Inf Div (L) Directorate of Engineering and Housing (DEH) personnel
locating a primary and alternate site on a map. This was followed : by site visits to confirm the possible dump locations. From this
information, DEH has coordinated with EOD and the 6th Engineers to perform an electromagnetic sweep of the areas to determine what, if anything, was buried there.
Concurrent with this action, an investigation of the map archives at the Corps of Engineers revealed a 1954 map showing a chemical disposal area at the same spot as the primary location identified by the informant. The map says "Chemical Disposal Area" in the middle of a full circle. On the radius line leading from the label to the circle are the words "2400 radius contamination zone" (see attached map). Aerial
photography from a 1957 overflight showing visible trenches collaborates this dump location. Based on this data, the alternate site has been dropped from the investigation. While preparations for the electromagnetic sweep are proceeding, the 6th Inf Div (L) has issued a request through WESTCOM to USATHAIJIA asking USATHAMA assistance in investigating the Poleline Road Chemical Disposal Site.
C. Action Required. Continue investigation efforts and have the 23rd Engineers perform the initial electromagnetic sweep, have EOD perform a follow-up sweep as soon as possible and USATHAMA encourage
to perform an investigation of this site and establish it as a project under the Installation Restoration Program (IRP). 4. REFERENCES.
a. AR 200-1, 15 June 1982, Environmental Quality, Environmental Protection and Enhancement. b. Memorandum, DEH, APVR-DE-PS, 13 Nov 89 Subject: Chemical Disposal Area (request for USATHAMA assistance). |
Jennifer Roberts |
| 2/8/1990 |
Update or Other Action |
Eagle River Flats Expanded Site Investigation Fort Richardson, Alaska Final Technical Report Data Item A011 USATHAMA June 1990 Contract No. DAAA15-88-0003 Task Order No. 11
EXECUTIVE SUMMARY-Clinical studies (e.g. histopathology, etc.) eliminated infectious disease, concussion, and inhalation of toxic substances as causes of waterfowl mortality. Laboratory testing also indicated that algal toxins were probably not the cause of the bird mortality at ERF. Field observations provided information on the seasonal distribution of waterfowl using ERF, located moribund and dead birds, and produced behaviorial information on wild birds. Results indicated that waterfowl, particularly dabbling ducks, were the group primarily affected and that the causitive substance(s) apparently did not produce secondary effects in predators or scavengers (e.g. bald eagles, gulls, etc.) that fed on affected waterfowl.
Integrated sampling for contaminants found a statistically significant relationship (p < 0.05) between explosives related contamination and affected ducks, indicating that chemicals from explosive ordnance were a probable cause of waterfowl mortality on ERF. Specific chemicals were not identified.
7.0 Recommendations (Page 7-1)
"Based on a preliminary briefing to General Fields at Fort Richardson by USATHAMA and Hunter/ESE on 8 February 1990, all firing into ERF was stopped as of 9 February 1990 and will not be continued until further notice. Arrangements are currently being made to shift range practice to other Army bases in Alaska in order to reduce waterfowl mortality." |
Jennifer Roberts |
| 4/6/1990 |
Update or Other Action |
SUBJECT: Update on Eagle River Flats/Poleline Road Contaminated Site Studies.
FACTS:
a. The 1989 Eagle River Flats study conducted by Hunter ESE under administration of USATHAMA has, as of this date, produced no conclusive results or findings as to the cause of the
waterfowl mortality in the impact area,
b. Some of the analytical results have still not been received & the final report which was originally due this month will not be available until April, according to USATHAMA.
C. In anticipation of all this, the Eagle River Flats Task Force decided it should come up with a contingency plan immediately as the spring waterfowl migration would be upon us before the USATHAMA final report was available.
d. A letter was sent from the Garrison Commander to the U.S. Fish & Wildlife Service (USFWS) Regional Director asking for assistance in developing a plan for 1990 based on the assumption
that the 1989 study failed to identify the problem (enclosure 1). In addition, a letter was sent to USATHAMA containing a number of questions brought up by Task Force members at their
last meeting on 8 November 1989 (enclosure 2). Answers to these questions have not yet been received.
e. In response to the Garrison Commander's letter, the USFWS Regional Director assembled a team of biologists & toxicologists from both his local & Washington, D.C. offices to develop a study plan for 1990, Unlike the previous study which was heavily concentrated on fieldwork & administrative labor costs ($527,556) as opposed to actual laboratory analysis ($168,582) the USFWS study plan proposes less fieldwork & administrative effort (approximately $197,015) with major emphasis on actual analysis (approximately $617,620). Total costs for last year's effort, as of 16 October 1989, was $696,138 plus approximately $75,000 in donated manpower & equipment support from this Command (totalling $703,638), Preliminary & final report preparation costs may bring this figure closer to $800,0000 for the FY 89 study. The estimated cost for the USEWS FY 90 study is approximately $815,000.
f. From a technical aspect, the USFWS Study Plan takes a more rudimentary approach in its attempt to isolate & identify the chemical components of Eagle River Flats water & sediment. Instead of looking for specific or limited suites of chemicals in the samples, the plan proposes to test for just about everything possible using the most sophisticated analysis methods available.
g. Due to the complex nature of the study, technical & highly integrated the USFWS recommends the majority of the analytical work be handled by a private consultant. The chemical isolation/identification process requires expertise the USFWS does not employ in Alaska, their facilities elsewhere or is it readily available in any of They are, however, open to further discussions with the Command concerning the performance of certain identified tasks, particularly Sample Collection, Microtox & Bird Utilization,
h. In recent discussions with Mr. Ali Alavi of USATHAMA it was stated that 1990 DERA funding for Eagle River Flats work was highly unlikely due to the following:
(1) A significant increase in competition for DERA funds nationwide.
(2) Substantial budget cuts for FY 90 ($206 million reduced to $175 million).
(3) The feeling that they (USATHAhA) have exhausted all their technical expertise during the 1989 study & do not know what else they can do.
(4) The Eagle River Flats project is technically ineligible for DERA funding due to its active use as an impact area.
(5) The hazard presented by the Eagle River Flats situation (i.e,, standards. health risks) is considered low by USATHAMA
According to USATHA&A the Eagle River Flats project only received funding because of the local publicity it was generating. They have indicated that they have no intention in managing any future work on Eagle River Flats & are reluctant to supply additional funding.
The Eagle River Flats Task Force was informed at their last meeting (8 November 1989) that USATHAMA had set aside The Eagle River Flats Task Force was informed at their $500,000 for FY 90 Eagle River Flats studies. They now say that under the new circumstances, they are diverting that money toward the investigation of the recently discovered Pole Line Road contaminated site.
i. The Poleline Road contaminated site was brought to the Command's attention in fall 1989 by Mr. Floyd C. Fruik (a former soldier on Fort Richardson during the early 1950s) & later confirmed by old photographs & maps obtained from the Corps of Engineers.
k. The scope of work for the Poleline Road contaminated site study has just been completed & the estimated costs are approximately $300,000.
See site file for additional information. |
Jennifer Roberts |
| 4/9/1990 |
Document, Report, or Work plan Review - other |
EPA D. Johnson comment letter to Army. ERF Expanded site investigation March 1990. Please regard the following comments as very general. It is my intention to complete a more substantive review of this document and provide you with more detailed comments within the next 30 days.
General Comments- As I stated in my March 6, 1990 letter to you regarding the FY90 Scope of
Work, I was concerned that references made by the USATHAMA and their contractor implying that explosives were the cause of the avian mortalities at Eagle River Flats were inappropriate prior to the review of this report by the your staff or the members of the Eagle River Flats Task Force.
I am concerned that this report does not adequately substantiate these references. I believe that the USATHAMA contractor stated that there was an 80 to 90% probability that munitions were the cause of the avian mortality at the impact area. Upon review of this report, I am confused by an apparent contradiction in findings and justification of facts.
The Executive Summary states: ... "chemicals from explosive ordnance were the probable cause of waterfowl mortality on ERF."
As stated on pages 5-30 through 5-33, all primary munition chemical constituents or degradation products (PETN, Tetryl, HMX, RDX, 2,4-DNT, 2,6-DNT, and Nitrobenzene) were unlikely to cause waterfowl mortality. I am confused by these findings and what is stated in the Executive Summary. In light of my absence from the April 9, 1990 meeting, I am asking clarification of this discrepancy. I feel that based on my quick review of this report, USATHAMA should at a minimum provide you and the Task Force very candid explanations for these discrepancies. I am concerned that inlight of the closing of the impact area and previous information releases, we are in a unique if not indefensible position from both a technical and a public perception standpoint. Signed Douglas W. Johnson. |
Jennifer Roberts |
| 4/12/1990 |
Update or Other Action |
Preliminary brief of proposed FY90 ERF study information memorandum. Purpose. To provide the Commanding General (CG) with a summary of objectives and initial strategies for FY 90 Eagle River Flats Study as developed by the U.S. Army Toxic and Hazardous Materials Agency (USATHAMA) and the Eagle River Flats Task Force during the 10 April 1990 meeting. Design and direction of the FY 90 study was largely influenced by findings of the FY 89 study which underwent initial review by the task force the previous day.
Objectives: ( 1) To establish a baseline of inorganic parameters for ERF using control sites. To accomplish this, 3 different sites similar to ERF will be sampled in upper Cook Inlet. The task force wants this done because they are not confident that the samples taken at the FY89 study control site (Cottonwood Slough) adequately represented background levels of metals and other chemicals which were shown to be at elevated levels in ERF.
(2) To visually inspect ERF sediment under low power microscopes. This was never done
before and there is still some question about whether it is possible for the birds to be picking up small undissolved bits of unexploded material (RDX, HMX, etc,) as they sift through the sediment. USATHAMA agrees that this analysis would be easy, inexpensive, and has merit. Undissolved explosive material can easily escape chemical analysis using standard extraction methods.
(3) To monitor and document waterfowl use of & on ERF. Aerial surveys conducted by the U.S. Fish and Wildlife Service coupled with helicopter and on-the-ground observations by the DEH wildlife biologist and assistants (possibly summer hire) will be used to detect any noticeable changes in mortality rates from previous years when mortar and artillery firing regularly occurred.
(4)* To conduct bioassavs. Laboratory birds will be given water and sediment from suspected "hot spots" (areas where the biologist is observing wild bird mortality) on ERF and closely observed for any symptoms or unusual behaviors. Although bioassays were conducted during FY 89, the task force feels that two major factors warrant the duplication of this effort. The first being that 12-day old ducklings instead of adult birds were used which may have been a confounding element in that the literature states ducks this young appear to be highly susceptible to salt poisoning.
In addition, they may have been more susceptible to other things, including stress of handling, etc. The second factor is that all the remaining water and sediment samples used in this experiment were discarded and never analyzed although some ducklings got sick and died. This year's effort integrates objectives 4 and 5.
(5)* To conduct chemical analysis of ERF sediment and water, Sediment and water from the same samples used in the above stated bioassay will be chemically analyzed at the same time as the bioassay is being conducted. If bioassay birds become sick and die, it can be directly correlated with the laboratory analysis- Chemical analysis will include gas chromatography, mass spectrophotometry and standard procedures for inorganics.
Strategies:
(1) Sampling: Using protocol provided by USATHAMA. The DEH wildlife biologist and assistants (EOD personnel and possible summer hires) will take samples from the three control sites (Goose Bay, Cottonwood Slough and Susitna Flats). As many as 20 samples (10 sediment and 10 water) per control site will be taken. In addition to this, sometime within the second two weeks of May (to be determined by the wildlife biologist based on mortality observations) samples (10 sediment and 10 water) will be taken from Eagle River Flats in areas identified as "hot spots.” These samples will be used for both chemical analysis and bioassay work. The latter may necessitate the use of as many as 100 laboratory birds and will require very large samples. Considerable helicopter, vehicle, and manpower support will be necessary to accomplish these taskings.
(2) Monitoring waterfowl use and mortality. The DEH wildlife biologist and/or personnel under his supervision will routinely observe and document waterfowl use, behavior, and mortality rates in Eagle River Flats from both helicopters and ground positions. U.S, Fish and Wildlife Service will conduct aerial surveys to document total bird numbers and species composition. These activities will take place throughout the entire study period (16 April - 31 October 1990).
*It is the consensus of the entire task force that in the event that money constraints severely limit the number of samples, sediments take priority over water. |
Jennifer Roberts |
| 5/15/1990 |
Update or Other Action |
Cold Regions Research and Engineering Laboratory (CRREL) and Fort Richardson Wildlife biologist conducted sampling at four control sites in the flats. Soils and water samples were analyzed on-site with field kits. None tested positive for RDX or TNT. All samples were sent to the CRREL Lab. Sediment and water samples were taken in areas where the highest mortality rate occurs. 2,4-DNT was identified in two soil samples analyzed by the lab. |
Jennifer Roberts |
| 6/29/1990 |
Update or Other Action |
Update Eagle River Flats Waterfowl Investigation by William A. Gossweiler (APVR-DE-PSE/Env Res Br) factsheet.
BACKGROUND:
a. Eagle River Flats, a 2500-acre wetland on Fort.Richardson, has been an impact area for heavy artillery training for approximately 40 years. The area is also an important staging ground for waterfowl during spring and fall migrations.
b. In 1981 it was discovered that an unusually high number of ducks were turning up dead in the Flats. Subsequent investigations by Army, U.S. Fish and Wildlife Service IUSFWS) and Alaska Department of Fish and Game (ADF&G) biologists indicated a serious problem existed.
FACTS BEARING ON THE SUBJECT:
In 1987, an interagency task force consisting of representatives from the USF & WS, the Army, U.S. Environmental Protection Agency (EPA) ADF&G and the Alaska Department-of Environmental Conservation (ADEC) was established to investigate the Eagle River Flats waterfowl mortality problem.
b. Laboratory analysis of bird carcasses between 1983 and 1989 ruled out diseaae, trauma, concussion and direct injury from fragments as well as heavy metals and organic compounds such as DDT and PCBs as causative agents.
ACTION TAKEN:
a. In a continuing effort to resolve the problem, the U.S. Army Garrison, Alaska requested technical assistance from the U-S. Army Toxic and Hazardous Materials Agency (USATHAMA), who in turn contracted Hunter ESE, Denver, Colorado, to conduct a site investigation of the Eagle River Flats problem. The $750,000 study conducted by Hunter BSE in FY 89 produced no conclusive
results or findings although the company stated they were 80-90% sure munitions were somehow responsible. As a result of that statement, MG Fields closed the impact area to all firing activities.
b, The contractor's draft report was reviewed by the federal and state agencies of the Task Force and found to contain numerous errors and inconsistencies in the text, methodology and statistical analysis of data, resulting in skepticism of the report's quality and credibility.
c. The U.S. Army Cold Regions Research and Engineering Laboratory (CRREL) was then contracted to confirm or refute the contractor's findings. CRREL's newly developed munitions field tests were used to screen samples, which were then sent for confirmatory testing, CRREL also assisted DEH in sampling to establish a valid baseline against which to compare the Eagle River Flats
samples.
d. Preliminary findings from CRREL's spring sampling effort indicate the presence of the propellent 2,4-Dinitrotoluene (2,4-DNT 2009 18 AAC 75 cleanup level is 0.0093 mg/kg) in two sediment-samples near the former EOD Range and trace amounts of 2,4,6-Trinitrotoluene (TNT 2009 18 AAC 75 cleanup level is 0.49 mg/kg) [and by-product 1,3,5-Trinitrobenzene (TNB) 2009 18 AAC 75 cleanup level is 19 mg/kg] in four sediment samples.
ACTION REQUIRED. Observation of mortality on the flats is continuing through monthly helicopter overflights and ground observation. CRREL will conduct more sampling during the fall migration, when, in the past, significant mortality was observed. |
Jennifer Roberts |
| 8/3/1990 |
Update or Other Action |
U.S. Army CRREL interim report concerning the source of waterfowl mortality in Eagle River Flats. Two hypothesis. The first is 2,4-DNT leaching into the wetlands from the explosive ordnance disposal. The second is white phosphorus particles from shell detonation. Behavior of waterfowl observed is similar to that of research in the phosphorus poisoning of waterfowl. Continued field study will focus on concentration and spatial extent of 2,4 DNT. Collect sediment samples for white phosphorus. Collect tissue samples from impaired ducks and document their behavior.
Field and laboratory studies conducted in 1990 provided evidence that white phosphorus was the likely cause of the mortality. In addition, because white phosphorus persists (does not sublimate and oxidize) when wet or submerged, the water and sediment conditions at ERF are conducive to the long-term retention of white phosphorus in the sediments. ERF investigations performed in the following 3 years focused on defining the extent of the white phosphorus residual matter, determining site conditions and other factors that affect the likelihood of exposure to white phosphorus, and understanding the physical dynamics of ERF. |
Jennifer Roberts |
| 12/18/1990 |
Update or Other Action |
CRREL Memo to US ARMY DEH Col Edwin Ruff re: Eagle River Flats Waterfowl Mortality Study Ft. Richardson.
On 10.December 1990, CRREL presented a draft report and briefing on the role of munitions in waterfowl mortality on the Eagle River Flats (ERF) impact area to USATHAMA, Army 6th ID (light) and-the Interagency ERFTask Force,- A final report will be submitted 1 February 1991. However, the facts outlined in this memorandum will not change.
Based on our 1990 field and laboratory studies, we have identified white
phosphorus as the cause of waterfowl mortality in ERF, a 2500 acre estuarine salt marsh where thousands of waterfowl feed during the spring and fall migrations. White phosphorus is a compound fired by mortars and howitzers to produce smoke for concealment, It is toxic to waterfowl af a dose of only a few milligrams (equivalent to a tiny part of a 250 mg aspirin tablet).
Ordinarily white phosphorus IS highly reactive in air where particles are rapidly oxidized QT burned into a non-toxic compound that poses no danger.
However, in a coastal salt marsh such as, ERF, burning particles of white phosphorus may be extinguished at the shallow water surface and then stored in the bottom sediments where oxygen is absent. Evidence obtained by CEREL indicating white phosphors is the cause of waterfowl mortality in-ERF includes:
a) detection of this compound in sediment samples from the bottom of a shallow pond where ducks feed. b) detection of white phosphorus in the gizzards and tissues of stricken ducks and swans collected in ERF. c) similarities in the behavior of sick birds in ERF and three mallard ducks dosed with white phosphorus in the laboratory
The extent of white phosphorus occurrence in ERF needs to be determined and remedial methods developed to detoxify or remove white phosphorus without destroying the integrity of the salt marsh habitat. |
Jennifer Roberts |
| 12/28/1990 |
Document, Report, or Work plan Review - other |
Letter to Colonel Edwin Ruff regarding draft report Waterfowl Mortality in Eagle River Flats, Alaska: the Role of Munitions Compounds November 1990. It is ADEC's opinion that this high level of scientific work was achieved in part by the flexibility allowed by CRREL by the Army, and USATHAMA. ADEC recommends that further work with CRREL retain the flexibility that produced a high quality and sound scientific work.
1. There is a need to expand the information on how white phosphorus (WP) effects waterfowl. Include minimum lethal dosage, possible concentration buildup effects, low level dosage effects over short and long term time periods.
2. The possible effects on predators feeding on waterfowl containing WP. This should include similar information in Item 1.
3. Determine the areas of WP contamination. This should include the vertical and horizontal extent of contamination and creating an accurate concentration map. Again, this information is essential in determining a remedial strategy.
4. Determine the areas of 2,4-DNT contamination that are adjacent to the EOD site. This should include the vertical and horizontal extent of contamination and create an accurate concentration map. This information is essential for determination of a remedial strategy.
5. Establish WP characteristics. This should include behavior in water/sediment systems similar to ERF, breakdown rates, conditions for oxidation, the presence or absence of an oxidized coat, and other physical characteristics. These characteristics should be established for a variety of conditions; for example, temperature, pH, redox potential, water depth, burial depth and vegetation cover.
6. A detailed study on ERF sedimentation rates and deposition characteristics. This should be related to how WP is being buried or uncovered within the ecosystem. This information is needed to determine a remedial strategy.
The Department's final recommendation is that use of the Eagle River Flats area as a firing range and EOD site be suspended until more definitive information on the effects of these activities can be assessed. |
Jennifer Roberts |
| 1/1/1991 |
Update or Other Action |
COE report stating the major cause of mortality of dabbling ducks was white phosphorus. Unknown when ADEC received report. Because of the large quantity of 2,4-DNT required to be ingested, the 2,4 DNT was not seen as the source of acute mortality. The report presents the research leading to the conclusion that white phosphorus was the source of mortality. Since 2/90, the wetlands, Eagle River Flats have not been used as an artillery impact range. |
Jennifer Roberts |
| 2/7/1991 |
Update or Other Action |
Fact sheet from APVR-DE-PSE/Env Res Branch William Gossweiler Subject: Eagle River Flats Waterfowl investigation.
In 1981 it was discovered that an unusually high number of ducks were turning UP dead in the Eagle River Flats (ERF). Subsequent investigations bv Army, U.S. Fish and Wildlife Service (USFWS) and Alaska Department of Fish and Game (ADF&G) biologists indicated a serious problem existed. In 1987. an interagency task force consisting of representatives from the USFWS, the Army, U-S, Environmental Protection Agency (EPA), ADF&G, and the Alaska Department of Environmental Conservation.(ADEC) was established to investigate the ERF waterfowl mortality problem.
Lab analysis of bird carcasses between 1983 and 1989 ruled out disease. trauma. concussion and direct injury from fragments as well as heavy metals and organic compounds such as DDT and PCBs as causative agents. In a continuing effort to resolve the problem. the U.S. Army Garrison, Alaska requested technical assistance from the U.S. Army Toxic and Hazardous Materials Agency (USATHAMA), who in turn contracted Hunter ESE. Denver, Colorado, to conduct a site investigation of the ERF problem.
The $750.000 study conducted by Hunter ESE in FY 89 produced no conclusive results or findings as to the cause of the unnatural waterfowl die-offs occurring on ERF. The company stated that even though they could not identify the problem they felt confident (80-90% sure) that the deaths could be linked to-munitions fired into the area. Based on their conjecture, MG Fields suspended all firing in the impact area in February of 1990. The 6th Infantry Division [Light) and the ERF Task Force, not being satisfied with the work performed in FY 89, requested that the U-S, Army Cold Regions Research and Engineering Laboratory (CRREL) be utilized for future studies.
The FY 90 study conducted by CRREL, 6th Infantry Division and the U.S. Fish and Wildlife Service consisted of a combination of very thorough field and laboratory work Researchers collected over 200 water and sediment samples which were analyzed by several highly sophisticated laboratory methods.
In addition. detailed observations were made of afflicted birds and tissues were collected for analysis. These results, presented before the Eagle River Flats Interagency Task Force on 10 December 1990, irrefutably named white phosphorus as the culprit. They have also shown that chemical compounds found in other types of munitions fired into the Flats are not present and. in their opinion, pose no threat to the environment.
White phosphorus is a compound fired by mortars and howitzers to produce smoke for concealment. It is toxic to waterfowl at a dose of only a few milligrams [equivalent to a tiny part of a 250 mg aspirin tablet). Ordinarily, white phosrhorus is highly reactive in air where particles are rapidly oxidized or burned into a nontoxic compound that poses no danger, However, in a coastal salt marsh such as Eagle River Flats. burning particles of white phosphorus may be extinguished at the shallow water surface and then stored in the bottom sediments where oxygen is absent,
Evidence obtained by CRREL indicating white phosphorus is the cause of waterfowl mortality in ERF includes:
Detection of this compound in sediment samples from the bottom of a-shallow pond where ducks feed;
Detection of white phosphorus in the gizzards and tissues of stricken ducks and swans collected in ERF;
Similarities in the behavior of sick birds in ERF and three mallard ducks dosed with white phosphorus in the laboratory.
ACTION TAKEN: a. This Command has been an active member of the investigative task force and has contributed significantly toward the entire effort. It has provided almost 100% of logistical needs in the field to include helicopter and vehicle support, use of canoes, tents and snowshoes. In addition, a significant amount of manpower support has been provided by the DEH Environmental Resources Branch, Aviation Office, Safety Office, and EOD.
Firing into the ERF impact area remains suspended pending further study.
Actions Required-The extent of white phosphorus occurrence in ERF needs to be determined and remedial methods developed to detoxify or remove white phosphorus without destroying the integrity of the salt marsh habitat. |
Jennifer Roberts |
| 2/21/1991 |
Update or Other Action |
PRESS RELEASE #: 91-2-4-12. Army officials here today released a report, prepared by the D.S. Army Cold Regions Research and Engineering Laboratory (CRREL.), which identifies the ingestion of white phosphorus as the cause of the unusual raterfowl deaths on the post's Eagle River Flats.
The identification was based upon field and laboratory work accomplished last year by CRREL researchers who collected and analyzed the tissues of 14 waterfowl and more than 250 water and sediment samples. The 80-page report, entitled "Waterfowl Mortality in Eagle River Flats, Alaska: The Role of Munition Compounds," was prepared by CRREL at Hanover, N-H.,under a $305,000 study funded by the U.S. Army Toxic and Hazardous Materials Agency at Aberdeen Proving Ground, Md. The report was presented to the 6th Infantry Division (Light) Commander, Maj. Gen. Samuel E. Ebbesen, yesterday, and to the members of the Eagle River Flats interagency Task Force at a meeting today.
The federal and state agencies of the task force have been working together to determine the cause of the waterfowl mortality since the group's formation in Nov. 1987. Besides the Army, the task force includes the U.S. Fish and Wildlife Service, U.S. Environmental Protection Agency, Alaska Department of Fish and Game and the Aaska Department of Environmental Conservation.
In addition to presenting their report on the work completed in 1990, and the conclusion drawn from that work, CRREL scientists have recommended studies continue in 1991. The proposed effort would focus on locating specific areas of high concentrations of white phosphorus contamination as well as evaluating and testing potential remedial solutions. The Army is pleased by the hard work, scientific approach and spirit of cooperation over the past months which have resulted in a definitive identification of white phosphorous as the cause of the duck mortality. General
Ebbesen has directed that white phosphorous will not be fired into the Eagle River Flats impact area in the future.
The 6th Infantry Division (Light) does intend to resume artillery and mortar firing at Eagle River Flats, following completion of an environmental assessment and a firing plan which the commanding general has ordered prepared. |
Jennifer Roberts |
| 3/13/1991 |
Enforcement Agreement or Order |
ADEC receives the EPA/ARMY FFCA for Fort Richardson EPA ID Number AK1210022157 Docket No. 1090-05-29-6001. Federal Facility Compliance Agreement ("Agreement") is entered into pursuant to RCRA, and Executive Order 12088, Federal Comnliance with Pollution Control Standards (43 Fed. Reg. 47707, October 13, 1978).
This Agreement in no way restricts EPA from taking such additional action as it deems appropriate to address past, present and future violations of RCRA or other environmental laws and regulations, other than those specifically addressed by this Agreement. Further, this Agreement is not intended to circumvent the permitting process established under RCRA, nor the statutory requirements of § 120 of the Comprehensive Environmental Response, Compensation, and Liability Act, as amended ("CERCLA"), 42 U.S.C. § 9620.
This Agreement does not address corrective action or response measures pursuant to sections 3004(u), 3004(v) or 3008(h) of RCRA, 42 U.S.C. §§ 6924(u), 6924(v) or 6928(h), or pursuant to CERCLA, 42 U.S.C. § 9601 et seq. This Agreement has been entered into by the Army and EPA to resolve only the matters stated below and to facilitate implementation of the measures
described herein.
Notwithstanding any other provision of this Agreement, EPA expressly reserves all of its statutory and regulatory powers, authorities, rights, defenses, and remedies, both legal and
equitable, including but not limited to the following:
A. the right to disapprove of work performed by the Army;
B. the right to bring any enforcement action against the Army's contractors, subcontractors and/or operators;
C. the right to take further action pursuant to RCRA, or CERCLA, against the Army or any other party subject to such authority; and
D. the right to take or order additional work or other actions, including but not limited to, the investigation, prevention or abatement of a threat to the public health, welfare, or environment arising from conditions at the facility.
Fort Richardson shall continue the current contamination assessment study of the portion of the Eagle River Flats Area immediately surrounding and affected by potential releases from the OB/OD area at least until the site has been adequately characterized to determine if
hazardous constituents have been released into the environment from OB/OD or other RCRA regulated activities. Fort Richardson shall provide data and information from this assessment to EPA and ADEC consistent with the Memorandum of Understanding signed February 1988. Fort Richardson shall incorporate any relevant findings of this study into the OB/OD closure plans. EPA reserves the right to require additional measures under appropriate statutory authorities. |
Tim Law |
| 3/21/1991 |
Update or Other Action |
SUBJECT: Eaqle River Flats Study--Progress Report I.
BACKGROUND: On 20 Feb 91 the Command was briefed on 4he findings of the FY ?O Eagle K'iver Flats study. The following day the Eagle River Flats Task Force met to review and diEcu5s the FY 90 study final report and the FY 91 proposal. Based on the information which linked waterfowl deaths to white phosphorous, the Commandinq General decided to pursue the resumption of artillery and mortar firing (excluding the use of white phosphorous-containing rounds) in the impact area. These intentior;s were made public in a press release which came out in local newspapers on 22 Feb 91. On 20 Mar 91 a test firing mission was conducted on Eaqle River Flats to determine the degree of protection a thick ice cover afforded underlying sediments when impacted by commonly fired artillery and mortar rounds.
DISCUSSION:
a. General consensus among the Task Force was that the FY 90 study was carried out in a professional high-quality fashion resulting in long-awaited answers. Although the task force concurred with the final report's conclusions, they felt some strengthening could be made through additional laboratory work and statistical analysis in the upcoming year.
b. Resumption of firing in the Eagle River Flats impact area requires preparation of an Environmental Assessment IEA) to include Eaqle River Flats Task Force and public involvement. As a basis for thp assessment, a firing plan will be prepared describinq in detail training parameters for Eagle River Flats.
c. The 20 Mar 91 test fire utilized both howitzer (105mm) and mortar (81mm and 60mm) point detonated and delayed fuse rounds. Ice cover on the Flats was between one and two feet thick with an additional six inches of snow on the top. Freliminarv analysis of the impact craters indicated that disturbance to the soil layer from point detonated rounds was minimal. Within
most of the eight- to ten-foot (diameter) howitzer craters. the ice sheet remained intact with only a two- to three-foot (diameter] area of broken ice in the center. It appeared that little or no sediment was ejected from the craters. In one case, a four-foot section of the ice sheet was completely blown out of the crater exposinq the surface of the underlying frozen sediment
which remained virtually undisturbed. Effects from the Blmm and 60mm mortar point detonated rounds were even less severe, producinq shallow craters with slight depressions in the center.
Two 81mm mortar delayed fuse rounds produced anamalaus craters--mounds of broken ice and snow piled above the surface with no apparent depression. Upon removing some of the loose ice and snow, it was discovered that beneath the mound was a two-foot (diameter) by four-foot deep hole well into the ice and frozen sediment. It appears that the explosion was confined enough to break and heave up the ice without ejectinq any material from the crater.
Another unusual result was observed involving two 105mm delayed fuse rounds. The projectiles hit the ice and frozen ground, then ricocheted into the air where they exploded. One round blew up at 50 feet or less above the ground and the other at approximately 10Q feet high.
d. Initial conclusions, based on this experiment, find point detonated rounds to have little impact on frozen ground beneath the one- to two-foot layer of ice. Delayed fuse projectiles, on the other hand, behave very erratically in areas of ice and frozen grol!nd and it is recommended that they no lonqer be lrtilired on Eagle River Flats.
4. Action Taken:
a. Detailed evaluation of 20 Mar 91 test fire results is being done for incorporation in the EA to resume firing.
b. Post hioloqists had a preliminary meeting with MAJ Niederlander and MM tiest of DIVARTY to brief them on the Eagle Eiver Flats studies, describe procedures involved in preparinq the EA, and discuss initiation of a firing plan for the Flats.
ACTION REWIRED:
a. Conduct a meeting with ACofS, G3 (LTC Gerding!, DIVAKY (COL Hiqby), IST BDE (COL Close) and DEH (COL Ruff) to iran out details regarding the firing plan and EA.
b. Finalize FY 91 Eagle River Flats scope of work and sampling plan.
c. Continue to provide logistical support {most of which is cost reimbursable through DERA funds).
d. Continue. to work closely with the Eagle F:iver Flats Task Force during the upcoming study and in development of the EA. |
Louis Howard |
| 6/21/1991 |
Update or Other Action |
Dept. of Army USAEHA Aberdeen Proving Ground MD 21010 Memorandum for Commander, US Army Toxic and Hazardous Materials Agency, ATTN: CETHA-TS-S, Aberdeen Proving Ground MD 21010-5401. Subject: Preliminary Evaluation of Possible Human Health Hazard from Waterfowl at Eagle River Flats (ERF) and Recommendations for Additional Studies. Enclosure 1 provides a prelixinaq eva.luation of potential health hazards from ingestion of contaminaxei waterfowl and recommendations for further study. A statistical sampling plan for hunter harvested ducks in the Cook Inlet Area is presented in Enclosure 2. The Health Risk Assessment Branch, this Division, and CPT Brian G. Scott, Division, MS, Occupational and Environmental Medicine Division, have provided input to and concurrence with the conclusions and recommendations contained in the enclosure. POC-Mr. Dennis Z. Druck and Dr. Jack Hellar.
The data from the Final CRREL Waterfowl Mortality in ERF indicate that the poisoned waterfowl are incapacitated or die within a relatively short period of time from ingestion (of white phosphorus). This factor should serve to make them relatively unavailable to the hunting community or would at least severely restrict the geographical area in which they would be found. It is unlikely that birds that are asymptomatic would have significant tissue levels of elemental phosphorus. Recommendations: Data clearly support continuation of the firing ban at ERF. Though data are fragmentary, there is sufficient evidence to suggest phosphorus toxicity in waterfowl and perhaps predators higher up in the food chain. Additional field sampling and lab studies should be performed.
Data are insufficient to make a clear determination of possible human health hazard. Since this has been a persistent problem for at least ten years with no complaints of adverse human health effects it would appear that there is no confirmed basis for closing or restricting the forthcoming waterfowl season. Documented elevated phosphorus levels are a clear cause for concern and may in fact indicate a significant hazard, but the extremely sparse data for edible portions (muscle) in the waterfowl tested are insufficient to justify a major change to current procedures or regulations. Since hunting has already been banned at ERF, the only contaminated birds that hunters are likely to encounter are ones that were exposed at ERF and then migrated to an area where hunting is permitted. The probability of a hunter taking a large number of contaminated birds in a given season is very small. The health concerns in this situation appear to be more of an acute problem than chronic. Since P4 was used commercially as a rodenticide, there is information available on its toxicity to animals. Human data, from accidental ingestion, is also available. Based on this information, and the very limited data on tissue, P4 levels from wild and farm reared birds, it is very unlikely that hunters or their families could ingest quantities of P4 that would result in an acute toxic effect. Hunters should be warned not to consume sick waterfowl or waterfowl found dead in the area adjacent to ERF.
Additional studies need to be urgently performed on waterfowl under stringently controlled lab conditions. A statistically significant number of controls and treated birds need to be examined and edible portions (muscle) and also bone need to be examined for both elemental and total phosphorus content in animals dosed with P4. Field sampling is required to determine if contaminated birds are leaving ERF, and if they are, the types and approximate numbers that are dispersed in the general population. This data would significantly aid the assessment of potential hazard to human health. POC: Mr. Leroy W. Metker. |
Jennifer Roberts |
| 7/8/1991 |
Site Ranked Using the AHRM |
Initial ranking. |
Louis Howard |
| 8/8/1991 |
Update or Other Action |
US ACE CRREL Preliminary Analysis of Artillery Test Firing into Eagle River Flats during the winter of 1991 Charles M. Collins. The artillery test firing onto the ice of Eagle River Flats took place on 20 March 1991. The first part of the test consisted-of firing a series of 105 mm
howitzer high explosive (HE) projectiles with point detonating fuses, the configuration normally fired into the Flats for training, This was followed by a series of HE projectiles with time delay fuses. The objective of the time delay fuses was to see if the slight delay before’detonation allowed the projectile to penetrate through the ice cover before exploding. The HE projectiles were fired from MlOlAl IO5 mm howitzers of the 4th Battalion, 11th Field Artillery.
The second round of tests consisted of firing 31 mm mortar projeckiles, first point detonating and then time delay fused, into an area just to the north. of the impact area. Because of initial problems by the mortar crew on getting the projectiles on target, not all the era ters were accessible for later measurement. Several hit in the river and on the far side of the river. The third round of tests consisted of-point detonating fused 60 mm mortar projectiles fired into an area west of the 105 mm impact area.
In almost all cases, firing into Eagle River Flats when the ground was frozen and covered with an ice sheet had little significant effect on the underlying frozen sediments. Point detonating fused projectiles of both mortars and 105 mm howitzers appear to have little impact on the
underlying sediment with the craters confined to the overlying snow and ice sheet. Except for one 105 mm and one 60 mm dud, performance of the point detonating projectiles was satisfactory. Delayed fused projectiiles operated very erratically in areas with frozen ground and an ice cover and should not be used in the future in ERF.
The 105 mm howitzer projectiles, using point detonating fuses, created 2 to 3 m dia craters with an apparent depth of 0.25 to 0.4 m. Much of this apparent depth was due to removal of the 20 cm deep snow cover over the ice sheet. In most cases, the 30 to 60 cm thick ice sheet was still intact with only a 0.6 to 1.0 m dia area of broken ice in the center of the crater. Little or no sediment was seen to have been ejected from the craters. In one case a 1.3 meter diameter area of the ice sheet was completely lifted and blown out of the crater,esposing the frozen ground underneath. The exposed frozen ground was not visibly disturbed or cratered by the explosion.
The four projectiles of delayed fused 105 mm projectiles behaved very erratically. Two projectiles hit the ice and frozen ground and ricocheted into the air before exploding. One projectile exploded at a height of 50 ft or so. The other projectile exploded at least 100 ft up. One other crater looked very similar to the point delayed projectile craters. The other crater ( from the near surface burst?) was very oblong as if the projectile started to ricochet and was near the surface and traveling outward when it exploded.
The 60 mm and 81 mm mortars produced similar results in that the craters did not penetrate the ice cover. The 60 mm mortar, using a point detonating fuse, produced a 6 ft dia and 8 to 12 in deep crater. The explosion removed the 8 to 12 in snow cover, exposing the top of the ice sheet in the bottom of the crater. Little or no visible cratering of the ice occurred. The 81 mm mortar with the point detonating projectile produced 2.2 m diameter craters in the snow with just slight depressions in the ice at the center of the craters. Two of the 81 mm mortar projectiles with delayed fuses produced similar maters. |
Jennifer Roberts |
| 9/25/1991 |
Update or Other Action |
Press release from Army 6th ID (Light) Eagle River Flats Studies continue. With the cause of
waterfowl deaths on the Eagle River Flats narrowed earlier this year to white phosphorous from ammunition, Army scientists now are focusing their efforts on defining the scope of the white phosphorous
contamination and preventing or lessening exposure of other birds to the chemical.
With Army expenditures at nearly a half million dollars, and about $1.75 million spent on the project since 1989, the Army is diligently
working to find immediate and long term resolutions to the problem.
The more than 700 sediment samples taken in the flats from May 1990 to the present indicate that there are certain "hot spots" where white
phosphorous pellets are concentrated and where birds die in higher numbers. So far, these areas have been confined to low wet ground. Scientists with the U.S. Army Cold Regions Research and Engineering
Laboratory (CRREL) are continuing to analyze soil samples in an effort to identify any additional sites of contamination
Systematic searches of post lakes using canoes have revealed one dead bird, tentatively identified as a grebe, found on Clunie Lake, about two miles east of the Flats. Tissue samples on that bird indicated the presence of white phosphorous. The only other bird ever found to contain white phosphorous outside the flats was a mallard hen at Gwen Lake, also on post, in 1988.
While several herring gull eggs from the flats were found to contain white phosphorous, the eggs from the same nest that were not taken hatched successfully and researchers have not drawn any conclusions from this finding.
Recognizing that the possibility does exist that birds visiting or raised on Eagle River Flats can fly to nearby wetlands, the task force contacted the State of Alaska Department of Health and Social Services for an opinion regarding potential health risks associated with eating those birds.
Following a review of the investigation findings, Dr. John Middaugh, state epidemiologist, concluded that, "While the risk of adverse health effects from potential exposure to elemental waterfowl cannot be said to be zero, based upon evidence from available scientific data and findings of the ongoing investigation, the risk can be said to
be so low as to constitute no basis for public health concern. |
Louis Howard |
| 10/31/1991 |
Document, Report, or Work plan Review - other |
Letter from Kurt Eilo (EPA) to U.S. Army Colonel Robert D. Wrentmore. RE: Eagle River Flats Management Plan
The ongoing contamination study of the Eagle River Flats is beginning a new direction by addressing remediation alternatives. As members of the task force, both EPA and ADEC have suggested that the ongoing study efforts be redirected to follow consistently with EP As' Guidance for Conducting Remedial Investigations and Feasibilitv Studies (RIFS) Under CERCIA and the Risk Assessment Guidance for Superfund (Vol - I and II).
At the most recent ERF task force meeting, the task force appears to have reached agreement that the next step in the ERF study progress is to create a management plan consistent with the RIFS guidance. I would like to emphasize the importance of continuing the ERF study within this framework to provide an organized and cohesive approach.
A well-developed and expeditiously prepared management plan might best be facilitated if this project is completed locally where direct oversight and input by the DEH and task force members can be accomplished. The cooperative effort by the involved agencies has historically been a critical component in this study. It is also essential that the development of the management plan will not impact your limited resources currently devoted to achieving compliance with federal and state environmental programs.
I appreciate the ongoing efforts of Fort Richardson in addressing the contamination in Eagle River Flats. |
Louis Howard |
| 11/1/1991 |
Document, Report, or Work plan Review - other |
Comments sent to Army on the Environmental Assessment. Care should be taken to delineate between the effects of past practices and the effects of the proposed action. Type of munitions used on Eagle River Flats (ERF) should be limited to those with task force approval. Use of any new munitions should be accompanied by task force review for possible toxic effects.
Environmental assessment: Was white phosphorus (WP) proven to be the exclusive agent in waterfowl deaths? No effort is made to determine the presence of endangered species in the ERF area.
Is there any possibility of an overwintering population of salmon fry in the ERF area?
What are the components of the smoke emissions?
What amounts of toxics are released in the plume?
What criteria would "environmentally sensitive areas" be determined? A standard minimum ice thickness should be established pending a more thorough investigation by CRREL and task force approval.
Has an acceptable level of die-off been proposed? |
Jennifer Roberts |
| 11/13/1991 |
Update or Other Action |
Waterfowl Mortality In Eagle River Flats (ERF), Alaska: The Role of Munitions Compounds. During the study efforts of the summer of 1990, 26 co-located sediment & water samples were collected in ERF. These samples were analyzed by certified U.S. Army Toxic & Hazardous Materials Agency (USATHMA) methods by the laboratory of Environmental Science & Engineering Inc., of Englewood, Colorado. The samples were analyzed for all compounds in the U.S. EPA Target Compound Lists for volatiles, semivolatiles, inorganics & 10 compounds in USATHAMA'S munitions/explosives list. The results of this sampling & analysis did not lead researcher's to firm conclusions on the chemical toxicant responsible for the waterfowl mortality. Due to the fact that no chemicals analyzed for showed elevated levels, analysis of several the Army initiated a physical gross selected sediment samples.
In the summer of 1991, a sediment sample being prepared for visual inspection by the Army released a white puff of smoke upon
stirring. White smoke is characteristic of white phosphorus (WP) munitions & immediately led the Army to consider WP as a possible cause of the waterfowl mortality & conduct a search of available literature on the toxicity of WP to waterfowl. At this point, WP became the prime suspect of the waterfowl mortality. The WP is known to be highly toxic to waterfowl & other animals, including humans. Army arsenal (Pine Bluffs Arkansas) –& a white phosphorus manufacturing plant (Long Harbour, Newfoundland) into fresh & marine waters respectively, caused massive fish kills.
The WP does not exist in nature since it spontaneously oxidizes in the presence of oxygen to form phosphorus oxides. The Army conducted both field & laboratory studies of waterfowl & sediments from ERF & made an assessment of the toxicity of WP in the laboratory.
The Role of Munitions Compounds Of these tissues, the fat of both wild & farm-reared ducks contained the highest WP concentrations as would be expected of a lipid-soluble chemical, In contrast none of the five green-winged teal from the Susitna Flats contained WP In either the gizzard contents or their body fat. All domestic mallards that were dosed orally with WP, contained WP in their tissues.
The highest concentrations of WP were detected in body fat & were generally higher than the concentrations in fat from wild birds. In terms of acute exposure, there is no value comparable to an Rfd with which to compare the W levels. There are data from humans, however, which indicate that the lowest recorded lethal dose (LDLo) of WP as a result of accidental poisoning is approximately 1.4 mg/kg (EPA 1990). Again using the values from the teal found dead or dying on ERF a human would have to consume 3,333 teal in a single sitting to achieve the LDLo of 1.4 mg/kg.
Based on the chronic & acute human health risk assessment data, & several reports generated previously Dr. John Middaugh, M.D,, AK State Epidemiologist stated that “While the risk of adverse health effects from potential exposure to elemental phosphorus in waterfowl cannot be said to be zero, based upon evidence from available scientific data & findings of the ongoing investigation, the risk can be said to be so low as to constitute no basis for public concern.".
|
Jennifer Roberts |
| 11/29/1991 |
Update or Other Action |
Fort Richardson-Finding of no significant impact and environmental assessment for the resumption of firing in the eagle river flats impact area 11/91. Soil and water contamination will be eliminated by not using white phosphorous in munitions rounds fired into the flats and by conducting exercises in the flats only in the winter when sufficient ice cover is present to protect the underlying sediments. Comments deadline 12/20/91 to the 6th Infantry Division (Light) and U.S. Army Garrison |
Jennifer Roberts |
| 12/19/1991 |
Update or Other Action |
Memo for the Record: Eagle River Flats (ERF) waterfowl die-off abstract.
1. Eagle River Flats (ERF) has served as the primarv ordnance impact area for Fort Richardson since 1949. Ordnance fired into ERF included 0.50 caliber and M-60 machine gun rounds. 40mm,/90mm recoilless rifle rounds. M203 grenades. antitank rockets and incendiary missiles. Various calibers of artillery and mortar rounds fired into ERF include White Phosphorus. CWF) smokes, illumination. incendiary and high explosive rounds.
2. This important wetland is also a major staging area for a variety of waterfowl during spring and fall migrations. Biologists from the U.S. Army have conducted aerial waterbird surveys by helicopters and fixed-wing aircraft in thz Eaale River Flats since the early 1980's. While these surveys do not provide comprehensive data on the total number of birds that utilize the
flats. counts made during periods of peak waterfowl density provide the best information that-is available- During 1990, peak surveys showed as may as 1.460 swans. 2.450 geese, 2.355 ducks. 27 bald eagles, 52 sandhill cranes. 140 common raven, approximately 150 gulls and several thousand shorebirds using the Eagle River Flats, The fall migration through the flats is more important than the spring because much greater numbers of waterfowl use the flats at that time of the year.
3. Since August 1982. an estimated 1500-2000 waterfowl deaths have been observed each year at ERF (U-S. Army 19841. In January 1991, researchers from the U-S. Army Cold Regions Research and
Engineering Laboratory (CRREL) under contract to U.5, Army Toxic and Hazardous Materials Agency lUSATHAMAl determined that waterfowl mortality at ERF was caused by ingestion of residual WP
particle's stored in bottom sediments (USATHAMA 1991). WP particles, which are highly toxic to waterfowl, extinguish upon entering the shallow ponds on ERF and settle into bottom sediments
where they remain in a long term storage condition.
4. The 1991 field work involved invkstigation of the area1 extent, of WP within ERF sediments. the overall species being exposed to WP (including,predators), the possibility of exposure to humans through duck hunting and possible remedial alternatives for analysis.
5. Preliminary analysis of limited field data by the U.S. Army Environmental Hygiene Agency concluded that potential health risks associated with consuming waterfowl taken in areas near the ERF are minimal. Dr. Middaugh. State Epidemiologist, stated in a letter dated 28 Aug 91 on this subject that "the potential for any adverse health effect to a hunter or person consuming waterfowl obtained by hunters is extreme1y low". State and Army biologists collected over 300 duck gizzards from hunters in areas near ERF on the opening day of duck hunting season (1 Sep 91) and the shipped them to CRREL for analysis. The majority of these have been analyzed and to date not one has shown evidence of WP contamination.
6. FY92 field work will concentrate on conducting treatability studies and evaluating the feasibility and effectiveness of remedial alternatives. Data will be compiled in a Risk Assessment Helicopter and support services from Fort Richardson will continue to be provided as required.
7. Based on the findings of the CRREL 1991 final report coupled with the observation that lack of firing in the flats apparently had no effect on reducing: waterfowl mortality, Major General
Samuel Ebbesen, directed that an environmental assessment (EA) be prepared to evaluate the resumption of firing into the ERF using only nonphosphorus containing munitions. Major General Ebbesen's decision was made public in the press release by the 6th Infantry Division [Light) on 21 Feb 91, which was published in several local newspapers- An additional press release was made public and newspaper articles were printed in late September and early October 1991.
8, The EA for resumption of firing in ERF was released to the public for review and comment on 20 Nov 91. A well advertised public meeting was conducted on 26 Nov a-t which only one member of
the public was present. The public comment period ends on 20 Dee 91. at which time the Environmental Resources Branch will review and evaluate comments and modify the-EA as necessary for finalization.
9. At this time no impediments to firing in January are anticipated. CRREL is monitoring ice thickness and will continue to do so over the next few months. Mortar firing in the flats is
scheduled to commence on 2 Jan 92 and a test fire using 105mm high explosive rounds is projected for 8 Jan 92. DEH will continue ,to work with DIVARTY and 1st Brigade to iron out details regarding firing schedules and parameters. |
Jennifer Roberts |
| 1/1/1992 |
Site Added to Database |
White phosphorus contamination. |
Louis Howard |
| 1/11/1992 |
Update or Other Action |
In March 1991, the Army initiated a public review process that evaluated alternatives for the resumption of live firing. ERF was reopened for training uses in January 1992, following a series of test firings. Several restrictions were established, including only allowing firing during winter months after a thick ice cover is formed, preventing disturbance of underlying contaminated sediments. The Army also banned the use of white phosphorus in wetland impact areas nationwide on the basis of discoveries in ERF. |
Louis Howard |
| 1/31/1992 |
Document, Report, or Work plan Review - other |
Comments sent to Army regarding Remedial Investigation White Phosphorus (WP) contamination of Salt Marsh Sediments at Eagle River Flats (ERF) January 1992 Draft report. This letter is an expedited review of the above report to accommodate the short review period. We have no major technical comments concerning this report. However, ADEC requests that any interim and final or remedial treatment technology options be submitted to ADEC for review and approval 90 days prior to field testing. While not required, in order to facilitate future reviews, we suggest that ADEC be included in lab or bench studies involving interim and finai remediatial techniques.
The Department agrees with the objectives stated in Section X. Remediation starting on
page X-l : “Our objectives are to eliminate waterfowl mortality caused by WP and preserve the ERF wetland as a very productive and diverse habitat.” Capping or covering contaminated areas to make the WP particles inaccessible to sediment feeding waterfowl may be the most feasible strategy, but the Department’s position is that the treatment of the salt marsh sediments of ERF will likely require a combination of remediation strategies. Use of geotextile fabrics over the bottom of the contaminated ponds is feasible only if the fabric itself allows plant growth while maintaining a barrier to WP.
The interim remediation techniques that were presented at the January 22, 1992 task force meeting are listed below. Close coordination with ADEC is needed at this point to facilitate ADEC involvement & approval of the listed remedial actions proposed.
Interim Actions-Map distribution of WP & concentration of WP in ERF sediments to coordinate with the use of methyl anthranilate.
Remediation Techniques-By covering or capping of white phosphorus sediments Deposits by natural sedimentation. Use of geotextile that allows plants to grow through while containing the WP. Stability of geotextile fabric from weathering or freeze-thaw cycles may be an issue. Use of sand/clay cap to cover WP sediments.
Oxidation of White Phosphorus-Sediment drying and aeration. Chemical oxidation.
Sediment Aeration by vegetation that introduces oxygen.
Mortality Monitoring-Monitor 1991 mortality transect. The Department concurs. Refine & extend mortality transect. The Department concurs. Mortality monitoring to support hazing remediation. The Department disagrees with premise that hazing is a remediation method. Hazing in itself is an interim method to be used until a remedial plan can be implemented to eliminate contact with or removal of WP contamination. Mark & recapture of waterfowl to establish estimates of % mortality. The Department concurs. WP particle forms in relation to feeding behavior. The Department concurs. Effects on waterfowl eating predators. The Department concurs.
Movements of WP poisoned birds in ERF. The Department concurs. Eagle River Flats data management through database tracking based on geographical information systems (GIS) and other pertinent data mentioned. The Department concurs.
Note to file: "Interim Remedial Actions" or "IRA" discussed in the Preamble to 40 CFR 300.430(a) (I), 55 Fed. Reg. 8703-8706 (March 8 , 1990), and shall mean all discrete actions
implemented under remedial authority that are taken to prevent or minimize the release of hazardous substances, pollutants, or contaminants so that they do not endanger human health or the environment. Interim actions shall neither be inconsistent with nor preclude implementation of the final expected Site remedy and shall be undertaken in accordance with the NCP, 40 CFR Part 300, as amended, and with the requirements of CERCLA. |
Jennifer Roberts |
| 3/9/1992 |
Update or Other Action |
EPA letter to Army. This letter provides EPA comments on the scope of remedial
investigation for the ongoing studies of waterfowl mortality at Eagle River Flats based
upon the 1992/1993 Comprehensive Workplan compiled by Captain Steven T. Bird of
U.S. Army Toxic and Hazardous Materials Agency.
At prior ERF Task Force meetings, it was EPA’s understanding that the continuing investigation of mortality should follow a more defined scope consistent with the Superfund/CERCLA remedial process. The result of the most recent discussion was
that a Management Plan would be developed to outline this process and clarify potential
interim efforts and final remediation technologies based upon treatability studies and the base-line risk assessment under the RemediaI Investigation (RI) guidelines.
In the absence of the management plan which outlines the remedial process and data objectives, it is essential that close examination of the comprehensive workplan
tasks be completed to assure they align with the primary data gaps. The comprehensive
workplan fails to indicate establishing a risk-based white phosphorous clean up level as
an objective, Which should be the primary focus of the 1992/1993 research. This must be
done prior to initiating extensive field treatability studies and remediation alternatives.
If the study continues without conducting a risk assessment, then no clean up level can
be established and treatment or remediation must be to background or nondetectable levels
of white phosphorous. Conducting a baseline risk assessment will provide the data to
propose a clean up level other than background.
The primary focus of 1992/1993 study must be to obtain data to establish a risk based
clean up level. The following is necessary, at a minimum, to complete a risk assessment:
sufficient toxicity data, relationship of particle size to toxicity, chronic effect levels, . relationship if incidental ingestion vs. selective ingestion as a mortality factor, data on waterfowl exposure time to the contaminate.
Certain tasks of the comprehensive workplan will provide data that will be useful in establishing a risk-based clean up level. The management plan and the comprehensive workplan should address how this information will be consolidated. Each task provided in the comprehensive workplan is described only generally. Specific detail including each investigations methodology is necessary to provide thorough agency review. The comprehensive workplan would be more useful if the objectives of the data were presented.
Any proposed treatability studies should be presented to the task force with sufficient data to demonstrate: (1) no new variables will be introduced as a causative agent (direct or synergistic effects) of waterfowl mortality, (2) the treatability study cannot be further developed in a lab situation, (3) the study is directed towards a plausible final remedy or interim measure, (4) potential impacts and effects to study area, and (5) other ecological risks are minimal.
The efforts of the task force has been to provide preliminary input of basic directions in study development. EPA suggests that we clarify our joint responsibilities and the roles which are defined to the researchers, Fort Richardson DEH, USATHEMA, and task force members. It is essential that the task force function as a scientific board to review research results, guide research efforts, and offer agency perspectives, experience, and guidance for U.S. Army decisions. |
Jennifer Roberts |
| 3/10/1992 |
Document, Report, or Work plan Review - other |
Comment letter sent to Army on Eagle River Flats 1992/1993 Comprehensive Workplan by Captain Steve Bird USATHAMA February 1992. The workplan submitted is a scope of work not a workplan. The document lacks the details, specific actions, quality assurance/quality control (QA/QC), field and lab procedures that are essential components of a workplan. Prior to any field testing of interim (hazing, methyl anthranilate) or final remedial measures, comprehensive and detailed work plans must be submitted, reviewed and approved by ADEC for the department to concur with any interim or final remedial action.
Currently, the department is requesting that workplans for investigation and cleanup of contaminated sites (Eagle River Flats) be submitted ninety (90) days in advance of any scheduled work. This schedule will allow for a thirty (30) day review period by the department, twenty (20) days for any necessary revisions by the Army, another thirty (30) days for the department to review the revised document and grant approval, and an additional ten (10) days for any unforeseen delays. This will ensure that any field work is conducted in accordance with applicable state guidelines and regulatory requirements, thereby helping to ensure that work does not have to be redone by the Army.
The department agrees with the premise that the primary objectives are to: discover, develop, and initiate remedial actions to reduce waterfowl mortality as quickly as possible. The questions posed as to WP suspended in the water column, vertical extent of WP in sediments, physical forms availability to wildlife, and other questions are applicable, but these questions need to address neutralization and/or removal of WP contamination from sediments to reduce further impacts to wildlife and the environment. Establishing cleanup levels for WP sediment contamination wasn't mentioned, but it should be developed as a part of a remedial investigation plan for Eagle River Flats. |
Jennifer Roberts |
| 3/19/1992 |
Update or Other Action |
U.S. Department of the Army HQ memorandum on ERF Study bird hazing activities signed by Jon Nelson USFWS Co-Chair ERF Task Force and Robert J. Wrentmore DEH 6th ID (L) Co-Chair ERF Task Force
This memorandum is to reaffirm the position of the Eagle River Flats (ERF) Task Force and 6th Infantry Division (Light) regarding the integration of bird hazing and repellant operations in the Fy92 study. After review of the FY92 study plan presented by CPT Steve Bird at the 10 March 1992, meeting, the Task Force was unanimous in the decision that bird hazing activities would only be implemented following the collection of spring waterfowl mortality data by Cold Regions Research and Engineering Laboratory (CRREL) Scientists.
Baseline waterfowl mortality information has been extremely difficult to obtain and is needed to evaluate the success of future remediation work. Biologists with CRREL will use a transect method to search for dead and dying waterfowl in designated areas which will serve as an index for determining overall
mortality rates. Hazing activities will alter or skew this data, therefore, they will be postponed until the biologists have collected sufficient data from the spring migration. It is anticipated that hazing will commence around
15 May 92. CRREL and Department of Agriculture personnel will closely coordinate these activities. |
Jennifer Roberts |
| 3/26/1992 |
Document, Report, or Work plan Review - other |
Letter from Environmental Health Pesticide Program Richard Barrett.
1. Methyl anthranilate (MA) is an experimental pesticide, but based on the criteria set forth in CFR 172.3 in this particular application, it is exempt from requiring an "Experimental Use Permit" from EPA since the total land and aquatic application is much less than one acre.
2. MA has a very low toxicity for birds and mammals, but there is some evidence of toxicity to aquatic and marine organisms. In this instance, because of the small size of the application area, the impact of the application of MA would be minimal. An evaluation of the aquatic toxicity is a proposed task within the workplan. If in the future, there is proposed a widespread/broadcast application of MA, then by state regulations (18 AAC 90.600), the applicant would be required to obtain a permit from our program to apply the pesticide to the "waters of the state". |
Jennifer Roberts |
| 8/21/1992 |
Update or Other Action |
Staff sent comment letter to Office of Governor, Division of Governmental Coordination regarding the ERF firing resumption Environmental Assessment and Finding of No Further Significant Impact State ID AK920812-08A.
Care should be taken to delineate between the effects of past practices and the effects of the proposed action. Provide detailed explanation on why ERF is the optimum training area for live artillery training and not just an exclusion of other sites. No attention is paid to the cumulative effects of bombardment on ice cover. A shell takes out 80% of ice cover, what is the possibility of another shell removing more than the remaining 20%. A standard minimum ice cover thickness should be established pending more thorough investigation by CRREL and task force approval. The type of munitions used on ERF should be limited to those with task force approval. The use of any new munitions should be accompanied by task force review of possible toxic effects. |
Jennifer Roberts |
| 2/10/1993 |
Update or Other Action |
Memorandum for Director Environmental Programs, ATTN BG Gerald Brown Chief of Engineers, 2600 Army Pentagon, Washington D.C. 20310-2600 from Dept. of Army, HQ 6th ID (L), & US Army Garrison, Alaska Ft. Wainwright AK 99703-5000 APVR-PW Dated 10 February 1993.
Request that the project to investigate and remediate white phosphorous contamination on Eagle River Flats (ERF) be transferred from the Army Environmental Center (AEC) to the U. S. Amy Garrison, Alaska at your earliest convenience. The consensus of opinion of the ERF Task Force members is that continued management by AEC is no longer in the best interests of remediating the environmental damage on ERF. The Task Force has lost confidence in the ability of AEC, and particularly in the AEC project manager, to execute this project on our behalf. AEC was originally invited to participate on the Task Farce with the understanding that USATHAMA would serve as our contractor to provide a product to Task Force specifications and requirements.
Over time USATHAMA/AEC’s role has evoked to one of overall project management, while becoming increasingly less response to the concerns and guidance of the Task Force. Today there is a very wide gap between AEC and the Task Force with respect to both technical and procedural issues, Both parties are genuinely convinced that they are correct; however, the impasse ensures that little or no progress will be forthcoming for the energy and money that will be applied to this project. AEC’s agenda may be environmentally and technically sound; but so long as the regulatory agencies in the State of Alaska., all of which are represented by senior membership on the ERF Task Force, do not feel the agenda is in consonance with their guidance, plans, programs, and applicable rules and regulations, there can be no meaningful progress on this remediation effort.
The Alaska District of the Corps of Engineers is fully staffed and prepared to execute all aspects of this project in our behalf and their exceptional track record for quality workmanship in the area of environmental studies and remediation bodes well for success. Therefore, in the interests of moving forward we strongly recommend that all management aspects of this project be immediately transferred to the U. S. Army Garrison, Alaska who will serve as the Executive Agent for the Eagle River Task Force. Signed: Robert J. Wrentmore, Col. EN, Director of Public Works, Everett Robinson-Wilson, U.S. Fish & Wildlife Service, Daniel Rosenberg, Alaska Department of Fish & Game, Jennifer Roberts Alaska Department of Environmental Conservation. |
Jennifer Roberts |
| 3/3/1993 |
Update or Other Action |
Memorandum from ADEC to Wendy Fully Fort Richardson regarding Management plan criteria. Enclosed is a list of management plan elements and criteria for Eagle River Flats management plan as desired by ADEC. List of criteria may be incomplete as ADEC is not in the business of writing management plans (9 pages faxed to Army on 3/3/93).
1. Introduction
A. Incorporate background information from literature searches, personal interviews, and previous investigations.
B. List project objectives of site from previous work and identify data gaps to make recommendations on future work.
C. Provide scoping documents which clearly identify project activities before beginning the field work. These documents present rationale for conducting specific project activities, and serves as a tool for assigning responsibilities and setting the project schedule and cost,
D. Quality Assurance Project Plan (QAPP) and Field Sampling Plan (FSP), These 2 parts make up the Sampling and Analysis Plan (SAP), are presented as Appendices to the Mgt Plan: The QAPP describes the Quality assurance objectives for the various sampling activities performed during the project. The FSP provides the requirements and procedures for all field work to be conducted. The objective and purpose is stated for the overall plan and each operational segment, The FSP will achieve a level of detail so that a sampling team unfamiliar with the project will be able to collect the required samples.
II. Conceptual Site Model [CSM)
A CSM serves to provide a framework for conducting the RI/FS and provide a comprehensive overview of the site by summarizing past investigative work, and in doing so, identify date gaps/deficiencies (both general and specific) and recommendations for addressing these gaps.
8. Data quality objectives (DQOs), are a statement of “quality" of the data required to enable the project personnel to make decisions, The statement of quality must include a detailed specification of the following components: types of data required to make a decision (chemical analysis of groundwater, groundwater level measurements, etc.), quantity of data required to make a decision (how many samples are required to achieve a given level of statistical power with specified Type I and Type II error rates) and measurement objectives (precision, accuracy, etc) for each type of measurement data to be collected. The establishment of DQOs is discussed in greater detail in “Data Quality Objectives for Remedial Response Activities (USEPA, March 1987)“.
DQOs consist of several elements which focus data collection planning so that sufficient data is available for decision makers to resolve project objectives: decision makers, decisions to be made to complete the RI/FS, generic definition of the DQOs that must be formulated for the next phase of the RI/FS activities, risk-based concentrations (RBCs) that may be of concern at the site, potential remedial alternatives.
In closing, the objective of the CSM is to identify potential contaminants, potential source areas, potential release mechanisms, potential transport media, and potential exposure routes and receptors, This information, integrated with geologic and hydrologic data, provides the details necessary to evaluate human health and ecological risk as well as remedial action alternatives.
III. Applicable or Relevant and Appropriate Requirements (ARARs) evaluation
A. ARARs may be categorized a8 chemical specific requirements that may define acceptable exposure levels and therefore be used in establishing preliminary remediation goals; as location specific requirements that may set restrictions on activities within specific locations, and as action specific, which may set controls or restrictions for particular treatment and disposal activities related to the management of hazardous wastes.
B. Other federal and state criteria, advisories, and guidance and local ordinances should also be considered, as appropriate, fn the development of remedial action alternatives. For documentation purposes, a list should be maintained of potential ARARs as they are identified for the site, As the RI/FS progresses each ARAR will need to be defined.
IV. Description of RI/FS study tasks
A. The RI/FS tasks are designed to address the DQOs as outlined in the Conceptual Site Model for the site. These tasks are designed to build on data from previous investigations and introduce methods to fill the remaining data gaps. This will allow for the resolution of the primary remedial Investigation objectives, |
Louis Howard |
| 3/4/1993 |
Update or Other Action |
USFWS letter to Army. The U.S. Fish and Wildlife Service encourages the most expeditious means to resolve the
waterbird mortality problem on Eagle River Flats (ERF), without compromising the long-term health of the wetlands. Permanent removal of white phosphorus from the wetlands, without long term damage to the wetlands, would be the ideal solution. Any reasonable means to obtain this end should be explored.
However, in the event that removal can not be accomplished, then capping techniques currently being tested or considered by contractors will need to implemented.
Currently we do not have enough information on any of the treatability or capping techniques
to adequately plan our future remediation efforts. Therefore, the 1993 field season should focus on the various remediation experiments that have been proposed for ERF, with certain guidelines that will prevent long-term disturbance and destruction of the wetlands. The proposed experimental remediation activities for ERF that the Service supports for 1993 include the following, with stipulations:
1. Experimental treatment of sediments to remove white phosphorus. Treatment of
sediments may include aeration, or other mechanical, chemical or thermal means of white phosphorus elimination. Acceptable methods for exposing and/or treating sediments include:
Dredging, Pumping (and diking-external fill)
Unacceptable methods for exposing and/or treating sediments include: Blasting channels,
Digging channels, Diking by extensive scraping/dozing.
2. Geotextile Caps. Continue to explore the use of geotextile caps, and other proposed
products such as bentonite, to act as a barrier to feeding birds. The Service supports the continued use of temporary methods to reduce waterbird mortality, such as hazing and testing of methyl anthranilate in 1993. |
Jennifer Roberts |
| 3/11/1993 |
Document, Report, or Work plan Review - other |
Eagle river flats remediation alternatives letter sent to the Army. ADEC supports the implementation of the treatability analysis of the remediation measures for Eagle River Flats which were discussed at the Hanover, New Hampshire meeting December 1992. The measures discussed were: hazing, repellents, draining, pump and treat, geotextiles, natural cap, phyto fill, impoundment, pond swap, sonication, dredging with physical separation, thermal treatment and land farming. |
Jennifer Roberts |
| 3/19/1993 |
Update or Other Action |
Department of Army, Office of the Chief of Engineers Washinton D.C. 20310-2600 to Commandor 6th ID (L) and U.S. Army Garrision Alaska, ATTN: Col Wrentmore, Fort Wainwright, AK 99703-5000. RE: 2/10/1993 memorandum. I have reviewed referenced memorandum which expresses your
dissatisfaction with the U.S, Army Environmental Center (USAEC) project management of Eagle River Flats (ERF) and requests that the management of the white phosphorus contamination on ERF be transferred from the USAEC to the U.S. Army Corps of Engineers Alaska, District. I have also reviewed USAEC's ERF plan and current schedule which shows completion of the Record of Decision and initiation of remedial design in October 1994.
The USAEC has also assured me that the contracts are in place or will soon be in place to insure that the schedule will be met. I am
concerned and frankly surprised by the apparent lack of coordination and cooperation between the Eagle River Flats Task
Force and the USAEC. As you know, the USAEC manages numerous projects on many installations and their reputation for
professionalism, thoroughness and customer service is widely recognized.
We all share a responsibility to ensure that this project is conducted expeditiously and with the best interest of the Army and the tax payer as the primary focus. I have directed the Commander of the USAEC visit with you in the very near future. He will sit down and discuss all credible options including those you propose. After his visit and your discussions, I will make a decision regarding your request. Signed Gerald Brown, Brigadier General, U.S. Army Director, Environmental Programs. |
Jennifer Roberts |
| 5/7/1993 |
Document, Report, or Work plan Review - other |
Letter sent to Colonel Robert Wrentmore on Remedial Investigation report and treatability studies February 1993. At no time in the past has the Army submitted comprehensive RI and TS management plan for ERF site work that meet the requirements of an RI/TS, since it does not meet the NCP or EPA guidance definitions or the needs of ADEC, or was done under an approved RI/FS/TS management plan. ADEC will review and comment on the document as a Limited Field Investigation. An LFI is a preparatory report that gathers enough information to allow development of a RI/FS/TS management plan. |
Jennifer Roberts |
| 11/15/1993 |
Update or Other Action |
Letter sent to Director Division of Wildlife Conservation, Department of Fish and Game, U.S. FWS Walter Stieglitz, Alvin Ewing USEPA. In June 1993 Fort Richardson was proposed for listing on the National Priorities List (NPL) established under Section 105 of Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA also known as Superfund). Negotiations between the Department of Environmental Conservation, EPA. Army, are ongoing and a final Federal Facility Agreement (FFA) is anticipated by November of this year. The FFA is the regulatory agreement that will establish remedial investigations, remedial activities and schedules for these activities at Fort Richardson.
This letter serves as formal notice that we are withdrawing from the ERF Task force pursuant to Section VI of the ERF task force charter. The dissolution of the ERF Task Force becomes effective 60 days from the date of this letter. In order to retain the valuable input of the FWS and F&G, we propose to develop an ERF Working Group. This working group will supersede the ERF task force and contribute directly during the CERCLA Process. Signed Janice Adair Regional Administrator November 16, 1993 and George Vakalis Colonel U.S. Army Garrison Commander November 8, 1993. |
Janice Adair |
| 4/4/1994 |
Update or Other Action |
USFWS letter to Army.
When Fort Richardson was placed on the National Priorities List, the Eagle River Task Force wes disbanded and replaced with the Remedial Project Managers (RPM) group (represented by the Army, the State of Alaska Department of Environmental Conservation, and the U.S. Environmental Protection Agency) and a Biological Technical Assistance Group (STAG) (represented by the U.S. Fish and Wildlife. Service, Alaska Department of Fish and Game, the U.S. National Oceanic and Atmospheric Administration, and the U.S. Environmental Protection Agency). The purpose of the BTAG is to provide technical advice to the RPMs, similar to the role performed by former task force members to decision makers. The success of the ERP Task Force prior to its termination was founded upon good communication and cooperation among the participating agencies.
We expected to continue this cooperative effort through the BTAG/RPM format that has now been established under the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA). Recently, the BTAG became aware that cooperation with the RPMs regarding the future direction of research, monitoring, and treatability studies on ERF had broken down. The BTAG was not included in the initial review of scientific proposals for the 1995 field season and learned that some studies had been eliminated by the RPMs and new studies pursued, without any technical advice from the BTAG.
Since BTAG members represent agencies with a strong interest and responsibility for the protection and maintenance of the natural resources of ERF, significant actions without BTAG input are unacceptable. One of the BTAG members, Mr. Dan Rosenburg of the Alaska Department of Fish and Game, has been 2 member of the Task Force since its inception and was instrumental in directing the investigations which identified white phosphorus as the cause of wildfowl mortality on the Flats. He was concerned enough about the occurrences described above to write a letter to you regarding the entire BTAG's extreme displeasure with this method of operation.
With this letter, the BTAG, and the Service in particular, wishes to show support for Mr. Rosenburg's position. We also wish to inform you that, at the recent meeting to discuss the field work proposals at Ft. Richardson, the BTAG resolved the differences with the RPMs. A cooperative working relationship has been reestablished and we will make every effort to have it continue. We understand that the CERCLA process requires the U.S. Army to conduct studies that likely would not have been undertaken with the former Eagle River Task Force.
However, we must also emphasize that regardless of CERCLA related activities and decisions, if a significant risk to waterbirds on ERF continues, the Service will address the problem as mandated by the Migratory Bird Treaty Act. We continue to appreciate the Army's unstinting support in solution of this problem and we are now confident that we can maintain the cooperative approach that has proven so effective in the past to address the contaminant and mortality concerns on ERF. |
Jennifer Roberts |
| 5/15/1994 |
Update or Other Action |
Field Evaluation: Mortality of Mallards Feeding in Areas Treated with Methyl Anthranilate (MA). In 1992 a study was conducted to determine MA effectiveness in reducing the
mortality of exposed mallards. The mortality of ducks continuously exposed to WP contaminated sediment in a treated MA and control pen was equal at 24 hours but increased in the control pen through the conclusion of the test.
Subsequently mallard mortality was reduced 60% in the MA-treated pen. However, modification in the MA bead formulation and replicated testing were needed. The purpose of this test was to determine the mortality of mallards feeding in pens treated with a modified MA formulation, JR930725.
The mortality of ducks continuously exposed to WP-contaminated sediment was 60% lower in pens treated with MA JR930725 than in pens treated with JR930413 within 24 hours post-treatment (Fig. VW-l). In JR930725-treated pens, feeding activity was also reduced where consumption of supplemental food increased. The results were similar to laboratory trials; immediately following
the treatment, duck activity between the treated and control areas was not
significant. However, the MA formulation JR930725 caused sufficient avoidance
of the treated pen to reduce the overall mortality by 50%. Indications are that
ducks encountering the MA initially responded positively on subsequent treatment days. Also, MA formulation JR930725 indicates that there were residual effects because ducks exhibited some learned avoidance behavior
following the treatment.
Ducks were restricted to feeding in confined areas: 7 x 20 m pens. Since pens were highly contaminated and duck movements and feeding were restricted, it placed ducks at an abnormally higher risk, suggesting that MA would actually perform better in an open field situation. Thus, we anticipate that the relative
risk of poisoning in MA-treated areas would decrease if the ducks were allowed to leave the area. During August and September, telemetry data indicated that turnover of waterfowl using ERF was low. Therefore, each duck had a higher risk of encountering WP. But if MA exposure translates to learned avoidance, then the low turnover should equivocate to overall lower mortality. |
Jennifer Roberts |
| 5/16/1994 |
Update or Other Action |
Pond 285 (0.9 acres) on Racine Island was capped and filled as part of a treatability study. Evaluation of Concover and Bentoballs (later to be called AquaBlock). The results of laboratory and field trials of Concover@ and BentoBallsTM indicate that the BentoBallsTM barrier system has potential for reducing
waterfowl mortality. The cost per hectare of the BentoBallsm barrier system versus other systems, such as a Plastic Membrane barrier system, would be $17,537 ($12,103 materials + $5434 on-site manufacturing cost) and $65,632, respectively (T. Nachtman, pers. comm., 1993). The higher cost of the Plastic
Membrane barrier system involves the use of more materials.
For example, Geotextile would be laid on the existing subgrade, followed by Geonet,
Geomembrane and venting pipes to create a gas venting system, and 10 cm of sand for a weighting layer. However, with this system extra substrate at additional cost would be needed for reestablishing vegetation. Further, the performance of the Plastic Membrane barrier system in areas of frequent freezing
and thawing is questionable. For example, it is made of four materials that have varymg thermal properties, and this may lead to rapid deterioration of individual system components, ultimately causing poorer performance of the
entire system in the long run. The constructability of this system is also more
difficult in that the flexibility of the Geomembrane decreases in lower
temperatures, and cracks may develop in temperatures ranging from 41” to -22”F, especially at seams or spot tack welds.
The advantage of the BentoBall barrier system is its organic clay structure, which allows gas to vent and vegetation to become established. Further, it will shrink and swell as evaporation and flooding occur in the marsh. The costs of
production could be minimized by either purchasing a portable batch cement
unit or producing the material through a batch cement plant that is idle during the winter months and then utilizing local aggregatesIn addition, the bentonite can be shipped by rail to reduce the freight charges. Further research could derive formulas that can be tailored to specific water qualities and types to maximize the clays as a long-term barrier, and development efforts using organic clay can be
investigated to augment in-situ fixation of WP and heavy metal contaminants. |
Jennifer Roberts |
| 5/31/1994 |
Document, Report, or Work plan Review - other |
Comment letter on Draft Final Comprehensive Evaluation Report & Draft Final Potential ARARs evaluation. The ADEC has reviewed the Draft Final Comprehensive Evaluation Report & Draft Final Potential ARARs Evaluation for Eagle River Flats site at Ft. Richardson
Army Post, dated May 1994. These documents are prepared to assist the remedial project managers (RPMs) in developing a comprehensive & cohesive management strategy for site assessment & treatability work that will be done prior to actions necessitated by the CERCLA Federal Facility Agreement (FFA). ADEC has formatted its comments into ARARs & then the Comprehensive Evaluation Report (CER).
ADEC has not sent this version of Potential ARARS Evaluation for review by state legal counsel, but has done a preliminary comparison to state regulations & statues. When the site moves into the formal CERCLA RI/FS process, another version of ARARs will be submitted to ADEC that will comply with the legal aspects of the FFA. At that point, I will submit the ARARs to state legal counsel for formal review & comment.
Review of the Potential ARARs indicated that, in general, the AK Statues, Title 46 were not referenced to the appropriate regulations. Additional references to the appropriate statues would make this document more accurate.
In Table 4, page 18, the Potential Action-Specific ARARS table does not list 18 AAC 60, Alaska Solid Waste Regulations. This regulation may apply in addition to Alaska Hazardous Waste Regulations.
Table 5, Potential Other Criteria or Guidance to be Considered table under the State of AK, there is typographical error in all the bullets, Alaska EUSEPArtment of Environmental Conservation, it should read Alaska ADEC of Environmental Conservation.
DRAFT FINAL COMPREHENSIVE EVALUATION REPORT
Page 2-5, Section 2.1, last paragraph
The paragraph discusses the mission of the US. Army at Fort Richardson changing from light infantry to brigade. Please give more details of how that will effect the change in practice range activities & munitions, & how that will impact ERF. A major concern is the impact of firing, even during the winter with ice pack covering the flats, & how that may impact the effectiveness of remedial action(s).
Page 2-14, Section 2.3.6
This paragraph refers to salinity of sediments & water in ERF. As a point of reference it would be useful to have salinity figures of water in Knik Arm &; if known, other areas similar to ERF.
Page 2-17, Figure 2-3
Please include the vertical exaggeration used in the figure.
Page 2-24, Section 2.4.3
This paragraph discusses the impact features associated with artillery. The information of craters & how WP is dispersed during crater formation may be an important link in determining hot spots. Much field work was done to evaluate crater formation & WP concentrations. The report would benefit from a discussion of that information.
Page 2-31, Section 2.4.4.6, second paragraph
The paragraph briefly discusses ERF as a fish rearing location for salmon & Dolly Varden. Please state which areas of Eagle River are utilized by salmon & Dolly Varden for rearing activities.
Page 4-7, Section 4.4.2, second paragraph
This paragraph discusses measuring the natural erosion processes & that the accuracy was limited to plus or minus 10 cm. This accuracy seems to allow a high degree of error. If this information is of importance a better method should be developed to minimize the margin of error. It is ADEC’s position that knowledge of the natural processes may be critical information in developing remedial strategies for ERF & requests that a serious effort be made to increase the accuracy of information on erosional processes.
Page 4-8, Section 4.4.2, second paragraph
This paragraph discusses the deposition & erosion rates for ERF & the problems with artillery firing destroying the makers placed during summer field season. ADEC again wants to stress that information on the natural processes (deposition & e.rosion) are critical to evaluate the effectiveness & feasibility of potential remedial actions. Therefore, ADEC encourages the Army to actively pursue better methods to gather this type of information.
Page 4-30, Section 4.7.1, #2 bullet
The last sentence contains an incorrect word, the sentence should read “Recent sediment deposits in ponds will be screened for WP.
Section 5.1
This section discusses the purpose & scope of the baseline risk assessment. ADEC would like to stress that ERF is a unique site with very unusual land use issues & contaminate receptors. Based on decisions made by the RPM’s, certain deviations from the traditional CERCLA human health risk assessment may occur & will be fully addressed in the RI mgt plan & report.
Page 5-9, Section 5.2.4, first paragraph
This paragraph is identical to the last paragraph on page 5-8, is that incidental or a word processing redundancy.
See site file for additional information. |
Jennifer Roberts |
| 7/1/1994 |
Update or Other Action |
Final Comprehensive Evaluation Report (CER) Contract No. DACA 85-92-D-0007 Delivery Order 0013. The CER is the result of a review and evaluation of the various studies and investigations completed at the Eagle River Flats (ERF) since 1982. It summarizes and presents the informaiton obtained to date from the ERF investigations. It is designed to assist the U.S. Army and the signatories to the FFA in determining practical, implementable, and effective remedial actions at the ERF.
The persistence of WP at the ERP also results from the characteristics of the tidal flats environment. White phosphorus reacts violently with air (oxygen) because it is a strong
reducing agent and oxygen is a powerful oxidizer. In the absence of oxygen (or other strong oxidizers such as hydrogen peroxide), WP will persist. One measure of the oxygen concentration is the redox potential (Eh); the lower the Eh, the less oxidized and the more reduced the environment. In Area C, Ehs ranged from -100 mV to -400 mV, extremely low values, which means WP will persist. These low values are attributable to the abundance
of organic material decomposing in the water and sediments of a salt marsh environment.
The frequent flooding of the tidal flats also contributes to WP persistence. Because so much of the area is frequently submerged, the sediments remain saturated, oxygen cannot
diffuse through them to reach the WP, and the WP cannot sublimate. White phosphorus is also resistant to photolysis and anaerobic biodegradation, making it stable in oxygen deficient sediments (USAEHA, 1993).
When WP-containing munitions explode, unoxidized WP particles will settle to the bottom of the water column in the water bodies they contact and become incorporated into the sediments- White phosphorus particles may also be present in an oxidized form as either soluble or insoluble phosphates in the surface water column. White phosphorus has been found often in shallow ponds and only a few times in the gullies. Only limited sampling has been done in Eagle River, and no WP has been detected at its mouth.
The Alaska State Epidemiologist described acute WP exposure risk this way: “While the risk to adverse health effects from potential exposure to elemental phosphorus in waterfowl
cannot be said to be zero, based upon evidence from available scientific data and findings of the ongoing investigations, the risk can be said to be so low as to constitute no basis for
public health concern” (Middaugh, 1991). He also states that the potential for any adverse health effect to a hunter or person consuming waterfowl obtained by hunters is extremely
low because of the following key factors:
Relatively small numbers of waterfowl are affected, compared to all waterfowl in the area;
The data indicate that poisoned waterfowl are incapacitated or die in a relatively short time after ingestion of elemental phosphorus.
Low levels of elemental phosphorus are found in the tissues of dead birds.
Exposure calculations based on sample data indicate that a human lethal dose would require consumption of 3,333 teals.
|
Jennifer Roberts |
| 8/31/1994 |
Update or Other Action |
Mead Treadwell Deputy Commissioner to Donald G. McCaig Sales manager Ellicott Machine Corp., Baltimore MD. Thank you for sharing your concerns about the U.S. Army's bid specs for the dredge which will be used to cleanup Eagle River Flats. Cleanup activities at Fort Richardson are being guided by a Federal Facility Agreement between the Army, Environmental Protection Agency (EPA),. and the ADEC. Our role (as a regulatory agency) is limited to providing input into the site investigation and cleanup to ensure that State concerns are addressed during the environmental restoration project. The agreement does not provide ADEC with any authority to influence the Army's equipment procurement process. Contractor selection and equipment procurement is strictly an Army function. Our Southcentral Regional Office is responsible for ensuring, along with the EPA, that the U.S. Army's remedial action objectives for Eagle River Flats are met. I have asked them to be especially cognizant of the safety issues as they observe the cleanup. |
Jennifer Roberts |
| 11/17/1994 |
Enforcement Agreement or Order |
Federal Facility Agreement (FFA) under CERCLA 120 Administrative Docket # 1093-05-02-120 signed by U.S. Army, U.S. EPA, & ADEC (John Sandor). The agreement ensures that the environmental impacts associated with past & present activities at the Post are thoroughly investigated & that appropriate removal &/or remedial action(s) is/are taken as necessary to protect the public health, welfare, & the environment.
Major sources of contamination at Fort Richardson (referred to collectively here as the Fort) include areas of white phosphorus at Eagle River Flats, PCB contamination at the Roosevelt Road transmitter site, volatile organic compounds at the Poleline Road disposal area, & the fire training pits.
"Agreement" shall mean this document & shall include all Attachments to this document. All such Attachments shall be incorporated by reference & are an integral & enforceable part of this agreement.
The Project Mgrs may decide to address a source area identified in Attachment I within the scope of a Two Party Agreement (TPA) between the ADEC & the Army. In such a case, & upon unanimous written agreement of the Army, US EPA, & ADEC Project Mgrs, the agreed upon activities at the source area may commence pursuant to the TPA, Such source areas will remain within the scope of this Agreement to the extent established in Part 3.5 of Attachment I.
An outline of the planned activities for the upcoming quarter & a revised depiction of the timeline for Attachment I using the CPM process. Any revisions to the primary milestones to this timeline shall be made pursuant to the procedures specified in Part XXXIII of this Agreement.
Enforceable deadlines (subject to extension pursuant to Parts XXV & XXXIII) for the draft primary documents are established in Attachment. The Army will propose secondary document target dates not otherwise established in Attachment. Unless the Parties agree on another disposition, new source areas will be addressed under the last scheduled OU as described in Attachment I.
The purpose of Attachment 1 is to set forth the elements of work required to be performed in responding to hazardous substance/waste releases, or the threat of such releases, at or from source areas at the Fort which pose an actual or potential threat to human health or the environment.
This document provides the site management approach to implement the remedial response process under the FFA entered into by the Army, the ADEC, & the US EPA. The source areas at the Fort have been divided into 4 manageable OUs. A critical path schedule has been developed for performing the general remedial activities at each OU, & an optimal sequence has been established for addressing each OU.
Attachment 1
2.0 Source Area Grouping into OUs
Levels of investigation for each source (PSE or RI/FS) per OU are set out below:
Remedial Investigation/Feasibility Study (RI/FS)
Roosevelt Road PCB site
Ruff Road Fire Training Area
Bldg. 986-POL lab.
Eagle River Flats Impact Area
OB/OD Area, Eagle River Flats
See site file for additional information.
|
Louis Howard |
| 1/31/1995 |
Update or Other Action |
CRREL Report 95-2: Winter Tests of Artillery Firing into Eagle River Flats, Fort Richardson, Alaska.
Winter tests of artillery firing were conducted in the Eagle River Flats impact range to determine the physical effects of exploding high-explosive (HE) projectiles on the ice-covered terrain. Eagle River Flats is an estuary at the mouth of the Eagle River used as the artillery impact range for Ft. Richardson. The Army suspended use of the impact range following the discovery that white phosphorus (WP) deposited in the salt marsh was responsible for large numbers of waterfowl deaths each summer.
The purpose of these tests was to assess if seasonal firing of HE projectiles from 60- and 81-mm mortars and l05-mm howitzers into Eagle River Flats could be resumed without significantly disturbing the sediments contaminated with WP. The results of the test firings indicated that a minimum of 25 cm of ice over frozen sediment or a minimum of 30 cm of floating ice over
shallow water was required to prevent disturbance of the WP-contaminated sediment by exploding l05-mm howitzer projectiles. Only l0 cm of ice was required to prevent disturbance by exploding 60-and 81-mm mortar projectiles.
In summary, based on the results of the test firing and observations of subsequent firing, winter
firing into Eagle River Flats under conditions similar to those during the tests will not disturb the underlying sediments containing white phosphorus particles. For 105-mm howitzers, a minimum
of 25 cm of ice over frozen sediment or a minimum of 30 cm of floating ice over shallow water is
required. For 60- and 81-mm mortars, minimums are much less, on the order of 10 cm of ice. Winter
firing with point-detonating projectiles when a sufficiently thick snow and ice cover is present
appears to be the best approach to training in Eagle River Flats to prevent disturbance and mixing of the WP-contaminated sediments. |
Louis Howard |
| 3/7/1995 |
Update or Other Action |
ADF&G Div. of Wildlife Conservation to US ARMY. Although many members of these two groups served together on the ERF Task Force, the RPM's (U,S. Army, Fort Richardson;
Alaska Department of Environmental Conservation; Environmental Protection Agency) and BTAG (ADFG, USFWS,
Environmental Protection Agency, and National Oceanic and Atmospheric Administration) now serve in different capacities.
The purpose of the Eagle River Flats BTAG is to advise and assist the Remedial Project Managers to plan, develop, conduct, and evaluate remedial and removal actions which
will permanently eliminate or greatly reduce white phosphorous poisoning of waterfowl and other biota while maintaining or restoring the viability of the wetlands as a feeding and staging area for migratory birds. To this end
the BTAG reviews scientific and technical proposals; identifies data needs and recommends studies; and evaluates research, monitoring, and treatability studies in order to guide the RPMs in developing and selecting appropriate removal Or remediation methods that will achieve the above goals. The reason for creating this two tier system is because of the different areas of expertise and responsibilities mandated to the RPM's that may preclude them from fully evaluating biological and technical aspects when recommending remedial action.
It is the purpose of the BTAG to assure that the RPM's have the benefit of being
thoroughly informed of the biological, chemical, physical and technical aspects of waterfowl and wetland ecology and its relationship to remediation. Among superfund sites, the ERF is unique and must be treated accordingly, Unlike other sites, there is little to no public health risk (with the important but distinct
exception of on-site investigators), and acute wildlife mortality exists, primarily to ducks and swans. Thus, the knowledge and expertise of ADFG and the USFWS is paramount in directing the focus and objectives of remediation towards the elimination of mortality and maintaining the viability of ERF.
Recently, concerns arose regarding the future direction of research, monitoring, and treatability studies on ERF and the nature and extent of cooperation between the RPM's and the members of the BTAG. The BTAG was not consulted in the initial review of scientific proposals for 1995 field work and was informed after-the-fact that several studies had been eliminated by the RPM's and others pursued without BTAG knowledge or input.
The success of the ERF Task Force prior to its termination was founded upon good communication and cooperation among the participating agencies. We hoped to continue this cooperative effort through the BTAG/RPM format that has now been established under CERCLA. We appreciate the opportunity to reconsider the decisions on the technical proposals that were made without BTAG input and hope that in the future we can continue to work cooperatively to resolve the waterfowl die-off on the ERF. |
Jennifer Roberts |
| 6/30/1995 |
Meeting or Teleconference Held |
CERCLA oriented Public Meeting held in June 1995 at the Russian Jack Springs Chalet and held quarterly until the RAB was formed. |
Louis Howard |
| 7/23/1995 |
Update or Other Action |
Letter from Alaska Department of Fish & Game (ADF&G) regarding discussion of potential assessment and measurement endpoints. Waterfowl Mortality: Still the primary issue and focus. Continue with methods used to measure waterfowl mortality on Eagle River Flats (ERF). On ground mortality transects and ground and/or aerial counts of bird use as a measure of the rate of exposure and; Radio teIemetry studies. These can be conducted less frequently than the ground transects and Sentinel bird studies.
Predator Exposure as measured by:
1. Aerial counts of-bald eagles and mortality of ducks (see above).
If exposure drops significantly than we can assume mortality will also drop. This depends on results of the current baId eagle studies which may shed light on a new approach.
Magnitude and Distribution of WP as measured by:
1. Sediment samples in intermittent to permanentIy flooded ponds with craters within or adjacent to ponds and;
2. Sentinel bird studies in known “hot spots” that have been remediated mechanically or naturally.
Waterfowl Mortality-Waterfowl mortality should focus on mallards, green-winged teal, and trumpeter and tundra swans.
Assessment should be conducted during spring and fall migrations. Endpoints should be based on background mortality as measured in other similar Cook Inlet marshes for the same species during the same time frame, using the same methods. Background levels should be reached in 5 years (for sake of discussion) on the ERF. Mortality transects on ERF should be located in same areas that have been surveyed historically.
Because mortality transects cannot cover the entire ERF and background levels for white phosphorous mortality are zero on other cook Inlet marshes radio telemetry surveys should be conducted with dead birds recovered and analyzed for white phosphorous. These surveys need not begin until mortality trapsects indicate that ERF mortality is similar to background mortality.
Predator Exposure:Bald Eagles should be the focus of predator exposure studies. Eagle numbers are likely indicative of the available food source. As the food source declines a decline in eagles is expected. Thus exposures will decline. Thus a decline in dead ducks should lead to a decline in eagle numbers and exposure if there are no other changes in the system. Radio telemetry studies currently being conducted and egg and nestling survival will provide new information to come up with endpoints.
Magnitude and Distribution of WP:Following remediation w-p sediment sampling will need to be repeated in areas previously sampled and any newIy discovered areas. A frequency of hits and concentration of a given sample will need to be established. Further in all known hot spots that are remediated sentinel ducks wii be placed and any mortalities analyzed for WP. Signed Dan Rosenberg |
Jennifer Roberts |
| 8/30/1995 |
Update or Other Action |
An autonomous pumping system consisting of a float-mounted centrifugal pump and a separate float-mounted generator set (genset) connected by power and control cables was designed and built for testing purposes in 1995. In the initial planning phase of the project, it became obvious from the relatively low relief of the shallow ponds that a sump in the middle of the pond is needed for the pumps to operate effectively.
Without a sump, the pumps will cycle frequently as the water is repeatedly drained down around the pump. In addition, shallow drainage ditches are needed to connect scattered low points in the pond area to the sump. Ditches are also useful in treating adjacent contaminated ponds without the need of additional pump
systems and sumps. All this needs to be accomplished with minimum human exposure to unexploded ordnance (UXO). |
Louis Howard |
| 9/30/1995 |
Update or Other Action |
During 1994 and 1995, Cold Regions Research and Engineering Laboratory (CRREL) completed several field investigations of the ERF physical system and laboratory studies of white phosphorus’s potential to bioaccumulate. The bioaccumulation studies were performed to assess the impacts of white phosphorus on wildlife at ERF. Additional studies were conducted on waterfowl utilization of ERF, waterfowl mortality, waterfowl distribution and movements in ERF, and toxicological studies of white phosphorus in waterfowl to determine acute lethal doses for ducks (Mallards).
Results of a 1994 CRREL study showed that white phosphorus particles remained intact and relatively unaffected in water-saturated sediments, but began to immediately degrade and disappear when the sediments became unsaturated, especially at warmer temperatures (>15°C). Therefore, sublimation/ oxidation was determined to be a viable remedial option for mud flats and intermittent ponds that have the potential to drain and dry. |
Louis Howard |
| 4/1/1996 |
Update or Other Action |
Memorandum for distribution from the U.S. Army regarding Authority for entry into Eagle River Flats Impact area for the purposes of Environmental Remediation and continued site investigation. IAW the provisions of AR 385-63 Range Safety, authority is granted to permit entry into Eagle River Flats Impact area for the purpose of dredging and associated remediation and site investigation activities in support of the ongoing Environmental Restoration Project. |
Jennifer Roberts |
| 4/30/1996 |
Update or Other Action |
Drainage ditches have been explosively excavated to permanently drain
contaminated ponds at ERF. The first, excavated in April 1996, drained Pond
109, a large, contaminated pond known as the Bread Truck Pond. Bread Truck Pond, the first pond permanently drained, was originally scheduled to be drained using a pump system. Budgetary constraints at that time prohibited the deployment of the system, and the pond was drained instead. |
Louis Howard |
| 7/23/1996 |
Update or Other Action |
Draft Remedial Investigation and Risk Assessment reports. The letter serves as formal notice pursuant to Section 25.1 of the Fort Rich FFA. ADEC is requesting a 20 day extension for review and comment on the RI/RA reports for OU C. Extend comment period from 7/12-8/12 to 7/12 to 9/6/1996. This extension request is to ensure, in part, that Alaska Fish and Game staff adequate time to review these documents given their current field schedule. |
Jennifer Roberts |
| 4/30/1997 |
Update or Other Action |
A second ditch, was explosively excavated in April 1997, drained a small, highly contaminated pond complex (Ponds 293 and 297) on Racine Island in the southern part of Eagle River Flats. Pond 293 is frequently flooded by high tides and was the location of high waterfowl mortality, so it was targeted for draining to remove it from use.
Prior to the excavation of the ditch to Pond 293, a review of the results of the previous spring’s operation was conducted. One of the lessons learned from that operation was that the charge spacing used (5 m) was slightly too long, resulting in some craters not overlapping. This produced narrow berms or barriers across the newly excavated ditch that did not allow flow out of the ditch until a flooding tide later in the spring eroded out the berm.
The other lesson was that the cratering charges were not fully tamped, despite the holes being filled with water, resulting in part
of the explosive force going upward instead of laterally, reducing the excavation efficiency of the charge. This resulted in several craters not being excavated to the expected diameter, again resulting in several narrow berms or barriers across the ditch. |
Louis Howard |
| 5/15/1997 |
Site Characterization Report Approved |
Final Remedial Investigation Report approved. The findings documented in this report are based primarily on data collected before implementing the CERCLA process at OUC.
However, the analytical process for the identification of WP concentrations was first developed during this phase and has since been adopted by the USEPA as "Method 7580 in SW 846 Update III."
Compilation and review of these data have led to the following conclusions:
1. WP is the primary cause of waterfowl mortality. Symptoms exhibited by exposed ducks in ERF are similar to those observed in ducks dosed with WP in the lab. WP also was detected in tissue samples collected from duck carcasses found in ERF.
2. WP was deposited in the sediment primarily during range firing activities. WP smoke munitions were used during training activities in ERF for several decades. Rounds were fired onto the flats and detonated, dispersing WP particles over large areas. Further distribution of the particles likely occurred when high explosive rounds exploded in WP-contaminated soil and sediment.
3. Craters in ERF potentially indicate the level of range firing activity. Detonation of HE munitions generally creates a crater at the point of impact. Although WP munitions do not form craters upon detonation, they typically have been used in conjunction with HE training activities. By applying a cause-and-effect approach, it can be deduced that the more craters in an area, the more munitions that have likely been fired there, and thus the higher probability of WP contamination.
4. WP particles are not homogeneous throughout ERF. WP particles are dispersed after munitions containing WP are detonated. Particle sizes vary because of the nature of an explosive release. Particle size, dispersion pattern, and ultimate resting location also depend on whether the munitions were detonated on land or over water. Even within small areas, the particle density can vary substantially.
5. The detection frequencies and concentrations for WP in sediment are highest in Area C, Bread Truck, and Racine Island. Sixty-three percent of the overall ERF sampling locations had nondetectable concentrations, but at least 45 percent of the locations in each of these three areas had detectable concentrations. The highest concentration, 3,071 micrograms per gram, was found on Racine Island.
6. WP particles can break down (sublimate) when exposed to air, but are long lasting in water-saturated media. WP particles are readily oxidized when exposed to air at temperatures exceeding 20°C. Because they dissolve so slowly, particles have an indefinite life when quenched in the water and allowed to settle into pond or
marsh bottom sediments.
7. Waterfowl are exposed to WP from the sediment of ponds and sedge marshes while they are feeding. Some WP particles match the size of food (such as seeds and macroinvertebrates) sought by dabbling ducks and swans. As the waterfowl forage for food in pond and marsh bottom sediments, it is possible that they cannot differentiate between WP and their normal food source. Dabbling ducks and swans are the primary receptors of WP.
See site file for additional information. |
Jennifer Roberts |
| 7/1/1997 |
Update or Other Action |
A single 2,000-gpm pump powered by a separate floating diesel generator was used to drain Pond 183 in Area C to test the equipment and determine feasibility. |
Jennifer Roberts |
| 10/9/1997 |
Meeting or Teleconference Held |
First RAB meeting held on October 9, 1997 and held quarterly since that time. RAB meetings included site visits and presentations on remediation progress. |
Louis Howard |
| 2/5/1998 |
CERCLA Proposed Plan |
Final Proposed Plan received. The primary cleanup objective for ERF is to reduce the number of duck deaths attributable to white phosphorus. The Army, EPA, & ADEC have set a short-term (5-year) goal of reducing the death rate documented in 1996 by 50 percent. This death rate was established to be 35 percent based on the deaths of radio-collared birds in 1996. The results of radio tracking & aerial surveys suggest that about 1,000 birds died at ERF in 1996. [Therefore, the short-term goal is to reduce the number of duck deaths to 500 birds or less in five years or less].
The long-term (20-year) goal is to reduce. the death rate attributed to WP poisoning to no more than 1 percent of the total annual ERF duck population. Currently the duck population is approximately 5,000; therefore, the allowable number of duck deaths from WP would be 50. This number could be adjusted based on population studies to be conducted during the monitoring program. The long-term goal of 1 percent of the total annual duck population is both measurable & attainable. It also addresses relevant provisions of the Migratory Bird Treaty Act of 1972. A review will be conducted in 5 years to determine whether the 20-year goal is achievable with the cleanup technologies selected.
Site investigations performed at ERF found WP particles were causing waterfowl deaths. Results were used to identify 18 ponds for cleanup. It was determined that for all hot ponds, attainment of cleanup objectives would best be accomplished by Alternative 3, pumping to drain ponds, followed by capping & filling for areas that do not dry sufficiently. Draining ponds & drying contaminated sediments to the maximum extent practicable before application of cap-&-fill material is preferred because it would produce a significant, & potentially total, reduction in risk.
Through the results of pumping & the natural processes that would follow, residual risk would decrease because the source of contamination would be permanently removed. Capping & filling would break the exposure pathway to the WP that may remain in sediment. Alternative 3 would have minimal short term destructive impacts on the wetlands at ERF.
See site file for additional information.
|
Jennifer Roberts |
| 2/12/1998 |
Meeting or Teleconference Held |
Public meeting for presenting the proposed plan for OUC was held. Public comments taken and March 6 was the deadline for public comments. |
Louis Howard |
| 2/23/1998 |
Site Number Identifier Changed |
Changed workplan from X9 to X8 (Other) to reflect ordnance being the primary contamination of concern at this site. |
Jennifer Roberts |
| 3/12/1998 |
Update or Other Action |
Alaska Administrative Codes and Statutes with regard to Environmental Conservation sent to Captain Steve Bird USAEC, CETHA-IR-A, ABG-EA Maryland. |
Louis Howard |
| 7/1/1998 |
Update or Other Action |
A pumping system treatability study was conducted using six pump systems. Pumps were deployed in Ponds 183, 155, and 146 in Area C and Ponds 290, 256, and 258 in Area A. |
Jennifer Roberts |
| 7/2/1998 |
Update or Other Action |
Updated USARAK institutional control policies and procedures received. The draft USARAK Command Policy Memorandum, ICs standard operating procedure and revised excavation clearance request have been finalized. To ensure the effectiveness of institutional controls, all organizational units and tenant activities will be informed on an annual basis of the institutional controls on contaminated soils and groundwater in effect on USARAK property. Where institutional controls are applicable to any organization, tenant, or activity, land use restrictions shall be incorporated into either a lease or Memorandum of Agreement, as appropriate. Costs for any and all remedial actions and fines and/or stipulated penalties levied as a result of a violation of an established institutional control shall be funded by the violating activity or organization. |
Louis Howard |
| 8/10/1998 |
Update or Other Action |
Letter from PERP J. Ginalias closing out the diesel spill from the EOD pad occurring on June 29, 1998. No additional information is required on the adequacy of the cleanup of the spill. 3 samples were analyzed and the remaining contamination meets the proposed 18 AAC 75 regulations.
Disposal methods proposed for the recovered fuel and excavated soils is approved. Approval only applies to the June 29, 1998 diesel generator spill and does not affect other cleanup requirements or department issues pending at the site. |
Jeff Ginalias |
| 9/30/1998 |
Update or Other Action |
Monitoring will be conducted at ERF to verify that the remedial action objectives (RAOs) are achieved. The goals of monitoring is to verify that an exposure pathway does not exist between the waterfowl and the white phosphorus contaminated sediments, to determine the number of waterfowl using ERF, to determine the number of waterfowl dying as a result of feeding in white phosphorus contaminated sediment, to determine whether remedial action is effective or needs modification. Major components of preferred remedy: treat WP sediments by draining ponds for five summers with pumps in beginning in 99. Season begins with May and ends in September.
In some cases explosives may be used to make small sumps for the pumps and shallow drainage channels. Other activities include cap and fill with bentonite or fill material areas of highest contamination in year 5, inspect cap every year for 4 years after material is placed (yr. 5, 6, 7, 8) and in Year 10, 15, 20. Contingency for hazing is allowed every year for first 5 years if needed. Implementation of remedy would begin 1999 and end in 2018.
Applicable or Relevant and Appropriate Requirements (ARARs)-Chemical Specific Requirements:On the basis of available information collected to date about the chemicals of concern associated with past activities at OU-C, white phosphorus at ERF has been identified as the chemical of concern. Currently, there are no promulgated numerical cleanup or discharge limitation values for white phosphorus; therefore, there are no chemical specific ARARs for potential remedial actions at OU-C.
Location Specific Requirements:Clean Water Act (CWA), Section 404: Section 404 of the CWA, which is implemented by the USEPA and the Army through regulations found in 40 CFR 230 and 33 CFR 320 to 330, prohibits the discharge of dredged or fill materials
into waters of the United States without a permit. This statute is applicable to the protection of wetlands at ERF. Section 404 of the CWA authorizes the U.S. Army Corps of Engineers (USACE) to regulate the discharge of dredged or fill material into all “waters of the United States (including wetlands).” The definition of “discharge of dredged material” was revised by the USEPA and
USACE (Federal Register, 58:45008) on August 25, 1993. Under the newly defined “discharge of dredged material,” USACE regulates discharges associated with mechanized land clearing, ditching, channelization, and other excavation activities that destroy or degrade wetlands or other waters of the United States under Section 404 of the CWA. The substantive requirements of the CWA Section 404 (b)(1) guidelines (hereinafter
referred to as the Guidelines) are applicable to cleanup activities that involve water discharges from the pumping operations and channel clearing conducted in wetlands at ERF.
Action Specific Requirements:Alaska Oil Pollution Regulations (Title 18, Alaska Administrative Code, Chapter 75 [18 AAC 75]) set requirements for discharge reporting, cleanup, and disposal of hazardous substances for spills of hazardous substances to
Alaska’s land or water within specified time frames. The broad ADEC definition of “hazardous substance” includes constituents such as oil and other petroleum products. The selected remedy will involve the use of onsite diesel generators to power the pump systems. These regulations are applicable for the discovery and cleanup of spills of diesel fuel or other hazardous substances at OU-C that are regulated by the State of Alaska.
Alaska Water Quality Standards (18 AAC 70) in general, apply to
groundwater and surface water and establish criteria for protected classes of water use. Where water is used for more than one purpose, the most stringent water-quality criteria ARARs will be used. Eagle River is protected for all water use classes. Specific criteria applicable to Eagle River will depend on the parameter being evaluated and the potential impact or discharge that may occur as a result of implementation of the remedy. The “Criteria for Growth, Propagation of Fish, Shellfish, other Aquatic Life and Wildlife” are the most stringent and, therefore, applicable to OU-C. Because pumping and installation of cap-and-fill material may affect surface water, these ARARs are applicable.
Regulations contained in 40 CFR 266, Subpart M, specify when military munitions become solid, and possibly hazardous, wastes and include requirements for storage and transportation of military munitions wastes that are designated as hazardous waste.
See site file for additional information. |
Louis Howard |
| 9/30/1998 |
Institutional Control Record Established |
ICs established by signing of ROD & subsequently been enforced by land planning department at the Post, the fact that it is an active firing range for the Post with limited access, & environmental restoration staff oversight.
ICs include the restrictions governing site access, construction, & road maintenance & the required training for personnel who work at OU-C source areas. The objective of these ICs is protection of human health, safety, & the environment by limiting or preventing access to contaminated areas or otherwise denying exposure pathways.
NOTE TO FILE: § 300.430 RI/FS & selection of remedy.(a) General—(1) Introduction. The purpose of the remedy selection process is to implement remedies that eliminate, reduce, or control risks to human health & the environment. Remedial actions are to be implemented as soon as site data & information make it possible to do so.
Accordingly, EPA has established the following program goal, expectations, & program management principles to assist in the identification & implementation of appropriate remedial actions.
(iii) Expectations. EPA generally shall consider the following expectations in developing appropriate remedial alternatives:
(D) EPA expects to use ICs such as water use & deed restrictions to supplement engineering controls as appropriate for short- & long-term management to prevent or limit exposure to hazardous substances, pollutants, or contaminants. ICs may be used during the conduct of the RI/FS & implementation of the remedial action &, where necessary, as a component of the completed remedy. The use of ICs shall not substitute for active response measures (e.g., treatment &/or containment of source material, restoration of GW to their beneficial uses) as the sole remedy unless such active measures are determined not to be practicable, based on the balancing of trade-offs among alternatives that is conducted during the selection of remedy.
April 11, 1997 18 AAC 75 CS regulations citation
18 AAC 75.319. DISPOSAL OF HAZARDOUS SUBSTANCES. Prior department approval is required for the ultimate disposal of a hazardous substance & of soil, cleanup materials, or other substances contaminated with a hazardous substance. (Eff. 5/14/92, Register 122)
Authority: AS 46.03.020 AS 46.04.020 AS 46.09.020
AS 46.03.745 AS 46.04.070
18 AAC 75.327. CLEANUP. (a) Immediately upon becoming aware of a discharge of a hazardous substance to land or waters of the state, any person responsible for that discharge shall contain, clean up, & dispose of the material collected, using methods for which approval has been given by the department. The discharge must be cleaned up to the department's satisfaction.
(b) Upon request, the department, in consultation with federal officials, as appropriate, will waive the requirements of (a) of this section if the department determines that it is technically not feasible to contain or clean up the discharge or that the containment or cleanup effort would result in greater environmental damage than the discharge itself. (Eff. 5/14/92, Register 122)
Authority: AS 46.03.020 AS 46.04.020
AS 46.03.740 AS 46.04.070
AS 46.03.745 AS 46.09.020 |
Louis Howard |
| 9/30/1998 |
CERCLA ROD Approved |
Record of Decision (ROD) signed. Selected remedy: Treat white phosphorus-contaminated sediment by draining ponds with pumps for five summers beginning in 1999. Pumping allows the ediments to dry and the white phosphorus to sublime and oxidize. The treatment season is to begin in May and end in August or September. A pond elevation survey will be conducted to determine the optimal pump placement. To enhance drainage, explosives will be used to make sumps for the pumps and shallow drainage channels. These shallow drainage channels enhance the hydraulic connectivity between ponds to encourage drainage.
Implement the following protective procedures to minimize disturbances to wetlands habitat: Restriction of activities that disturb wildlife in Area B and Area D, which are prime waterfowl habitat areas, Selection of the narrowest and shortest walking corridors to minimize disturbances to vegetation and habitat, Proper maintenance of equipment and structures, Minimize the use of equipment and staging-area footprints, Minimal localized use of explosives, Prepare work plans and solicitation of agency reviews, Monitor for impacts to wetlands habitat, Monitor for waterfowl use of ERF.
The ROD outlined a cleanup level description or remedial action objectives (RAO): Short Term RAO: Within 5 years of signature, reduce dabbling duck mortality rate from white phosphorus (WP) to 50% of 96 mortality rate attributable to WP. Radio tracking and aerial surveys suggest 1,000 birds died from WP in 1996 so allowable number of duck deaths from WP is 500 birds.
Long-term RAO: Within 20 years of ROD signature, reduce mortality from WP to no more than 1% of total annual fall population. In 1998, the population was 5,000, therefore allowable number of duck deaths is 50. These numbers would be adjusted based on future population studies conducted during monitoring program.
These objectives will be achieved by reducing the area of white phosphorus-contaminated media and reducing the exposure to white phosphorus. Reducing the exposure to white phosphorus will reduce the availability of white phosphorus to ducks, which in turn will reduce duck deaths.
After remedial action objectives are achieved and pumping is discontinued, cap-and-fill material was to be applied in ponded areas that did not drain and dry sufficiently to enable the white phosphorus to sublime and oxidize.
Maintain institutional controls, including the restrictions governing site access, construction, and road maintenance and the required training for personnel who work at OU-C source areas. The objective of these institutional controls is protection of human health, safety, and the environment by limiting or preventing access to contaminated areas or otherwise denying exposure pathways. |
Jennifer Roberts |
| 12/15/1998 |
Update or Other Action |
Remedial design/remedial action (RD/RA) statement of work received 12/01/98 and approved. |
Louis Howard |
| 5/3/1999 |
CERCLA Remedial Design/Remedial Action Plan Approved |
Draft RD/RA work plan and Pre-Final design received on 4/12/1999 and approved May 3, 1999.
Remedial Design Summary The objective of this remedial action is to temporarily drain ponds to allow the pond sediments to dry and allow white phosphorus to sublime and oxidize. This action consists of draining ponds using mechanical pumps after flooding cycles and/or rain. After several drying periods and verification sampling (approximately 5 years), capping and filling would be performed in areas where white phosphorus remains.
In the summer of 1997, this technology was tested through a pond pumping treatability study. Baseline and verification sampling was performed before and after pumping and the results showed an 80 percent decline in white phosphorus concentrations in the top 3.5 inches of sediments.
In each pond system, a dedicated pump system is installed annually after spring breakup and is removed before the winter freeze. The typical useful drying season is mid-May to mid-September with the emphasis on the earlier, normally drier months. Pumped water is discharged to an adjacent unconnected pond, river, gully, or open area. Mounted on floats, each pump system is completely automated to start and stop at established elevations of pond surface. Scheduled maintenance service and refueling is required. Typically, explosives are used to create sump holes for placement of the pumps, and to create short ditches for drainage to the pumps. The affected areas are small, and impacts are minimal and temporary. |
Louis Howard |
| 5/24/1999 |
Update or Other Action |
Pumping of ponds to dry out sediments for white phosphorus contaminants, sampling and field studies begins. The treatment season will begin in May and end in August or September 1999. A pond elevation survey will be conducted to determine the optimal pump placement. To enhance drainage, explosives may be used to make sumps for the pumps and shallow drainage channels. These shallow drainage channels will enhance the hydraulic connectivity between ponds to encourage drainage. |
Louis Howard |
| 10/11/1999 |
Update or Other Action |
Quarterly update received. 6 pumps used in ERF with one of them in a new location: Area C/D. More tide gates installed than were last year and it appeared to be a success at controlling refilling of ponds where pumping was occurring. Internet Web cam installed by CRREL, but cellular connections with equipment prevented it operating at its best. 27 mallard carcasses recovered which showed mortality from white phosphorus (WP). 8 other mallard carcasses were recovered that were not part of the radio collared mallards and will be analyzed for white phosphorus. |
Louis Howard |
| 12/7/1999 |
Meeting or Teleconference Held |
Annual meeting with EPA and Army project managers with contractors to discuss: waterfowl surveys, waterfowl mortality, pond pumping, attenuation monitoring, meteorological data, sampling of ponds, and determine scope of next year's field work. Numbers of dabblers have declined in both user of ERF and deaths. 1996: 5,413 dabblers used the flats and 655 deaths from white phosphorus were recovered (12% of total), 1997: 6,063 dabblers and 240 dead (4%), 1998: 3,722 dabblers and 355 dead (9.5%) 1999 1,704 dabblers used the flats and 198 white phosphorus mortalities were recovered (11.6% of the total). |
Louis Howard |
| 1/26/2000 |
Update or Other Action |
Quarterly report received for Post. OUC future actions are to continue pumping of ponds to dry out sediments for white phosphorus attenuation at the flats. |
Louis Howard |
| 6/20/2000 |
Risk Assessment Report Approved |
Staff reviewed and commented on the interagency expanded site investigation and field work report from 1999. No major comments so work continues as it has successfully in the past. |
Louis Howard |
| 9/30/2000 |
Update or Other Action |
The telemetry monitoring scheduled to occur every year for the first five years, did not occur in 2000. This was due to a contracting problem as well as low availability of a helicopter at the time due to the high occurrences of forest fires in other areas of Alaska. Full scale remediation continued using six pumps during the 2000 field season in the same ponds as in 1999: Ponds 183, 155 and 146 in Area C; Pond 730 in Area C/D; and Ponds 256 and 258 in Area A. After remediation was complete in 2000, Ponds 256 and 258 in Area A were judged to be remediated based on the sampling and monitoring program. |
Louis Howard |
| 6/19/2001 |
Update or Other Action |
Notice of Intent to Sue by Cox and Moyer Attorneys at Law. Letter to Secretary, U.S. Department of the Army, Washington D.C. sent by Cox and Moyer representing Alaska Community Action on Toxics, Cook Inlet Keeper, the Chickaloon Village Traditional Council, Janet Daniels, Richard Martin, and the Military Toxics Project (collectively "Plaintiffs"). Plaintiffs intend to file suit (or suits) against the Army. Subject of the suit is the Army's inactions and inactions at Fort Richardson, an Army base located near Anchorage Alaska. Plaintiffs allege that the Army has violated, and continues to violate, the Comprehensive Environmental Response, Compensation, and Liability Act 42 U.S.C. 9601 et seq. ("CERCLA"), the Federal Facility Agreement for Fort Richardson (the "FFA"), the Clean Water Act, 33 U.S.C. 1251 et seq. ("CWA"), the Solid Waste Disposal Act, 42 U.S.C. 6901 et seq. (SWDA"), and various provisions of Alaska law suit or suits will be brought pursuant to the authority under 42 U.S.C. 9659(a)(1), 33 U.S.C. 1365(a)(1), and/or 42 U.S.C. 6972(a)(1)(A) and (B).
The Army has discharged and continues to discharge munitions, and the constituents and byproducts of munitions into the waters of Eagle River, Eagle River Flats ("ERF"), and the Knik Arm.
The Army has neither applied for, nor been issued, a permit authorizing the discharge of munitions or the constituents or byproducts of munitions into the waters as described herein. The munitions and constituents and byproducts of munitions that have been, and continue to be, discharged into said waters may include: radiological, chemical, or biological warfare agents ("RCB"), including without limitation incendiary chemical warfare agents, or smoke causing chemical warfare agents.
With respect to UXO outside the current boundaries of Fort Richardson, Plaintiffs believe that the Army must undertake a systematic effort to identify lands outside of Fort Richardson where UXO may be located, and to take appropriate actions to clear such lands of UXO dangers. Unlike lands inside the current boundaries of the base, lands outside the base are open to unrestricted access by the members of the public. UXO contains numerous hazardous substances, pollutants or contaminants such as heavy metals and other hazardous chemicals. As a result, the presence of UXO in, on and/or under lands and waters on Fort Richardson constitute a "threat of release" of the hazardous substances, pollutants, or contaminants in the UXO.
The Chickaloon Village Traditional Council (the "Council") wishes to express its view that this case of environmental justice - or more precisely, environmental injustice. The Council has been uniquely harmed by the Army's actions and inactions. Despite the adverse impact of the Army's actions on the Council, the Council believe that the Army has not made a meaningful effort to remedy those impacts. Nor has the Army taken any meaningful effort to consult with the Council on a government to government basis regarding the impacts of the pollution at Fort Richardson on the Council and the Army's proposals to address that pollution. By failing to address the Council's concerns, and by failing to meaningfully consult with the Council on these issues, the Army has failed to comply with the President's Executive Order on Environmental Justice Executive Order 12898. |
Louis Howard |
| 6/29/2001 |
Document, Report, or Work plan Review - other |
Staff reviewed and commented on the interagency remediation and monitoring of white phosphorus at ERF in 2000. No major comments so work continues as it has successfully in the past. |
Louis Howard |
| 6/30/2001 |
Update or Other Action |
The third ditch, explosively excavated in June 2001, drained a previously treated small pond (Pond 285) on Racine Island where the capping treatment failed to prevent waterfowl from feeding in the contaminated sediments. *NOTE to file: Capping treatment was known as "bento-balls" or later to be called "aquablock". BentoBallsTM barrier system, a blend of calcium bentonite/organo
clays, gravel and polymers that bind together to form a sealant. The product was to be broadcast over contaminated areas to eliminate feeding by waterfowl by acting as a barrier to the sediment. |
Louis Howard |
| 7/25/2001 |
Update or Other Action |
The Alaska Department of Environmental Conservation (ADEC) is concerned that the Army will be in violation of the selected remedy identified in the Operable Unit C Eagle River Flats (ERF) 1998 Record of Decision (ROD) if it does not conduct mortality counts of waterfowl in 2001. The ROD specifically states, as a part of monitoring activities, waterfowl telemetry and mortality studies will be conducted every year for the first eight (8) years, years 10, 15, and 20 (11 events) as part of the selected alternative for ERF. Please refer to the time frames listed in the OU C ROD: Description of Selected Remedy Tables 1 and 2 which is also repeated in Table 7-1 Sequence of Activities for the Selected Remedy on page 7-2 and Table 7-2 Schedule of Activities for Selected Alternatives on page 7-3.
For the year 2000, the Army was not able to conduct any mortality studies to determine the number of waterfowl dying as a result of feeding in white phosphorus contaminated sediment. The Army was not able to obtain helicopter support for conducting the mortality study in 2000 and the National Guard Blackhawk helicopters were too powerful to be used for this purpose. ADEC is very concerned that the waterfowl telemetry and mortality studies will not be conducted during the 2001 field season, if helicopter support is not obtained, as required by the ROD.
While ADEC realizes that the mortality counts will be more than likely an indicator of trend information of waterfowl deaths, it is a legally binding requirement the Army has signed up to perform for eight consecutive years in the ROD. If the Army has to deviate from the schedule listed in Table 1 (page V) and Table 2 (page VI), then it must be documented on why the Army is deviating from the requirements listed in the ROD. ADEC requests the Army formally document in writing the failure to conduct a mortality survey in 2000 as soon as possible.
Documenting Post-ROD changes is typically covered in one of several ways :
1. Memorandum to the File (may not be appropriate for in this instance);
2. Explanation of Significant Differences;
3. ROD Amendment; or
4. Notification of a Force Majeure per the Federal Facility Agreement (FFA) Section XXVI paragraph 26.1.
Based on discussions in previous joint meetings with EPA and the Army project managers, it appears the prohibition of federal employees from riding on helicopters, which do not have a particular passenger carrier license, is the reason the mortality counts could not be conducted in 2000. ADEC is concerned that the Army may be unable to conduct mortality counts on ERF in 2001 due to this same requirement and the Army not having a contingency for conducting the counts absent the helicopter support.
This passenger carrier-licensing requirement severely limits the Army’s choices of transportation to 3 or 4 companies, which hold this particular license and may not want to commit to this type of work since more profitable work is available. This situation may qualify as a Force Majeure under the FFA.
See site file for additional information. |
Louis Howard |
| 8/22/2001 |
Update or Other Action |
Staff sent a request for information letter to the Army regarding the potential record of decision violation at Eagle R. Flats. The Alaska Department of Environmental Conservation (ADEC) has sent a letter (ADEC July 25, 2001) to the Army regarding its potential violation of the selected remedy identified in the Operable Unit C Eagle River Flats (ERF) 1998 Record of Decision (ROD) if it does not conduct mortality counts of waterfowl in 2001. While ADEC realizes that the mortality counts will be more than likely an indicator of trend information of waterfowl deaths, it is a legally binding requirement the Army has agreed to perform for eight consecutive years in the ROD. If the Army has to deviate from the schedule listed in Table 1 (page V) and Table 2 (page VI), then it must be documented on why the Army is deviating from the requirements listed in the ROD.
ADEC is awaiting a written response from the Army, regarding the Army’s failure to conduct mortality surveys for the year 2000. Additionally, ADEC is waiting for a written response on how the Army will continue to meet the requirements of the ROD for conducting annual waterfowl telemetry and mortality studies for the current field season and subsequent field seasons. ADEC will consider extending the deadline for submittal of the Army’s documentation if just cause is provided. |
Louis Howard |
| 9/19/2001 |
Document, Report, or Work plan Review - other |
Staff commented on the Army's response to the 8/22/01 letter for potential ROD violation. The Alaska Department of Environmental Conservation (ADEC) has received the Army’s letter and draft memorandum for Eagle River Flats Operable Unit (OU) C via facsimile on September 10, 2001. ADEC has reviewed the documentation and it appears that our concerns have been adequately addressed regarding the 2000 field season and subsequent mortality/telemetry studies at Eagle River Flats. ADEC requests the Army provide immediate written notification to both project managers from both EPA and ADEC as soon as possible regarding any substantive delays in meeting previously negotiated schedules or any failure to perform tasks identified in the OU C ROD.
In addition to notifying the agencies of delays, ADEC refers the Army to the Federal Facility Agreement for Fort Richardson under Section XXV Extensions. This section identifies the procedures for the Army to follow when requesting an extension of a deadline or a schedule which may be extended upon receipt of a timely request for extension and when a good cause exists for the requested extension. Pending receipt of the Environmental Protection Agency’s comments, ADEC will consider the matter resolved. |
Louis Howard |
| 10/9/2001 |
Update or Other Action |
Under NEPA, the Army signed a RECORD OF ENVIRONMENTAL CONSIDERATION (REC), TITLE: Modified Firing Regime for the Eagle River Flats (ERF) Impact Area, Fort Richardson, Alaska. A Record of Environmental Consideration (REC) is a signed statement submitted with project documentation that briefly documents that an Army action has received environmental review. RECs are prepared for CXs that require them, & for actions covered by existing or previous NEPA documentation. A REC briefly describes the proposed action & timeframe, identifies the proponent & approving official(s), & clearly shows how an action qualifies for a CX, or is already covered in an existing EA or EIS.
When used to support a CX, the REC must address the use of screening criteria to ensure that no extraordinary circumstances or situations exist. A REC has no prescribed format, as long as the above information is included. To reduce paperwork, a REC can reference such documents as real estate Environmental Baseline Studies (EBSs) & other documents, as long as they are readily available for review. While a REC may document compliance with the requirements of NEPA, it does not fulfill the requirements of other environmental laws & regulations.
DESCRIPTION OF PROPOSED ACTION: The proposed action will afford the USARAK command more flexibility for conducting necessary firing activities within the ERF Impact Area. The following is a list of restrictions as they pertain to specific types of ammunition fired into the ERF Impact Area:
a. Helicopter Door Gunnery (Small Arms)
1. No firing activities will be conducted while any waterfowl are present in the ERF (normally November through April).
2. No Wildlife will be purposely killed, injured or targeted.
b. High Explosive Proximity Fuse (VT) Rounds
1. No firing activities will be conducted during ERF Clean-up & monitoring operations when equipment & personnel are actively deployed (normally from April to mid October).
2. No firing activities will be conducted in the spring once waterfowl begin arriving (as determined by DPW Environmental Department & Range Control). This normally occurs in early April.
3 . No firing activities will be conducted in the fall until the majority of waterfowl have departed (normally from mid to late October) as determined by DPW Environmental Department & Range Control. This determination will be made when no more than 25 swans & 100 ducks are sighted in the ERF for three consecutive days.
c. Illumination Rounds
No firing activities will be conducted during ERF Clean-up operations when equipment & personnel are actively deployed for the remediation phase (normally May through September).
d. High Explosive Point Detonated Rounds
Mortar (60mm & 80mm)- No firing activities will be conducted when there is less than two inches of ice cover on water bodies within the ERF.
Artillery (105mm)-No firing activities will be conducted when there is less than five inches of ice cover on water bodies within the ERF
ANTICIPATED DATE &/OR DURATION OF PROPOSED ACTION: The new firing regime for the ERF Impact Area is anticipated to begin Fall 2001 & remain in place until the situation or changing conditions dictate.
MITIGATION &/OR SPECIAL CONDITIONS: The aforementioned stipulations for this modified firing regime are based on conditions & activities normally associated with the ERF Impact Area. In the event that such conditions change, firing activities will conform to whatever schedules may be necessary to insure safety, regulatory compliance & environmental protection.
CATEGORICAL EXCLUSION: This action is determined to be adequately covered in an Environmental Assessment entitled: Resumption of Firing in the ERF Impact Area, Fort Richardson, Alaska, December 1991.
Prepared by W. A. Gossweiler Env. Resources Dept.
Reviewed by C. Fosbrook for D. W. Johnson Chieff, Env. Resources Dept.
Proponent L. E. Fussner LTC, GS Director of Plans, Training, Security & Mobilization
Approved by D. B. Snodgrass, LTC (P), EN Directorate of Public Works |
Louis Howard |
| 12/12/2001 |
Update or Other Action |
1. All organizations conducting activities on United States Army Alaska (USARAK) controlled land are responsible for complying with established institutional controls (ICs). ICs are administrative, procedural, and regulatory measures to control human access to and usage of property. They are applicable to all known or suspected contaminated sites where contamination has been left in place.
2. These controls have been established to implement the selected remedial actions agreed upon by the U.S. Army (Army), the U.S. Environmental Protection Agency (USEPA), and the Alaska Department of Environmental Conservation (ADEC) in accordance with the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) as amended by the Superfund Amendment Reauthorization Act (SARA). These controls also apply to remedial actions agreed upon under Two-Party Compliance Agreements. These agreements are concluded between USARAK and ADEC and apply to petroleum/oil/lubricants- (POL) contaminated sites.
3. ICs such as limitations on access, water use, excavations, and property transfers will supplement engineering controls as appropriate for short-term and long-term management to prevent or limit human and environmental exposure to hazardous substances, pollutants, or contaminants. Specific ICs include, among other things: limitations on the depth and location of excavations, prohibition of or restrictions on well drilling and use of ground water, requirements for worker use of personal protective equipment, site monitoring, and prohibition of certain land uses, types of vehicles, etc.
4. Organizational units, tenants, and support/contractor organizations must obtain an Excavation Clearance Request (ECR) for all soil disturbing activities impacting soils six inches or more below the ground surface. The review process for approval of an ECR begins with the identification of the current status (known or suspected hazardous waste site or “clean” site) of a work location. ECR’s for work in known or suspected hazardous waste sites:
a. will include specific limitations and controls on such work;
b. will include specific IC procedures, and notification, monitoring, reporting, and stop work requirements;
c. may include procedures for management, characterization, and disposal of any soil or groundwater encountered or removed;
d. will identify “project managers” for both the unit/contractor requesting the work and DPW Environment Resources.
5. The DPW project manager will conduct on-site inspections of each work site (at which ICs apply) to determine continued compliance with the terms and conditions of the approved ECR. DPW has the authority to revoke ECR approval if the specified terms and conditions are not being met. ECR forms are available at the Customer Service Desks at: a. Building 730 at Fort Richardson; b. Building 3015 at Fort Wainwright; c. Building 605 at Fort Greely.
6. USARAK has negotiated (with USEPA and/or ADEC) decision documents and/or Records of Decision (RODs) that mandate the implementation of ICs USARAK Directorate of Public Works, Environmental Resources Department (PWE), maintains copies of all decision documents and RODs requiring ICs in its real property files. PWE provides regularly updated post maps showing all areas affected by ICs. These maps can easily be accessed by using an approved intranet mapping interface application. Copies of these maps will be available to each directorate, activity, and tenant organization. To ensure the effectiveness of ICs, all organizational units and tenant activities will be informed on an annual basis of ICs on contaminated soils and groundwater in effect near their facilities.
7. ICs are enforceable by the U.S. Environmental Protection Agency (USEPA) and the Alaska Department of Environmental Conservation (ADEC). Failure to comply with an IC mandated in a decision document or ROD will violate the USARAK Federal Facility Agreement and may result in stipulated fines and penalties. This does not include the costs of corrective actions required due to violation of an established IC.
|
Louis Howard |
| 5/6/2002 |
Document, Report, or Work plan Review - other |
Staff commented on the draft FY01 ARARs for Remediating and Monitoring White Phosphorus Contamination at Eagle River Flats. The Department requested the following be incorporated into this section which were identified as Applicable or Relevant and Appropriate Requirements (ARARs) in the 1998 OU-C Record of Decision (see 8.2.4 Action Specific Requirements):
Alaska Oil Pollution Regulations (Title 18, Alaska Administrative Code, Chapter 75 [18 AAC 75]), set requirements for discharge reporting, cleanup, and disposal of hazardous substances for spills of hazardous substances to Alaska’s land or water within specified time frames.
Alaska Water Quality Standards Regulations (Title 18, Alaska Administrative Code, Chapter 70 [18 AAC 70]) in general, apply to groundwater and surface water and establish criteria for protected classes of water use. The “Criteria for Growth, Propagation of Fish, Shellfish, other Aquatic Life and Wildlife” are the most stringent and, therefore, applicable to OU-C.
Summary of Mortality
Table II-1-1 Estimated Waterfowl deaths each year since 1996 Pages 18 and 19.
The table shows the year and estimated deaths in the table. The Department requests the actual counts of waterfowl deaths be included in the table and in the text for each year versus simply stating the number of estimated deaths.
Performance Standards Page 20: The text states that mortality has decreased from 1996 to 2001, however it does not give specific counts or mortality numbers as to how much and to what degree it has decreased. The Department requests the inclusion of specific mortality numbers be mentioned in the text for the time period beginning in 1996 to 2001.
The Department concurs with the recommendations made in each of the studies (III-2 through IV-7). Please note, the Department’s review and concurrence on the recommendations in report is to ensure that the work is done in accordance with State of Alaska environmental conservation laws and regulations. While the Department may comment on other state and federal laws and regulations, our concurrence on the recommendations does not relieve the U.S. Army from the need to comply with other applicable laws and regulations. |
Louis Howard |
| 8/23/2002 |
Document, Report, or Work plan Review - other |
Staff reviewed and approved the draft interim remedial action report for the Eagle River Flats.
Institutional controls (ICs) at OU-C have been implemented. Fort Richardson has established a post wide IC policy at all known or suspected contaminated sites. Further details regarding the Army/Fort Richardson IC policy can be found in the OU-D ROD, the U.S. Army Institutional Controls Standard Operating Procedures [APVR-RPW (200-1)], and a Memorandum on Institutional Controls [APVR-RPW-EV (200-1c)], from Major General James J. Lovelace – Fort Richardson, Alaska. This policy is reviewed annually and revised every two years.
This policy ensures that there are limitations on access, water use, excavations, and property transfers as appropriate for the site. At OU-C, controls include a locked gate limiting access, fences and signs around the perimeter of the area, and large signs at access points to Eagle River. One component of the IC policy involves obtaining an Excavation Clearance Request (USARAK Form 81 a – 1 Mar 02) to prevent undertaking work inconsistent with established ICs at a particular site. The Directorate of Public Works (DPW) maintains a Geographic Information System database with information on all of the contaminated sites on post. The DPW is responsible for ensuring ICs on Fort Richardson. ICs will remain in place as long as hazardous substances remain on site at levels that preclude unrestricted use.
Components of the preferred remedy described in this document that were scheduled to occur from 1999 to 2002 have been implemented as planned with one exception. The telemetry monitoring for duck mortality did not occur in 2000. Therefore, the remedy is operational and functional.
estimated in the Record of Decision. The additional costs are due to the following: Costs estimated in ROD for 1999 and 2000 did not include placement of 6 pumps for pumping. It was anticipated that high flooding tides in those years would not be ideal for pumping conditions. However, due to innovations with small tides gates, it was determined that many of the flooding tides would be held back. Therefore, all 6 pumps were placed for pumping in these years. Helicopter costs have increased significantly since the ROD costs were estimated.
This has primarily impacted the costs of the telemetry work. The costs in the ROD did not include costs for the Corps of Engineers support. The costs for this IRAR and the Five Year Review were also not included in the ROD costs. Telemetry costs for 2000 were significantly less than estimated in the ROD. Due to difficulties in procuring a helicopter to support this work, the telemetry study was not completed that year. However, some costs were incurred. |
Louis Howard |
| 11/30/2002 |
Update or Other Action |
In 2002 field season, full scale remediation continued using six pump systems. One pump system was installed in the newly identified area in Northern C marsh. The other five systems were deployed in the same locations as 2001. One system was deployed in Ponds 226/246 in Area A, one each in Ponds 155 and 146 in Area C, one in Pond 730 in Area C/D, and one in Pond 75 at the border of Area C/D and Coastal East. After remediation was completed in 2002, Ponds 226/246 in Area A, Pond 75 in Coastal East, and Pond 146 in Area C were judged to be remediated based on the monitoring program. |
Louis Howard |
| 12/26/2002 |
Document, Report, or Work plan Review - other |
Staff reviewed and commented on the draft five year review report for the Post.
6.2.2 Remedial Action Objective Page 6-7: The text states the long term goal could be adjusted based on future population studies conducted during the monitoring program. The Department interprets this to mean that the total annual fall population of dabbling Eagle River Flats ducks may be changed from the 5,000 ducks mentioned in the ROD, due to natural fluctuations in the existing population. However, the one percent (1%) number used in the ROD may not be changed when calculating the long term remedial action objective for mortality attributable to white phosphorus.
6.4.1 Are the Remedies Functioning as Intended by the Decision Document? Page 6-11:
The table shows the short term remedial action objective (RAO) that within five years reduce the mortality attributable to white phosphorus to 50% of the 1996 mortality rate attributable to white phosphorus. The mortality attributable to white phosphorus was 1,000 birds and therefore 50% of that number would have been 500 birds. Performance to date is shown by the 1999 and 2001 seasons as being below the short term RAO (198 and 87 deaths, respectively). The Department requests a complete listing of mortalities for all the years either in section 6.3 page 6-10 where it states mortality has decreased from 1996 to 2001 (2002 estimates are now available). Alternatively, the actual mortality counts for each year can be listed in the Performance to Date table to give the reader a more complete picture of mortality estimates from 1996 to 2002 (whether or not they met the short term RAO). |
Louis Howard |
| 1/15/2003 |
Update or Other Action |
Bread Truck Pond tidal gate was installed to prevent further erosion and flooding during high tides. The large tide gate was constructed during the winter by excavating a hole in the ice and placing rock within the Bread Truck Ditch. |
Louis Howard |
| 2/20/2003 |
CERCLA ROD Periodic Review |
Jennifer Roberts (ADEC) signed the five year review document for the Post. ADEC’s concurrence with the findings of this five year review is based on the information presented in the accompanying Five-Year review Report, First Five-Year Review Report for Fort Richardson, Alaska. The objectives of the Five-Year Review are to answer the following questions:
•Are the remedies functioning as intended by the decision document?
•Are the exposure assumptions, toxicity data, cleanup levels, and remedial action objectives (RAOs) used at the time of the remedy still valid?
•Has any other information come to light that could call into question the protectiveness of the remedy?
Issues: at OUC, waterfowl mortality data may be skewed by active remedial activities.
Recommendations and follow-up: At OUC, evaluating waterfowl recovery trends upon completion of remedial action is recommended.
Short and long-term RAOs for the remedial action at OUC are as follows:
• Within five years of the ROD being signed, reduce the dabbling duck mortality rate attributable to white phosphorus to 50% of the 1996 mortality rate attributable to white phosphorus. Radio tracking and aerial surveys suggest that about 1,000 birds died from white phosphorus at ERF in 1996. Therefore, the allowable number of duck deaths from white phosphorus would be approximately 500.
• Within 20 years of the ROD being signed, reduce the mortality attributable to white phosphorus to no more than 1% of the total annual fall population of dab¬bling ERF ducks. Currently, that population is about 5,000. Therefore, the allow¬able number of duck deaths from white phosphorus would be approximately 50. This long-term goal could be adjusted based on future population studies conducted during the monitoring program.
Because duck mortality data are obtained concurrently with remediation and sampling activities that can cause bird hazing, the true mortality will not be known until after remediation is completed and waterfowl usage of ERF is uninhibited by remedial activities. Mortality rates that are being derived from the telemetry data and the mortality model show a decreasing rate of mortality in ERF. This reduction is strengthened by the sediment-sampling program, which is showing a large decrease in the amount of white phosphorus contamination. The combination of the results of the sampling program with the morality data indicates that cleanup goals are being met.
Performance to date: The duck mortality rate is currently less that the short term RAO. Waterfowl mortalities in 1999, 2001, and 2002 were below the short-term RAO of approximately 500. Based on the mortality model, population studies have shown an overall decrease in the duck population. However, duck mortality is still above 1% and the long term RAO has not been met.
The next Fort Richardson Five-Review will be conducted in 2008, five years from the date of this review. The next Five-Year Review will be the first full-term review for the OUC ROD. |
Jennifer Roberts |
| 5/12/2003 |
Update or Other Action |
Commissioner Ballard signs the Interim Remedial Action report for OUC-Eagle River Flats (ERF). The objectives of the remedial action (RA) at ERF are to ensure the protection of human health and the environment by: Reducing the white phosphorus (WP) present in ponds utilized by waterfowl for feeding; Reducing waterfowl mortality due to the ingestion of WP. The major components of the remedy are: Pumping permanent ponds dry to allow for the sublimation and oxidation of the WP present in the pond; Sampling of ponds under treatment to determine that WP concentrations are being reduced; Conducting waterfowl mortality studies to determine quantity and location of ducks that are dying due to WP.
This remedy was chosen to reduce the concentration of WP and reduce the waterfowl mortality. The RA began the summer of 1999 and pond pumping is intended to continue through summer 2003. Monitoring activities and waterfowl mortality studies will continue to determine if the remedial action objectives (RAOs) have been met. The plan will be re-evaluated during the 5-year review. The components scheduled to occur from 1999 – 2002 have all been instituted with one exception. The telemetry monitoring scheduled to occur every year for the first five years, did not occur in 2000. This was due to a contracting problem as well as low availability of a helicopter at the time due to the high occurrences of forest fires in other areas of Alaska.
The project managers will evaluate the planned monitoring on an annual basis until RAOs are achieved. They will review the results from the monitoring to determine if conditions are progressing towards achieving the RAOs. Based on the results of the annual evaluation, the project managers will set the operating and monitoring parameters for the next year. The Army will then operate the systems, or perform monitoring as agreed over the coming year, making adjustments as they consider reasonable and in accordance with agreements made during the last annual evaluation. If the project managers can not reach concurrence on the operating or monitoring parameters of the systems, then previously agreed to parameters will be followed until the issue is resolved in accordance with the dispute resolution procedures incorporated in the Federal Facility Agreement.
The short term RAO is to reduce the dabbling duck mortality rate attributable to WP to 50% of the 1996 mortality rate attributable to WP within 5 years of the ROD being signed (e.g. 2003). Radio tracking and aerial surveys calculated that about 1,000 birds (waterfowl or ducks) died from WP at ERF in 1996. Therefore, the number of duck deaths from WP would need to be less than 500. Further refinement of the mortality model has reduced the calculated 1996 overall duck mortality to 655 ducks. Therefore, the allowable number of duck deaths by 2003 is 327. Duck mortalities in 1999 and 2001 were below this target number and it appears that the short-term objective is being successfully met. However, duck usage of the flats has also been decreasing due to the activities at the site.
The long term RAO, within 20 years of the ROD being signed, is to reduce the mortality attributable to WP to no more than 1% of the total annual fall population of dabbling ERF ducks. In 1996, that population was about 5,000. Therefore, the allowable number of duck deaths from WP would be approximately 50. |
Louis Howard |
| 8/30/2003 |
Update or Other Action |
In 2003, a number of high-order 81-mm WP mortar body carcasses* were found that contained up to 250 g of unreacted obscurant. These carcasses auto-ignited shortly after exposure to the atmosphere, burning fiercely until most of the WP was consumed. These detonated rounds were found in an area that has had persistently high numbers of mortalities, northern C-Marsh. It is an area that has been targeted for further cleanup.
*NOTE TO FILE: These items may fall under the definition of UXO: Unexploded ordnance. It may be any kind of bomb, bullet cartridge, mine, grenade, or shell. By definition, UXO have been primed, fused, armed, or otherwise prepared for action so as to constitute a hazard. UXO remain unexploded either by malfunction, design, or any other cause. |
Louis Howard |
| 9/11/2003 |
Update or Other Action |
Fax of Motion for Summary Judgment filed in US District Court District of Alaska, Anchorage received from US Army environmental staff. Trustees of Alaska (attorneys for plaintiffs) represent: Alaska Community Action on Toxics, Cook Inlet Keeper, The Chickaloon Village Traditional Council, Janet Daniels, Richard Martin, and the Military Toxics Project.
Plaintiffs move for summary judgement on their First Cause of Action, which was brought to enforce the provisions of the Clean Water Act (CWA), 33 U.S.C. 1251 et seq.. As part of its operations, Fort Richardson fires munitions (primarily artillery shells and mortars) into Eagle River Flats, a wetland marsh located adjacent to Cook Inlet. The Army does not hold a permit issued by the EPA authorizing the discharge of munitions into ERF. This action is in violation of section 301 of CWA 33 USC 1311.
The plaintiffs move for summary judgment on their Third cause of action, brought pursuant to the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA), 42 U.S.C. 9601 et seq.. The Army has never performed a RI/FS addressing the risks to human health and the environment posed by UXO remaining at ERF in violation of CERCLA section 120(e)(1) 42 USC 9620(e)(1). |
Louis Howard |
| 10/31/2003 |
Update or Other Action |
Use of Military Demolitions Explosives in a Remediation Project (Eagle River Flats). The use of military explosives has proven to be a very effective means of surface water control at Eagle River Flats. The exposure of field personnel to UXO is greatly reduced when lanes in the mission areas are cleared beforehand
with a magnetometer. Post-detonation sweeping of the area for UXO is required after all detonations.
Planning is critical to the successful completion of the blasting missions. Areas to be addressed must be marked and cleared prior to the mission to ensure that the correct areas are addressed in a safe manner. This also aids in planning the amount of demolitions that will be required for the mission. Demolitions for
large missions should be drawn the day prior to deployment. Preparation of the demolitions,—cutting and bundling the det cord, preparing the shape charges, readying sand bags, and sorting the demolitions by mission segment—and predeployment
of the materiel can be done prior to arrival of the helicopter. With the helicopter on site, multiple sites can be prepared prior to blasting of the first site. In all operations, though, care must be taken to ensure that all safety procedures are followed.
Using the right materiel for the mission is also important. The use of cratering charges to blast ditches to drain ponds proved to be overkill. The use of Bangalores is a much less intrusive method to accomplish this task, but blasting must occur when the surface is thawed to be able to cut the ordnance into the soil and obtain the desired depth of penetration. It is also much easier to restore the
smaller ditch formed by the Bangalore than it is to restore the very large ditch formed by cratering charges. Conversely, the use of Bangalores for forming drainage ditches to sumps has been generally superceded by using multiple strands of detonation cord twisted and wrapped into a bundle and inserted into
the soil. The use of higher-strength commercial detonation cord would simplify this operation greatly.
Demolitions support at Eagle River Flats is critical to the execution of the remediation mission at this Superfund site. The ability to excavate large sumps, drain untreatable areas, and control surface water have all contributed to the success of this project. In addition, the use of explosives rather than manual or
mechanical excavation has reduced the exposure of personnel to unexploded ordnance, the greatest safety hazard on the project site. The techniques developed and experience gained in surface water management over the course of this project can be readily transferred to other areas and applications, both military and civilian. |
Louis Howard |
| 11/30/2003 |
Update or Other Action |
In 2003 field season, full-scale remediation continued using six pump systems. Three pump systems were installed in three newly formed sumps in the contaminated area in Northern C marsh. The other three pump systems were deployed in the same locations as in 2002. One pump each was deployed in Ponds 146 and 155 in Area C, and one in Pond 730 in Area C/D. Even though Pond 146 was remediated in 2002, the pump was redeployed to help dewater the Northern C marsh. After remediation was completed in 2003, Pond 730 in Area C/D was judged to be remediated based on the monitoring program. Other treated ponds contained just small, localized areas of contamination. |
Louis Howard |
| 6/30/2004 |
Update or Other Action |
Report received which presents the Cleanup Operations and Site Exit Strategy (CLOSES) evaluation for the Eagle River Flats (ERF) munitions impact area. Based on the evaluation, it is recommended that the DPW assess the waterfowl mortality monitoring program to ensure that it effectively and efficiently documents reductions in WP mortalities over the remaining 15 years of monitoring specified by the ROD. Specifically, it is recommended that an assessment be conducted of the waterfowl mortality model and methods of obtaining data for input to the model.
Tests of model sensitivity will help define the confidence levels of monitoring results, and an evaluation of alternate methods of data collection will provide potential options for improving the cost effectiveness of the monitoring program. The cost effectiveness of the current method has diminished with the need to contract privately for helicopter services, and the resulting gaps in annual mortality data. The weight-of-evidence (WOE) approach includes the integration of monitoring data from various lines of evidence to evaluate the success of WP remediation efforts at ERF. The WOE approach includes a monitoring plan that will help verify each of the following Remedial Action Objectives:
• "To verify that an exposure pathway does not exist between waterfowl and white phosphorus-contaminated sediment
• To determine the number of waterfowl using ERF
• To determine the number of waterfowl dying as a result of feeding in white phosphorus contaminated sediment
• To determine whether remedial action is effective or needs modification"
The monitoring plan in the WOE approach includes aerial surveys of waterfowl, ground-based surveys of duck mortality at various sites, necropsy to determine WP concentrations in duck gizzards, counts of feather piles as indicators of duck mortality, population estimates of scavengers and predators, and measurements of WP concentrations in sediment. This will provide sufficient evidence to verify that each of the RAOs are being met.
The following alternative options are suggested:
Methods to determine total duck population at ERF
−Aerial surveys of waterfowl using ERF appear to be an efficient and effective method of obtaining bird population data. Bird populations can be estimated from aerial surveys in several ways, and the precision of these estimates should be assessed to
determine the statistical confidence of this input to the bird mortality model.
−Existing data sets from aerial surveys and point-count surveys conducted in 1994 and 1995 could be compared to determine if an alternative to aerial surveys would provide value. Alternatively, point-count surveys could be conducted during future
aerial surveys to establish a correlation or index for estimating the population size from differing methods.
Methods to determine mortalities in a sample of the duck population at ERF
−Telemetry tracking of ducks should be replaced by ground-based transects for evaluating duck mortality. Ideally, radio-telemetry and ground transect surveys would be conducted concurrently and the results compared to determine a
correlation factor that might allow alternatives to be used in lieu of telemetry tracking and the associated high cost and potential unavailability of helicopters. Data sets from radio-telemetry and ground transect surveys are available for 1994-1995 and should be compared to determine the efficacy of the ground transect
method. |
Louis Howard |
| 8/30/2004 |
Update or Other Action |
In 2004, a thorough sweep of the C-March and adjacent eastern Pond 183 areas using a magnetometer resulted in the detection and exhumation of several more WP mortar bodies, as well as many 57-mm recoilless rifle rounds containing at least trace amounts of white phosphorus (WP). A survey of the Duck Ponds near Bread Truck and 730 also resulted in the discovery of several old WP mortar rounds containing unreacted residual WP. Although not technically unexploded ordnance, (*NOTE TO FILE UXO-By definition, UXO have been primed, fused, armed, or otherwise prepared for action so as to constitute a hazard. UXO remain unexploded either by malfunction, design, or any other cause.), these rounds do contain live material that will readily react with oxygen and burn. The Army has had two cases of clothing catching on fire due to exposure to soils near these rounds and the people had to strip off their clothes. The two incidences involved a particle of white phosphorus that
started smoking as the mud that contained it started to dry out. One incident was on a glove, the other incident was on a sock that had gotten mud on it when the boot was taken off. Neither incident involved open flame and no one was injured in either incident.
In August 2004, over 10 UXOs were detected in the C-marsh area. These rounds were intact, fully fuzed, severely corroded, and dangerous. EOD was called down for disposal, and both the EOD and UXO personnel determined the rounds were HE (high explosive). Between seven and nine of these rounds were detonated (blown-in-place) by EOD. Most of the rounds turned out to be instead white phosphorus rounds. The area is now highly contaminated with WP particles and may be dangerous. In addition, several UXOs remain behind, some of which may contain WP and in their present corroded condition may auto-ignite through perforations. If autoignition occurs, there is a very good chance these fully loaded rounds will detonate distributing large quantities of burning white phosphorus in a wide area. |
Louis Howard |
| 10/27/2004 |
Update or Other Action |
The Army announced 27 Oct. 2004 that it has settled the Eagle River Flats (ERF) lawsuit in an agreement under which the Army will continue to train at ERF. ERF is an active military artillery range located near the mouth of the Eagle River on Ft. Richardson. The Army has used the range for weapons training for approximately 40 years. As part of the settlement, U.S. Army Alaska will continue to refrain from firing while the cleanup activity is ongoing and during the spring and fall waterfowl migration periods, practices that were already in place prior to the lawsuit.
Under the terms of the agreement, among other things, U.S. Army Alaska will continue its monitoring studies to ensure that constituents of munitions are not moving off of the range into Knik Arm. Studies to date have not indicated such movement is occurring.
U.S. Army Alaska will also monitor beluga whales in the vicinity of the range and will continue to assist the National Marine Fisheries Service, as needed, in any research it conducts on belugas in the upper Cook Inlet.
To assist the plaintiffs in their understanding of the data from these studies, U.S. Army Alaska will fund a technical expert to review the studies and results. Further, U.S. Army Alaska will provide information to the plaintiffs on the numbers and types of munitions used at the range. |
Louis Howard |
| 11/30/2004 |
Update or Other Action |
In 2004, because of expected flooding tides each month, remediation conditions were expected to be poor. Limited remediation was undertaken using one pump system in Pond 146 in Area C. Because of the interconnected drainage ditches installed over the last three years, the pump was very effective in dewatering most of Area C including Pond 155 and Northern C marsh. Despite monthly flooding tides, warm dry conditions throughout most of the summer in Southcentral Alaska and ERF produced good remediation conditions. |
Louis Howard |
| 1/18/2005 |
Update or Other Action |
RECORD OF ENVIRONMENT AL CONSIDERATION
TITLE: Modification of Munitions Firing at Eagle River Flats Impact Area, Fort Richardson, Alaska.
The current firing restrictions at ERF include a requirement for 2” of ice formation prior to firing point-detonated mortars (60-mm & 81-mm) & 5” of ice formation prior to firing 105-mm point detonated artillery rounds. The sole reason these restrictions are in place is to prevent WP-contaminated sediments (where present in ERF) from being disturbed or redistributed, resulting in potential waterfowl mortality. It is critical to note that after 6 years of WP cleanup work at ERF approximately 95% of the area has been remediated. Thus, for about 95% of the ERF area potential disturbance of WP contaminated sediments is no longer a concern.
The Army proposes to initiate firing of 40-mm grenades & 120-mm mortars at the ERF Impact Area. These munitions have not been previously used or tested at ERF. The net explosive weight (NEW) of the new munitions was compared to the NEW of the previously tested munitions (60-mm & 81-mm mortars; 105-mm artillery) to determine potential impacts. The 40-mm grenade (M383 LNKD) has a NEW of 0.1402 pounds (lbs), much less than the NEW of an 81- mm mortar (M374/A3), which has a NEW of 2.428 lbs. As mentioned previously, the 81-mm mortars had no impact to sediments covered with a minimum of 2" of ice. Thus, based on the NEW of the respective munitions, firing 40-mm grenades at ERF will not cause disturbance of WP-contaminated sediments under conditions suitable for firing point-detonated mortars.
The 120-mm mortar (M933) has a NEW of 7.9177 lbs, slightly less than the NEW for a 105-mm howitzer round (M1) that is 7.96 lbs. Testing conducted in 1991 using 105-mm howitzer rounds indicated that 5” of ice cover over frozen sediments was adequate to prevent disturbance of any under1ying WP contamination. Since the 120-mm mortars have a lower NEW than the 105-mm howitzer rounds, the 120-mm mortar will create a smaller crater than the 105-mm howitzer rounds & would result in no adverse effect.
ANTICIPATED DATE &/OR DURATION OF THE PROPOSED ACTION: The new firing regime for the ERF Impact Area is anticipated to begin in late January 2005 & remain in place as long as adequate ice thickness conditions are present (2” for the 40-mm grenades & 5” for the 120-mm mortars).
ENVIRONMENTAL FACTORS & CONSIDERATION: The potential impacts associated with the firing of the 120-mm mortars & 40-mm grenades are comparable with the 105-mm howitzer rounds & the 81-mm mortars that were analyzed in the Resumption of Firing in the ERF Impact Area, Fort Richardson, Alaska Environmental Assessment (December 1991 ). This document thoroughly evaluated the potential environmental impacts associated with the types of firing activities that are being contemplated under this action. Accordingly, the proposed action does not represent any activity of which the potential environmental impact has not been thoroughly evaluated.
MITIGATION &/OR SPECIAL CONDITIONS: An initial test firing will be conducted with 120-mm mortars & 40-mm grenades to validate the ice crater depth comparisons made with the 60-mm & 81-mm mortars & the 105-mm artillery on the ice at ERF. Initial testing will be conducted in mid to late January 2005. Current ice thickness data from ERF (12 January 2005) indicate that the ice thickness is about varies from about 12 to 20 inches, much greater than the current requirement for firing 105-mm howitzer rounds at ERF.
Because the 120-mm mortars are expected to have less impact (smaller craters) than the 105-mm howitzer rounds, the current ice conditions will ensure that WP-contaminated sediments are not disturbed during the initial test firing. Subsequent to the testing, the Army will establish formal ice thickness for firing 120-mm mortars & 40-mm grenades at ERF. All firing activities associated with this action will be conducted in accordance with Army range regulations. Changes or modifications to the scope of this project require further coordination with the USAG-AK Environmental Office.
CONCLUSIONS: This action is determined to be adequately addressed in an Environmental Assessment entitled: Resumption of Firing in the ERF Impact Area, Fort Richardson, Alaska, December 1991. The environmental impacts associated with the firing of the 120-mm mortars & 40-mm grenades are comparable in degree or type from those analyzed in the 1991 EA. The proposed action would not degrade the existing environment & it would not adversely affect environmentally sensitive resources.
Signed Victoria Reardon Research Associate, Environmental Dept. DPW January 14, 2005.
Terry Boone Chief, Environmental Dept. Directorate of Public Works January 14, 2005
Allan Lucht Director, Directorate of Public Works January 18, 2005 |
Louis Howard |
| 4/29/2005 |
Update or Other Action |
Received the updated Interim Remedial Action Report (IRAR) for the U.S. Army at Eagle River Flats (ERF), Operable Unit C (OU-C), Fort Richardson, Alaska. Eagle River Flats is one of two OU-C source areas. The objectives of the remedial action at ERF are designed to ensure the protection of human health and the environment by: Reducing the white phosphorus present in ponds that are utilized by waterfowl for feeding. Reducing waterfowl mortality due to the ingestion of white phosphorus.
The major components of the remedy are: Pumping permanent ponds dry to allow for the sublimation and oxidation of the white phosphorus present in the pond. Sampling of ponds under treatment to determine that white phosphorus concentrations are being reduced. Conducting waterfowl mortality studies to determine quantity and location of ducks that are dying due to white phosphorus.
In 2004, ground-based transects was introduced as the method for determining waterfowl mortality. This method is currently under evaluation to determine its use in meeting the long-term mortality objective. Also, monitoring activities in 2004 indicated that an area in Northern C still contained white phosphorus and that bird mortality continued in this area due to its presence. Therefore, it was determined that pumping activities in this area would be performed in the summer of 2005.
No official pre- or final inspections for OU-C have been conducted. However, representatives of USEPA, ADEC, and the Army have inspected the remediation activities at various times since the fieldwork began and have noted no significant operational problems with the treatment system. Initiation of the treatment system was authorized through review of work plans and health and safety plans.
Institutional controls (ICs) at OU-C have been implemented. Fort Richardson has established a post wide IC policy at all known or suspected contaminated sites. Further details regarding the Army/Fort Richardson IC policy can be found in the OU-D ROD, the U.S. Army Institutional Controls Standard Operating Procedures [APVR-RPW (200-1)], and a Memorandum on Institutional Controls [APVR-RPW-EV (200-1c)], from Major General James J. Lovelace – Fort Richardson, Alaska. This policy is reviewed annually and revised every two years.
This policy ensures that there are limitations on access, water use, excavations, and property transfers as appropriate for the site. At OU-C, controls include a locked gate limiting access, fences and signs around the perimeter of the area, and large signs at access points to Eagle River.
One component of the IC policy involves obtaining an Excavation Clearance Request (USARAK Form 81 a – 1 Mar 02) to prevent undertaking work inconsistent with established ICs at a particular site.
The Directorate of Public Works (DPW) maintains a Geographic Information System database with information on all of the contaminated sites on post. The DPW is responsible for ensuring ICs on Fort Richardson. ICs will remain in place as long as hazardous substances remain on site at levels that preclude unrestricted use.
|
Louis Howard |
| 5/31/2005 |
Update or Other Action |
The big event this year will be the improvement of the trail along the east side of the Flats to the old observation point along C-Marsh. This access will be used to place the genset and double-walled fuel tanks for the pump system generator for the northern C-Marsh ditch. The area will be large enough for two gensets in case a second unit is deployed from there in future years. With the loss of access to the Chinook helicopters, this long-term strategy will allow us to continue addressing the contaminant in C-Marsh.
The work this year will be performed by Bering Sea Ecotech (BSE), the same firm providing the UXO support. This should allow us a smooth integration of functions across lines of specialties. BSE was used for UXO clearance during an earlier live-fire exercise on the ice at the Flats and worked out quite well. We look forward to continuing our relationship with them. Other tasks for BSE will include a continuation of the sweep of the C-marsh area for WP rounds or debris.
Although no formal waterfowl mortality monitoring will take place in the spring (most birds will have moved on by the time we get there), we will be continuing to look for carcasses. Last year, we found none in our work areas, but with the detonation of several WP rounds last August, we are anticipating the possibility of carcasses this year. On the instrumentation front, we will be adding a third camera to monitor the physical state of the ditch complex in Area C. Along with monitoring instrumentation, it should give us a good indication of the efficacy of the added pump in one of the sumps in the ditch. A relay station will be installed at Cole Point to improve the transmission of images from the Flats to the base station on Post.
The all-important sampling program will continue, with the greatest effort reserved for the fall. Spring sampling will concentrate on the newly contaminated areas near the detonations in an attempt to "assess the damage." Particles will be planted again to assess natural remediation in a controlled manner. |
Louis Howard |
| 9/12/2005 |
Update or Other Action |
Office of the Garrison Commander sent letter to K Fredriksson (ADEC Commissioner). SUBJECT: Resuming Year~Round Firing Activities at Eagle River Flats (ERF).
This letter is to notify you the U.S. Army, Alaska (AK) plans to undertake a National Environmental Protection Agency (NEPA) analysis to assess the proposal to start year-round firing activities at ERF Impact Area. If the NEPA analysis is accomplished in time & is supportive of this proposal, year-round firing into all or part of ERF could commence as early as next summer.
ERF is a 2,160-acre salt marsh on Fort Richardson where the Eagle River meets tidal waters in Knik Arm of the Cook Inlet. It has been used for artillery training since 1949. In the early 1980's, the Army noticed an unusually high number of waterfowl deaths. In response the Army, with cooperation of federal & state agencies, initiated a comprehensive sampling program to determine if munitions or munitions constituents were the cause of mortality. In 1990, the Commanding General of U.S. Army, AK temporarily halted all firing into ERF until the cause of the bird mortality was found. In 1991, it was determined that white phosphorus was causing the bird mortality & the Army applied restrictions to include winter only firing & banned the firing of smoke grenades containing white phosphorus.
Fort Richardson was listed on the National Priorities List (NPL) in June 1994 & ERF Impact Area identified as a CERCLA site due to the white phosphorous. The Army's Remedial Project Manager (RPM) has been working with the EPA & ADEC RPMs to identify areas where white phosphorous has been remediated, & year-round training activities can resume. The RPMs, in a draft Decision Summary have identified areas within ERF where firing activities could be conducted without exposing white phosphorous contaminated sediments & affecting waterfowl mortality.
ERF Impact Area is the only impact area for heavy artillery & mortars on Fort Richardson. Live fire training is absolutely essential in maintaining military readiness & sustainability, hence our intention to consider the proposal to resume year-round firing in ERF.
If you require more information, please contact Terry Boone, Chief, Environmental Resources Department, at (907) 384-3093, or Cristal Fosbrook at (907) 384-2713. I am forwarding copies of this letter to Marsha Combs, EPA-Anchorage & to Jennifer Roberts, ADEC-Anchorage.
Signed Donna G. Boltz Colonel, US Army Commanding |
Louis Howard |
| 9/16/2005 |
Spill Transferred from Prevention Preparedness and Response Program |
Project management transfer from PERP (Young Ha) to CS Program/Federal Facilities for the two releases of diesel fuel occurring at Eagle River Flats. Spill size was much less than the 100 to 150 gallon release estimate. More likely less than 25-50 gallons were released by the tanker truck coupling the fill hose to the tanker while fueling generator sets. PERP spill #s at the ERF Fuel tanker spill: 05239925504 and ERF Porcupine spill: 05239924402. |
Louis Howard |
| 9/26/2005 |
Update or Other Action |
Ft. Richardson Eagle River Flats Fuel Tanker – 05239925504 & Ft. Richardson Eagle River Flats Porcupine – 05239924402 Request for Transport
COMMENTS: ADEC has received the Army’s request to approve transport of petroleum contaminated soils to be excavated from the Eagle River Flats spills on September 26, 2005. *Based on generator knowledge of the source of the petroleum contaminated soils, ADEC approves transport of these specific petroleum contaminated soils to Alaska Soil Recycling. Be aware that confirmation sampling will be required of the excavated areas to identify any residual contamination remaining at each area: DRO, RRO, BTEX and if the diesel spilled was Diesel #1 or Arctic grade diesel fuel then include gasoline range organic (GRO).
ADEC’s review and concurrence on the request to thermally treat the POL contaminated soil is to ensure the proposed request is in accordance with State of Alaska environmental conservation laws and regulations. While ADEC may comment on other state and federal laws and regulations, our concurrence on the request for treatment does not relieve the United States Army or its consultants, contractors, subcontractors, or Army civilian personnel from the need to comply with other applicable laws and regulations |
Louis Howard |
| 10/27/2005 |
Update or Other Action |
The Army announced Oct. 27 that a legal settlement will allow training to continue at Eagle River Flats (ERF) on Fort Richardson, Alaska (FRA). The Army has used the mortar & artillery range for about 40 years.
U.S. Army Alaska (USARAK) Commander Brig. Gen. James T. Hirai noted that the use of the range is crucial to the Army's efforts in the global war on terrorism. "Our mission is to train Soldiers for combat. While doing that, we continue to make every effort to be good stewards of our training lands," said Hirai. "It's never an easy task, but it's one we take very seriously."
A lawsuit filed by environmental groups, the Chickaloon Tribe & individual citizens in June 2001, alleged the Army was in violation of the Clean Water Act (CWA), the Solid Waste Disposal Act (SWDA) (also known as the Resource Conservation & Recovery Act, or RCRA), & the Comprehensive Environmental Response, Compensation, & Liability Act (also known as the Superfund law).
Plaintiffs claimed that the Army's use of munitions while training Soldiers on the ERF range required permits under the CWA & the SWDA, as well as initiation of cleanup activities under Superfund. The lawsuit sought to enjoin further live-fire training at ERF.
Although the court dismissed the SWDA count, the Army continued to dispute the other two claims. Because of ambiguities in current law regarding the applicability of environmental regulations to critical testing & training on military ranges, however, the Army believes that settling the case was the best way to ensure training could continue at ERF.
FRA provides a combination of training opportunities & ranges for maneuver & live-fire exercises by the 172nd Infantry Brigade & other Alaska-based units, such as Task Force 1-501, which recently returned from Afghanistan. Because ERF is the only artillery & mortar impact area available at FRA, Army officials said they believe restriction of the live-fire capacity ERF would decrease the readiness of the units that need to train there.
The relative importance of FRA to overall Army readiness will increase in the near future, said USARAK officials, as the 172nd continues its transformation into a Stryker Brigade Combat Team, & Task Force 1-501 continues to train for its missions. USARAK has been actively engaged in a remediation project to eliminate potential danger to waterfowl since 1997, well before the plaintiffs brought their lawsuit, officials said.
An Army study had discovered that migratory birds were ingesting residual white phosphorous, used to create smoke screens for military training. The remediation project has been successful, Richardson officials said, as waterfowl mortality has declined.
As part of the settlement, USARAK will continue to refrain from firing during cleanup activity & during spring & fall waterfowl migration periods, practices in place before the lawsuit. Among the terms of the agreement, USARAK will continue its monitoring studies to ensure that constituents of munitions are not moving off range into Knik Arm. Studies to date do not indicate such movement is occurring.
USARAK will also monitor beluga whales near the range & will continue to assist the National Marine Fisheries Service, as needed, in any research it conducts on belugas in the upper Cook Inlet.
To assist the plaintiffs in understanding the data from these studies, USARAK will fund a technical expert to review the studies & results & provide information to the plaintiffs on the numbers & types of munitions used at the range. |
Louis Howard |
| 1/31/2006 |
Update or Other Action |
The estimated cost for remedial action construction, and operation and maintenance through the post-record of decision (ROD) period between 1998 and 2006 was $6,907,924 and the actual cost was $8,995,576, or about a 30 percent difference. The greatest cost difference is in projected monitoring costs for the period between 2006 and 2018 (The estimate in the ROD was based on ending monitoring at an earlier date). Projected long-term monitoring costs are 200 percent higher than estimated in the ROD. |
Louis Howard |
| 3/15/2006 |
Document, Report, or Work plan Review - other |
Staff reviewed and commented on the 2006 Draft Long Term Monitoring Work Plan Operable Unit C, Fort Richardson, AK. Document was approved pending incorporation of EPA’s comments. The Army is responsible for the actions of contractors, agents, or other persons who perform work to accomplish the approved work plan. For any activity that significantly deviates from the approved plan, the Army shall notify ADEC and obtain written approval in the form of a work plan amendment before beginning the activity.
Any action taken by the Army or an agent of the Army that increases the project's overall scope or that negates, alters, or minimizes the intent or effectiveness of any stipulation contained in this plan will be deemed a significant deviation from the approved plan. The final determination as to the significance of any deviation and the need for an amendment is the responsibility of ADEC and EPA. Therefore, it is recommended that the EPA and ADEC be consulted immediately when a significant deviation from the approved plan is being considered. |
Louis Howard |
| 5/24/2006 |
Update or Other Action |
CRREL (C. Collins) email to Fort Richardson (R. Nenahlo, K. Gardner, C. Fosbrook & BJ Baker SJA). Subject: Eagle River Flats (ERF) 120mm mortar Winter Firing Data.
Following the initial firing of 120 mm mortar projectiles into ERF in February 2005, we measured 12 representative craters to determine rate of penetration into the ice & frozen sediment. The measurement methods were similar to those used in 1991 to determine minimum required ice & frozen ground thicknesses for 105 mm howitzer projectiles.
Craters formed by 120 mm mortar projectiles consisted of a large shallow outer crater & a much smaller, but deeper inner crater. Outer 120 mm mortar craters averaged 4.10 m in diameter. Outer craters did not penetrate underlying ice cover. Bottom of outer crater was the top of the ice sheet, or in one instance where no ice was present, the top of frozen ground. The depth of outer crater was the depth of the snow cover, averaging 15 cm.
Inner crater averaged 0.8 m in diameter. Inner craters penetrated into the underlying ice sheet. Average inner crater depth was 20 cm. If the ice thickness was greater than 20 cm (7 craters) then the inner crater was entirely within the ice layer. If the ice thickness was less than 20 cm, then there was frozen ground exposed at the bottom of the inner craters. One inner crater penetrated 5 cm & one 2 cm into the frozen ground. Two craters had frozen ground exposes at bottom of inner crater but with no penetration. In one instance where there was no ice cover under the snow, only frozen ground, the inner crater penetrated 10 cm into the frozen ground.
The 120 mm mortar projectile craters had less penetration of the ice than the 105 mm howitzer projectiles that we measured back in 1991, so any firing restrictions applicable to 105 mm howitzer will be more than sufficient if applied to 120 mm mortars.
Since all of the non-ponded mudflat areas, such as the area where the 120 mm mortar projectiles were fired into, & all major ponds are now free of white phosphorus contamination in the surface sediments, the minimal disturbance we observed from the measured & other observed 120 mm craters should not cause any additional white phosphorus-contaminated sediments from being exposed by such firing activity. |
Louis Howard |
| 5/31/2006 |
Update or Other Action |
Eagle River Flats FY05 Data Report received. ERF experienced an earlier spring breakup in 2005 than in 2004. It was 60% open by 23 April 2004, but completely open on 25, April 2005. In 2005, three types of ground-based surveys were conducted: core group of transects covering areas with known remaining white phosphorus contamination and areas most highly used by waterfowl. This core group was surveyed at least twice a week. The second survey type involved transects in areas used by waterfowl that have been remediated or have no known contamination. These transects were monitored less frequently than the core transects, generally weekly or bi-weekly.
A third survey type, conducted only once during the fall consisted of forest-edge transect surveys to the east of Eagle River Flats. Between mid-August and the third week of October, the surveys identified 49 waterfowl mortalities along transect in Eagle River Flats, consisting of carcasses, feather piles, and partial skeleton remains. 25 mortalities or 51% of the total were found along the Ditch Transect in Northern C Marsh, an area of known remaining white phosphorus contamination.
Based on field observations, and experience and knowledge of Eagle River Flats, estimates of dabbling duck mortality may be as 50% higher than 49 actually counted in 2005 but not higher than that. For the original population model, combining our estimated error for carcass counts and population estimates gave a mortality rate of between 1.9% and 4.3% of the estimated fall 2005 dabbling duck population, with the median estimate being 3.1%. For the revised population model using the each species population counts, combining the estimated error for carcass counts, and population estimates, it gave a mortality rate of between 1.1% and 2.4% of the estimated fall 2005 dabbling duck population, with the median estimate being 1.8%.
The original population model gives a more conservative estimate of population and thus mortality, while the revised model better reflects the species dynamics of Eagle River Flats. Both estimated mortality rates are well below the short term RAO, but still above the long term RAO of 1% mortality rate of the fall dabbling duck population. Tidal predictions for 2006 indicates a very good year for remediation, with no flooding tides predicted from May until August. Following the August tides, the period from 16 August to 7 September will not flood. Over the last several seasons, the rainfall trend has been little precipitation through July and sometimes through early August. If this trend continues, 2006 should have an excellent remediation season. If weather conditions hold, significant remediation should occur with three systems deployed to Area C. However, creation of additional drainage in C-Marsh area may be required to facilitate drying along the northern ditches. The outlook for 2007 is even better with no flooding tides from mid-May through the end of August.
Sublimation/oxidation conditions were excellent in June and July 2005 in Ponds 146 and 171, where losses from planted white phosphorus particles were 100% and 97%, respectively, for these two ponds. Sublimation/oxidation conditions were marginal for Area C Pond 155 and the eastern side of Area BT, but some decontamination was evident. Fortunately, the blow in place detonations in August 2004 of WP filled projectiles did not recontaminate the nearby large waterfowl feeding ponds. However, the Area C Marsh still has lethal quantities of WP, especially in parts of the drainage ditches.
Based on the predicted tide cycles, 2006 and 2007 have the greatest number of days between flooding tides than any of the active remediation years (1988 to 2003). Consequently, decontamination of much of the remaining surface sediments in the marsh of Area C and in Area BT is possible prior to capping of the remaining contaminated pools. To minimize the amount of capping material, sampling will be needed to define the boundaries of the locations that need treatment.
Gravel alone should be used for any capping. Because of the difficulty of achieving uniform coverage when applying the cap from helicopters, application of a cap should be done from the surface if at all possible. Many areas of ERF are accessible during the winter by truck across the ice covered surface. Gravel can be hauled directly to the particular site, dumped on the ice surface, spread out, and allowed to melt through and settle over the contaminated area during the spring. Other small areas are accessible during the summer using ATVs along cleared trails. |
Louis Howard |
| 7/6/2006 |
Update or Other Action |
Final Letter Report received for removal, disposal, treatment of 27 cubic yards of diesel contaminated soil at two locations on Eagle River Flats at pumps number 3 and number 5. Confirmation sampling taken during excavation activities showed that all petroleum contamination associated with these spills were cleaned up to below ADEC Method Two cleanup levels. No further action is warranted at these two sites. |
Louis Howard |
| 10/2/2006 |
Update or Other Action |
Environmental Protection Agency issues a Preliminary Close Out Report (PCOR) which documents that US Army Garrison, Alaska (USAG-AK) has completed all construction activities for the Fort Richardson Superfund Site (“the site”), in accordance with the U.S. Environmental Protection Agency (EPA) guidance, Close Out Procedures for National Priorities List Sites (OSWER Directive 9320.2-09A-P, January 2000). EPA and the Alaska Department of Environmental Conservation (ADEC) have determined that USAGAK constructed and/or implemented the remedies in accordance with remedial design (RD) plans and specifications. USAGAK has initiated activities necessary to achieve performance standards and site completion.
Remedial activities conducted at Operable Unit (OU)C have achieved the objectives of the Record of Decision (ROD). Monitoring in 2004 demonstrated that the duck mortality rate was less than the short term remedial action objective (RAO) and nearing the long-term 20 year RAO. Continued pumping in years 2005 and 2006 has helped treat several small ponds that pose risk. Data confirms that no filling and capping is needed to meet RAOs. Active pumping is expected to be completed in 2007.
Remedial activities conducted at OUC to date have achieved the short-term objectives of the ROD. All construction activities have been completed.
As part of the IC Policy, the Army maintains a GIS database containing environmental data that have been collected at Fort Richardson. The GIS database contains a map outlining IC areas and specific descriptions of the ICs. The GIS database is an integral part of the Master Planning process. Information contained in the database (IC map and chemical data) alerts planners to areas where ICs have been established and allows planners to make accommodations when designating land use and/or planning future projects.
An additional aspect of the IC policy at Fort Richardson is the requirement that all organizations operating on Fort Richardson complete an excavation clearance request (ECR) prior to excavating to a depth of more than six inches. Each ECR is reviewed for compliance with the IC policy prior to approval.
ICs have been implemented to restrict access to the Eagle River Flats Impact Area. Access is controlled by means of locked gates and the entire area is surrounded by warning signs. Because ERF is an active munitions impact area, the area is also patrolled to prevent unauthorized access. |
Louis Howard |
| 12/4/2006 |
Meeting or Teleconference Held |
Based on information provided at the Federal Facilities Agreement meeting it appears that 2007 will be the last year for active white phosphorous remedation (i.e. pumping ponds). October 27, 2004 Settlement Agreement states in Section III.C. "Analysis of use alternatives for ERF." Upon the completion of the active white
phosphorous remediation and prior to the lifting of existing firing restrictions for ERF, USARAK shall undertake an environmental review of its use of the ERF range in accordance with the
policies and guidance set forth in the National Environmental Policy Act, 42 USC §§ 4321 to 4370f, Council for Environmental Quality regulations, 40 CFR Parts 1500-1517, and Army regulations for environmental analysis of Army actions, 32 CFR Part 651.
This review will include an assessment of potential alternatives to the way USARAK currently uses ERF to determine whether any aspects of that use can be modified to further minimize environmental impacts while continuing to satisfy training needs and requirements.
"Monitoring for beluga whale presence in ERF before, during and following firing activities." In addition to the monitoring described paragraph III.B.2 above, in the event that USARAK conducts artillery firing activities at ERF between July and October, USARAK
Environmental Department personnel shall, during the months of July, August, September and October, conduct specific surveillance activities immediately before, during and following all
ERF artillery firing activities to help ensure that beluga whales are not harmed by the artillery firing activities.
Surveillance operations shall be conducted from established observation points. This obligation shall be in addition to, and shall not alter, the year-round USARAK and Army requirements that training units immediately cease fire if major mammal species are observed in the target area. |
Louis Howard |
| 12/5/2006 |
Update or Other Action |
October 27, 2004 Final Settlement Agreement continued: "Firing restrictions."
1. USARAK shall adhere to the following prohibitions on the use of ERF:
(a) absent authorization or regulatory approval from the Department of Interior or other applicable federal regulatory authority, USARAK shall not engage in artillery firing activities at ERF during periods of spring and fall waterfowl migration, as determined by the USARAK Biologist in consultation with the United States Fish and Wildlife Service;
(b) USARAK shall not discharge radiological warfare agents, hazardous chemical warfare agents, biological warfare agents or depleted uranium into ERF; and (c) USARAK shall adhere to USARAK and Army requirements that no wildlife will be purposefully killed, injured or targeted, and that training units immediately cease fire if major mammal species are present in the target area.
2. In addition, through the end of the active white phosphorous cleanup, USARAK shall adhere to the following prohibitions on the use of ERF:
(a) USARAK shall not engage in artillery firing activities at ERF during ERF cleanup and monitoring operations when cleanup and monitoring equipment or personnel are actively deployed on ERF; and
(b) USARAK shall not fire mortar rounds or artillery rounds when the ice cover on water bodies within ERF is less thick than specified in the restrictions set forth in the procedures established in the 1991 Environmental Assessment and associated FONSI concerning the use of ERF.
Said limitations will be periodically reviewed to ensure that these firing restrictions are sufficient to ensure that firing activities do not adversely impact ERF cleanup and monitoring efforts.
USARAK shall not lessen the restrictions discussed in this paragraph III.F.2 without providing prior written notice to Plaintiffs.
H. "Munitions Response" USARAK agrees to mark and treat UXO that falls inside the ERF impact area when such activity is necessary to facilitate ERF white phosphorous cleanup efforts and can be accomplished with reasonable safety. |
Louis Howard |
| 2/6/2007 |
Exposure Tracking Model Ranking |
|
Louis Howard |
| 3/28/2007 |
Document, Report, or Work plan Review - other |
The Alaska Department of Environmental Conservation (ADEC) has received the Draft Long Term Monitoring and Remediation Work Plan for Operable Unit C, Fort Richardson, AK dated February 2007 for review and comment on March 21, 2007. Based ADEC’s review of the information provided in the submitted work plan, ADEC will approve the document as final, with all its recommendations, pending incorporation of EPA’s comments.
ADEC’s review and approval on the document is necessary to ensure the proposed work is in accordance with State of Alaska environmental conservation laws and regulations. While ADEC may comment on other state and federal laws and regulations, our approval does not relieve the United States Army or its consultants, contractors, subcontractors, or Army civilian personnel from the need to comply
Any significant action taken by the Army or an agent of the Army that significantly increases the project's overall scope or that negates, alters, or minimizes the intent or effectiveness of any stipulation contained in this plan will be deemed a significant deviation from the approved plan. The final determination as to the significance of any deviation and the need for an amendment is the responsibility of ADEC and EPA. Therefore, it is recommended that the EPA and ADEC be consulted immediately when a significant deviation from the approved plan is being considered. |
Louis Howard |
| 6/8/2007 |
Update or Other Action |
The start of the study for the Environmental Impact Statement began this year with two significant events that will help determine if year-round firing into the Flats is feasible. The first was a live-fire exercise involving 120-mm mortar rounds, the largest rounds currently fired into the Flats, and 81-mm mortars. On 5 June, a 100- x 100-m area was sampled in the Bread Truck (BT) area to obtain background data on high-explosives and white phosphorus levels. On 6 June, a total of 14 high-explosive 120-mm mortar rounds were fired into Northern C and Southwest BT areas. Thirteen of the 14 rounds detonated high-order, one detonated low-order. Three of the rounds fell into the pre-sampled BT area.
All detonation points were sampled within the crater and in the ejecta field following the exercise to determine the presence of explosives and white phosphorus. The previously-sampled area in BT into which the three rounds detonated was also resampled. All craters were measured to determine depth of penetration and area. The following day, firing continued with training practice rounds for the 120-mm and 81-mm mortars. Preliminary results indicate that no white phosphorus is detectable in the 13 of the 14 detonation points that resulted from high-order explosions. Similar results from the high-explosives analyses are anticipated.
The second EIS test entailed setting off fixed explosions to determine the seismic and acoustic effects of the live-fire detonation of 155-mm high-explosive artillery rounds. A series of nine detonations of 12 blocks each of the explosive C4 were conducted at high and low tide to determine the ground to water coupling of the ground wave resulting from the detonation of the explosives. Instrumentation was set up from the detonation line to the Eagle Bay and parallel to the shore at the edge of the Flats. Hydrophones recorded the sound levels in the water just off shore of the sensor array to determine the noise levels Beluga Whales may be exposed to during the course of an exercise. Microphones along the seismic array and noise meters in observation towers sensed acoustic noise levels. Small seismic arrays were also placed at four points along the edge of the Flats. The low-tide explosives were placed in the high-tide test craters to provide better ground coupling of the detonations. All detonation craters and the ejecta field were sampled pre- and post-detonation for explosives and white phosphorus. Analysis of the samples and seismic-acoustic data are not yet complete. |
Louis Howard |
| 6/29/2007 |
Update or Other Action |
Preliminary results from the June 2007 seismic acoustic experiment at ERF artillery impact range received. Established behavioral disturbance threshold for ocean mammals of 160dB is exceeded for the detonations of equivalent blast levels to 155mm ordnance. All shot locations were greater than the 500m "safety zone" from the shore of Eagle Bay. Results indicate that the peak sound pressure levels in the Eagle River will yield even higher peak pressures as the river cuts directly into the artillery impact zone. Acoustic ocean mammal monitoring systems are suggested as a means for determining safe operations of the ERF training range.
Future Research
Specific audiological and behavorial assessments of Pacific salmonids and the Cook Inlet population of beluga whale should be investigated relative to both land and water ordnance strikes and especially in the Eagle River based on hydroacoustic data collected from nearshore and in-water explosions.
The development of an acoustic array at the mouth of the Eagle River to detect movement of marine mammals (specifically beluga whales, harbor porpoise and seals). The ability to track and determine Cook Inlet social structure using vocalization and a Hidden Markhov classification system.
|
Louis Howard |
| 8/31/2007 |
GIS Position Updated |
61.3099 N latitude -149.7079 W longitude |
Louis Howard |
| 2/27/2008 |
CERCLA ROD Periodic Review |
ADEC signed the 2nd Five Year Review. The United States Army Alaska (USARAK) conducted the second Five-Year Review of the remedial actions at the Fort Richardson National Priorities List (NPL) site, Anchorage, Alaska, from November 2007 through February 2008. The purpose of this review is to ensure that remedial actions selected in the Records of Decisions (RODs) for the Operable Units (OUs) are being implemented and that they continue to be protective of human health and the environment. To achieve this purpose, this review evaluates the status of implementation of the selected remedies, identifies significant variances from the RODs, and makes recommendations for reconciling variances and/or for improving performance of remedial actions.
As part of this review, significant ARARs for each ROD were reviewed for changes or the promulgation of new laws since the ROD was signed that might be considered ARARs if the
RODs were to be written today. New laws that might be considered ARARs today are applicable
for Fort Richardson only if they are essential to ensure protectiveness of the remedies.
As part of this review, RAOs were reviewed, and contaminant-specific standards used to set
numeric cleanup goals in each ROD were compared to present day values to assess continued
protectiveness of the remedies. More specifically, current Maximum Contaminant Levels (MCLs)
and toxicity and/or carcinogenicity values were compared to MCLs and toxicity/carcinogenicity
values at the time of the RODs. At sites where regulatory values for COCs were not available at
the time the ROD was developed, RBC values were used to establish cleanup goals. For these
sites, current Region 3 (2002) RBCs were used to evaluate if ROAs have changed. The OUspecific
RAOs, ARARs, and cleanup goals are discussed in the OU sections of this report.
Eagle River Flats Impact Area (OUC)-At OUC, waterfowl mortality data may be skewed by active remedial activities. Evaluating waterfowl recovery trends upon completion of remedial action is recommended. The remedy at OUC is expected to be protective of human health and the environment upon completion. Exposure pathways that could result in unacceptable risks are being controlled with ICs.
Institutional controls (ICs) at OUC have been implemented. Fort Richardson has established a
post wide IC policy at all known or suspected contaminated sites. Further details regarding the
Army/Fort Richardson IC policy can be found in the OUD ROD, the U.S. Army Institutional
Controls Standard Operating Procedures [APVR-RPW (200-1)], and a Memorandum on
Institutional Controls [APVR-RPW-EV (200-1c)], from Major General James J. Lovelace – Fort
Richardson, Alaska. This policy ensures that limitations on access, water use, excavations, and property transfers as appropriate for the site have been established. At OUC, controls include a locked gate limiting access, fences and signs around the perimeter of the area, and large signs at access points to Eagle River. One component of the IC policy involves obtaining an Excavation Clearance Request (USARAK Form 81 a – 1 Mar 02) to control excavation inconsistent with established ICs at a particular site. ICs will remain in place as long as hazardous substances remain on site at levels that preclude unrestricted use. Army Regulation (AR) 385-63 (Access Restrictions to Army Impact Areas and Ranges) and USARAK Regulation 350-2 (Training) provide further use
restrictions for OUC.
If in the future a decision is made to close ERF, the human health risk from exposure to UXO will be addressed using the ARARs that are in place at the time. The Army is in the process of developing an Environmental Impact Statement (EIS) that identifies and evaluates a range of alternatives to accommodate training needs at Ft Richardson. The results of remedial action work performed at ERF indicate that the areas west of Eagle River, Northern Area A and Pond 290, consistently meet the remedial action objectives (RAOs) (Section 6.2.2) outlined in the ROD since 2002 and provide no evidence that these areas pose unacceptable risk to human or ecological health. The Army will account for this information while developing and evaluating alternatives for the EIS. |
Jennifer Roberts |
| 12/5/2008 |
Update or Other Action |
Engineers finish Eagle River Flats marsh clean up ahead of schedule
After initially dredging & draining, pond pumping proved to be the more effective & least disruptive means of removing the white phosphorus, so CRREL established a six-pump system. Pumping the ponds allows the white phosphorus to dry & oxidize, eliminating the threat to waterfowl. Pumping alone successfully remediated 90 percent of the ponds.
“We did five years of active remediation, & then we scaled back to focused remediation using three pumps to concentrate our efforts in specific areas that were still considered contaminated,” said JoAnn Walls, project manager with the Alaska District.
The remediation was extremely successful because of cooperation among multiple agencies, according to Charles Collins, CRREL project manager.
“I think (the multi-agency cooperation) was very beneficial to getting the project done since it was such a complex project,” Collins said. “Understanding the saltwater marsh environment is very complex. I think it was a great working relationship.”
The project was a team effort with numerous agencies involved. CRREL became involved because of its expertise in munitions analysis, & provided the primary project engineers directing the cleanup.
Alaska District provided contractual support to CRREL, which included obtaining helicopters to assist with remediation & unexploded ordnance technicians, who cleared the area for workers by disposing of all known UXO that builds up during the winter when the grounds are used as an impact area.
Meanwhile, engineer Soldiers from the active Army & Reserve, working under the CRREL Fairbanks office, created sumps & drainage ditches used by the pump systems.
The Directorate of Public Works at Fort Richardson, the primary customer & landowner, was responsible for overseeing remediation & ensuring that cleanup occurred, while the EPA & Alaska Department of Environmental Conservation regulated the project. They ensured that cleanup met the objective of protecting human health & the environment.
Finally, the project depended on the cooperation of the U.S. Fish & Wildlife Service to track the cleanup success by taking an aerial count of ducks every summer & fall.
When the record of decision was signed in October of 1998, which marked the beginning of remediation, the 20-year goal was to reduce the waterfowl mortality rate to 1 percent. That goal was met in the 2006 season, 12 years ahead of schedule, & has since been maintained. In 2007, the U.S. Army Corps of Engineers reported 35 waterfowl fatalities, or 0.7 percent of the total fall population, based on mortality monitoring using radio-collared wild mallards.
“In one sense it seems like we’ve been doing this forever, but we’re certainly reaching the remedial goal much sooner than we expected,” Collins said. “I think it’s pretty amazing, considering the extent of the remediation. I think we’re all pretty amazed that we’ve been able to get as far as we have.”
Because of the discoveries & efforts of the Alaska District & CRREL, the rest of the nation, as well as many other countries, have stopped firing white phosphorus into wetlands.
There are still small pools that are large enough for ducks to feed in but too small to feasibly pump. In these cases, trucks dump gravel over the entire surface to cap these areas during the winter, when the marsh is frozen & can support the vehicles’ weight. During the summer, CRREL personnel test those capped areas to ensure no hazardous areas are exposed.
“The major remediation is complete,” Collins said. “The capping of the last remaining hot spots is almost complete, & we’ll finish that up next winter. We’re now in the long-term monitoring phase of the project.”
That monitoring includes continued white phosphorus sampling of the marsh, which is scheduled to continue through 2012.
“We’re using just one pump to lower the water level to make it safer & easier to do the sampling work,” Walls said.
A ground-based waterfowl mortality study on transect paths will also continue annually through 2012 & then at five-year intervals.
“There may be a time in the future where we go back & do more remediation based on long-term monitoring, but for all intents & purposes remediation is complete,” Collins said.
See site file for additional information.
|
Louis Howard |
| 10/9/2009 |
Update or Other Action |
Memorandum of Agreement between US Air Force & US Army for Joint Base Elmendorf-Richardson. The purpose of this MOA is to define the installation support relationship between the supporting Component – the United States Air Force (USAF), hereafter referred to as the “supporting Component”, & the supported Component(s) – the United States Army (USA), hereafter referred to as the “supported Component(s)” for fully implementing Base Realignment & Closure (BRAC) 2005 Joint Base decisions per references (a), (b), (c), & (d) at Joint Base Elmendorf-Richardson. For the purposes of this MOA, the terms “party” & “parties” shall be understood to refer exclusively to the supporting Component & the supported Component(s), either collectively or individually.
This MOA establishes a comprehensive framework for Joint Base Elmendorf-Richardson implementation, & captures the most practical methods for transferring Installation Support functions while meeting mission requirements. The MOA represents Full Operational Capability (FOC). Initial Operational Capability (IOC) requirements, to include reimbursement arrangements, will be addressed in the Implementation Plan. PERIOD OF PERFORMANCE a. IOC: 31 January 2010 to 30 September 2010. b. FOC: 1 October 2010 until terminated by the signatories of this MOA.
Major milestones & transfer date for each annex to successfully achieve FOC which area applicable to environmental issues.
#15 Annex G: Review existing environmental contracts/determine optimum methods to complete the JB mission Activation or completion date: 01/31/2010,
#16: Develop JB Environmental Quality organizational structure 01/31/2010
#17: Merge JB tank inventories into a single, common data base (DB) 03/01/2010
#18: Work with external regulatory agencies to optimize the merger of all air permits 06/01/2010
#19: Begin Merger of JB air emission inventories into a single, common DB 09/01/2010
#20: Determine additional air regulatory requirements due to JB merger 06/01/2010
#21: Begin Merger of JB drinking water (DW) programs 06/01/2010
#22: Determine DW regulatory requirements due to JB merger 06/01/2010
#23: Merge JB environmental management system (EMS) programs 08/01/2010
#25: Complete new JB compliance inventory & risk analysis 08/01/2010
#27: Establish JB Environmental, Safety, & Occupational Health Council (ESOHC) 08/01/2010
#33: Merge JB hazardous waste (HW) programs 10/01/2010
#34: Work with external regulatory agencies to optimize incorporating Fort Richardson into Elmendorf Air Force Base Part B permit 03/01/2010
#35: Develop JB OPLAN for HW/toxic waste operations 06/01/2010
#36: Merge JB HW inventories/accumulation points into common DBs 10/01/2010
#37: Merge JB Land Use Controls (LUC) programs 10/01/2010
#42: Merge JB contaminated sites (CS) program 10/01/2010
#43: Merge JB CS inventories into a single, common DB 10/01/2010
#44: Convert Fort Richardson CS to meet Air Force protocols 10/01/2010
#45: Begin Merger of JB spill prevention & reporting programs 01/31/2010
#46: Develop JB spill contingency plan 03/01/2011 Note: this is when current plans expire. EPA says we can use existing plans until then.
#58: Review existing Agreements & Plans 09/01/2010
#88: Transfer all environmental files from Fort Richardson to JBER 09/01/2010
#90: Merge Fort Richardson & Elmendorf Air Force Base Geographic Information System (GIS) into AF-approved GIS 09/01/2010
#96: Review Comprehensive Environmental Response, Compensation, & Liability Act (CERCLA) activities to ensure compliance with the Federal Facility Agreement (FFA) 03/01/2010
#97: Draft notification of responsibility change for FFA 09/01/2010
#98: Negotiate revisions/amendment to Two party Agreement 10/01/2010
#99: Prepare annual update of the status of all two-party sites 09/01/2010
#103: Prepare/update JB instruction for management of LUCs 09/01/2010
#104: Update maps/GEOBASE depicting LUC boundaries 10/01/2010
#105: Prepare/submit annual LUC report to EPA & ADEC 10/01/2010
#106: Update Air Force base general plan 10/01/2010
#107: Merge JB CERCLA administrative record 09/01/2010
#108: Merge project & contract files into common formats & DBs, libraries 10/01/2010
#109: Prepare & update the Community Relations Plan 10/01/2010
#110: Develop 1- & 2- year work plans for the (Defense-State Memorandum Of Agreement) DSMOA cooperative agreement 10/01/2010
#111: Merge JB CS programs 09/01/2010
#112: Merge JB CS inventories into a single, common DB 10/01/2010
#113: Convert Fort Richardson CS to meet Air Force protocols 10/01/2010
#114: Merge JB Military Munitions Response Program (MMRP) sites programs 10/01/2010
#115: Merge JB MMRP site inventories into a single, common DB 10/01/2010
#116: Convert Fort Richardson MMRP sites to meet AF protocols 10/01/2010
#120 I-1.3 Transfer Records Mgt. Functions to the Joint Base 06/30/2010
|
Louis Howard |
| 3/30/2010 |
Update or Other Action |
Chapter 2 Description of Proposed Action and Alternatives
2.2.1.1.1 Mortar Training Requirements Page 2-3
Mortar training consists of a variety of different exercises. Field training exercises (FTX) and situation training exercises (STX) may entail dry fire, live-fire, or training devices, either alone or in combination, depending on the specific objective of the exercise. Live-fire exercises (LFX) involve the use of full range training rounds and service ammunition (high-explosive, illumination, and smoke).
2.2.1.1.2 Artillery Training Requirements Page 2-6
A critical task in artillery and mortar training is to learn where to place rounds for given scenarios. Soldiers must learn, for instance, where to place smoke rounds to effectively provide cover for Soldiers operating in the field, or where to place illumination rounds to allow Soldiers to confirm or deny the presence of the enemy without revealing the location of friendly Soldiers and/or weapons.
2.2.1.3 Weapon Systems and Munitions Pages 2-8 and 2-9
The cartridge, or projectile body of the round, may contain either high explosive (HE), illumination (ILLUM), smoke, or inert materials.
Smoke is used as screening, signaling, spotting, marking, casualty-producing, or incendiary agent. Smoke rounds are also considered a class of pyrotechnic round. There are three types of smoke producing agents used in Army mortar and howitzer munitions; white phosphorus (WP), red phosphorus (RP), and hexachlorethane (HC). WP and RP rounds are prohibited from use in impact areas containing wetlands or open water per Army regulations (U.S. Army 2003b) and thus are not currently and would not be used at ERF Impact Area (OUC).
NOTE TO FILE: If the long-term and/or short term goals stated in the ROD go up significantly, then it may pay to look for the impacts/effects of hexachloroethane as well as white phosphorus if WP is not present in amounts that affect waterfowl.
The NOAA Screening Quick Reference Table (OR&R Report 08-1) lists criteria for Hexachloroethane [(HC) (CAS No. 67721]. HC has an AET in Marine Sediment of 73 ug/kg and an Eco Tox EqP@1% TOC of 1 mg/kg.
The EPA lists a freshwater screening benchmark for HC at12 ug/L and HC is considered to be bioaccumlative (U.S. EPA. OSWER (Office of Solid Waste and Emergency Response). 1996. Eco Update: Ecotox thresholds. Washington, D.C. EPA 540/F-95/038 specifically Table 2. It is available at: http://www.epa.gov/oswer/riskassessment/pdf/eco_updt.pdf and GLWQI Tier II values (U.S. EPA OSWER 1996, Suter and Tsao 1996.)
The OSWER Ecotox Thresholds Sediment Screening benchmark is 1 mg/kg. OSWER AWQC
These are values from OSWER (1996). The AWQC are NAWQC or FCV's (final chronic values) as of 1996.
EPA Region 4 Acute Saltwater Screening benchmark is 0.094 mg/L and the chronic saltwater screening benchmark is 0.0094 mg/L (Risk Assessment Information System Ecological Benchmark Toolhttp://rais.ornl.gov/tools/eco_search.php) |
Louis Howard |
| 4/1/2010 |
Enforcement Agreement or Order |
Dept. of Army Office of the Garrison Commander (Colonel Timothy R. Prior) letter to EPA RPM Bill Adams and ADEC L. Howard.
This letter serves as formal notice to the Environmental Protection Agency Region 10 (EPA Region 10) and the State of Alaska Department of Environmental Conservation, (ADEC) that on 1 October 2010 the U.S. Air Force will assume the U.S. Army's obligations under the 1994 Federal Facility Agreement for Fort Richardson (Docket No.1 093-05-02-120) and any amendments thereto (hereinafter collectively referred to as "the FFA"). The Air Force assumes these authorities and obligations as the Army's successor and assignee for the environmental restoration program at Ft. Richardson in accordance with subsection 2.1 (i) of the FFA.
This is a transfer of responsibility between the Military Departments for the purpose of carrying out the terms and responsibilities of the FFA; it is not a transfer of property subject to the requirements of Section 120(h) of the Comprehensive Environmental Response, Compensation and Liability Act (42 U.S.C. §9620(h)). This transfer of responsibility is in accordance with the Base Realignment and Closure Act of 2005 and the Joint Base Elmendorf-Richardson Installation Support Memorandum of Agreement between the Army and the Air Force, dated 9 October 2009.
This letter replaces our earlier letter dated 17 February 2010. If you have any questions about this matter, please contact Mr. Mark Prieksat at (907) 384-2716.
On and after 1 October 2010" the Air Force and, to the extent necessary, the
Department of Defense will fund all activities required by and subject to the FFA. |
Louis Howard |
| 4/20/2010 |
Document, Report, or Work plan Review - other |
U.S. F&W Service comments on the Draft EIS for Resumption of Year-Round Firing Opportunities at Fort Richardson, AK January 2010. The Service believes that Alternative l (No Action) would maximize conservation benefits for migratory birds, relative to the other alternatives analyzed in the DEIS. The No Action alternative would continue to limit indirect live-fire training at Fort Richardson to winter-time firing at the Eagle River Flats (ERF) Impact Area when ice conditions permit. This approach has been very successful thus far, greatly reducing mortality of migratory birds at ERF. The other proposed alternatives appear to have greater potential for harming avian resources managed by the Army & the Service.
Should Alternative 2, the Army's preferred alternative, be adopted, we recommend that all training activities cease during periods of peak migration. Our recommended approach will ensure that: I) bird disturbance is minimal during times when the most number of birds are present, & 2) reduce the risk of large numbers of birds being disturbed from the (ERF) impact area & potentially increasing the number of birds flying into Elmendorf Air Force Base (EAFB) airspace.
Under Alternative 2, we appreciate the inclusion of habitat protection buffers around feeding ponds for protection of migratory birds; however, we are concerned that during training, rounds may miss their targets & stray into these buffer areas.
The inclusion of a Monitoring Plan was a helpful addition to the preliminary draft. The Plan addressed several of our concerns about how the Army will detem1ine the impact of the proposed year-round firing regime on migratory birds & the environment.
Under Alternative 2 the Service recommends the Army:
l. Cease all training activity during peak spring & fall migration. Currently, the proposal is to only stop firing High Explosive (HE) ordnance, but continue with all other types of training.
2. Conduct mortality monitoring on a weekly basis using transects, beginning when birds arrive in spring & continuing through fall. The DEIS currently proposes that mortality monitoring begin in mid-August. Even weekly monitoring may not be adequate given the speed at which carcasses disappear, but we consider this approach better than the proposed option.
3. Conduct sampling of white phosphorus (WP) & inspect cap integrity weekly throughout the period when birds are present (spring through fall), instead of sampling twice a year during the peak migration.
4. Develop a contingency plan or decision tree that clearly describes what actions would be taken if an increased number of birds start dying again from WP poisoning.
5. Consult with the Service's Migratory Bird Mgt Office to determine when 'peak' migration is occurring.
6. Monitor for hexachloroethane (HC) residues.
7. Develop a contingency plan that clearly outlines steps that will be taken if an unacceptable number of birds fly into critical airspace around EAFB because training activities have disturbed them out of ERF. The DEIS states that EAFB will be informed if birds are moving out of ERF onto this airspace, but there is no discussion of alternatives for preventing a human safety hazard.
8. Consult with the Service as soon as possible to determine the need for a permit under the Bald & Golden Eagle Protection Act. We recommend that the Army go to
http: //region7.fws.gov/eaglepermit/ index.htm (50 CFR Part 22: 26 & 27) for the latest information on the new eagle take regulations. |
Louis Howard |
| 7/13/2010 |
Document, Report, or Work plan Review - other |
Staff reviewed and commented on the FY09 Data Report for Eagle River Flats.
II-2. Ground-Based Waterfowl Mortality Surveys-Conclusions Page 40
ADEC concurs with the recommendation to cap additional areas of identified contamination this next winter to further assist the reduction of waterfowl mortality from white phosphorus. Annual monitoring will need to continue beyond 2012 if year-round firing begins at Eagle River Flats to ensure that waterfowl mortality from white phosphorus does not significantly increase beyond the long-term remediation goal of one percent (1%) mortality of the fall dabbling duck population.
III-1. Eagle River Flats Remediation Operations-Beyond the 2009 Season Page 53
ADEC concurs with the recommendation to keep additional pump systems in inventory and operationally available as a contingency measure in case year-round training activities disturb white phosphorus which increases the waterfowl mortality beyond the long-term goal established in the September 1998 Record of Decision.
III-2. Sediment Sampling and Monitoring for White Phosphorus-Laboratory Analysis of Sediments for White Phosphorus Residues Page 61
ADEC requires the complete analytical laboratory report(s) shall be included as part of all submittals to ADEC for which environmental samples (including white phosphorus samples) have been collected, analyzed and reported. *Note: The “raw” analytical data, e.g. bench sheets, chromatograms, calibration data, etc., are not required submittals, however, must be retained on file by the laboratory for at least ten years after the analysis date (ADEC Technical Memorandum “Environmental Laboratory Data and Quality Assurance Requirements” March 2009).
All reports submitted to ADEC containing analytical laboratory sample results (which includes Eagle River Flats data report) shall contain a completed Laboratory Data Review Checklist and a Quality Assurance (QA) Summary, which includes this data report. ADEC will require this to be a part of every data report for Eagle River Flats as long as it includes analytical laboratory sample results. The QA Summary must be included as a specific text section of the report. All laboratory results, including laboratory quality control (QC) sample results, must be reviewed and evaluated for quality, validity and usability. The text must include any affects on data validity and/or usability due to field sampling and laboratory quality control discrepancies.
ADEC commented on these two laboratory data requirements in previous comments (see March 12, 2009 ADEC letter commenting on the work plan section 5.0 Sediment Sampling and Monitoring for White Phosphorus).
Conclusion Page 84
ADEC concurs with recommendation to expand the gravel caps in Area C near the “south ditch junction” to the west to cover the contaminated sediment. The drainage ditch which was planned to be capped in March 2010 may not have been completed due to overflow water on top of the ice encountered this year and may need to be rescheduled for February/March 2011, weather permitting. ADEC concurs with the recommendation to sample the referenced unmapped pond to determine if capping or draining is warranted. ADEC concurs with the recommendations that a magnetometer survey be conducted on the west side of the [Eagle River} river mouth.
Our review and comments on this data report was to ensure the work was done in accordance with State of Alaska Environmental Conservation laws and regulations. While ADEC may comment on other state and federal laws and regulations, our comments on the report does not relieve the Army, its contractors, subcontractors or agents acting on its behalf, from the need to comply with other applicable laws and regulations.
|
Louis Howard |
| 11/17/2010 |
Meeting or Teleconference Held |
A meeting of the remedial project managers (RPMs) convened at 0900 on 17 November 10 at
the Joint Base Elmendorf-Richardson (JBER)-Richardson Conference Room in Building 658.
Attendees included: Mr. Bill Adams - Environmental Protection Agency (EPA); Mr. Louis
Howard - Alaska Department of Environmental Conservation (ADEC); Mr. Robert Shirley - Air
Force Center for Engineering and Environment (AFCEE) Western Region Environmental Office;
Mr. Nick Muszynski - AFCEE Restoration - Program Management Office (R-PMO); Mr. Rafael
Vazquez - AFCEE R-PMO; Mr. Jim Klasen - lith Air Force Environmental Attorney;
Ms. Renee Wright - Environmental Restoration Community Relations Coordinator; and CEANR
personnel - Mr. Gary Fink, Mr. Mark Prieksat, Ms. Donna Bawnler, Mr. Don Aide, Mr. Tim
Plucinski, Mr. Dick Nenahlo, and Ms. Cynthia Tomlinson.
Eagle River Flats (ERF) - Mr. Mark Prieksat provided a detailed overview ofthe ongoing
cleanup activities of white phosphorus at this active range (Attachment 2). This intertidal range is still used for training purposes during the winter months; however, white phosphorus is not contained in any of the munitions. White phosphorus does not completely breakdown in a wet environment, such as this wetland impact area and the remaining particle is toxic when
consumed by dabbling birds. Several ponds were drained to expose white phosphorus particles
to oxygen allowing for complete breakdown into harmless materials; however, it is virtually
impossible to drain all of the ponds due to tidal influence on these ponds. Capping has proven
successful in areas where pond drainage is not effective. Bird mortality rates are observed
annually and long-term remedial action objectives (mortality rate < 1 % annually) has been
achieved since 2006.
Some additional capping efforts are expected to be completed in Mar 2011 and bird mortality monitoring will be continued. The Army is currently pursuing an environmental impact statement (E1S) in an effort to open this impact area up to year-round firing. Many public comments have been received and responses to those comments are being prepared. 1fthe ERF were opened to year-round firing, a legal change to the record of decision (ROD) may be necessary. The EPA has agreed to an explanation of significant differences (ESD) to require additional monitoring at this active range. Some things to consider: who pays for additional monitoring (operations or environmental?); how can we reduce life cycle costs;what is the exit strategy for this site. |
Louis Howard |
| 12/7/2010 |
Exposure Tracking Model Ranking |
Initial ranking with ETM completed for source area id: 71410 name: White phosphorus contamination |
Louis Howard |
| 10/27/2011 |
Update or Other Action |
Staff received the CRREL LR-11-04 report: Remediating & Monitoring White Phosphorus Contamination at Eagle River Flats (Operable Unit C), Fort Richardson, Alaska FY10 [21st Annual] Data Report.
During the 2010 transect surveys, six mortalities (three carcasses and three feather piles) were found around the Pond 730 transect. This is a noticeable reduction from the 21 mortalities observed in 2009 (Table 9). The reductions can be attributable to several factors. 2009 was a very dry year up until mid-September and most of the mortalities occurred before mid-September when water levels were low.
It is hypothesized that because of the shallower than normal water levels, ducks were able to access small unknown hot spots of contamination in the Pond 730 area that would normally have been in deeper water and inaccessible to dabbling ducks (Bigl, S.R. and C.M. Collins. 2010). This year was a more normal year and water levels remained high throughout the fall migration period.
Secondly, a previously unknown white phosphorus-contaminated hot spot was identified in May 2010 in the western end of Pond 730. A temporary 4.5-m by 6-m geotextile cap was placed over the hot spot in June to keep waterfowl from feeding there through the fall. The temporary cap may have prevented additional mortality in this area during the fall migration period. This temporary geotextile cap will be replaced with a permanent gravel cap in March 2011.
No mortalities were found along the Canoe transects in 2010. This may also reflect fewer ducks being poisoned in the nearby Pond 730 area because ducks often feed in the Pond 730 area then move over to the much deeper Pond 40 along the Canoe transect to loaf and rest.
Eleven mortalities (five carcasses and six feather piles) were found along the Ditch transects, an increase from 2009. The reason for the increase is unknown. Small areas of contamination adjacent to capped areas that were identified last year and again this spring may account for the mortalities. In addition, the raised, dry tops of the numerous gravel caps in this area may be convenient feeding locations for raptors resulting in a concentration of feather piles in this area.
Three duck mortalities, all feather piles, were observed in Area A in 2010, a large decrease from the nine mortalities (four carcasses and five feather piles) in 2009. Known contaminated ponds in Area A were pumped and treated over several years from 1998 to 2002. Repeated sediment sampling for white phosphorus in the major ponds since then has been negative (Walsh et al. 2007, 2008). The two locations in Area A where some white phosphorus was detected in the late 1990s were re-sampled this year. Trace amounts of white phosphorus were found.
One partial carcass of a trumpeter swan was found along the Area A transect adjacent to Pond 226 on 14 September 2010. The carcass was partially predated but the gizzard was recovered. The contents were analyzed and tested positive for white phosphorus indicating the swan died of white phosphorus poisoning. This is the first swan carcass found in several years in Eagle River Flats. This carcass is not used in calculations of duck mortalities.
Two duck mortalities were found on the Pond 183 transect, both were remains left by eagles on top
of the tower. No duck mortalities were found on the Duck Ponds, BT, C/D, or Woodland Transects this year.
One swan feather pile was found in the woods south of Woodland transect #4 where it had been carried into the woods and consumed by wolves. There was no evidence as to whether the swan died before being predated or had been caught and killed by the wolves. This swan feather pile was also not used in the calculation of the duck mortality for Eagle River Flats
The estimated range for the 2010 mortality data of 0.35% to 0.79% is below the long-term remedial action goal of less than 1% mortality. Waterfowl mortality due to white phosphorus poisoning has decreased significantly in Eagle River Flats following completion of full-scale
Ground-based surveys were again conducted in 2010 to determine waterfowl mortality. A core group of transects, in areas with known remaining white phosphorus contamination & other areas most frequented by waterfowl, was surveyed at least three times a week over the fall migration period (mid-August to mid-October). These transects covered the marshes of northern Area C & eastern BT Area & the major waterfowl feeding ponds in Area C. Other transects in remediated areas with waterfowl use & in areas with no known contamination were surveyed less frequently. During the mortality surveys conducted from 18 August to 15 October 2010, eight carcasses & fourteen feather piles were found along the surveyed transects. Gizzards were collected from all eight carcasses & all eight tested positive for white phosphorus.
See site file for additional information. |
Louis Howard |
| 11/8/2011 |
Update or Other Action |
2010 ANNUAL SUMMARY REPORT OPERABLE UNIT C – EAGLE RIVER FLATS received by staff.
The major components of the preferred remedy for OU-C are outlined in Section 2.2. All major components of the preferred remedy scheduled to occur from 1999 through 2004 have been instituted with two exceptions. The telemetry monitoring scheduled to occur annually for the first five years (1999-2004), did not occur in 2000 or 2003 as the result of contracting issues and/or reduced helicopter availability. Beginning in 2004, ground-based transect surveys were utilized in lieu of telemetry monitoring to determine waterfowl mortality.
Refinement of the mortality model in 2005 reduced the calculated 1996 mortality rate from 1,000 to 655 ducks. Therefore, to meet the short-term RAO the allowable number of duck deaths attributable to white phosphorus needed to be less than 327 deaths by 2003. As shown in Table 8, duck mortalities since 1999 were below this target number. Based on the mortality data the short-term RAO has been successfully met.
The estimated range for the 2010 mortality data of 0.35% to 0.79% is below the long-term remedial action goal of less than 1% mortality. Waterfowl mortality due to white phosphorus poisoning has decreased significantly in Eagle River Flats following completion of full-scale
active remediation of the white phosphorus-contaminated areas. The apparent increase in 2009 over the previous three years was surprising, but it is believed to be due to unusually dry conditions during the first half of the 2009 fall migration season. Because of the shallower than normal water levels, ducks were able to access small unknown hot spots of contamination in the ponds that would normally have been in deeper water and inaccessible to dabbling ducks. Mortality decreased in 2010 as normal water conditions returned during the fall migration period.
Even with the spike in mortality in 2009, the mortality rate has been below the long-term Remedial Action Objective of 1% mortality of the fall dabbling duck population for the last five years. Further capping of the few additional areas of identified contamination in March 2011 will further help this trend. However, in order to truly determine if the 20-year remedial action goal of less than 1% mortality rate has been met, annual monitoring of mortality should continue for the next two years. Presently, the Long Term Monitoring and Remediation Work Plan (ERDC/CRREL 2009) calls for annual mortality monitoring through 2012, the date of the next Five-Year Review.
Although pond acreage treated is not a specific RAO for this project, it is a good indicator that white phosphorus residual matter is being remediated. The ROD identified 57.6 acres as contaminated or potentially contaminated at Eagle River Flats. Sampling and Analysis since 1999 has indicated that some areas previously thought to be contaminated were not; whereas other area thought to be un-contaminated were not. The current revised estimate of the total contaminated area is 45.0 acres. Currently, 44.77 acres have been remediated, and 0.14 acres are currently undergoing remediation. Table 12 provides data on the contaminated pond acreage at ERF, and lists the pond acreage that has been remediated, that is undergoing remediation, and that remains untreated.
Quality Assurance/Quality Control (QA/QC) procedures were outlined in the QAPP of the RAWP. The overall objective of the QA program was to establish procedures for obtaining data of known and acceptable quality. These procedures have been followed for this project.
The QAPP did not cover analytical QA/QC at offsite laboratories for white phosphorus analysis. The method used was SW-7580. This method was developed by the CRREL as part of the OU-C project. The SW-7580 method includes the generation of a daily calibration (five standards) curve with check standards run every 10 samples. Spike recovery samples are also analyzed.
JBER Environmental maintains a GIS database with information on all of the contaminated sites on base. JBER Environmental is responsible for ensuring ICs are maintained. ICs will remain in place as long as hazardous substances remain on site at levels that preclude unrestricted use.
The major components of the preferred remedy for OU-C are outlined in Section 2.2. All major components of the selected remedy scheduled to occur in 2010 were completed. The remedy remains operational and functional. |
Louis Howard |
| 11/25/2011 |
Update or Other Action |
MEMORANDUM TO THE SITE FILE received & approved by ADEC.
Statement of Purpose- The purpose of this Memorandum to the Site File is to present a non-significant or minor change to the Record of Decision (ROD) for Eagle River Flats (ERF) - Operable Unit C (OUC), now part of Joint Base Elmendorf-Richardson (JBER). This site was originally part of Fort Richardson, AK but, in October 2010, Fort Richardson was joined with Elmendorf Air Force Base to become JBER.
This Memorandum to the Site File was prepared in accordance with the EPA Guide to Preparing Superfund Proposed Plans, Records of Decision, & Other Remedy Selection Decision Documents (July 1999, Section 7.3.1 & Highlight 7-1), & will become part of the administrative record for OUC & JBER.
The original sequence & schedule for monitoring & maintenance activities that were to be conducted at ERF are presented in Tables 7-1 & 7-2 of the OUC ROD. However, the schedule that was published in the ROD was primarily for cost estimation purposes, & the agencies understood that minor modifications would almost invariably be necessary as active remediation progressed.
Remedial action (active pond pumping/draining) began in 1999. The short-term RAO was achieved after one year of the start of remedial action & the long-term RAO was first achieved in 2006, as well as during subsequent years. The consistent downward trend in mortality since year 2000 is a strong indication of the success of the selected remedy, as well as the strength & reliability of the data. The 2011 data set is not yet complete, but 14 waterfowl mortalities were detected & attributed to white phosphorus. Based on preliminary waterfowl population data, the projected mortality rate for 2011 is 0.3%, less than the long-term RAO.
Basis for this Document-During a meeting in January 2008, the Remedial Project Managers (RPM) agreed that in light of the accelerated achievement of the long-term RAO, as well as previously agreed to modifications to the treatment schedule, the remedial action schedule outlined in the ROD needed to be updated. Based on this agreement, a modified schedule was incorporated into the work plan for the 2008 season & later incorporated in Table 1.1 of the 2009 Long Term Monitoring Work Plan for OU C - ERF. The following sections discuss the major components of the selected remedy & compare the ROD schedule to the currently proposed LTM schedule.
Waterfowl telemetry & mortality monitoring-Active pond draining was conducted from 1999 through 2007, necessitating continued mortality monitoring. Additionally, as documented in this memorandum, the RPMs agreed that 7 years of mortality monitoring would be necessary to establish a long-term trend. The currently proposed LTM schedule is to conduct annual mortality monitoring through 2012 & then during years preceding 5-year reviews. Mortality data collection is conducted in the fall & the data is generally not processed until the December time frame. Since the follow-on 5-year review date is in February 2018, it will be necessary to conduct monitoring (as well as Elements M2 & M3) in 2016 to ensure the data is available in 2017 for incorporation into the 5-year review.
Ponds survey, ground truthing, limited aerial survey-The meaning of the term “limited” is therefore unclear. The long-term RAO has been consistently met since 2006 & monitoring is being conducted under Elements M1, M2, & M3. Therefore this element of the remedy is no longer necessary. Because of redundancy in the schedule between this & other elements & because the long-term RAO was achieved starting in 2006 as opposed to the project 2018 date, this element will be removed from the ROD schedule.
Pond pumping treatment: The estimate at the time the ROD was written was that it would take 5 years of dewatering the ERF wetland to remediate WP contamination. Wet conditions (high precipitation & flooding tides) during several years resulted in limited sediment drying, & also previously undetected WP was discovered in the C & C/D areas. These areas were also difficult to drain & sediment drying was slower than anticipated. These factors lead to the decision to extend active pond pumping through the 2007 field season. This decision resulted in subsequent modification to the schedules for almost all other elements of the remedy.
Cap & fill application-pond pumping treatment was extended through 2007 & capping did not take place until that time. The proposed schedule would extend cap & fill operations through 2012 & then only during years prior to the 5-year reviews, as necessary, to address any newly identified WP-contaminated areas that were not successfully remediated. |
Louis Howard |
| 5/17/2012 |
Update or Other Action |
Staff received the updated Final Environmental Atlas for JBER dated April 2012. |
Louis Howard |
| 9/21/2012 |
Update or Other Action |
Draft Basewide UFP-QAPP received. This UFP-QAPP encompasses activities at 141 sites on JBER during the 8 year contract POP. The project approach is to advance sites to site closeout utilizing Optimized Exit Strategies (OES). Activities will include investigations/characterizations, remedial actions, active and passive remediation, long term monitoring/management and the use of the Hydrocarbon Risk Calculator (HRC), where applicable. |
Louis Howard |
| 12/18/2012 |
Document, Report, or Work plan Review - other |
EPA provided comments on the draft 3rd 5 Year Review.
The draft report deviates from the “Comprehensive Five Year Review Guidance”, EPA OSWER No. 9355.7-03 B-P (June 2001) in that for two issues & two OUs the report concludes the answer to the question about whether the issue may affect future protectiveness the answer given is “TBD”. The only options available consistent with the guidance are “yes” or “no”, & when the answer is uncertain, the appropriate response is “Yes” the issue may affect protectiveness, in this case future protectiveness. From that, the appropriate conclusion for each of those OUs in terms of protectiveness is one of the following:
1. “protectiveness deferred”, with recommendations & followup actions to be taken to resolve the uncertainty (which the Guidance calls for the lead agency to do within 1 year);
2. “currently protects, & in order to remain protective for the long term the following factions need to be taken:...” ; or
3. “Not protective” & say what will be done about the issue.
If protectiveness if deferred, the Guidance calls for issues to be resolved in 1 year if at all possible.
Tables 2-3 & 2-4 do not appear to present a complete chronology of events for OUC & OUE respectively. For example, Tables 2-3 & 2-4 do not include the site visits/inspections conducted for the FYR Report in June 2012. In addition, neither table includes the construction complete date (September 2006 according to the Summary Form on page ES-3). Groundwater monitoring is initiated in 2004, however annual monitoring appears chronologically in 2008. Please explain the gap in sampling. Please revise Tables 2-3 & 2-4 to provide a complete chronology of the significant events for OUC & OUE respectively.
According to lines 3 through 5 on page 4-26, “it is expected that white phosphorus monitoring within the ERF [Eagle River Flats] area will be discontinued upon completion of the 2012 field season;” however, the objectives that have to be met during the 2012 field season in order for phosphorus monitoring to be discontinued are not provided. It is understood that a Memorandum to Site File dated 23 November 2011 was issued & may contain this information, but a summary of the criteria that will trigger the discontinuation of phosphorus monitoring should be included in the FYR Report. Please revise page 4-26 to include a summary of the objectives that have to be met during the 2012 field season in order to trigger the discontinuation of phosphorus monitoring at OUC.
h) Monitoring for waterfowl use of ERF. The text on page 4-28 states that “U.S. Fish & Wildlife Service personnel conduct periodic aerial surveys throughout the field season,” but does not define the frequency of these surveys (i.e., monthly, quarterly, etc.). Please revise the text on page 4-28 to specify the frequency of the aerial surveys conducted by the U.S. Fish & Wildlife Service.
Sample Pond Bottoms for WP Component 3. No information is provided on sample methods, frequency & general concentrations found pre-treatment. Please provide a description of pre-season sampling for white phosphorus & concentrations detected in ponds requiring remediation.
Please describe the physical characteristics (frequent tidal flooding, upland riparian, etc. ) of the new contaminated area near the mouth of Eagle River. Provide additional information on the methods used for soil sampling (using discrete or ICMS methods), depth of the subsurface sample, & the method used for sample analysis (discrete, stirred, sieved particles, etc…). Please explain monitoring & remediation plans for this new source area as appropriate.
Not all ponds show a progression of ‘contaminated’ to’ tested & confirmed to be remediated’. Figure 4-5 contains a number of ponds (#75, #730, unnamed shapes) with no color shading (& therefore no status), however many of these areas are shaded as remediated or capped by Figure 4-8. Please resolve this discrepancy.
Please add the location(s) where projectiles were detonated near the river mouth in 2010 & code as contaminated as appropriate on Figure 4-8.
Table 4-5 does not display waterfowl mortality rates for 2000 & 2003. Please revise Table 4-5 to include a footnote to explain why no waterfowl mortality rates have been included for these years.
Pages 4-41 & 4-42 briefly discuss the placement of cap-&-fill material at ERF; however, there is no figure displaying the location of capped areas, especially regarding capped ditches. Please revise the FYR Report to include a figure showing the location of capped areas at OUC or add reference of capped areas, including ditches capped in 2012. |
Louis Howard |
| 2/19/2013 |
CERCLA ROD Periodic Review |
The Alaska Department of Environmental Conservation (ADEC) has received the 3rd five year review report for review on February 12,2013. ADEC appreciates the opportunity to review the third Five Year Review report for the Fort Richardson (now JBER-R) Superfund site, in Anchorage Alaska. ADEC reviewed this report for technical adequacy, accuracy, and consistency with EPA guidance and the Fort Richardson Federal Facility Agreement. Also included are additional recommendations and follow-up actions necessary to address issues raised in the Five Year Review that affect or could affect protectiveness. In general, ADEC agrees with the protectiveness determinations in this report.
OUB Poleline Road
ADEC concurs that the remedy for OUB Poleline Road Disposal Area is currently protective
through implementation of Land-Use Controls (LUCs) However, to be protective in the long-term,
JBER must conduct additional monitoring to augment the monitoring well network in the shallow
aquifer to defme the downgradient limit of the plume. Additionally, the remedial action objectives for OUB COCs need to be updated based on changes in the toxicity factors (e.g. 1,1,2,2- tetrachloroethane for groundwater and soil and tetrachloroethylene for soil). The 1997 Record of Decision RAOs were based on 10-4 risk-based concentrations and a residential exposure scenario.
OUC Eagle River Flats
ADEC concurs that the remedy for OUC Eagle River Flats is currently protective of human health
and the environment based on current use as an active military range. The long term RAO at Eagle
River Flats has been met under current site use: ".Within 20 years of the ROD being signed to
reduce the mortality attributable to white phosphorus to no more than 1 percent of the total annual fall population of dabbling ducks in the ERF". Resumption of year-round flring at Eagle River Flats may change site conditions and waterfowl mortality in such a way that mayor may not affect
protectiveness of the remedy in the future.
OUE Armored Vehicle Maintenance Area (AVMA)
ADEC concurs with the deferred protectiveness determination for OUE AVMA pending an
assessment in 2014 of the vapor intrusion pathway at buildings above the A VMA plume, An
addendum to the Five-Year Review report should be prepared which incorporated the results of the
assessment and any change on protectiveness for OUE.
ADEC appreciates the Air Force's efforts in completing the Third Five Year Review and your
project team on addressing ADEC's comments to fInalize the document. ADEC, EPA and JBER
project managers have an excellent working relationship and ADEC looks forward to continuing
this spirit of cooperation into the future. |
Louis Howard |
| 5/31/2013 |
Update or Other Action |
Draft Environmental Restoration Program Remedial Action Summary for 2012-2013 received for review & comment.
Cap integrity monitoring/repair ongoing. Next occurrence 2016 (verification)-2017 (repairs, if needed). The areas of the expanded caps & augmented temporary caps will be measured during the next field effort, in 2016.
The OUC ROD for XU022 included two RAOs based on reducing the mortality rate of dabbling ducks attributable to WP. The RAOs included a short-term objective to reduce the mortality rate to less than 50 percent of the 1996 mortalities, estimated at 1,000 individuals, within 5 years (by 2003); & a long-term objective to reduce the mortality rate to less than 1 percent of the migrating population within 20 years (by 2018).
The mortality rate of dabbling ducks at XU022 indicates that both RAOs have been achieved. Refinement of the mortality model in 2005 reduced the calculated 1996 mortality rate from 1,000 to 655 ducks (Bigl & Collins, 2007). Therefore, to meet the short-term RAO, the allowable number of duck deaths attributable to WP needed to be less than 327 by 2003. Duck mortality rates since 1999 have been less than this target number. Based on the mortality data, the short-term RAO has been successfully met.
The calculated mortality rate has been below 1 percent since 2006, & the upper bound of the conservative estimated range also was below 1 percent in 2008, 2010, & 2011. Overall, waterfowl mortality resulting from WP poisoning has decreased significantly in ERF since remedial activities have begun. This decreasing trend is expected to continue following the capping operations performed in February 2013.
Mortality monitoring will next be conducted in 2016
Although treated pond acreage is not a specific RAO for this project, it is a good indicator that WP residual matter is being remediated. The ROD identified 57 acres as contaminated or potentially contaminated at ERF; Figure 5-1 shows the status of ponds at XU022 at the time of the ROD. Monitoring activities performed since 1999 have indicated that some areas previously thought to be contaminated were not, whereas other areas thought to be un-contaminated were not.
The current revised estimate of the total area that had been contaminated by WP (before treatment) is approximately 47 acres. Pumping & draining remediation activities have successfully treated most of the contaminated area. Smaller hot spots with WP concentrations above the target of 1 µg/g in areas that could not be drained or pumped consisted of less than 0.5 acre; these areas were remediated through capping. Figure 5-2 shows the status of ponds at XU022 as of 2012.
Since the follow-on 5-year review date is in February 2018, it will be necessary to conduct monitoring (as well as Elements M2 & M3) in 2016 to ensure the data is available in 2017 for incorporation into the 5-year review.
Element M2 (Aerial waterfowl surveys): Since this element is essential to determining waterfowl mortality, the rationale for the change in schedule for this element is the same as discussed for element M1.
Element M3 (White phosphorus monitoring of treated ponds): The schedule for this element corresponds to the schedule for element M1 & therefore the rationale for the change in schedule for this element is the same as discussed for element M1.
JBER Environmental maintains a GIS database with information on all of the contaminated sites onbase. XU022 restrictions include preventing site access to personnel without appropriate site specific training (on UXO, range procedures, & WP.) Site access is controlled by a locked gate.
JBER Environmental is responsible for ensuring that ICs are maintained. Evidence of trespassing by unauthorized individuals was not detected in 2012. In addition, firing is restricted to winter months, when ice protects caps & potential buried munitions from being exposed by the impact of munitions. ICs will remain in place as long as hazardous substances remain onsite at levels that preclude unrestricted use. |
Louis Howard |
| 5/31/2013 |
Document, Report, or Work plan Review - other |
OUC Draft Remedial Action Summary Report received.
The RAOs included a short-term objective to reduce the mortality rate to less than 50 percent of the 1996 mortalities, estimated at 1,000 individuals, within 5 years (by 2003); and a long-term objective to reduce the mortality rate to less than 1 percent of the migrating population within 20 years (by 2018).
The mortality rate of dabbling ducks at XU022 indicates that both RAOs have been achieved. Refinement of the mortality model in 2005 reduced the calculated 1996 mortality rate from 1,000 to 655 ducks (Bigl and Collins, 2007). Therefore, to meet the short-term RAO, the allowable number of duck deaths attributable to WP needed to be less than 327 by 2003. Duck mortality rates since 1999 have been less than this target number. Based on the mortality data, the short-term RAO has been successfully met.
The calculated mortality rate has been below 1 percent since 2006, and the upper bound of the
conservative estimated range also was below 1 percent in 2008, 2010, and 2011. Overall,
waterfowl mortality resulting from WP poisoning has decreased significantly in ERF since
remedial activities have begun. This decreasing trend is expected to continue following the
capping operations performed in February 2013.
Mortality monitoring will next be conducted in 2016.
Although treated pond acreage is not a specific RAO for this project, it is a good indicator that WP residual matter is being remediated. The ROD identified 57 acres as contaminated or
potentially contaminated at ERF. Monitoring activities performed since 1999 have indicated that some areas previously thought to be contaminated were not, whereas other areas thought to be un-contaminated were not.
The current revised estimate of the total area that had been contaminated by WP (before treatment) is approximately 47 acres. Pumping and draining remediation activities have successfully treated most of the contaminated area. Smaller hot spots with WP concentrations above the target of 1 µg/g in areas that could not be drained or pumped consisted of less than 0.5 acre; these areas were remediated through capping. Figure 5-2 shows the status of ponds at XU022 as of 2012.
JBER Environmental maintains a GIS database with information on all of the contaminated sites
on base. XU022 restrictions include preventing site access to personnel without appropriate site
specific training (on UXO, range procedures, and WP.) Site access is controlled by a locked gate.
JBER Environmental is responsible for ensuring that ICs are maintained. Evidence of trespassing
by unauthorized individuals was not detected in 2012. In addition, firing is restricted to winter months, when ice protects caps and potential buried munitions from being exposed by the impact of munitions. ICs will remain in place as long as hazardous substances remain onsite at levels that preclude unrestricted use. |
Louis Howard |
| 6/14/2013 |
Document, Report, or Work plan Review - other |
The Alaska Department of Environmental Conservation has received the Draft Environmental Restoration Program 2012-2013 Remedial Action Summary, on May 31, 2013 for review and comment for Operable Unit C Eagle River Flats. ADEC has reviewed the document and has no major comments on the document. ADEC concurs with the statements regarding the necessity of conduct water fowl monitoring, aerial waterfowl surveys, and white phosphorus monitoring of treated ponds, in 2016 to ensure that the data is available in 2017.
This decision assumes that any resumption of firing year-around at the flats does not cause an increase in waterfowl mortality above levels specified in the Record of Decision. Pending incorporation of any EPA comments, the document may be finalized.
|
Louis Howard |
| 11/4/2013 |
Update or Other Action |
MEMORANDUM FOR RECORD 04 November 2013
SUBJECT: Standing Operating Procedure for Measuring Ice Thickness at Eagle River Flats (ERF) Impact Area to Determine Adequacy for Firing Point-Detonated Mortars and Artillery
1. PURPOSE: The purpose of this directive is to establish standard procedures for measuring ice thickness within the ERF area. Ice thickness data will be used to determine whether adequate conditions exist to proceed with firing explosive munitions in the ERF in accordance with existing policy and restrictions.
2. OBJECTIVE: Ensure that consistent and representative ice thickness measurements are obtained to determine adequacy of ice cover prior to firing explosive munitions in the ERF.
3. PROCEDURE FOR OBTAINING ACCESS TO RANGE AND IMPACT AREAS:
a. ERF is an active impact area (dud-contaminated) where there is a high probability for encountering unexploded ordnance (UXO). All personnel entering the ERF area are required to be thoroughly briefed on the hazards ofUXO in accordance with U.S. Army, Alaska (USARAK) Regulation 350-2. Personnel entering the impact area are required to understand and abide by conditions listed in USARAK Regulation 350-2.
b. For safety reasons, at least 2 personnel must be present during ice thickness assessment activities. Personnel entering the permanent impact area will be accompanied by a member of the USARAK Explosive Ordinance Disposal (EOD) unit, Range Control or by other similarly qualified personnel in accordance with USARAK Regulation 350-2. Cold weather and dangers associated with accessing areas with unknown ice cover present potential hazards to personnel.
c. Testing will be directed and conducted by the Facility Manager, Richardson Range Control. The Facility Manager will conduct ice thickness testing in advance of the first training event of the winter season.
d. The access roads and survey areas must be surface-cleared of UXO and/or other safety hazards prior to entry. This surface-clearing must be conducted before substantial snow cover is present. All UXO survey work must be performed by qualified personnel in accordance with USARAK Regulation 350-2.
4. LOCATION OF ICE THICKNESS SURVEY SITES:
a. Multiple locations have historically been used to assess ice thickness within the ERF impact area. The area selected provides a stable site that has the safest access point for the measuring of ice thickness. See Figure 1
b. Global Positioning System (GPS) coordinates for the location is 06N UP5518 0147.
5. PROCEDURE FOR MEASURING ICE THICKNESS:
a. Location where ice thickness is to be measured must be surface-cleared to ensure that the site is clear of UXO and/or other safety hazards. All UXO survey operations must be conducted by qualified personnel in accordance with USARAK Regulation 350-2.
b. The basic procedure is to cut a hole in the ice at the location indicated in Section 3. A hand axe, chain saw or ice auger is used to make a hole in the ice large enough to insert the measuring device.
Signed Michael Bryers DAC, RTA Range Manager
See site file for additional information. |
Louis Howard |
| 7/23/2015 |
Update or Other Action |
Draft Field Activities Report received for review & comment.
No deficiencies were observed during the LUC inspection at EOD Area (XE023) in 2014. Monitoring wells are present, but long-term monitoring & LUCs for groundwater are not part of the selected remedy. Wells will be inspected in 2016 to coincide with planned LTM work at XU022 after the site has been cleared for UXOs. LUC inspections will continue to be conducted annually in accordance with the OUC ROD.
Five-Year Review
XE023 is required to have CERCLA five-year reviews conducted until such time as the cleanup goals are achieved. The purpose of the five-year review is to evaluate the implementation & performance of the remedial actions. To date, three CERCLA five-year reviews have been performed for JBER-Richardson (which includes XE023), in 2003, 2008, & 2013. No recommendations specific to XE023 were made in the Third CERCLA Five-Year Review Report for JBER-Richardson, Alaska.
NOTE To File: Future Five-Year Reviews for OUs B, C, and E are necessary because COC concentrations remain above levels that allow for unlimited use of the site and unrestricted exposure to the air, soil, and water. The next JBER-R Five-Year Review will be in April 2018.
Recommendations
Site XE023 is identified as a Green priority. No Further Action & continuation of LUC inspections are recommended for this site. No deficiencies were observed during the LUC inspection in 2014 at the Eagle River Impact Area (XU022). LUC inspections will continue to be conducted annually in accordance with the OUC ROD.
Five-Year Review
XU022 is required to have CERCLA five-year reviews conducted until such time as the cleanup goals are achieved. To date, three CERCLA five-year reviews have been performed for JBER-Richardson (which includes XU022), in 2003, 2008, & 2013. The Third CERCLA Five-Year Review Report for JBER-Richardson, Alaska for recommended that the USAF readdress waterfowl populations upon completion of seasonal field activities & compare population numbers with previous surveys to evaluate for any potential bias. A total of 21 aerial census surveys were conducted from August 16 to October 29, 2012, to determine the fall 2012 waterfowl population. In comparison, 24 aerial surveys were conducted in 2011, & 28 census surveys were conducted in 2010 during similar time periods. Observed waterfowl species were similar in types & relative numbers as in previous years. Similar analyses will be performed based on the forthcoming 2016-2017 monitoring efforts.
Recommendations
Site XU022 is identified as a Green priority. Long-term monitoring & continuation of LUC inspections are recommended for this site. |
Louis Howard |
| 8/10/2015 |
Document, Report, or Work plan Review - other |
Staff provided comments on the Annual CERCLA Report. Main comment was concurring with the recommendation to readdress waterfowl populations and compare numbers with previous surveys to evaluate for any potential bias. |
Louis Howard |
| 10/26/2015 |
Update or Other Action |
Dept. of Air Force memo to EPA. SUBJECT: AFCEC Response to EPA memo dated 27 May 27 concerning live-fire exercise at Eagle River Flats Impact Area.
1. The attached memorandum provides information requested by EPA and ADEC in a letter dated 27
May 2015 regarding a training exercise that occurred at Eagle River Flats (ERF) in April 2015. In
question is the protectiveness of the remedy in the OUC ROD as a result of the live-fire exercise that occurred outside of the 1 Nov - 31 Mar operational range restriction. The supporting information confirms that proper procedures are in place and were followed and adequate ice thickness was present to be considered protective of both migratory birds and the gravel caps. Based on the information provided, AFCEC does not intend to accelerate the approved long-term management schedule at XU022 under CERCLA at this time.
2. A final decision to resume year-round firing at ERF has not yet been made and until such time it is recommended that no modifications to the OUC ROD be made. In the meantime, if LTM
activities determine that the RAOs are no longer met and the remedy is not protective, then further actions will be considered at that time.
3. AFCEC requests a formal response from the EPA as to whether the agency interprets the live-fire
exercise window of 1 Nov - 31 Mar as a LUC under the CERCLA OUC ROD. Additionally, under what conditions would the agency allow for firing outside of the operational range restriction referenced above?
Signed Gary Fink Chief, JBER Environmental Restoration. |
Louis Howard |
| 1/7/2016 |
Update or Other Action |
Memo received from Air Force. The purpose of this memorandum is to summarize information requested by the United States Environmental Protection Agency (EPA) and Alaska Department of Environmental Conservation (ADEC) in a letter dated May 27, 2015, regarding resumption of live-fire training exercises at XU022 – Eagle River Flats (ERF), Operable Unit (OU) C, Joint Base Elmendorf-Richardson [JBER]-Richardson [JBER-R]). Live-fire training exercises were performed
April 1-3 and 13-14, 2015, to provide mandatory unit certification.
Prior to each firing event, the Unit Officer-in-Charge and Forward Observers verified that the
down range area was absent of wildlife. The absence of migratory birds was further supported
through JBER Bird/Wildlife Aircraft Strike Hazard (BASH) reports for areas around the flightline and cantonment area and was confirmed by the United States Department of Agriculture as follows:
“We have a few new birds but you're right the migration hasn't started yet. Some geese have been seen in Fairbanks but thus far we haven't seen any. We have been watching out for the eagles to build a new nest but we haven't seen any activity yet. No snow or standing water this year so the birds might just bypass us on the way to the nesting grounds.” (Morrill, 2015)
Between 0 and 25 mallards (a species that includes some year-round resident birds) were
observed during each of the weeks ending March 28, April 4, and April 11, 2015 (see Attachment 5). In addition, the lack of open water, as evidenced by the measured 12 inches (or greater) of ice during the time of the events, would also make the area an unlikely stopping point for migratory waterfowl.
Considering that ice thickness was measured at 12 to 24 inches on ERF, compared with the 5 inches considered protective for the type of munitions fired and the 6 inches noted in the ROD, and that minimal waterfowl were observed at JBER, site conditions during the live-fire training exercises from April 1-3 and 13-14, 2015, were considered protective of both migratory waterfowl and the gravel caps. In addition, the closest target point was more than 250 meters southeast of the nearest cap, and firing was not observed outside of the impact zones/targets.
At this time, USAF does not intend to further accelerate long-term management activities for XU022 under CERCLA (i.e., sediment sampling, waterfowl mortality survey, and cap repairs), and considers any additional activities to monitor for potential impact craters from live-fire training exercises unnecessary. If long-term management activities completed in 2015 determine
that the mortality rate has increased and the long-term RAO is no longer met, or that there has
been a significant rebound in WP concentrations in areas previously remediated or capped, then
further actions will be considered at that time. |
Louis Howard |
| 1/7/2016 |
Update or Other Action |
Dept. of Air Force AFCEC sent memo re: Revision of Attachment to AFCEC Response to EPA memo dated 27 May 2016 concerning live-fire exercise at Eagle River Flats Impact Area (26 Oct 2015).
1. The attachment to the AFCEC Response to EPA memo dated 27 May 2015 concerning live-fire
exercise at Eagle River Flats Impact Area (dated 26 Oct 2015) has been revised to include additional and updated information. The specific revisions are:
a. Changed date of attachment from September 2015 to January 2016
b. Added information to Section 4.1 concerning Eagle River Flats 120mm mortar firing data from winter 2005
c. Changed Section 4.1 to reference 2013 Standard Operating Procedure (SOP) for measuring ice thickness instead of 2007 SOP
d. Updated Section 7.0 to include new reference concerning 120mm mortar firing data from winter 2005and replacement ofreference to 2007 SOP with reference to 2013 SOP
e. Added copy of new reference concerning l 20mm mortar firing data from winter 2005 to Attachment 2
f. Replaced 2007 SOP for measuring ice thickness with the 2013 version in Attachment 4.
Signed Cynthia Tomlinson RPM. |
Louis Howard |
| 4/13/2016 |
Update or Other Action |
Draft Remedial Action Work Plan received for review and comment.
The objective of ongoing LTM for XU022 is to evaluate the continued effectiveness of the remedy
in accordance with the OUC ROD and Memo to Site File. Activities associated with LTM of XU022 that are planned for 2016 include the following:
• Waterfowl Telemetry and Mortality Study (transect monitoring) (Element M1). Waterfowl mortality transects will be traversed on foot and canoe to locate waterfowl carcasses (duck and swan), record locations of mortalities, and record other visual observations. Duck carcasses that are not too decayed to handle will be collected for analysis of gizzard contents to determine whether the cause of death was acute WP toxicity. Transect monitoring will be conducted in waterfowl feeding areas during the fall migration period, from approximately mid-August to mid-October.
• Aerial Waterfowl Surveys (Element M2). Concurrent with the waterfowl telemetry and mortality study, aerial waterfowl surveys will be conducted to provide population data for comparison. Population data and mortalities will be used to calculate the annual mortality rate for waterfowl (dabbling ducks).
• White Phosphorus Monitoring of Treated Ponds (sediment sample collection) (Element M3). Sediment samples will be collected from historically established locations in previously remediated ponds to evaluate current WP concentrations.
• Cap and Fill Integrity Inspection (sediment samples around cap perimeters and visual assessment of caps) (Element T3). Sediment samples will be collected from cap perimeters to evaluate whether areas remain effectively capped. Visual observations of capped areas will also be conducted during monitoring and sampling to assess condition of the caps. Any damage will be photographed and described in the field notes.
• Geographic Information System (GIS) Database Management (Element M5). Waterfowl mortality and sediment sample data will be incorporated into the GIS database.
Cap and fill integrity inspections and GIS database management are scheduled for 2017 in the
Memo to Site File. Accelerating these activities is proposed to more comprehensively evaluate the
integrity of the remedy and to allow for capping, if necessary, in 2017.
Field activities that are planned for 2017, if necessary, include the following:
• Cap and Fill Application (Element T2). Cap and fill operations will be conducted to address
any newly identified WP-contaminated areas that were not successfully remediated or capped.
• GIS Database Management (Element M5). Data for any additional or expanded cap
locations will be incorporated into the GIS database.
See site file for additional information. |
Louis Howard |
| 4/19/2016 |
Document, Report, or Work plan Review - other |
Staff reviewed and commented on the RA work plan and had one comment regarding the identification of staff that are either qualified environmental professionals and staff that are qualified samplers. Staff listed in the resume section had either no degree but were working towards a degree with work experience and staff that had degrees and work experience. Staff without a degree can only be considered qualified samplers and not qualified environmental professionals regardless of how many years of experience they had. |
Louis Howard |
| 1/13/2017 |
Update or Other Action |
ADEC received a GW monitoring report for several JBER sites which summarizes the 2015 annual long-term management (LTM) activities, including remedial action-operation (RA-O) & ROD requirements conducted at JBER CERCLA sites.
Site XU022 is identified as a Green priority. Long-term monitoring and continuation of LUC
inspections are recommended for this site.
See site file for additional information. |
Louis Howard |
| 6/7/2017 |
Document, Report, or Work plan Review - other |
Staff received and reviewed the Draft Remedial Action Long-Term Management Report at Operable Unit C Eagle River Flats, XU022, JBER Alaska dated June 2017. The document is well written and is approved for finalization without modifications. |
Louis Howard |
| 1/23/2018 |
Document, Report, or Work plan Review - other |
Draft Fourth Five-Year Review report received for review and comment.
Main comments were requesting a notice of environmental contamination be placed with Alaska Dept. of Natural Resources land records prior to the next Five-Year Review. Other comments were to note the short and long-term remedial objectives have been met, but change in site use from winter only firing to year-round firing may alter site conditions and cause waterfowl mortality to change from white phosphorus exposure previously not available before firing year-round.
See site file for additional information. |
Louis Howard |
| 1/29/2018 |
Document, Report, or Work plan Review - other |
EPA comments on the draft Five Year Review (FYR). Protectiveness statement: Suggested revision:
The remedy at Site OUC-XU022 is protective of human health and the environment. There are no immediate threats from OUC-XU022, and the remedy is being implemented in accordance with the ROD. LUCs and ICs are implemented and effective, and no exposures are occurring from contaminated materials remaining at the site. All short- and long-term RAOs have been achieved.
Site Numbers instead of Operable Units. The Air Force trend to complete RODs based on site identifiers and not operable units is problematic for the EPA Superfund tracking system SEMS (Superfund Enterprise Management System). For example, SS090 is listed in SEMS as Fort Richardson OU 11; SS047 Nike Site Summit is listed as OU 6. OU B is OU2; OU C is OU 3, and OU E is OU5 in the EPA SEMS system.
There is a recommendation for NFA at OUC XU-022. Clarify if ICs will continue to be required at the site. If so, the site cannot be designated as ‘No Further Action’.
Potential changes to the timing of the training and firing regime to year round, as suggested by previous conversations with the Air Force but not discussed in this 5YR, would likely require continued monitoring for waterfowl mortality and possible additional remediation of contaminated sediments and invalidate a NFA status
Component 8: Clean Water Act Section 404 requires mitigation for the loss of habitat caused by the remedial action. Was there ever an estimate on the acreage of wetland habitat lost due to drainage? Were any mitigation projects required? What is the status? Not necessarily a protectiveness issue, but it should be reported as part of the status of the RA.
EPA believes a OUC-XU022 NFA closure document is pre-mature due proposed changes to the firing regime. Changes to the timing of training operations (Record of Environmental Consideration, Modification of Firing Regime for ERF, October 2001) and a pending draft EIS to conduct training exercises year round at ERF may impact the protectiveness of the remedy.
Component 12: With the recent retirements of Drs. Marianne and Mike Walsh, PIs on the ERF project for CREEL, who has the data?
Component 13 mentions alerting boaters. Are there ever reports of boaters missing the take out at Bravo Bridge? If so, does Range Control or JBER police respond? Are these types of 'trespass events' reported to IRP? Have any occurred?
See site file for additional information. |
Louis Howard |
| 2/15/2018 |
Document, Report, or Work plan Review - other |
Staff commented on the Annual Report for CERCLA sites. Main comments were to concur with the recommendations in this section, as long as site conditions remain as they are currently at XU022. If year-around firing resumes at the ERF impact area, then ADEC will view this as a change in site condition from the current Winter only firing regime currently in place. This future change in frequency of firing (pending successful finalization of the NEPA process ), may or may not cause an impact to the long term 20 year ROD goal of mortality attributable to WP to no more than 1 percent of the total annual fall population of dabbling ERF ducks.
See site file for additional information. |
Louis Howard |
| 2/23/2018 |
CERCLA ROD Periodic Review |
Staff reviewed and concurred with the protectiveness statements, in general, for the Fourth Five-Year Review report at JBER-Richardson. Main comments were: Resumption of year-round firing at Eagle River Flats may change site conditions and waterfowl mortality in such a way that may or may not affect protectiveness of the remedy in the future. Based on current site conditions and usage, there are no immediate threats from OUC-ERF and the remedy is being implemented in accordance with the 1998 ROD. LUCs and ICs are implemented and effective, and no exposures are occurring from contaminated materials remaining at the site, at this time.
See site file for additional information. |
Louis Howard |
| 4/11/2018 |
Update or Other Action |
USDOI Fish & Wildlife Service Memo from Principal Deputy Director to Service Directorate: April 11, 2018 Guidance on the recent M-Opinion affecting the Migratory Bird Treaty Act. To ensure consistency with the recently issued M Opinion, the U.S. Fish and Wildlife Service (FWS) is modifying some policies and practices within its programs. This memorandum provides guidance to clarify what constitutes prohibited take, what actions must be taken when conducting lawful intentional take (e.g., obtain a permit via 50 C.F.R. Part 21), and what changes to prior practice should be made in light of the M-Opinion.
The M-Opinion concludes that the take of birds resulting from an activity is not prohibited by the MBTA when the underlying purpose of that activity is not to take birds. We interpret the M-Opinion to mean that the MBT A's prohibitions on take apply when the purpose of an action is to
take migratory birds, their eggs, or their nests. Conversely, the take of birds, eggs or nests
occurring as the result of an activity, the purpose of which is not to take birds, eggs or nests, is not prohibited by the MBTA.
See site file for additional information. |
Louis Howard |
| 8/9/2018 |
Update or Other Action |
DoD Migratory Bird Treaty Act – Incidental Take Provision Info memorandum: After coordinating with OSD Counsel, the DoD NR Program confirmed that the M-Opinion is not litigable and that the USFWS Guidance has no legal weight. Therefore, the February 2018 memo and the August 2017 Guidance remain in effect. This means that, “to the extent practicable and without diminishing the effectiveness of military readiness activities,” installations should minimize the incidental take of migratory birds. This does not mean that no incidental take can occur.
See site file for additional information. |
Louis Howard |
| 8/22/2018 |
Update or Other Action |
Annual RA-O and Monitoring Report (May 2018 for 2016 activities) CERCLA Sites: Based on the early achievement of the long-term RAO, the frequency of LTM activities has been reduced to a frequency of once every five years (prior to Five-Year Reviews). In addition, the implementation of some of the specific monitoring and remedial action components of the remedy have been updated. Upcoming remedial action management events are scheduled to precede five-year reviews for the site in order for the results to be incorporated in the reviews. The changes to the ROD schedule and implementation of remedy components have been documented in Memos to the Site file (USAF, 2011e; USAF, 2017e). The next LTM event for XU022 is scheduled for the fall of 2021. Site XU022 is identified as a Green priority. LTM and continuation of LUC inspections are recommended for this site.
See site file for additional information. |
Louis Howard |
| 8/2/2019 |
Update or Other Action |
Draft 2018 Annual RA-O & Monitoring Report CERCLA Sites (August 2019). Remedy components and changes to the schedule over time are documented in the ROD (US Army, 1998) and two Memos to the Site file (USAF, 2011e; USAF, 2017e). Upcoming remedial action management events are scheduled to precede five-year reviews for the site in order for the results to be incorporated in the reviews. Site XU022 is identified as a Green priority. LTM and continuation of LUC inspections are recommended for this site. As a result of the November 30, 2018 magnitude 7.1 earthquake (UAF AEIC, 2018), the 2019 LUC inspection should include an evaluation of the site for any obvious signs of subsidence or other obvious changes to the wetland or associated waterways.
See site file for additional information. |
Louis Howard |
| 8/21/2019 |
Document, Report, or Work plan Review - other |
Staff reviewed the annual report for select CERCLA sites. Main comments were on agreeing with the recommendations made in this section. Live firing outside of the winter time frame may require additional mortality monitoring via transects for waterfowl potentially exposed to white phosphorus-contaminated sediments and other efforts (waterfowl surveys, gravel cap maintenance) due to resumption of firing outside the winter months.
See site file for additional information. |
Louis Howard |
| 3/25/2020 |
Update or Other Action |
XU022 ERF Remedial Action Completion Report (RACR) received for review. The RACR document the completion of the remedial action at Department of Defense (DoD) Environmental Restoration Program(ERP) Operable Unit C (OUC) Site XU022 – Eagle River Flats (ERF). The RACR documents that all site remedial action objectives (RAOs) have been achieved and that the site is considered suitable for a site closeout (SC) under the DoD ERP and cleanup complete (CC) designation under Alaska Department of Environmental Conservation (ADEC) rules. The United States Air Force (USAF) is managing remediation of contamination at XU022 in accordance with the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) cleanup process, with oversight by both ADEC and Environmental Protection Agency (EPA).
The USAF determined that Site XU022 at JBER, Alaska has achieved all RAOs as specified in
the CERCLA ROD for ERF Site XU022 and is eligible for Site Closeout as specified in the
Department of Defense (DoD), Defense Environmental Restoration Program (DERP) Management Manual 4715.20, dated March 9, 2012. The DoD has completed active management and monitoring at the environmental restoration site, and no additional environmental restoration funds will be expended at the site. The ROD goals have been achieved. However, because the Eagle River Flats is an active military firing range where munitions may exist or come to exist because of military range controls, the site is not eligible for unlimited use or unrestricted exposure. A CERCLA response action may become necessary in the future should the DoD decide to close the range and make the range something other than operational.
See Site File for additional information. |
Louis Howard |
| 3/25/2020 |
Update or Other Action |
XU022 – Eagle River Flats Remedial Action Completion Report draft received for review. The USAF determined that Site XU022 at JBER, Alaska has achieved all RAOs as specified in the CERCLA ROD for ERF Site XU022 and is eligible for Site Closeout as specified in the Department of Defense (DoD), Defense Environmental Restoration Program (DERP) Management Manual 4715.20, dated March 9, 2012. The DoD has completed active management and monitoring at the environmental restoration site, and no additional environmental restoration funds will be expended at the site. The ROD goals have been achieved.
However, because the Eagle River Flats is an active military firing range where munitions may exist or come to exist because of military range controls, the site is not eligible for unlimited use or unrestricted exposure. A CERCLA response action may become necessary in the future should the DoD decide to close the range and make the range something other than operational. |
Louis Howard |
| 3/26/2020 |
Update or Other Action |
The U.S. Air Force (USAF) and the U.S. Army, acting as a Cooperating Agency, are issuing this Notice of Intent to prepare an Environmental Impact Statement (EIS) to assess the potential social, economic, and environmental impacts associated with modifying the conditions under which indirect live-fire weapons training can be conducted at Joint Base Elmendorf-Richardson (JBER), in order to meet Army training standards at home station. The EIS will evaluate the potential impacts associated with the proposed action, which includes indirect live-fire training during all-seasons at the Eagle River Flats (ERF) Impact Area on JBER, a military base in Alaska, in order to fully meet Army training standards.
The proposed action also includes expansion of the ERF impact area by approximately 585 acres. In addition, the EIS will evaluate an action alternative that would marginally meet Army training standards, and would not include expansion of the ERF impact area. Comments will be accepted at any time during the EIS process. To ensure the USAF has sufficient time to consider public input in the preparation of the Draft EIS, scoping comments should be submitted to the website or the address listed above by April 26, 2020.
|
Louis Howard |
| 3/31/2020 |
Document, Report, or Work plan Review - other |
Staff provided comments on the remedial action completion report. Main comments were regarding disagreeing with a cleanup complete determination without institutional controls. There are about 36 gravel caps over areas containing white phosphorus in concentration that would be harmful to dabbling ducks. They need to be maintained and inspected on a regular basis, forever and ever. Or until the white phosphorus is completely removed or treated to levels that are not harmful to dabbling ducks. Funding should be allocated for regular inspections and maintenance on the gravel caps at Eagle River Flats Impact Area (operable unit C) on JBER-Richardson.
See site file for additional information. |
Louis Howard |
| 4/12/2021 |
Document, Report, or Work plan Review - other |
DEC submitted comments on Draft JBER Basewide UFP-QAPP dated February 2021. |
William Schmaltz |
| 5/19/2021 |
Document, Report, or Work plan Review - other |
DEC Reviewed and approved of Basewide Uniform Federal Policy - Quality Assurance Project Plan. QAPP summarizes general activities for a 5 year period on JBER. |
William Schmaltz |
| 5/28/2021 |
Document, Report, or Work plan Review - other |
DEC Approved of Final LTM and LUC Inspection Work Plan for select CERCLA sites dated May 2021. |
William Schmaltz |
| 8/9/2021 |
Document, Report, or Work plan Review - other |
DEC staff reviewed and provided comments on Draft 2020 Land Use Control report for Select CERCLA sites dated June 2021. Report summarized LUC inspections performed in December 2020. Most sites were covered in snow and a full inspection could not be performed until spring 2021. DEC requested that the spring 2021 inspections are included in the 2020 report or as a separate cover because they are a continuation of the 2020 inspections and separate of the 2021 inspections. |
William Schmaltz |
| 9/10/2021 |
Document, Report, or Work plan Review - other |
DEC staff reviewed and approved XU-022 Eagle River Flats Remediation Action-Operations and Long-Term Management Work Plan dated August 2021. The work plan presents the approach to conducting
activities associated with ongoing remedial action-operations (RAO) and long-term management
(LTM) of XU022 that are planned for 2021 and 2022. The work plan will be performed under the
Basewide UFP-QAPP for JBER. |
William Schmaltz |
| 4/14/2022 |
Document, Report, or Work plan Review - other |
DEC reviewed and approved Draft 2021 Long-Term Management Report for XU022- Eagle River Flats. The report documented that dabbling duck mortality for white phosphorous was less than 1% in 2021, which has been the trend since 2006. In addition, the report sampled areas on and around the capped ponds for white phosphorous. White phosphorous was detected in only one sediment sample at a concentration of 0.0064 ug/g, which is below the project value of 0.01 ug/g. The LUCs and site restrictions remain in place and appear to be preventing unauthorized use of the area. |
William Schmaltz |
