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Site Report: Kincaid Park Former Biathlon Range

Site Name: Kincaid Park Former Biathlon Range
Address: vicinity of 9401 W. Raspberry Road, In immediate vicinity of Kincaid Outdoor Center at 9401 Raspberry Rd, Anchorage, AK 99502
File Number: 2100.38.500
Hazard ID: 4650
Status: Cleanup Complete
Staff: No Longer Assigned, 9074655229 dec.icunit@alaska.gov
Latitude: 61.152100
Longitude: -150.055222
Horizontal Datum:WGS84

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

Problems/Comments

Lead and lead-contaminated soil associated with the closed former biathlon shooting range target line at Kincaid Park was improperly transported and spread throughout much of a project site when the range was removed during pre-construction earthwork in early 2008. Cleanup of the lead contamination, found to be intermixed with soil within an approximately two-acre new soccer field and stadium project site in the vicinity of the Kincaid Chalet building, took place from May to early-October 2011. Cleanup entailed excavating and screening several thousand yards of potentially contaminated soil and segregating for treatment approximately 1344 cubic yards (CY) of soil that either contained visible lead or had lead concentrations that would be expected to exceed the site cleanup level of 400 mg/kg lead, which in either case would be expected to result in a classification of the soil as a characteristic hazardous waste if tested by the Toxic Characteristic Leaching Procedure (TCLP). Antimony was also a contaminant of concern at the site, but a correlation study satisfactorily demonstrated that the ratio of antimony to lead in ammunition and in the soil was such that the removal of lead-contaminated soil would also remove soil containing antimony concentrations above ADEC cleanup levels. All soil that met the cleanup level for lead was re-used as fill at the site; the 1,344 CY of contaminated soil that did not meet the cleanup level was treated on-site with chemical additives that had the effect of stabilizing the lead so that it no longer exhibited the toxicity characteristics of hazardous waste and was eligible for disposal as non-hazardous waste at the Anchorage Regional Landfill (ARL). Following the addition and mixing with soil of 132 tons of stabilizing chemicals, the post-treatment soil was disposed of at ARL in October 2011. Clean closure of the site by both the EPA and ADEC with no institutional controls was granted in May 2012.

Action Information

Action Date Action Description DEC Staff
3/3/2008 Update or Other Action ADEC staff learned of potential site through contact by Dwayne Adams of Kincaid Project Group requesting guidance for addressing potential lead contamination at Kincaid Park biathlon shooting range in area to be developed as a soccer field and stadium. Eileen Olson
3/24/2008 Update or Other Action Project manager provided guidance information and staff input to KPG representative regarding possible approaches to lead treatment and regulatory issues to be considered at the former biathlon range; KPG informed project manager that information would be forwarded to KPG's consultant, Shannon & Wilson. Eileen Olson
6/16/2008 Update or Other Action Received document dated June 16, 2008 titled 'Soil Treatment Plan, Kincaid Park Biathlon Range, Anchorage, Alaska.' Document included results of soil samples collected on April 20, 2008 from intact range documenting total lead levels as high as 68,300 mg/kg and TCLP results of up to 456 mg/L. Soil having TCLP results for lead of 5 mg/L or more is a characteristic hazardous waste. The document included the estimated volume of lead-contaminated soil to be excavated as 125 cubic yards (~188 tons), noting that if lead shot remains in the soil after excavation, additional soil may need to be removed. Consultant proposed that bulk lead fragments remain in the soil matrix to be treated, in the belief that a pyromorphite shell would form around bulk lead fragments. The document also noted that soil had already been excavated from the range target area. Eileen Olson
6/25/2008 Site Added to Database Site added to the database. Mitzi Read
6/26/2008 Exposure Tracking Model Ranking Initial ranking with ETM completed. Mitzi Read
7/1/2008 Update or Other Action First site visit by staff: Viewed stockpiled soils excavated from former shooting range. Photographs on file. Eileen Olson
7/14/2008 Proposed Plan ADEC received "Soil Stockpile Characterization Work Plan, Former Kincaid Park Biathlon Range, Anchorage Alaska" dated 7/14/2008. The plan provides some information regarding soil stockpiled near the firing range site, noting that on May 9, 2008, "the upper 6 inches of soil (approximately) in the target area was scraped off the surface and stockpiled adjacent to the construction site, but still within the Kincaid Park boundaries. The excavated soil (approximately 45 cubic yards, or ~68 tons) was placed on a liner, and covered with a 6-mil liner." Eileen Olson
7/21/2008 Update or Other Action ADEC approved,with conditions, the "Soil Stockpile Characterization Work Plan, Former Kincaid Park Biathlon Range, Anchorage Alaska" dated 7/14/2008. Eileen Olson
7/22/2008 Site Visit ADEC staff observed stockpile sampling and walked around the project area including the remaining portion of the former biathlon range and the newly constructed soccer field base. Eileen Olson
7/23/2008 Update or Other Action ADEC letter issued with subject line "Management of lead-contaminated soil at MOA Kincaid Park Biathlon Range site". The letter describes a site visit by ADEC staff on July 22, 2008 that included observing stockpile sampling by Shannon & Wilson. Eileen Olson
8/1/2008 Site Visit A.M Site visit by project manager to observe site work at soccer field and stadium area. Earthwork in progress, primarily above partially completed concrete stadium. Photographs on file. Eileen Olson
8/6/2008 Meeting or Teleconference Held ADEC staff Sundet and Olson participated in a teleconference with MOA internal and external counsel, EPA RCRA enforcement staff and legal counsel, Kincaid Project Group representative Dwayne Adams,and environmental consultant Matt Hemry. Three areas of the site requiring action or investigation were discussed. These included the stockpile for which EPA issued an NOV and for which EPA has sole oversight; the south end of the former range, which is the only part of the range that is semi-intact and that has not been excavated, and the soccer stadium and field development area that encompasses approximately three acres, over which lead-contaminated soil has been spread. Eileen Olson
8/18/2008 Proposed Plan Submittal of "Work Plan to Address Lead-Impacted Soil, Former Kincaid Park Biathlon Range" that proposes a combination of off-site transport and disposal and characterization of selected areas of the soccer field and stadium development area, including the relatively intact southern portion of the former biathlon range. Eileen Olson
9/5/2008 Document, Report, or Work plan Review - other ADEC issued a letter dated September 5, 2008 providing review comments on the 'Work Plan to Address Lead-Impacted Soil, Former Kincaid Park Biathlon Range' dated August 18, 2008. ADEC’s letter requested that the MOA and Kincaid Project Group (KPG) submit a revised plan by September 26, 2008. Eileen Olson
9/14/2008 Site Visit P.M. Site visit by project manager and EPA representative Kevin Schanilec to project site; also visited new state-of-the-art range approximately 1/4 mile from project site. Photographs on file. Eileen Olson
9/17/2008 Meeting or Teleconference Held Status meeting between ADEC, MOA, KPG and consultants held to fill in gaps regarding work done at the site, and next steps. Eileen Olson
9/18/2008 Document, Report, or Work plan Review - other Revised plan submitted and approved on this same date for excavating southern end of former range. Soil to be removed and transported as hazardous waste will not be sampled; confirmation samples will be taken following excavation as composites. Eileen Olson
9/24/2008 Site Visit Site visit by project manager during removal of stockpiled soil excavated in May 2008, and excavation of south end of former target line. Photographs on file. Eileen Olson
11/6/2008 Update or Other Action ADEC issued letter re status of lead management issues, and record of communications and approvals. The letter requested submittal of a workplan by December 31, 2008 to meet the requirements set forth in the letter, including a proposed start date for spring 2009 work. Eileen Olson
12/23/2008 Update or Other Action ADEC approved a request to extend the deadline for a work plan submittal from December 31, 2008 until February 13, 2009. Eileen Olson
1/6/2009 Potentially Responsible Party/State Interest Letter Cost recovery notification sent to both the MOA and KPG, copied to MOA outside counsel. Awaiting advice from potential RPs regarding determination of responsibility. Eileen Olson
1/14/2009 Update or Other Action ADEC copied on letter report to EPA dated 1/12/2009 by consultant Shannon & Wilson titled "Stockpiled Soil Removal" that documents hazardous waste transport and disposal associated with the former firing range at Kincaid Park. The report documents the removal in late September 2008 of approximately 20 cubic yards of soil that was excavated and stockpiled in early May 2008, and approximately 32 cubic yards (~48 tons) of soil excavated from the southern third of the former firing range that was loaded directly into transport containers for shipment as hazardous waste. All soil was transported to the Chemical Waste Management of the Northwest (CWMNW) facility in Arlington, Oregon for disposal in a Subtitle C landfill. Eileen Olson
1/15/2009 Update or Other Action ADEC received LDR Forms from consultant for disposal of D008 lead-contaminated soil. Eileen Olson
2/10/2009 Update or Other Action ADEC received from MOA outside counsel this date a copy of an information request letter from EPA to the MOA and KPG dated January 27, 2009. Eileen Olson
4/10/2009 Update or Other Action Report received titled "Target Line Soil Characterization and Disposal, Former Kincaid Park Biathlon Range...March 2009". The report includes a memorandum by KPG dated March 17, 2009 with subject "Earthwork Operations, Stadium Area Kincaid Park". Eileen Olson
4/13/2009 Update or Other Action ADEC received from EPA a copy of the response dated April 10, 2009 to a January 27, 2009 Information Request by EPA to MOA and KPG. EPA generally requested information on range usage, records of earthwork done at the stadium and soccer field site, and disposition of soil from the former range. MOA's outside counsel responded to EPA's information request on behalf of both parties. Eileen Olson
4/16/2009 Update or Other Action Workplan titled "Lead Management Work Plan, Former Kincaid Park Biathlon Range, April 2009" received. Eileen Olson
5/4/2009 Site Visit P.M. Site visit by project manager; noted erosional gullies along sides of soccer field base. South end of former target line is marked with orange construction fencing. Photographs on file. Eileen Olson
5/6/2009 Site Visit P.M. site visit by project manager during rainfall. Noted standing water near south end of former target line, numerous erosional gullies in fill. Photographs on file. Eileen Olson
5/8/2009 Update or Other Action Letter issued to KPG requesting corrective action with respect to erosion and sediment transport offsite observed during May 6, 2009 site visit. Eileen Olson
5/11/2009 Site Visit P.M. Site visit by project manager to meet with earthwork contractor and ADEC stormwater staff regarding overflow of silt fences at base of soccer field fill slope. Photographs on file. Eileen Olson
5/12/2009 Proposed Plan ADEC received "Work Plan to Address Soil and Sediment Control Issues, Former Kincaid Biathlon Range Site..." dated May 12, 2009. The plan responds to ADEC's letter dated May 8, 2009 requesting corrective action with respect to erosion. Eileen Olson
5/14/2009 Site Visit Site visit by ADEC project manager and CSP management to observe site conditions and corrective action that have been taken in response to ADEC's 5/8/2009 correspondence and the 5/11/2009 site visit by Water Quality staff. Corrective actions observed to have been taken prior to the site visit included placement of temporary construction fencing and placement of additional sediment curtain beyond the sediment that overflowed an existing sediment curtain. Eileen Olson
5/15/2009 Document, Report, or Work plan Review - other ADEC issued letter conditionally approving the portion of KPG's workplan dated May 12, 2009 that includes sampling sediment eroded from the west slope of the soccer field that overflowed a silt fence at the base of the slope. Sampling is planned for Monday May 18. Eileen Olson
5/18/2009 Site Visit Site visit by ADEC project manager to observe sampling preparations in area at base of western sideslope of soccer field where sediment was observed on May 6, 2009 to have eroded, accumulated and overflowed the silt fence. Eileen Olson
5/21/2009 Update or Other Action Issuance of review letter for work plan received April 16, 2009 delayed pending management review of regulatory oversight for the project. Eileen Olson
5/22/2009 Site Visit Site visit with two CS managers to observe lead on ground surface and other areas of site. Eileen Olson
5/26/2009 Site Visit Site visit by ADEC project manager and three managers within the Contaminated Sites Program managers as part of management review of regulatory oversight by the CSP. Observations included lead at the ground surface and inadequate site controls to prevent unauthorized access. Eileen Olson
5/28/2009 Update or Other Action ADEC letter sent to KPG requesting that the site be secured within 10 days of receipt of the letter to prevent unauthorized access to lead-contaminated areas, that a health and safety plan for workers be implemented, and that approval be obtained from DEC before reworking, removing or adding material to filled areas or to the remaining portion of the range. Eileen Olson
6/1/2009 Update or Other Action EPA sent a "pre-filing" letter dated May 29, 2009 to the MOA and KPG notifying them they are liable parties for violations of the Resource Conservation and Recovery Act (RCRA) and offering the opportunity to enter into settlement discussions prior to and in lieu of EPA filing a complaint. Eileen Olson
6/2/2009 Document, Report, or Work plan Review - other DEC letter issued that approves hydroseeding of west slope of the soccer field as an interim stabilization measure to bring the site into compliance with the existing SWPPP (Storm Water Pollution Prevention Plan) and CGP (Construction General Permit) for the construction project. Approval to hydroseed was requested in an email dated May 29, 2009 by KPG's consultant and was previously requested in a work plan dated May 12, 2009. DEC's letter notes that sediment sampling results have been provided to DEC and results did not exceed DEC's most stringent 18 AAC 75.345 method two migration to groundwater cleanup levels for lead or antimony. The letter also makes a record of the agreement between KPG and DEC that DEC will withhold issuing a review letter for the plan submitted on April 16, 2009 until EPA's requirements are better known. Eileen Olson
6/2/2009 Update or Other Action Analytical results for sediment sampling done on May 18, 2009 received. The results show that sediment sampling requested by DEC in a letter dated May 8, 2009 did not exceed the most stringent cleanup levels for lead and antimony. These results were referenced in DEC's letter issued on the same date, with DEC's non-objection to grading and hydroseeding of the sediment. Eileen Olson
6/3/2009 Update or Other Action DEC notified KPG by email that appropriate dust suppression for potentially contaminated soil at the site will be required as long as soil at the site remains susceptible to wind erosion, and until final site control measures are in place, and requested that KPG provide a description of the dust suppression measures that will be taken and maintain a log of dust suppression actions. The notification and requests were made because it appears likely that completion of the soccer field will be delayed beyond this summer pending resolution of regulatory issues, leaving soil exposed at the site surface that is susceptible to fugitive dust production and wind erosion and transport. Eileen Olson
6/4/2009 Document, Report, or Work plan Review - other DEC received and approved responses from KPG for site controls including 1) driven-post fencing and signage that are being put in place, with perimeter fencing to be completed by June 11th. Site access controls were requested in DEC's May 28th letter to KPG; 2) a description of dust suppression measures as requested in DEC's 6/3/2009 email; KPG responded that water will be applied on days when it does not rain and a record will be kept of water application. DEC responded that the dust suppression measures should be sufficient but are performance-based to the extent that monitoring should be done to determine whether the goal of suppressing dust is met; and 3)a health and safety plan for workers and site visitors as requested in DEC's May 28th letter to KPG. Eileen Olson
6/9/2009 Document, Report, or Work plan Review - other DEC email approval of fencing plan received by email dated 6/8/2009 with diagram of proposed fencing. DEC's approval stated that the location of the fencing is acceptable and once constructed will meet DEC’s requirements if it reasonably prevents unauthorized access, and if signage adequately notifies passersby and unauthorized persons that entry is prohibited. Eileen Olson
6/11/2009 Site Visit DEC site visit on the evening of the day the site perimeter fencing was to be completed. Fencing not completed, and public use of the site and the lack of signage or other means of discouraging use were observed. Eileen Olson
6/12/2009 Update or Other Action DEC email with attached photos to KPG as follow-up to 6/11 site visit recommending that access and signage issue be addressed in a manner that prevents or at a minimum discourages access over the weekend (email was sent on a Friday). The email noted that although DEC observed that quite a bit of fencing that was to completed by 6/11 was up, bicyclists and other passersby were freely accessing the site during the DEC site visit. Eileen Olson
6/14/2009 Site Visit Site visit by DEC staff Sunday p.m. Fencing was observed to have been completed since the last site visit of 6/11 and done according to the fencing plan received on 6/8/2009. In approving the plan DEC agreed that some areas of the site perimeter did not require fencing because heavy vegetation and nearly impassible ground surface conditions already adequately prevented access. "Keep Out" and other signs were in place along the fenced areas. Eileen Olson
6/16/2009 Meeting or Teleconference Held DEC staff met at the site with KPG, MOA, construction contractor and environmental consultant representatives to discuss site issues including actions taken to control site access and the next steps with respect to addressing site contamination. KPG's representative offered to provide a summary of the meeting and did so the following day. During the meeting KPG also provided a copy of the watering log for dust suppression at the site for the period June 5 through June 11 that responded to DEC's June 3rd email request to take measures to suppress dust and to keep a log of those measures. KPG responded to the email by proposing to water exposed areas of the site on days when there is no rain. Eileen Olson
6/16/2009 Site Visit Site visit for meeting by ADEC staff Olson and Nuechterlein; met with MOA, RHC, LDN and KPG representatives, including attorneys for each party. Eileen Olson
6/17/2009 Update or Other Action DEC received "Kincaid Status Report" from KPG dated June 17, 2009 as promised during meeting at site on 6/16/2009. The report summarizes the current status of various issues related to Kincaid Project Group improvements and includes information from the June 16, 2009 on-site meeting at which representatives were present from KPG, MOA, ADEC, Shannon & Wilson, Land Design North, and Roger Hickel Construction. Eileen Olson
6/19/2009 Update or Other Action DEC received the second watering log to date documenting dust suppression at the site by application of 3600 gallons of water daily for the period June 11th through 18th. KPG's representative submitted the log by email in accordance with KPG's plan to provide the log on a weekly basis. Eileen Olson
6/19/2009 Update or Other Action DEC was copied on an email from EPA counsel to KPG that commented on the Kincaid Status Report by KPG dated June 17, 2009. EPA noted that the site is subject to RCRA and stated that the April 16th work plan submitted to ADEC does not appear to provide for sufficient characterization. EPA stated that a sampling plan must identify areas where the bulk soil is contaminated as well as areas where intact bullets and larger lead fragments are present, and that once characterization is completed a corrective action plan must be developed for removing contamination where feasible and evaluating measures for any portions of the unit for which clean closure is not feasible. Eileen Olson
6/24/2009 Update or Other Action ADEC was copied on a letter to EPA from KPG's consultant. The letter revises information provided to the EPA in MOA and KPG's April 10, 2009 submittal that responded to EPA's information request. The letter evaluates lead usage at the range and concludes that projectile fragment mass in the cut/fill area of the site is small relative to the total lead removed. Eileen Olson
6/26/2009 Update or Other Action DEC received the 3rd watering log to date documenting dust suppression at the site when dry conditions warrant spray application of water. Log is cumulative and includes June 11 - 25. Eileen Olson
6/30/2009 Update or Other Action ADEC was copied on a letter dated 6/30/2009 and received 7/8/2009, from MOA outside counsel Susan Reeves. The letter notifies EPA that the MOA joins in a request submitted on behalf of Kincaid Project Group that EPA rely on the analysis of potential lead deposition rates presented in a letter to EPA dated June 24, 2009, from Shannon & Wilson, Inc. Shannon & Wilson's letter states that past estimates provided to EPA over-estimated the amount of ammunition used at the former range about four times, and states that the bulk of the lead at the site was removed during the 2008 excavations. Eileen Olson
7/6/2009 Update or Other Action DEC received the 4th watering log to date documenting dust suppression at the site when dry conditions warrant spray application of water. Log includes 6-19 through 7-2. Eileen Olson
7/7/2009 Document, Report, or Work plan Review - other ADEC received and reviewed in a letter of this date the July 6, 2009 report "May 2009 Sediment Sampling, Former Kincaid Biathlon Range, Anchorage, Alaska." The report documents collection of 11 metals samples from sediment that was eroded by water during spring breakup and subsequently collected at the base of the west slope of the new soccer field development area at the Kincaid Outdoor Center. The results of the composite sampling for lead and antimony did not exceed cleanup levels and were within the range of expected background concentrations. Eileen Olson
7/22/2009 Update or Other Action ADEC letter notifying the RPs that ADEC requirements are in addition to EPA requirements, and that the site is subject to the requirements of 18 AAC 75.325 - 18 AAC 75.390, referred to under chapter 75 as the "site cleanup rules." Under the site cleanup rules, work plans are required for site characterization and other environmental actions including work required by EPA under the Resource Conservation and Recovery Act (RCRA) regulations, and are subject to ADEC approval before work begins. Eileen Olson
9/1/2009 Update or Other Action Plan submitted to ADEC and EPA Region X titled "Work Plan for Lead Removal & Site Characterization, Former Kincaid Park Biathlon Range, Anchorage, Alaska, September 2009." EPA is the lead regulatory agency for the site. Eileen Olson
9/28/2009 Document, Report, or Work plan Review - other ADEC issued a letter to EPA providing review comments for the work plan titled "Work Plan for Lead Removal & Site Characterization,Former Kincaid Park Biathlon Range ... September 2009" submitted to ADEC and EPA on September 1, 2009 by responsible party Kincaid Project Group (KPG). The comments were provided to EPA according to the understanding between the Municipality of Anchorage (MOA) and KPG, EPA, and ADEC following a July 20, 2009 meeting between the RPs and EPA, that the responsible parties would submit a revised work plan and the regulatory agencies would coordinate the plan review, with EPA to prepare comprehensive review comments following receipt of ADEC's comments. Eileen Olson
11/20/2009 Document, Report, or Work plan Review - other ADEC received a cover letter and review comments by the Environmental Protection Agency’s (EPA) Resource Conservation & Recovery Act program (RCRA) for the work plan submitted to EPA and ADEC on September 1, 2009. EPA's review includes as an attachment ADEC's plan review comments that were provided to EPA at EPA's request in a letter dated September 28, 2009. The letter and comments outline requirements for the responsible parties to further characterize and remove lead and lead contaminated media associated with the former biathlon shooting range. The letter and comments are expected to be formally issued by November 23rd. Eileen Olson
1/8/2010 Meeting or Teleconference Held Contaminated Sites (CS) staff participated by teleconference in a meeting held in Seattle on January 8, 2010 between the EPA, ADEC and the parties responsible for lead contamination at the Kincaid site in Anchorage, a former biathlon range where lead contamination was spread over a large area during the development of a soccer field. The responsible parties are the Municipality of Anchorage (MOA) as landowner and the Kincaid Project Group (KPG) as operator. Participants included ADEC staff, EPA Federal Resource Conservation & Recovery Act (RCRA) staff and counsel, Jan Palumbo, Region 10, and Sylvia Burges, Air/RCRA Enforcement Officer, and representatives of the MOA and KPG. The MOA is represented by outside counsel Susan Reeves and the consulting firm Alta Geosciences. MOA Parks and Recreation Director John Rodda also attended the meeting. KPG, a non-profit park improvement and development group, was represented by KPG board member Peter Van Tuyn and the environmental consulting firm Shannon & Wilson. Discussion centered on site characterization plan review comments provided to the responsible parties by EPA in a letter dated November 23, 2009; on the revisions and additions to be made to the next plan; and on the regulatory status of the site. Eileen Olson
1/22/2010 Update or Other Action A plan titled "Soil Boring Work Plan" was submitted to ADEC and EPA on this date. The plan proposes placing two borings close to the south end of the former range to determine depth to groundwater, if present, and to assess the vertical migration of lead through the soil column. Eileen Olson
2/9/2010 Document, Report, or Work plan Review - other EPA issued a review letter to MOA and KPG with attached comments for the "Soil Boring Work Plan" submitted to EPA and ADEC 1/22/2010. EPA's letter notes that ADEC reviewed and concurs with the comments and recommendations provided. Eileen Olson
2/9/2010 Potentially Responsible Party/State Interest Letter ADEC issued PRP letters to the MOA and KPG as a means to obtain information regarding the transport and fate of bullet slugs and fragments, and lead- and antimony-contaminated soil associated with the range. The PRP letters to MOA and KPG are a formality in the sense that these parties were already aware of their PRP status and have been actively involved in planning, environmental work and negotiations with ADEC and the US Environmental Agency (EPA) since June 2008 when EPA and ADEC first became aware of federally-regulated hazardous waste and state-regulated hazardous substance contamination at the site. The letters include an information request for which a response is due by April 1, 2010. Eileen Olson
2/16/2010 Meeting or Teleconference Held Staff met with consultant representative to discuss locating former range with respect to current site configuration (stadium and field constructed); reviewed air photos and methodology; ADEC recd survey points and measurements from corner of lower stadium apron to light poles. Eileen Olson
2/16/2010 Update or Other Action EPA and ADEC received a draft work plan that revises the plan submitted 1/22/2010. Eileen Olson
2/17/2010 Potentially Responsible Party/State Interest Letter PRP letters were sent notifying three business entities for the first time that under state law they are “potentially responsible parties” (PRPs), meaning that that they may be financially liable for contamination associated with the Kincaid Park former biathlon range site in Anchorage. The entities are the environmental consulting firm Shannon & Wilson, Inc., Landscape Design North, Inc. (LDN) and Roger Hickel Contracting, Inc. Each of the PRP letters includes an information request that should assist the agencies in determining the fate (i.e. location) of lead-and antimony-contaminated soil and bullet slugs and fragments associated with the range. Responses to the information requests are due on April 2, 2010. CS is particularly interested in verifying that potentially contaminated soil was not used as fill at seven soccer fields that were constructed at Kincaid Park in 2008 concurrent with the soccer stadium preconstruction earthwork at the former range site. Eileen Olson
3/1/2010 Update or Other Action EPA and ADEC received "Soil Boring Work Plan, Former Kincaid Park Biathlon Range, Anchorage, ALaska" dated February 26, 2010 prepared by consultant Shannon & Wilson. The plan incorporates revisions to the draft plan submitted on 2/16/2010. Eileen Olson
3/4/2010 Update or Other Action Consultant Shannon & Wlson submitted to SPAR a review request on a standard form titled "DEC Informal Review Pursuant to 18 AAC 15.185" contesting ADEC's determination that Shannon & Wilson is a potentially responsible party (PRP) and requesting that ADEC remove the PRP designation. Eileen Olson
3/5/2010 Document, Report, or Work plan Review - other EPA review letter dated March 5th with subject line "Approval with Conditions of “Soil Boring Work Plan, Former Kincaid Park Biathlon Range, Anchorage, Alaska” dated February 26, 2010." Although EPA is the lead regulatory agency, ADEC regulations are also applicable to the site; therefore the letter states that EPA and ADEC "...jointly reviewed the subject Soil Boring Work Plan (Plan) submitted March 1, 2010 on behalf of the Kincaid Project Group (KPG). The Plan incorporates revisions requested by EPA in a letter dated February 8, 2010, and incorporates additional revisions requested by EPA and ADEC (“the Agencies”) following review of a draft revised plan submitted to the Agencies on February 16, 2010." The workplan proposes drilling a boring using a direct push GeoProbe rig to determine whether groundwater is present within the upper 75 to 100 feet below ground surface at the site. Eileen Olson
3/29/2010 Update or Other Action ADEC received report titled "Shallow Groundwater Determinatin, Former Kincaid Biathlon Range, Anchorage, AK" that documents the Geoprobe boring that was made on March 17, 2010 to determine whether groundwater is present beneath the soccer field area. Eileen Olson
3/29/2010 Update or Other Action ADEC received email submittals of a draft agenda and various supporting documents as preparation for the April 1 meeting between EPA, ADEC and the involved parties. Eileen Olson
4/1/2010 Meeting or Teleconference Held Staff participated in teleconference with EPA and other involved parties to discuss results of recent boring and approach to site characterization. Discussed resolution of question of whether potentially contaminated soil may have been transported to lower fields; indications are that it was not and documentation is reportedly available to verify. Seattle participants were Jan Palumbo/EPA; Sylvia Burges/EPA; Bob Hartman/EPA; Alex Tula, Alta Geosciences; and John Rodda, MOA Parks & Recreation. Anchorage participants were Steve Bainbridge/DEC; Rich Sundet/DEC; Peter Van Tuyn/KPG; Dwayne Adams/LDN; Nelson Page/counsel for LDN; Mike Pollock/RHC; Scott Dunlap/RHC; Terry Turner, counsel for RHC; Susan Reeves, counsel for MOA; Michael Dodd, Shannon & Wilson; and Matt Hemry, Shannon & Wilson. Eileen Olson
4/13/2010 Update or Other Action ADEC received a copy of an affidavit dated September 4, 2010 that was prepared by the environmental consultant for the Kincaid project. The affidavit was not provided to DEC earlier because it was part of settlement- and enforcement-related submittals to EPA by the involved parties, but the environmental consultant determined it could be released. Eileen Olson
4/21/2010 Update or Other Action Received preliminary draft plan from consultant Shannon & Wilson. Eileen Olson
5/2/2010 Site Visit Brief site visit. site is clear of snow, but observed meltwater ponding at southeast end of soccer field, adjacent to former south end of target line. Eileen Olson
5/3/2010 Document, Report, or Work plan Review - other DEC and EPA provided joint comments on a preliminary, partial plan submitted 4/21/2010. The plan had the purpose of reaching an understanding between the agencies and involved parties regarding major elements of the planned site characterization, including a proposed statistical approach for sampling, and field screening and sampling methodology and frequency. Eileen Olson
5/6/2010 Meeting or Teleconference Held DEC, EPA and the environmental consultant's representative participated in a teleconference intended to provide the consultant with additional explanation and clarification with respect to the agency review comments provided on 5/3/2010. Eileen Olson
5/13/2010 Meeting or Teleconference Held 10:15-~11:30: Staff participated in a teleconference with EPA’s Jan Palumbo and Matt Hemry of S&W. During the call Mr. Hemry stated his opinion that all of the fill areas would have to be excavated regardless of the results of the planned investigation, and said he would advise his client that everything must be dug up (as part of the investigation). Later in the day EPA provided an email clarifying that EPA and DEC do not concur with this conclusion, and noting that the purpose of the site investigation is to identify the extent of the contamination at the site, so that the contaminated areas may be selectively addressed; and further noting that the intent of this approach is to minimize costs by defining the specific areas that are contaminated, so that costly excavation and treatment or processing of large volumes of clean fill is unnecessary. Eileen Olson
5/18/2010 Site Visit Site visit to Kincaid to observe sample preparation with Andrew Lee of Shannon and Wilson. Brenton Porter
6/1/2010 Meeting or Teleconference Held DEC staff participated in a teleconference with Jan Palumbo and Kevin Schanilec of EPA; Matt Hemry of Shannon & Wilson; Alex Tula of Alta Geosciences; and John Rodda of the Municipality of Anchorage (MOA) Parks & Recreation Department. Kevin is an Enforcement Officer with the Air/RCRA Compliance Unit and has been involved in the project in the past. The teleconference was requested by Ms. Palumbo to discuss two conceptual drawings prepared by Mr. Hemry based on his discussions with Mr. Rodda. The diagrams were submitted to EPA and DEC (the agencies) on 5/28/2010 and indicated that only shallow investigative trenches would be excavated. Ms. Palumbo clarified that the requirement by the agencies that the fill areas at the site be investigated to the total depth of fill, as described in the agency comments dated 5/3/2010, has not changed. Eileen Olson
6/14/2010 Update or Other Action In a letter dated June 14, 2010 EPA notified three additional parties (Roger Hickel Contracting, Inc., Dwayne Adams of Land Design North, and Shannon & Wilson, Inc.) of their status as parties liable as generators and/or operators under the Resource Conservation and Recovery Act (RCRA) for alleged RCRA violations. The MOA and KPG were similarly notified of their status as liable parties in a letter dated May 29, 2009 (see June 1, 2009 entry). Eileen Olson
6/25/2010 Update or Other Action DEC transmitted by email a draft limited site characterization plan to involved parties on this date as an example of an approvable site characterization work plan. The plan was prepared at the request of KPG and the MOA and addresses only the largest fill area, Fill A1. Staff noted in the email accompanying the draft plan that 1) EPA expects to complete a review of the plan by Monday or Tuesday of next week (June 28 or 29), but has communicated their position that EPA cannot approve any plan that has not gone through the public notice and comment process; 2) Therefore EPA’s involvement in the plan review process will not constitute approval of the plan, and 3) This leaves the parties in the position of completing characterization work that carries a risk of not sufficiently meet EPA’s requirements, but that should expedite completion of the project; or delaying work until a closure plan has been through the 30-day public notice process and determined to be satisfactory by EPA. Eileen Olson
6/30/2010 Update or Other Action EPA transmitted Final DEC workplan with EPA edits to involved parties on this date. The attachment to the email is dated 6/28/2010. The workplan introduction states that the "limited site characterization workplan is intended to be an example of a plan that could be approved by the DEC, and could potentially be part of a Resource Conservation and Recovery Act (RCRA) plan submitted to EPA. The plan is not comprehensive and includes only one area of the Kincaid Park Former Biathlon Range site, as requested of the Alaska Department of Environmental Conservation (DEC) by the Municipality of Anchorage (MOA) and the Kincaid Project Group (KPG). Other areas of the site requiring investigation and any standard plan elements not included in the section below will need to be added by the environmental consultant for the Kincaid parties, and a comprehensive workplan submitted that addresses the entire site." Eileen Olson
7/7/2010 Update or Other Action Response to 6/30/2010 DEC plan received this date by DEC and EPA from KPG and the other parties identified by EPA as liable parties. The email accompanying the comments states as follows: "KPG and MOA, along with their respective environmental consultants, Shannon & Wilson Inc. (S&W) and Alta Geosciences Inc. (Alta), have thoroughly reviewed the work plan section provided by DEC, and accept the DEC and EPA premise that characterization of the Fill A1 Area must comprise direct assessment of a substantial volume of soil, using a combination of visual observation, field screening, and analytical samples. Accordingly, we accept this section of the plan, subject to the modifications noted here and in the attached more specific comments from S&W. The two primary proposed modifications are replacing the trenching component with near-complete removal of fill soil for screening and/or sampling, and application of currently-promulgated cleanup levels as the appropriate standards for clean closure." Eileen Olson
7/10/2010 Site Visit Visited site to observe and document photographically limits of fill and graded areas. Eileen Olson
7/14/2010 Document, Report, or Work plan Review - other DEC and EPA issued comments on this date in reply to Shannon & Wilson's response of 7/7/2010 to the workplan prepared by DEC that was submitted to involved parties in final form on 6/30/2010. The comments centered largely on the specifics of field screening and sampling. EPA also answered questions posed earlier by the involved parties regarding federal regulations applicable to the site. Eileen Olson
7/22/2010 Update or Other Action Additional communications received and responded to re plan prepared by DEC finalized 6/30/2010: On July 20th Shannon & Wilson, consultant for the Kincaid Project Group (KPG) proposed conducting a second X-Ray Fluorescence (XRF) field screening correlation study to determine a threshold XRF value below which lead contamination would be considered to be below the applicable cleanup levels set by the U.S. Environmental Protection Agency (EPA) and DEC. Determining such a threshold would allow soil that meets the field screening level to be immediately re-used as fill without laboratory analysis or confirmation sampling. On July 22nd DEC, in consultation with EPA, responded that sufficient XRF field screening and laboratory analytic data is available to set the threshold for XRF readings at the detection limit for the XRF Analyzer but no higher than 25.1 parts per million (ppm or mg/kg) lead, which was the highest detection level recorded for during the first correlation study in March 2010. The next step is the submittal of a complete workplan by Shannon & Wilson for agency review and approval. Eileen Olson
7/28/2010 Site Visit Site visit by project manager. Liners partly removed from soccer field area, vegetative growth around field perimeter including former south end of target line. Eileen Olson
8/10/2010 Update or Other Action Draft plan received. EPA received and forwarded to DEC this date "DRAFT Work Plan for Site Characterization & Interim Removal Action Former Kincaid Park Biathlon Range, Anchorage, Alaska, August 2010". Eileen Olson
8/16/2010 Site Visit Staff Weimer and Olson met with Dwayne Adams, former LDN principal, Shannon & Wilson representatives and Scott Dunlap of RHC (earthwork contractor)to walk through all areas of the soccer field and stadium project area that were disturbed by cut, fill and grading operations. LDN made the case that a berm at the west side of the south end of the base for the artificial turf field is not a built-up berm but was graded from an elevated area, and therefore will not need to be excavated to depth, but will require at least surface evaluation for lead fragments. Also discussed with RHC representative the applicability of the Construction General Permit to earthwork related to environmental cleanup. Since the CGP is expected to remain in effect through the end of construction, compliance by the involved parties with the requirements of the CGP should be sufficient to ensure that stormwater runoff doesn't transport potentially contaminated soil offsite. If it is not additional actions may be required under the Contaminated Sites regulations. Eileen Olson
8/20/2010 Document, Report, or Work plan Review - other DEC and the US Environmental Protection Agency (EPA) separately provided review comments to the Kincaid Project Group (KPG) and other involved parties for the plan submitted August 10th titled “Draft Work Plan for Site Characterization & Interim Removal Action”, prepared by Shannon & Wilson. KPG’s plan is intended to be comprehensive in that all disturbed areas of the site, including cut, fill and graded areas will be evaluated. CS staff met with the involved parties on August 16th to ensure that all disturbed areas will be included in the characterization plan. DEC’s requests for corrections and revisions to the plan largely pertain to agreements made with the involved parties during the site visit, so it is anticipated that the turnaround time for submittal of a final plan by Shannon & Wilson will be short, allowing work to begin within the next two weeks. The plan proposes to excavate virtually all fill areas at the site, and the reliance on a Niton X-ray fluorescence (XRF) analyzer for field analysis will allow characterization of contamination and the interim removal of lead and lead-contaminated soil to take place nearly concurrently. Eileen Olson
8/31/2010 Update or Other Action Received partial revised plan and associated table and figure from consultant Shannon & Wilson as follow up to 8/26/2010 teleconference. Eileen Olson
9/7/2010 Update or Other Action DEC and EPA received "Work Plan for Site Characterization & Interim Removal Action Former Kincaid Park Biathlon Range, Anchorage, Alaska, September 2010" prepared by Shannon & Wilson, Inc. Eileen Olson
9/10/2010 Document, Report, or Work plan Review - other DEC conditionally approved the "Site Characterization & Interim Removal Action" plan for the Kincaid Park Former Biathlon Range site received September 7, 2010. Eileen Olson
9/21/2010 Site Visit Site visit by Jan Palumbo of EPA, DEC staff Sundet, Olson and Weimer and various of the involved parties and/or their counsel. Eileen Olson
9/30/2010 Update or Other Action Affidavit regarding DEC actions at Kincaid site executed by DEC staff this date and provided to EPA. Eileen Olson
10/7/2010 Update or Other Action DEC received from EPA a copy of a signed Consent Agreement and Final Order (CAFO) between EPA and the liable parties for the Kincaid site. The document was signed on October 4th. Eileen Olson
10/7/2010 Update or Other Action Press Release issued by EPA this date regarding the site and Consent Agreement and Final Order (CAFO):"Firing range cleanup agreement means Kincaid Park soccer field construction can move forward Contact Info: Kevin Schanilec, RCRA Compliance Officer, (206) 553-1061, schanilec.kevin@epa.gov Tony Brown, EPA Public Affairs, (206) 553-1203, brown.anthony@epa.gov (Seattle --- Oct. 7, 2010) The Municipality of Anchorage, Kincaid Project Group, Land Design North and Roger Hickel Contracting, Inc., have agreed to complete the clean up of lead-contaminated soil at Kincaid Park in Anchorage, Alaska under a settlement announced today by the Environmental Protection Agency. According to Edward Kowalski, EPA’s Director of Compliance and Enforcement in Seattle, today’s cleanup agreement will allow the construction of a new and safer soccer field at the site of a former firing range in the park. “This settlement is great news for Anchorage-area youth, for the environment, and for the community as a whole,” Kowalski said. “It means the cleanup will get done and ultimately children and their families will have a safe place to play without risk of exposure to lead-contaminated soil.” Today’s consent agreement requires the parties to submit a cleanup plan to EPA within 90 days. Once the plan is approved, it will be implemented as soon as practicable. Under the settlement, the parties also agreed to pay a penalty of just over $63,000 for violations of federal hazardous waste management rules also known as Resource Conservation and Recovery Act. Kincaid Park is a 1,500-acre City Park owned by the Municipality of Anchorage. A biathlon shooting range operated at the park from approximately 1988 to 2007. The shooting range was contaminated with lead from bullets, with lead soil levels ranging as high as 68,000 parts per million. In May 2008, during construction of a soccer field at the former shooting range, The Kincaid Project Group and two contractors moved lead-contaminated soil at the site, thereby generating approximately 30 tons of lead-contaminated hazardous waste soil and debris. The contaminated material was stored and disposed of on-site without treatment and without proper testing. Lead contamination from other areas of the shooting range was also disturbed and spread over approximately 4-acres without prior testing to determine whether the lead levels would be classified as hazardous waste. Some of the waste has since been properly disposed of, but additional cleanup is required in order for the site to be safely used by the community. Lead is highly toxic to people, especially children, when ingested or inhaled. Short term exposure can cause brain and kidney damage. Long term exposure can damage the blood and central nervous system." Eileen Olson
10/25/2010 Exposure Tracking Model Ranking A new updated ranking with ETM has been completed for source area 75717 Lead and antimony from 22-caliber ammunition . Eileen Olson
11/1/2010 Update or Other Action ADEC received a letter from Shannon & Wilson dated November 1, 2010 proposing modifications to the conditionally approved "Site Characterization & Interim Removal Action, Former Kincaid Park Biathlon Range" plan submitted to ADEC and EPA on September 7, 2010, with Shannon & Wilson's stated goal in proposing the modifications to create a stand-alone plan that could be approved without conditions. Eileen Olson
11/10/2010 Document, Report, or Work plan Review - other ADEC's letter dated November 10, 2010 conditionally approved modifications proposed in a letter from Shannon & Wilson dated November 1, 2010 to the "Site Characterization & Interim Removal Action, Former Kincaid Park Biathlon Range" plan submitted to ADEC and EPA on September 7, 2010. ADEC previously approved the plan with conditions set forth in a letter dated September 10, 2010, but the plan submitted by Shannon & Wilson on November 1, 2010 did not provide the changes required under Section 6.6 of the ADEC's September 7, 2010 conditional approval letter. The only condition in the November 10, 2010 approval letter is to include the requirements under Section 6.6 in the ADEC's previous approval letter. Eileen Olson
12/1/2010 Update or Other Action In an email dated 12/1/2010, Shannon & Wilson requested on behalf of client KPG, reconsideration of proposed plan modifications that ADEC declined to approve in ADEC's letter dated November 10,2010, and also requested that if the reconsideration is denied that ADEC provide an explanation for the denial. Eileen Olson
12/3/2010 Document, Report, or Work plan Review - other ADEC issued a letter after consultation with EPA with subject line "Response to December 1, 2010 email request for reconsideration of site characterization requirements; Kincaid Park Former Biathlon Range site, vicinity of 9401 W. Raspberry Road, Anchorage, AK 99502 (Hazard LD. No. 4650)". ADEC's letter declined approval of the request to modify the conditions of approval for site characterization and provided detailed rationale for the denial. Eileen Olson
12/9/2010 Update or Other Action Plan submitted - ADEC received a "Work Plan for Site Characterization & Interim Removal Action, Former Kincaid Park Biathlon Range...December 2010" prepared by Shannon & Wilson, Inc. The plan was accompanied by an email stating "We have incorporated the conditions stated in your September 10, 2010 letter, as modified and clarified in subsequent letters dated November 10 and December 3, 2010. Note that we did not re-submit the appendices as these have not changed. We look forward to your review and ADEC approval of this work plan without conditions." Eileen Olson
1/4/2011 Update or Other Action ADEC was copied on and received a copy of the "Former Kincaid Park Biathlon Range Closure Plan" dated January 4, 2010 by Alta Geosciences, Inc., submitted to EPA in accordance with the Consent Agreement and Final Order between EPA and the Kincaid Project Group, Inc., Land Design North, Inc., the Municipality of Anchorage, and Roger Hickel Contracting, Inc. The Closure Plan states that the December 2010 "Work Plan for Site Characterization & Interim Removal Action" is an integral part of the Closure Plan and is attached as Appendix A to the Closure Plan. Eileen Olson
1/26/2011 Document, Report, or Work plan Review - other EPA and ADEC issued Closure Plan review comments and an accompanying cover letter titled “Notice of Deficiency” were issued on this date. The comments were jointly prepared by and the cover letter co-signed by EPA and ADEC in support of the intent by the responsible parties that a single plan be submitted to meet the regulatory requirements of both EPA and ADEC. The letter requires that the Parties submit a revised closure plan to both EPA and ADEC by February 9th that addresses the review comments. The letter further states that 1) if the revised plan adequately responds to EPA and ADEC comments, EPA will issue a public notice that will open a 30 day public comment period for the plan and, based on public comment, EPA will approve the plan or modify and approve the plan, and 2) ADEC will either approve the revised plan without conditions, or if the plan is not fully responsive to the review comments, will conditionally approve the plan and require that the conditional approval become part of the Closure Plan. Work is scheduled to begin in late May 2011. Eileen Olson
1/28/2011 Meeting or Teleconference Held ADEC, EPA, MOA and ALTA Geosciences representatives held a teleconference to outline the approach and schedule for revising the Closure Plan. ALTA will be the technical contact for the responsible parties. ALTA requested and was granted an extension until February 22nd to submit the revised Closure Plan to the agencies. Following review of the revised plan by EPA and ADEC, the plan will go out to 30-day public notice and comment by March 15, 2011. Based on public comment, EPA will approve the plan or modify and approve the plan. ADEC will either approve the revised plan without conditions, or if the plan is not fully responsive to the review comments, will conditionally approve the plan and require that the conditional approval become part of the Closure Plan. The agencies expect to approve the plan no later than May 1, 2011, with work still scheduled to begin in late May 2011 or as soon as spring thaw permits. Eileen Olson
1/31/2011 Update or Other Action ADEC was copied on a letter from MOA outside counsel to EPA on behalf of responsible parties MOA, KPG, LDN and RHC. The letter followed and met a request made by EPA during the 1/28/2011 teleconference that the responsible parties verify that ALTA Geosciences will be the technical contact entity for the parties. Eileen Olson
2/14/2011 Update or Other Action A final, revised closure plan dated 2/14/2011 was submitted to EPA and ADEC this date by Alex Tula of ALTA Geosciences. The plan is a revision of the previous version of the plan, titled "Former Kincaid Park Biathlon Range Closure Plan" and dated January 4, 2010, also by Alta Geosciences, Inc. Eileen Olson
2/22/2011 Update or Other Action The Kincaid Park Biathlon Range site was mentioned in a Channel-11 KTVA Anchorage (CBS) news report on February 22, 2011 regarding cleanup costs at the Kincaid and another site for which the Municipality of Anchorage was named as being at least partly responsible. http://www.ktva.com/oldlocal/ci_17451242?source=rss. Contaminated Sites staff were not contacted for the news report. Eileen Olson
2/24/2011 Meeting or Teleconference Held Staff held a teleconference with the EPA and involved parties to discuss antimony sampling and analysis requirements. Eileen Olson
2/28/2011 Document, Report, or Work plan Review - other The EPA and ADEC (the agencies) jointly issued a cover letter and comments on the second draft Closure Plan, submitted on 2/14/2011, noting that the plan was reviewed as a second draft plan because it was not yet in a form that would allow the parties to proceed to the next steps (including approval, public notice, etc.) described in the EPA and ADEC joint Notice of Deficiency letter dated January 26, 2011. Additional revisions will be required before ADEC or EPA will approve or in the case of EPA approve or modify and approve the plan. The requested revisions were discussed during the February 24th teleconference and additional shorter teleconferences prior to issuance of the cover letter and comments dated 2/28/2011, with the result that an understanding was reached with respect to the most topic of most concern to the involved parties; that is, the frequeny and scope of antimony sampling. Eileen Olson
3/21/2011 Update or Other Action The final revised "Clean Closure and Site Cleanup Plan, Former Kincaid Park Biathlon Range Site...March 2011" was received at 1:12 pm (time noted as more than one version of the plan with the same title and date was circulated)and was subsequently posted for public comment online by EPA at http://www.epa.gov/region10/pdf/sites/kincaidpark/closure_plan.pdf. EPA also published a public notice advertisement in the Anchorage Daily News on 3/22/2011 that included the link to the plan. Eileen Olson
4/28/2011 Document, Report, or Work plan Review - other ADEC issued a plan approval letter for the "Clean Closure and Site Cleanup Plan, Former Kincaid Park Biathlon Range Site...March 2011" received March 21, 2011. ADEC's approval followed approval of the same plan by EPA in a letter dated April 27, 2011. EPA's letter followed EPA's 30 day public notice and comment period ending on April 21, 2011. No public comment was received. Eileen Olson
5/10/2011 Update or Other Action ALTA Geosciences submitted a "Treatability Study Work Plan...May 2011". ALTA is the environmental consultant for responsible parties MOA, KPG, LDN and RHC. The goal of the treatability study is to show that treatment with FESI-Bond lead stabilizer (FESI = Forrester Environmental Services, Inc.) will reduce the TCLP result for lead to a level below the 5 mg/L that constitutes characteristic hazardous waste, so that the treated soil will no longer be a hazardous waste and can be disposed of at the Hiland Road regional landfill. Eileen Olson
5/10/2011 Update or Other Action ALTA Geosciences submitted a "Kincaid Construction Schedule" memorandum that describes two phases of work, with the first to include mostly preparatory work such as setting up a field office and preparing soil storage areas, but also includes conducting a metal detector sensitivity study, tentatively scheduled for Tuesday morning May 17th; conducting focused soil excavation and stockpiling of metal detector anomaly areas as needed; and collecting treatability study samples according to the work plan also submitted by ALTA on this date. Excavation and investigation of the southern portion of the former target line and fill areas will begin on Tuesday May 31st. Eileen Olson
5/17/2011 Document, Report, or Work plan Review - other ADEC and EPA issued a joint "Agency" letter with subject line "Approval of Closure Plan modification proposed in Memorandum dated May 17, 2011 with subject "Correction and Modification to Closure Plan Section 4.8.3". The Agencies approved a correction and modification to the procedure for screening with a metal detector. Eileen Olson
5/18/2011 Site Visit Staff visited the site twice, once from 8:30 - ~10:15 and again at ~7pm to observe and photograph site conditions and field work. During the morning visit ALTA Geosciences subcontractors demonstrated to ADEC the use of the metal detector at four existing stations created earlier by ALTA to determine detection capabilities of metal detector. The 4 stations included a flattened lead disc placed on the ground surface and a buried nail, casing and lead slug, reportedly buried from 1/2 to 2 inches deep. Eileen Olson
5/23/2011 Site Visit Staff on site from 9:30 - 10:15 AM to observe & photograph field work and site conditions. Met with Rick Quine of ALTA Geosciences at Chalet. Eileen Olson
5/24/2011 Site Visit Staff on site observing work and site conditions 10:50 - 11:30 a.m. Eileen Olson
6/1/2011 Meeting or Teleconference Held ADEC staff Olson, Weimer and others met with the parties (RHC, MOA, KPG and LDN) and environmental consultant ALTA Geosciences representatives at the Kincaid Outdoor Center Chalet to discuss site status; EPA’s Jan Palumbo, in Seattle, was teleconferenced in for the meeting. Robert Weimer
6/1/2011 Site Visit Following the meeting held at the adjacent Kincaid Outdoor Center Chalet this date, most of the meeting participants visited the site and observed the use of the metal detector to identify surface and near-surface lead, and observed focused soil excavation and sifting. Robert Weimer
6/2/2011 Document, Report, or Work plan Review - other ADEC and EPA (Agency) letter issued with subject line ""Conditional approval of four submittals by ALTA Geosciences, Inc. including "XRF Standard Operating Procedures ... May 2011 received May 20, 2011"; "Closure Plan Modification Request, Stockpile Design Details" Memorandum dated May 25, 2011 and received May 26, 2011; "Closure Plan Modification Request; Surface Survey Transect Lines" Memorandum dated and received June 1, 2011; "Surface Transects and Slug Removal, Cut A Area" Memorandum dated and received June 2, 2011." Eileen Olson
6/2/2011 Site Visit Staff Robert Weimer visited the site to observe construction of the soil stockpile areas and results of the further metal detector sweeps of the surface of the site. A black bear had visited the site earlier in the day. Robert Weimer
6/3/2011 Site Visit Site visit by staff in p.m. Gusting winds and blowing-dust conditions; liners have been removed from about ¾ of soccer field base area. Eileen Olson
6/6/2011 Site Visit Site visit in a.m. at request of consultant ALTA to field check planned excavation perimeter of soil at south end of former target line. Site activities in progress included the use of the metal detector for identifying surface and near surface lead. Eileen Olson
6/7/2011 Site Visit Staff Robert Weimer visited the site twice, once in a.m. and once in late p.m. to observe metal detector survey and flagging of surface areas and excavation of soil at the south end of the former biathlon range target line. Eileen Olson
6/7/2011 Document, Report, or Work plan Review - other Agency (EPA and ADEC) letter issued approving "Closure Plan Modification - South Target Line Bench Excavation Sequence" proposed in ALTA Geosciences Memorandum dated and received June 3, 2011. Eileen Olson
6/8/2011 Site Visit Staff visited the site early AM to observe ongoing excavation of the former south end of the former target line, where an approximately foot-thick layer of lead-contaminated soil is being removed for disposal as hazardous waste. Eileen Olson
6/9/2011 Site Visit Staff Robert Weimer observed site work and the flagged areas during an a.m. site visit, noting that lead had been identified beyond the currently established areas of contamination ("AOCs") so that the AOCs will need to be reevaluated. Eileen Olson
6/10/2011 Site Visit A.M. Site visit by staff Robert Weimer; observed continued surface surveys and excavation, met with ALTA field staff. Eileen Olson
6/10/2011 Update or Other Action Weekly progress report by ALTA Geosciences provided to ADEC and EPA via email Friday 6/10/2011. The report lists work performed during the preceding week as 1) Completed Transect Surface Surveys in all areas and manual slug removal activity; 2) Constructed initial stockpile areas; 3) Completed excavation of South Target Line Bench area; and 4) Began Focused Excavation on Fill A2/A3 areas. Work planned for the following week is listed as 1)Complete Focused Excavation on Fill A2/A3 area; 2) Begin general fill excavation of Fill A2/A3 Area; 3) Relocate the fence on the Fill A2/A3 Area to immediately north of the trail. Complete the security fencing in other areas; 4) Submit plan for dealing with surface of the Cut A area; 5) Submit Treatability Study report; and 6) Begin work on Soil Treatment Work Plan. Eileen Olson
6/13/2011 Site Visit A.M. Site visit by staff Robert Weimer; met with ALTA field staff who described work done since Friday morning, on Friday and Saturday. Work included sampling of post-excavation surface of south target line area by XRF and analytical sample collection. All surface lead removed has reportedly been removed from the fill A1 area, a deep fill area at the northwest end of the soccer field footprint. Eileen Olson
6/14/2011 Site Visit A.M. Site visit by staff Robert Weimer met with ALTA field staff who described work done since the previous morning. Continued excavating Fill Areas A2/A3. ADEC staff observed and collected over a dozen lead fragments that were visible on and along the trail to the former stockpiling area. Eileen Olson
6/15/2011 Site Visit A.M. Site visit by staff Robert Weimer met with ALTA field staff who described work done since the previous morning. Continued excavating Fill Areas A2/A3. ADEC staff observed and collected over 20 lead fragments that were visible on and along the trail to the former stockpiling area. Robert Weimer
6/15/2011 Document, Report, or Work plan Review - other Agency letter by DEC and EPA issued that modifies the March 2011 Closure Plan to expand the Area of Contamination (AOC) to include areas outside the Area of Contamination (AOC) established for the site based on observations of lead beyond the perimeter of the AOC established in the Closure Plan. In some cases lead was found using a metal detector, but in most cases lead was identified during visual surveys. In addition to modifying the AOC the letter requires that a plan be submitted by July 1, 2011 for investigation and cleanup of the newly added area. Eileen Olson
6/16/2011 Document, Report, or Work plan Review - other Letter issued by EPA and ADEC (Agencies) providing comments regarding implementation of the March 2011 Closure Plan. The Agencies commented on four areas of the Closure Plan, requesting that field work be documented according to Section 6.1 of the plan; that imported gravel used as perimeter berms for the liner be removed according to Section 4.8 of the plan; that the locations and nature of the boundaries between cut, fill and other areas shown on figures in the Closure Plan be field truthed; and that areas identified as 'cut' areas in the plan that have been identified as being 'fill' areas be characterized and cleaned up as per Section 4.12 of the plan. Eileen Olson
6/16/2011 Site Visit A.M. Site visit by staff Robert Weimer met with ALTA field staff who described work done since the previous morning. Continued excavating Fill Areas A2/A3. Site fencing work was being conducted during the site visit. Robert Weimer
6/17/2011 Site Visit A.M. Site visit by staff Robert Weimer met with ALTA field staff who described work done since the previous morning. Continued excavating Fill Areas A2/A3. Robert Weimer
6/20/2011 Site Visit A.M. Site visit by staff Robert Weimer met with ALTA field staff who described work done since Friday morning. Continued excavating Fill Areas A2/A3. The grass had been cut along the trail to the former stockpile area and much of the pea gravel had been removed. Discussed with ALTA field staff that there is an area of soil in A3 near the south target line that still needs to be removed, there were areas where the pea gravel was not removed to the fill surface, some areas of cut grass had over an inch of cut material covering (the cut material was not collected), and the grass cutting was not conducted along the trail to the north. ALTA field staff said that work would be completed and that the removed gravel areas with be screened with the metal detector. Robert Weimer
6/21/2011 Document, Report, or Work plan Review - other ADEC and EPA review the results of the Lead/Antimony Correlation Study and the Field XRF Correlation Study. ADEC issues a joint agency approval letter for suspending laboratory analysis for Antimony in soils that are screened clean for Lead. The letter also approves that soils which are not visibly impacted and which exhibit 50 ppm Lead or less on the XRF be considered clean. Robert Weimer
6/21/2011 Update or Other Action ADEC and EPA review the results of the Soth Target Line sampling. ADEC issues a joint agency approval letter of non-objection to begin backfilling this area. Robert Weimer
6/22/2011 Site Visit A.M. Site visit by staff Robert Weimer met with ALTA field staff who described work done since Monday morning. Continued excavating Fill Areas A2/A3. They have hand dug the areas with metal detector hits on the surface of A2. They have also removed the remaining A3 Fill soils next to the South Target Line. Much of the A2 Fill closer to the trail had XRF readings greater than 50 ppm. ALTA field staff said that they plan to have the remaining gravel areas removed this afternoon so the surface of those areas can be screened with the metal detector. They have begun filling in the South Target Line area with "clean" excavated soil. Robert Weimer
6/23/2011 Site Visit A.M. Site visit by staff Robert Weimer met with ALTA field staff who described work done since yesterday morning and planned work for the next few days. Continued excavating the west end of Fill Area A2. Much of the A2 Fill closer to the trail had XRF readings greater than 50 ppm. ALTA field staff said that they plan to have the remaining gravel areas removed this afternoon so the surface of those areas can be screened with the metal detector. They have nearly completed filling in the South Target Line area with "clean" excavated soil. They will submit the results of the Fill Area A3 excavation and the eastern end of the Fill Area A2 excavation so those areas can be approved to be backfilled. ALTA will submit a plan for collecting surface XRF readings for each 5x5 foot area where visibly contaminated soils or >50 ppm XRF soils were removed from that surface. This could include XRF readings of soil in the excavator bucket for deeper excavations. Robert Weimer
6/24/2011 Site Visit A.M. Site visit by staff Robert Weimer met with ALTA field staff who described work done since yesterday morning and planned work for the next few days. Continued excavating the west end of Fill Area A2. Much of the A2 Fill closer to the trail had XRF readings greater than 50 ppm. ALTA field staff said that they plan to have the remaining gravel area on the north end of the soccer field removed this afternoon so the surface of that area can be screened with the metal detector. They have nearly completed filling in the South Target Line area with "clean" excavated soil and they have begun to fill in Fill Area A3 excavation and the eastern end of the Fill Area A2 those areas had less than 50 ppm on the XRF at the base of the excavation or the layer of soil just above the base of the excavation. They plan to finish up excavating A2 in the next few days and plan to start excavating Fill A1 area on Monday or Tuesday next week. ALTA field staff confirmed that the surface soils of Fill Area A1 where they found numerous lead fragments will be placed in the visibly contaminated pile after excavation. Robert Weimer
6/27/2011 Site Visit A.M. Site visit by staff Robert Weimer met with ALTA field staff who described work done since friday morning and planned work for the next few days. Excavation of the west end of Fill Area A2 was completed. The remaining gravel area on the north end of the soccer field was removed and the surface of that area was checked with the metal detector and two lead fragments were found. They were currently backfilling the Fill Area A2 with "clean" excavated soil. They plan to begin removing surface soils of Fill Area A1 on Wednesday where they found numerous lead fragments will be placed in the visibly contaminated pile after excavation. They also sampled the >50 ppm Lead on the XRF stockpiles and hope to have results back by Tuesday. Robert Weimer
6/29/2011 Site Visit A.M. Site visit by staff Robert Weimer met with ALTA field staff who described work done since Monday morning and planned work for the next few days. They plan to begin removing surface soils of Fill Area A1 in the next few days where they found lead fragments in the past will be placed in the visibly contaminated pile needing treatment after excavation. They were beginning cut the grass on the areas besides and along the paved portion of the trail to the west of the site. During the site visit Robert Weimer collected over 25 lead fragments that were visible on the surface in areas that had already been swept with the metal detectors in the Cut A area of the field. Robert Weimer
6/30/2011 Site Visit A.M. Site visit by staff Robert Weimer met with ALTA field staff who described work done since Wednesday morning and planned work for the next few days. They plan to begin removing surface soils of Fill Area A1 tomorrow where they found lead fragments in the past will be placed in the visibly contaminated pile needing treatment after excavation. They were beginning to conduct a metal detector and visual sweep of the areas besides and along the trail to the west and southwest of the site. During the site visit Robert Weimer collected over 150 lead fragments that were visible on the surface in areas that had already been swept with the metal detectors, including 4 lead fragments on the dirt trail to the southwest of the field, and 75 lead fragments from one 10x10 foot area in the Cut A area of the field. Robert Weimer
6/30/2011 Document, Report, or Work plan Review - other Agency plan review letter issued with subject line "EPA and ADEC ("Agency") conditional approval of ALTA Geosciences, Inc. "Project Memorandum Re: Cut A/FillA 1 Top Surface Remediation Procedures"". The ALTA submittal was dated and received June 27, 2011. The Agencies approved the proposed approach to remove surface soil within the grids where visible lead was present or was removed throughout the accessible Fill Al and Cut A areas with the conditions listed in the letter. Eileen Olson
7/1/2011 Site Visit A.M. Site visit by staff Robert Weimer met with ALTA field staff who described work done since Thursday morning and planned work for the next few days. They plan to begin removing surface soils of Fill Area A1 today where they found lead fragments in the past will be placed in the visibly contaminated pile needing treatment after excavation. ALTA field staff said that all of the under 400 ppm lead lab samples passed TCLP so those soils were being used as backfill in the Fill A2 area. They had conducted a metal detector and visual sweep of the areas besides and along the trail to the west and southwest of the site. The areas along the paved trail did not have lead, but the dirt trail areas did. Over 200 metal detector hits were identified along the dirt trail, over 40 besides the trail, and over 40 leading to and at the former stockpile area. ALTA will investigate how deep the disturbed soil is in all of those areas that could have lead fragments. They were preparing additional stockpile areas for the visually contaminated soils. Robert Weimer
7/5/2011 Site Visit A.M. Site visit by staff Robert Weimer met with ALTA field staff who described work done since Friday morning and planned work for the next few days. They plan to continue removing surface soils of Fill Area A1 where they found lead fragments in the past will be placed in the visibly contaminated pile needing treatment after excavation. They were still getting some metal detector hits on the new surface, they had excavated 4 locations and found intact slugs at 3 of locations and a shell casing at one. The former stockpile area near the dirt trail has about 50 locations where they got metal detector hits, those areas have not been excavated yet. Robert Weimer
7/6/2011 Site Visit A.M. Site visit by staff Robert Weimer met with ALTA field staff who described work done since Tuesday morning and planned work for the next few days. They plan to continue removing surface soils of Fill Area A1 where they found lead fragments in the past will be placed in the visibly contaminated pile needing treatment after excavation. They were still getting metal detector hits on the new surface, and have dug additional 3 inch lifts. They had about 30 locations with lead after the first lift, then about 15 of them after the next lift. They were beginning to assess the next lift below those 15 locations. At one of the locations they recovered about a dozen lead slugs. The lead recovered was intact slugs or partially flattened slugs. They were preparing additional stockpile areas for the additional visually impacted soils. Robert Weimer
7/7/2011 Site Visit A.M. Site visit by staff Robert Weimer met with ALTA field staff who described work done since Wednesday morning and planned work for the next few days. They have finished removing surface soils of Fill Area A1 where they found lead fragments in the past will be placed in the visibly contaminated pile needing treatment after excavation. They took XRF readings of the base of each area excavated and all of the XRF readings were below 50 ppm. They have begun excavation the deeper soils of the Fill Area A1, starting at the southwest corner. So far all of the XRF readings were non detect. Robert Weimer
7/8/2011 Site Visit A.M. Site visit by staff Robert Weimer met with ALTA field staff who described work done since Thursday morning and planned work for the next few days. They have begun excavation the deeper soils of the Fill Area A1, starting at the southwest corner. So far all of the XRF readings were non detect. They have encountered a lot of buried logs on top of the former ground surface including areas under the field. The excavator confirmed that when they constructed the field they dozed over the existing trees and brush prior to backfilling, but they tried to push the trees outside of the field area, so most of them would be buried under the slopes. Robert Weimer
7/9/2011 Site Visit P.M. Site visit by staff Eileen Olson to observe, from outside the site perimeter fence, the work done, which entailed continued excavation of the deeper soils within Fill Area A1, starting at the southwest corner. Contaminated stockpiles were covered and secure. Robert Weimer
7/12/2011 Site Visit A.M. Site visit by staff Robert Weimer met with ALTA field staff who described work done since Friday morning and planned work for the next few days. They continue to excavate the deeper soils of the Fill Area A1, starting at the southwest corner. So far all of the XRF readings were non detect or below 50 ppm. They have encountered a lot of buried logs on top of the former ground surface including areas under the field. The excavator confirmed that when they constructed the field they dozed over the existing trees and brush prior to backfilling, but they tried to push the trees outside of the field area, so most of them would be buried under the slopes. They removed approximately 40 cubic yards (~60 tons) of visually/metal detector hit contaminated soil from and besides the south trail, and the former stockpile area. Excavation continued until no visual or metal detector hit soils remained. The areas were then checked with the XRF on a 5X5 or closer grid, and all readings were below 50 ppm. Those areas were then backfilled with clean soil after excavation was completed. ATLA estimated that there is a total of 575 cubic yards (~826 tons) of contaminated soil currently stockpiled to be treated, the rest of the excavated soil has had XRF readings <50 ppm or analytical samples demonstrating that it meets default cleanup levels. Robert Weimer
7/14/2011 Site Visit A.M. Site visit by staff Robert Weimer met with ALTA field staff who described work done since Tuesday morning and planned work for the next few days. They continue to excavate the deeper soils of the Fill Area A1, starting at the southwest corner. They have begun backfilling portions of the Fill Area A1 that they have already checked out as being <50 ppm lead on the XRF and organic soils that are being backfilled are being placed beneath the slope and not under the field. ALTA will provide information documenting that all of the XRF non-detect readings are <50 ppm lead, they said the detection limit typically ranges between 5 ppm and 10 ppm lead. Robert Weimer
7/15/2011 Site Visit A.M. Site visit by staff Robert Weimer met with ALTA field staff who described work done since Thursday morning and planned work for the next few days. They continue to excavate the deeper soils of the Fill Area A1, starting at the southwest corner. They continue backfilling portions of the Fill Area A1 that they have already checked out as being <50 ppm lead on the XRF and organic soils that are being backfilled are being placed beneath the slope and not under the field. ALTA will provide information documenting that all of the XRF non-detect readings are <50 ppm lead, they said the detection limit typically ranges between 5 ppm and 10 ppm lead. Robert Weimer
7/15/2011 Meeting or Teleconference Held Rosemary Shinohara from the Anchorage Daily News called this afternoon about the status of the Kincaid Park Former Biathlon Range contaminated site cleanup, the cost of the project and who is paying for it. Staff provided her with the link to the on-line contaminated sites database report as a good resource as to the contaminated site history and current site work. Staff also provided her with an electronic copy of the ADEC/EPA approved “Clean Closure and Site Cleanup Plan” (Cleanup Plan) for this site, which contains a cost estimate for conducting the site cleanup. Staff discussed what areas of the site had been cleaned up and what areas they were still working on. Robert Weimer
7/18/2011 Site Visit A.M. Site visit by staff; Robert Weimer met with ALTA field staff who described work done since Friday morning and planned work for the next few days. They continue to excavate the deeper soils of the Fill Area A1, starting at the southwest corner and working north. They have had a few more detectable XRF readings in the excavated soil with the highest being 30 ppm. They continue backfilling portions of the Fill Area A1 that they have already checked out as being <50 ppm lead on the XRF. Organic soils that are being backfilled are being placed beneath the slope and not under the field. Did a visual walkthrough of some of the Cut A area outside of the current green flagged areas. Recovered 23 flattened lead fragments visible on the surface between rows 110 and 170 and columns F and N, including one flattened lead fragment from area F-130 of the lead fragment map, which previously had no lead fragments detected or recovered during the metal detector sweep. ALTA hopes to complete excavation of Fill Area A1 by the end of this week or early next week. ALTA expects to submit a treatment plan for treating stockpiled lead-contaminated soil soon; treatment may take place concurrently with excavation of remaining lead-contaminated soil. Robert Weimer
7/20/2011 Site Visit A.M. Site visit by staff. Robert Weimer met with ALTA field staff who described work done since Monday morning and planned work for the next few days. They continue to excavate the deeper soils of the Fill Area A1, starting at the southwest corner and working north. They have had a few more detectable XRF readings in the excavated soil with the highest being around 12 ppm. They continue backfilling portions of the Fill Area A1 that they have already checked out as being <50 ppm lead on the XRF. They are getting into an area that has a lot of organic soils under the excavated slope. These organic soils so far have all been <50 ppm lead on the XRF and are being reused as backfill beneath the slope and not under the field. Discussed with ALTA field staff that care should be taken so that the remaining contamination in the Cut A Area is not graded into soils being backfilled in the Fill Area A1. Robert Weimer
7/20/2011 Site Visit A.M. Site visit by staff. Robert Weimer met with ALTA field staff who described work done since Monday morning and planned work for the next few days. They continue to excavate the deeper soils of the Fill Area A1, starting at the southwest corner and working north. They have had a few more detectable XRF readings in the excavated soil with the highest being around 12 ppm. They continue backfilling portions of the Fill Area A1 that they have already checked out as being <50 ppm lead on the XRF. They are getting into an area that has a lot of organic soils under the excavated slope. These organic soils so far have all been <50 ppm lead on the XRF and are being reused as backfill beneath the slope and not under the field. Discussed with ALTA field staff that care should be taken so that the remaining contamination in the Cut A Area is not graded into soils being backfilled in the Fill Area A1. Robert Weimer
7/21/2011 Document, Report, or Work plan Review - other ADEC and EPA joint review letter issed for consultant ALTA Geosciences memorandum of same date "Fill A1 Progress, Findings, and Potential Opportunities" in which ALTA proposed to change the investigative approach specified in the approved Closure Plan for the site. The letter notes that the proposed change is substantive and would be approvable without a required 30-day public notice by EPA of the modified plan. Eileen Olson
7/22/2011 Document, Report, or Work plan Review - other ADEC notified ALTA and the parties by email that review of the memorandum dated July 13, 2011 (received 7/14/2011) is ongoing and that the proposed actions in the July 13th are not approved and the conditions in the June 30,2011 Agency (EPA & ADEC) review letter remain in effect. Eileen Olson
7/22/2011 Site Visit A.M. Site visit by staff Robert Weimer met with ALTA field staff who described work done since Wednesday morning and planned work for the next few days. They continue to excavate the deeper soils of the Fill Area A1, starting at the southwest corner and working north. They have had a few more detectable XRF readings in the excavated soil with the highest being around 12 ppm. They continue backfilling portions of the Fill Area A1 that they have already checked out as being <50 ppm lead on the XRF. They are getting into an area that has a lot of organic soils under the excavated slope. These organic soils so far have all been <50 ppm lead on the XRF and are being reused as backfill beneath the slope and not under the field. ALTA field staff said that they would be submitting a treatment plan soon and hope to have the treatment chemicals in about 2 weeks. They plan to begin excavating the Cut A soils by early next week to clear up an area to construct the soil treatment cells, they would then move the contaminated soils into the cells, and then complete the assessment and cleanup of the Cut A area under the stockpiles. Discussed with ALTA field staff that there are still some gravel berms that need to be removed and assessed under for lead, so additional lead contaminated areas may be found that need cleanup. They will also provide a corrected figure showing the letters and numbers along the grid lines as they are in the field. They hope to complete all of the assessment work by the end of July, and complete the treatment of the lead contaminated soil by mid August. Robert Weimer
7/25/2011 Site Visit A.M. Site visit by staff. Robert Weimer met with ALTA field staff who described work done since Friday morning and work planned for the next few days. Workers continue to excavate the deeper soils of the Fill Area A1, starting at the southwest corner and working north. They have had a few more detectable XRF readings in the excavated soil with the highest being less than 30 ppm. They continue backfilling portions of the Fill Area A1 that they have already checked out as being <50 ppm lead on the XRF. They are getting into an area that has a lot of organic soils under the excavated slope. These organic soils so far have all been <50 ppm lead on the XRF and are being reused as backfill beneath the slope and not under the field. ALTA field staff said that they would be submitting a treatment plan today and hope to have the treatment chemicals in about 2 weeks. They plan to begin excavating the Cut A soils later this week to clear up an area to construct the soil treatment cells, they would then move the contaminated soils into the cells, and then complete the assessment and cleanup of the Cut A area under the stockpiles. They hope to complete all of the assessment work by the end of July, and complete the treatment of the lead contaminated soil by mid August. Robert Weimer observed and collected 42 lead slugs/fragments from the ground surface just to the north of stockpile cells 2 and 3, and 2 lead fragments from the ground surface just north and just west of stockpile cell 4. Robert Weimer
7/27/2011 Site Visit A.M. Site visit by staff Robert Weimer. Staff met with ALTA field staff who described work done since Monday morning and planned work for the next few days. They continue to excavate the deeper soils of the Fill Area A1, starting at the southwest corner and working north. They have had a few more detectable XRF readings in the excavated soil with the highest being less than 15 ppm. They continue backfilling portions of the Fill Area A1 that they have already checked out as being <50 ppm lead on the XRF. They are getting into an area that has a lot of organic soils under the excavated slope. These organic soils so far have all been <50 ppm lead on the XRF and are being reused as backfill beneath the slope and not under the field. ALTA field staff said that they would be submitting a treatment plan today and hope to have the treatment chemicals in about 2 weeks. They plan to begin excavating the Cut A soils after they finish with the Fill A1 soils this week. They hope to complete all of the assessment work by the end of July, and complete the treatment of the lead contaminated soil by mid August. Robert Weimer
7/28/2011 Document, Report, or Work plan Review - other Agency (DEC and EPA) review letter issued following review of ALTA memorandum dated July 13, 2011 "Cut A Surface Remediation Plans" submitted on July 14, 2011. The memorandum proposed to reduce the area of excavation based on the apparent lack of observed or detected lead in certain areas. The Agency review letter notified the parties that the Agencies did not approve the modifications proposed in the memo, and that the conditions found in the Agencies' June 30, 2011 review letter remain in effect because the surface survey methods used resulted in incomplete detection and removal of lead fragments at and near the ground surface; therefore the assessment and excavation requested in the Agency letter dated June 30th is necessary. Eileen Olson
7/29/2011 Site Visit A.M. Site visit by staff Robert Weimer. Staff met with ALTA field staff who described work done since Wednesday morning and planned work for the next few days. They continue to excavate the deeper soils of the Fill Area A1, starting at the southwest corner and working north. They have had a few more detectable XRF readings in the excavated soil with the highest being less than 15 ppm. They continue backfilling portions of the Fill Area A1 that they have already checked out as being <50 ppm lead on the XRF. They are still in an area that has a lot of organic soils under the excavated slope. These organic soils so far have all been <50 ppm lead on the XRF and are being reused as backfill beneath the slope and not under the field. ALTA field staff said that their XRF had broken down and the manufacturer had sent them an older model while theirs was being repaired. The older model XRF takes about twice as long for readings so during those few days they were only able to excavate and check about half as much soil as normal, which has resulted in the completion date for the project being pushed back a couple of days. They plan to begin excavating the Cut A soils after they finish with the Fill A1 soils next week. They hope to complete all of the assessment work by early August, and complete the treatment of the lead contaminated soil by mid/late August. Robert Weimer
7/29/2011 Document, Report, or Work plan Review - other Agency (DEC and EPA) plan review letter issued following review of the "Soil Treatment Plan...July 2011" prepared by consultant ALTA Geosciences and submitted on July 27, 2011. The Agencies requested a revised plan that incorporates requirements listed in the review letter. Eileen Olson
8/1/2011 Site Visit A.M. Site visit by staff Robert Weimer. Staff met with ALTA field staff who described work done since Friday morning and planned work for the next few days. They continue to excavate the deeper soils of the Fill Area A1, starting at the southwest corner and working north. On Saturday they removed 2 cubic yards of ground/chipped material that had a XRF reading >1000 ppm with no visible lead. That soil was placed in the to be treated soil pile. All other soils had XRF readings were below 25 ppm. They are still in an area that has a lot of organic soils under the excavated slope. ALTA field staff said that they would be submitting a revised treatment plan today based on the Agencies letter of 7-29-11. They plan to begin excavating the Cut A soils after they finish with the Fill A1 soils this week. They hope to complete all of the assessment work by early August, and complete the treatment of the lead contaminated soil by mid/late August. While in the field DEC staff pointed out to ALTA field staff an area where they were beginning to dig deeper than they need to where it transitioned from the ground/chipped organic fill to the old natural ground surface. Robert Weimer
8/1/2011 Update or Other Action The Agencies (ADEC and EPA) received a revised "Soil Treatment Plan...August 2011" in response to the the Agency review letter issued July 28, 2011. Eileen Olson
8/3/2011 Update or Other Action DEC staff were interviewed by Channel 11 news regarding the progress of the clean up and current clean up costs for the site. The interview was part of the 10 PM telecast that evening about the Kincaid site cleanup. The written transcript of the broadcast is on file. Robert Weimer
8/3/2011 Site Visit A.M. Site visit by staff Robert Weimer. Staff met with ALTA field staff who described work done since Monday morning and planned work for the next few days. They continue to excavate the deeper soils of the Fill Area A1, starting at the southwest corner and working north. They are still in an area that has a lot of organic soils under the excavated slope. They plan to begin excavating the Cut A soils after they finish with the Fill A1 soils this week. There was a surveyor at the site to measure and estimate the volume of soil currently stockpiled to be treated, and the volume of soil that will need to be treated from the Cut A area. They hope to complete all of the assessment work by early August, and complete the treatment of the lead contaminated soil by mid/late August. Robert Weimer
8/5/2011 Site Visit A.M. Site visit by staff Robert Weimer. Because of the recent rains and muddy soil conditions they were not going to be conducting field work this day They hope to resume work on Saturday and may work on Sunday. Since Wednesday morning they had excavated additional soils of the Fill Area A1. They hope to finish excavating and backfilling the Fill Area A1 by Wednesday next week, then start removing the Cut A soils. They hope to complete all of the assessment work by mid August, and complete the treatment of the lead contaminated soil by late August. During the site walkthrough a flattened projectile was observed on the ground surface, photographed, and recovered by DEC staff from grid square 170-Y, which is an area where lead fragments were not detected during the metal detector sweep. During the site visit DEC observed that grid squares 320-O, 320-N, and 330-N appear to have been excavated and backfilled as part of the Fill Area A1 site work. Robert Weimer
8/8/2011 Site Visit A.M. Site visit by staff Robert Weimer. Staff met with ALTA field staff who described work done since Friday morning and planned work for the next few days. They continue to excavate additional soils of the Fill Area A1. They hope to finish excavating and backfilling the Fill Area A1 by Wednesday this week, then start removing the Cut A soils. They hope to complete all of the assessment work by mid August, and complete the treatment of the lead contaminated soil by late August. They plan to remove the liners from stockpile areas 2 and 3 so they can assess and remove contaminated soil from those areas. The surveyor estimated that 520 cubic yards of soil are currently stockpiled to be treated, which is less than the original 577 cubic yard estimate. With the contaminated soil remaining in the Cut A area, ALTA estimates that they will have between 900 and 1000 cubic yards of the contaminated soil that will need to be treated. We discussed that during soil treatment that care needs to be taken so the liner underneath is not damaged. Robert Weimer
8/10/2011 Site Visit A.M. Site visit by staff Robert Weimer. Staff met with ALTA field staff who described work done since Monday morning and planned work for the next few days. They continue to excavate additional soils of the Fill Area A1. They hope to finish excavating and backfilling the Fill Area A1 today or early Thursday, then start removing the Cut A soils. They hope to complete all of the assessment work by mid August, and complete the treatment of the lead contaminated soil by late August. They plan to remove the liners from stockpile areas 2 and 3 so they can assess and remove contaminated soil from those areas. Robert Weimer
8/10/2011 Document, Report, or Work plan Review - other Reviewed August 10th attachment to email by ALTA Geosciences of Cut A figure and proposed field procedures for the Cut A soil assessment and removal. Talked with ALTA staff about corrections needed to the Cut A figure (add Y170 and surrounding area, and correct the size and location of the stockpile areas) and the proposed field procedures. ALTA staff said they would make the corrections and submit revisions. Robert Weimer
8/11/2011 Site Visit A.M. Site visit by staff Robert Weimer. Staff met with ALTA field staff who described work done since Wednesday morning and planned work for the next few days. They have finished assessing Fill Area A1, except for the section along the base that they plan to assess after completing the Cut A area cleanup. They hope to finish backfilling the other areas of Fill Area A1 with clean soils this week. They were starting to remove the liners at of the former stockpiles 2 and 3, and the grid squares were being marked in preparation to beginning the Cut A area cleanup. ALTA staff mentioned that the start of the soil treatment may be delayed because they are still in discussions with the vendor for the treatment chemicals as to the amount and type of chemicals to be used to treat the lead contaminated soils, and thus the chemicals have not been ordered yet. Once the chemicals are ordered it will take about a week for them to arrive at the site. Robert Weimer
8/12/2011 Site Visit A.M. Site visit by staff Robert Weimer and Eileen Olson. Backfilling of Fill A1 area in progress using confirmed clean stockpiled soil. Eileen Olson
8/15/2011 Site Visit A.M. Site visit by staff Robert Weimer. Staff met with ALTA field staff who described work done since Friday morning and planned work for the next few days. They have begun to excavate the soils at the base of the Fill Area A1, all readings so far were below 50 ppm. They have also started excavating Cut A soils along row A-B north of stockpile 5, ALTA field staff said that all XRF reading were below 50 ppm and no visible or metal detector lead was found. The thickness of the Cut A soils in that row was about 2 to 3 inches. The liners have been removed from stockpile areas 2 and 3, a visual walk through by ADEC staff of those area found and recovered 23 projectile fragments. This included two grid squares (K-L 40-50, and L-M 100-110) that had not had visible projectile fragments found during the previous metal detector survey. ALTA field staff said that FESI requested additional contaminated soil be shipped to them so they could do more treatability design testing, which will result in delays in getting the treatment of the soils completed. FESI is still evaluating whether the FESI dry product (which is available in Anchorage) or the FESI wet product (which has to be shipped from Seattle) would work better in treating the lead contaminated stockpile soils. ATLA now hopes to complete all of the assessment work before the end of August, and complete the treatment of the lead contaminated soil by mid/late September. Robert Weimer
8/18/2011 Site Visit A.M. Site visit by staff Robert Weimer. Staff met with ALTA field staff who described work done since Monday morning and planned work for the next few days. They have completed the assessment of the soils at the base of the Fill Area A1, all readings were below 50 ppm. They have also started excavating Cut A soils and hope to have all of it done except for the soil under stockpile 5 by Saturday, ALTA field staff said that they had two XRF reading that were above 50 ppm below where they removed visible lead in the Cut A area. There were also a few areas where they need to remove additional soil in the Cut A area to get to the natural ground surface. They were just finishing removing the last of the clean soil from stockpile 1. ALTA field staff said that FESI is still testing the soil they sent them to determine the best product and application rate for treating the lead contaminated stockpile soils. ATLA hopes to complete all of the assessment work before the end of August, and complete the treatment of the lead contaminated soil by mid/late September. Robert Weimer
8/22/2011 Site Visit A.M. Site visit by staff Robert Weimer. Staff met with ALTA field staff who described work done since Thursday morning and planned work for the next few days. They hope to finish excavating Cut A soils except for the soil under stockpile 5 by Friday this week. There were some areas that they had to excavate more soil because XRF reading that were above 50 ppm below where they removed visible lead. ALTA field staff said that they hope to submit a soil treatment plan on Thursday or Friday this week after they receive information from FESI to determine the best product and application rate for treating the lead contaminated stockpile soils. ATLA hopes to complete the treatment of the lead contaminated soil by mid/late September. Robert Weimer
8/25/2011 Site Visit A.M. Site visit by staff Robert Weimer. Staff met with ALTA field staff who described work done since Monday morning and planned work for the next few days. They hope to finish excavating Cut A soils except for the soil under stockpile 5 by Friday. There were some areas where they had to excavate more soil because XRF readings were above 50 ppm or they were still getting metal detector hits below where they removed visible lead. ALTA field staff said that they hope to submit a soil treatment plan soon after they receive information from FESI to determine the best product and application rate for treating the lead contaminated stockpile soils. ALTA hopes to complete the treatment of the lead contaminated soil by mid/late September. Robert Weimer
8/25/2011 Site Visit A.M. Site visit by staff Robert Weimer. Staff met with ALTA field staff who described work done since Monday morning and planned work for the next few days. They hope to finish excavating Cut A soils except for the soil under stockpile 5 by Friday. There were some areas where they had to excavate more soil because XRF readings were above 50 ppm or they were still getting metal detector hits below where they removed visible lead. ALTA field staff said that they hope to submit a soil treatment plan soon after they receive information from FESI to determine the best product and application rate for treating the lead contaminated stockpile soils. ALTA hopes to complete the treatment of the lead contaminated soil by mid/late September. Robert Weimer
8/26/2011 Site Visit A.M. Site visit by staff Robert Weimer. Staff met with ALTA field staff who described work done since Thursday morning and planned work for the next few days. They hope to finish excavating Cut A soils except for the soil under stockpile 5 today. There were some areas that they had to excavate more soil because XRF reading that were above 50 ppm or they were still getting metal detector hits below where they removed visible lead. ALTA field staff said that they hope to submit a soil treatment plan this week after they receive information from FESI to determine the best product and application rate for treating the lead contaminated stockpile soils. ATLA hopes to complete the treatment of the lead contaminated soil by mid/late September. Robert Weimer
8/29/2011 Site Visit A.M. Site visit by staff Robert Weimer. Staff met with ALTA field staff who described work done since Friday morning and planned work for the next few days. They have finished excavating Cut A soils except for the soil under stockpile 5. ALTA field staff said that they hope to submit a soil treatment plan this week after they receive information from FESI to determine the best product and application rate for treating the lead contaminated stockpile soils. ALTA hopes to complete the treatment of the lead contaminated soil by mid/late September. Robert Weimer
9/1/2011 Site Visit Afternoon site visit by staff Robert Weimer. Staff met with ALTA field staff who were evaluating different mixing methods for conducting a pilot test of using 1 percent calcium phosphate (fertilizer) and 6 percent lime (pH buffer) to treat the excavated contaminated soil currently stockpiled at the site. ATLA selected 10 cubic yards of some of the most highly contaminated soil to do the pilot test on. They attempted to use two different types concrete mixing trucks to mix the soils, but the soils had too much silt in them to run through or load into the trucks efficiently. They plan to attempt mixing on a liner using a loader bucket tomorrow morning to see if that will work better Robert Weimer
9/1/2011 Site Visit Afternoon site visit by staff Robert Weimer. Staff met with ALTA field staff who were evaluating different mixing methods for conducting a pilot test of using 1 percent calcium phosphate (fertilizer) and 6 percent lime (pH buffer) to treat the excavated contaminated soil currently stockpiled at the site. ATLA selected 10 cubic yards of some of the most highly contaminated soil to do the pilot test on. They attempted to use two different types concrete mixing trucks to mix the soils, but the soils had too much silt in them to run through or load into the trucks efficiently. They plan to attempt mixing on a liner using a loader bucket tomorrow morning to see if that will work better. Robert Weimer
9/2/2011 Site Visit Morning site visit by staff Robert Weimer. Staff met with ALTA field staff who were evaluating different mixing methods for conducting a pilot test of using 1 percent calcium phosphate (fertilizer) and 6 percent lime (pH buffer) to treat the excavated contaminated soil currently stockpiled at the site. ATLA selected 10 cubic yards of some of the most highly contaminated soil to do the pilot test on. They successfully mixed the soil on a liner using a loader bucket. ATLA will collect confirmation samples from the 10 cubic yards of pilot test soil and have them analyzed in the laboratory for total lead and TCLP lead. ALTA hopes to submit the lab results to DEC and EPA by September 7, 2011 and submit a treatment plan for review and approval soon after that. They are prepared to begin treatment as soon as they have an approved plan. Once they begin treatment they estimate it should take less than 2 weeks to process and treat all of the stockpiled contaminated soils. Robert Weimer
9/9/2011 Update or Other Action ADEC and EPA (the Agencies) received the "Pilot Test Results" from environmental consultant ALTA that reports the results of analysis of lead-contaminated soil treated with a mixture of phosphates and calcium carbonate compounds, with analysis done for total lead and for leachable lead by the EPA Method 1311 Toxic Characteristic Leaching Procedure or TCLP. The soil treatment is intended to stabilize lead in the soil so that the soil will not fail the TCLP for lead. Soil from the Kincaid site that does not fail the TCLP for lead is not a hazardous waste and can be disposed of at the Anchorage Regional Landfill. Eileen Olson
9/19/2011 Site Visit Afternoon site visit by staff Robert Weimer. Staff met with ALTA field staff who were collecting field screening/confirmation laboratory lab samples from the 24 cubic yard stockpiles that have gone through the treatment process. The treatment process entails the mixing with a loader calcium phosphate (fertilizer) and hydrated lime (pH buffer) in 24 cubic yard batches. They have processed seventeen 24 cubic yard stockpiles (408 cubic yards) so far. They are now processing between 144 and 168 cubic yards each day. They hope to treat all of the stockpiled contaminated soils before the end of September. Robert Weimer
9/21/2011 Site Visit Afternoon site visit by staff Robert Weimer. Staff met with ALTA field staff who were collecting field screening/confirmation laboratory lab samples from the 24 cubic yard stockpiles that have gone through the treatment process. The treatment process entails the mixing with a loader calcium phosphate (fertilizer) and hydrated lime (pH buffer) with excavated contaminated soil in 24 cubic yard batches. They have processed thirty 24 cubic yard stockpiles (720 cubic yards) so far. They are now processing between 144 and 168 cubic yards each day. They hope to treat all of the currently stockpiled contaminated soils by Monday September 26th, then excavate and treat the remaining contaminated soil from the Stockpile 5 Area within a day or two after that. The post treatment lab results for the first processed piles are expected by Thursday September 22nd. Robert Weimer
9/23/2011 Site Visit Afternoon site visit by staff Robert Weimer. Staff met with ALTA field staff who were collecting field screening/confirmation laboratory lab samples from the 24 cubic yard stockpiles that have gone through the treatment process. The treatment process entails the mixing with a loader calcium phosphate (fertilizer) and hydrated lime (pH buffer) with excavated contaminated soil in 24 cubic yard batches. They have processed forty three 24 cubic yard stockpiles (1032 cubic yards) so far. They are now processing between 144 and 168 cubic yards each day. They hope to treat all of the currently stockpiled contaminated soils by late Monday September 26th, then excavate and treat the remaining contaminated soil from the Stockpile 5 Area within a day or two after that. The post treatment lab results for the first 7 pairs of 24 cubic yard processed piles (336 cubic yards) were received on Friday September 23rd and they all passed TCLP testing. Robert Weimer
9/26/2011 Document, Report, or Work plan Review - other EPA and ADEC approval letter for ALTA Geosciences, Inc. revised "Soil Treatment Plan...September 2011" received September 19, 2011. The revised plan replaces a previous version having the same title that was transmitted to EPA and ADEC on September 12, 2011. The revised plan was prepared and submitted in response to EPA and ADEC comments received by ALTA on Sept. 19, 2011. Approval of the plan constitutes approval to treat and test lead-contaminated soil for the sole purpose of disposal of the treated soil at a RCRA Subtitle C or D landfill. The approval notes that soils that pass the TCLP for lead may be disposed of at the Anchorage Regional Landfill (a Subtitle D landfill). Soils that do not pass the TCLP must be disposed of at a Subtitle C landfill. Eileen Olson
9/27/2011 Offsite Soil or Groundwater Disposal Approved EPA and ADEC approved transport of treated soil stockpiles designated # 1 through #9 and # 11 through # 14 to the Anchorage Regional Landfill (ARL) in Eagle River, Alaska Eileen Olson
9/27/2011 Site Visit Afternoon site visit by staff Robert Weimer and Eileen Olson. Staff met with ALTA field staff who were collecting field screening/confirmation laboratory lab samples from the 24 cubic yard stockpiles that have gone through the treatment process. The treatment process entails the mixing with a loader calcium phosphate (fertilizer) and hydrated lime (pH buffer) with excavated contaminated soil in 24 cubic yard batches. They have processed forty eight 24 cubic yard stockpiles (1152 cubic yards) so far. They are processing between 144 and 168 cubic yards each day. They hope to treat the remaining 24 to 48 cubic yards of contaminated soil by early Tuesday September 27th, then excavate and the remaining contaminated soil (estimated to be 48 to 96 cubic yards) from the Stockpile 5 Area by Wednesday September 28th, and treat those soils by Thursday September 29th. The post treatment lab results for the first 9 pairs of 24 cubic yard processed piles (432 cubic yards) all passed TCLP testing. ALTA field staff hope to have MOA landfill approval to accept the soils by September 28th. Robert Weimer
9/28/2011 Offsite Soil or Groundwater Disposal Approved Two stockpile transport approval letters sent this date; EPA and ADEC ("Agency") approval granted to transport treated soil stockpiles designated # 15 through # 17 to the Anchorage Regional Landfill (ARL) in Eagle River, and a second letter approving transport of treated soil stockpiles designated # 10 and #18 through #20 to the ARL. Eileen Olson
9/28/2011 Document, Report, or Work plan Review - other EPA and ADEC issued a joint letter of non-objection to soccer field project work taking place following completion of soil excavation, treatment and transport. The letter responded to an inquiry by a Municipality of Anchorage representative regarding whether project work associated with the soccer field and stadium project at the Kincaid Park Former Biathlon Range site can proceed as soon as all excavation, treatment and removal of lead contaminated soil at the site is complete. Project work includes placing gravel over the surface of the project area, trenching to create draining systems, and other earthwork and construction related to completion of the soccer field complex. EPA and ADEC had no objection to project work beginning immediately upon removal of all contaminated soil from the site, with the conditions that 1) the Parties keep the Agencies apprised in a timely manner ofwork in progress within the Area of Concern (AOC), and 2) any soils excavated within the AOC must remain within the AOC and the post-excavation location of such soils tracked until the Closure Report and Closure Certification for the site have been received and accepted by the Agencies. Excavation and placement of any soil excavated within the AOC must be documented and the Agencies notified of such excavation and placement of excavated soil within one week of excavation. Eileen Olson
9/30/2011 Site Visit Afternoon site visit by staff Robert Weimer. Staff met with ALTA field staff who were assessing the Stockpile 5 Area with a metal detector and XRF. They were finishing the removal of the soil from the Stockpile 5 Area. They have processed fifty five 24 cubic yard stockpiles so far with one more 24 cubic yard batch to treat for a total of 1344 cubic yards. The post treatment lab results for the first 20 pairs of 24 cubic yard processed piles (960 cubic yards) all passed TCLP testing and they were beginning to transport those soils to the Anchorage Regional Landfill for disposal. They hope to have the last lab results back by Wednesday October 5th, and complete the removal of the last treated piles and complete all site work by Friday October 7th. Robert Weimer
10/5/2011 Update or Other Action ADEC email to MOA approving placement of crushed gravel cap and sub-drain pipe following removal of treated soil, with request for notification when crushed gravel cap will be placed. Eileen Olson
10/7/2011 Offsite Soil or Groundwater Disposal Approved EPA and ADEC ("Agency") letter issued granting approval to transport treated soil stockpile designated #24 to the Anchorage Regional Landfill (ARL). Eileen Olson
10/9/2011 Update or Other Action ALTA Geosciences submitted electronic copies of the following: 1) final field log books for site work 9/13/2011 through 10/6/2011; 2) Final weekly progress report dated October 7, 2011; and 3) Final XRF logs through 10/5/2011. Eileen Olson
1/10/2012 Update or Other Action ADEC and EPA received copies of "Clean Closure and Site Cleanup Summary Data Report, Former Kincaid Park Biathlon Range Site...January 2012" (appendices to be provided later) prepared by ALTA Geosciences. Eileen Olson
1/19/2012 Exposure Tracking Model Ranking A new updated ranking with ETM has been completed for source area 75717 Lead and antimony from 22-caliber ammunition . Eileen Olson
1/31/2012 Document, Report, or Work plan Review - other ADEC and EPA jointly issued review comments on the draft "Closure Report" received 1/10/2012 and on the appendices received by mail on digital media on 1/30/2012. The agencies require submittal of a Revised Closure Report by February 14, 2012. Eileen Olson
2/7/2012 Update or Other Action ALTA Geosciences provided a memorandum to EPA and ADEC that commented on the review comments issued on January 31, 2012 by EPA and ADEC. Eileen Olson
2/9/2012 Meeting or Teleconference Held ADEC, EPA and representatives of the involved parties held a teleconference to discuss the EPA and ADEC review comments dated January 31, 2012 for the Draft Closure Plan. All issues set forth in the ALTA Geoscience memorandum dated February 7th were addressed and followed up in a letter by EPA and ADEC dated February 13, 2012. Eileen Olson
2/13/2012 Document, Report, or Work plan Review - other ADEC and EPA jointly issued a letter approving the request for an extension of time until March 30, 2012 for submittal of a revised closure report, with the exception of the survey of the site required by EPA that is due on May 15, 2012. EPA noted that failure to submit a report that meets EPA closure requirements by March 30, 2012 will result in the Parties being in violation of EPA's Consent Agreement and Final Order (CAFO) dated October 6, 2010. The letter responded to comments provided in the ALTA Geoscience memorandum dated February 7, 2012 that commented on ADEC and EPA's January 31, 2012 Draft Closure Report review comments. Eileen Olson
3/30/2012 Document, Report, or Work plan Review - other Review comments for the "Clean Closure" report received 3/20/2012 were issued jointly by EPA and ADEC. EPA and ADEC requested that the parties submit a revised closure report by April 15, 2012 and noted that all EPA requirements would not be complete until submittal of a site survey that is due by May 15, 2012. Eileen Olson
4/16/2012 Update or Other Action ADEC and EPA received the revised "Clean Closure and Site Cleanup Summary Data Report". This is the third version of the report; EPA and ADEC provided comments and requested revisions for each of the two previous versions submitted on January 10, 2012 and March 20, 2012. Eileen Olson
4/17/2012 Update or Other Action ADEC and EPA received a letter dated April 16, 2012 by ALTA Geosciences that provided explanation for revisions made and not made to the draft Closure Report received 4/16/2012. Eileen Olson
4/19/2012 Document, Report, or Work plan Review - other EPA and ADEC jointly issued a letter this date requesting additional records relevant to contamination at the site that are referenced in the Closure Report currently under review that was received on April 16, 2012 and in another public document. Eileen Olson
4/24/2012 Document, Report, or Work plan Review - other ADEC and EPA jointly issued a review letter for the "Clean Closure and Site Cleanup Summary Data Report...April 2012" received on April 16, 2012. Review comments centered on estimates of the number of rounds fired during the 20-year life of the range and estimates of the quantity of lead removed from the site, with ADEC and EPA basing estimates on information provided by the responsible parties in April 2009. A revised closure report is due by May 2, 2012, and a survey plan of the site, which has the same boundaries as the EPA-designated "Area of Concern" as defined under hazardous waste regulations, is due by May 15, 2012. Eileen Olson
5/1/2012 Site Visit Site visit to walk the site to identify the boundaries of the Area Of Contamination (AOC) for the final site survey to be completed and submitted by May 15, 2012. They hope to complete the survey on May 2, 2012 and submit the results by May 4, 2012. Robert Weimer
5/11/2012 Cleanup Complete Determination Issued ADEC issued a closure decision document granting Cleanup Complete status. Also on May 11,2012 EPA issued a closure letter with subject line "Approval of Clean Closure and Site Cleanup Summary Data Report and Acceptance of Certification of Clean Closure" for the Kincaid Park Former Biathlon Range Site. The ADEC and EPA decisions were based on review of the Closure Report by ALTA Geosciences received on May 10, 2012. Eileen Olson
5/12/2012 Exposure Tracking Model Ranking A new updated ranking with ETM has been completed for source area 75717 Lead and antimony from 22-caliber ammunition . Eileen Olson
6/7/2012 Update or Other Action ADEC received and acknowledged a letter dated June 7, 2012 from the Kincaid Project Group with subject line "Notice of Intent to Commence Excavation Work at Kincaid Park" describing trenching and utility installation locations and work expected to start on June 11, 2012 within the area of concern at the site. The letter documents KPG's intent to conduct excavation and earthwork with oversight by a qualified person to ensure compliance with the requirements specified in ADEC's May 11, 2012 site closure letter, as well as in compliance with other environmental laws, regulations, and agency guidance, with the plan to stop work if lead contamination or other hazardous materials are observed, and to notify and consult with ADEC, EPA,and KPG to determine the next steps. Work was later completed with no further communications. No follow up was required. Eileen Olson
8/7/2015 Update or Other Action This file has been archived at Alaska Archives Barcode 896977 Box 411 Susan Carberry

Contaminant Information

Name Level Description Media Comments
Lead - Total < Method 2 Most Stringent Soil 400 mg/kg is residential cleanup level.
Antimony - Total < Method 2 Most Stringent Soil 3.6 mg/kg is cleanup level (Method Two, migration to groundwater).

Control Type

Type Details
No ICs Required

Requirements

Description Details
Advance approval required to transport soil or groundwater off-site.

No associated sites were found.

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