2016 Final Decision Document OB/OD Area DD Signed

FT FINAL MMRP PROPOSED PLAN, OB/OD AREA (MRS-04) AND REMAINING OB/OD AREA (MRS-14), FORMER FORT GLENN, UMNAK ISLAND, ALASKA DECISION DOCUMENT

OB/OD AREA (MRS-04) MILITARY MUNITIONS RESPONSE PROGRAM

FORMER FORT GLENN, UMNAK ISLAND, ALASKA

FUDS PROJECT NUMBER: F10AK029804

September 2016

Environmental & Special Programs Branch 2204 3rd Street, P.O. Box 6898 Joint Base Elmendorf-Richardson, Alaska 99506-0898

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DECISION DOCUMENT OB/OD AREA (MRS-04)

FORMER FORT GLENN, UMNAK ISLAND, ALASKA

FUDS # F10AK029804

Prepared for:

U. S. Army Engineering and Support Center Huntsville, Alabama and U. S. Army Corps of Engineers, Alaska District Elmendorf AFB, Alaska

Contract No. W912DY-09-D-0061 Task Order 0002

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4 Table of Contents

Table of Contents Section 1 Declaration ...... 1-1 1.1 Site Names and Location ...... 1-1 1.2 Statement of Basis and Purpose ...... 1-1 1.3 Assessment of Site ...... 1-1 1.4 Description of Selected Remedies ...... 1-1 1.4.1 Remedy Components ...... 1-1 1.4.2 Remedy Performance Criteria...... 1-2 1.5 Statutory Determinations ...... 1-2 1.6 Data Certification Checklist ...... 1-2 1.7 Authorizing Signature ...... 1-3

Section 2 Decision Summary ...... 2-1 2.1 Site Name, Location, and Description ...... 2-1 2.2 Site History and Regulatory Activities ...... 2-1 2.3 Previous Investigations ...... 2-2 2.3.1 Inventory Project Report ...... 2-2 2.3.2 Archive Search Report ...... 2-2 2.3.3 2001 Fort Glenn Remedial Investigation/Interim Removal Action Report ...... 2-3 2.3.4 Disposal/Removal Action ...... 2-3 2.3.5 Archives Search Report Supplement ...... 2-3 2.3.6 Site Inspection Report ...... 2-3 2.3.7 Remedial Investigation ...... 2-4 2.3.8 Feasibility Study ...... 2-4 2.3.9 Proposed Plan...... 2-4 2.4 Community Participation ...... 2-4 2.5 Scope and Role of Response Action ...... 2-5 2.6 Site Characteristics...... 2-5 2.6.1 Climate ...... 2-5 2.6.2 Topography ...... 2-5 2.6.3 Geology ...... 2-6 2.6.4 Hydrogeology ...... 2-6 2.6.5 Hydrology ...... 2-6 2.6.6 Nature and Extent of Contamination ...... 2-7 2.6.7 Conceptual Site Model ...... 2-8 2.7 Current and Potential Future Land and Resources Uses ...... 2-9 2.8 Summary of Site Risks...... 2-9 2.8.1 Human Health Risks ...... 2-9 2.8.2 Ecological Risks...... 2-10 2.9 Remedial Action Objectives and ARARs ...... 2-10 2.9.1 OB/OD Area (MRS-04) Remedial Action Objective ...... 2-11 2.9.2 ARARs ...... 2-11 2.10 Description of Alternatives ...... 2-11

Decision Document i Former Fort Glenn, Umnak Island, Alaska F10AK029804 Table of Contents

2.10.1 Alternative 1 – No Action ...... 2-12 2.10.2 Alternative 2 – LUCs ...... 2-12 2.10.3 Alternative 3 – Focused Surface Removal and LUCs ...... 2-13 2.10.4 Alternative 4 – Surface Removal and LUCs...... 2-14 2.10.5 Alternative 5 – Surface Removal, Focused Subsurface Removal, and LUCs ...... 2-15 2.10.6 Alternative 6 – Surface Removal, Subsurface Removal, and LUCs ...... 2-16 2.10.7 Alternative 7 – Surface Removal, Focused Soil Cover, and LUCs ...... 2-18 2.10.8 Alternative 8 – Focused Surface Removal, Focused Subsurface Removal, and LUCs ...... 2-19 2.11 Summary of Comparative Analysis of Alternatives ...... 2-21 2.11.1 Overall Protection of Human Health and the Environment ...... 2-21 2.11.2 Compliance with ARARs ...... 2-22 2.11.3 Long-Term Effectiveness and Permanence ...... 2-22 2.11.4 Reduction of Toxicity, Mobility, or Volume through Treatment ...... 2-24 2.11.5 Short-Term Effectiveness ...... 2-24 2.11.6 Implementability ...... 2-25 2.11.7 Cost ...... 2-25 2.11.8 Regulatory Agency Acceptance ...... 2-26 2.11.9 Community Acceptance ...... 2-27 2.12 Principal Threat Wastes ...... 2-27 2.13 Selected Remedy ...... 2-27 2.13.1 Description of the Selected Remedy ...... 2-27 2.13.2 Remedy Cost Estimate Summary ...... 2-28 2.13.3 Expected Outcomes of Selected Remedy ...... 2-28 2.14 Statutory Determinations ...... 2-28 2.15 Documentation of Significant Changes ...... 2-29

Section 3 Responsiveness Summary ...... 3-1 3.1 Stakeholder Issues and Lead Agency Responses...... 3-1 3.2 Technical and Legal Issues ...... 3-2

Section 4 References ...... 4-1

Decision Document ii Former Fort Glenn, Umnak Island, Alaska F10AK029804 Table of Contents

List of Tables List of Tables Table 2-1 Detailed Analysis of Remedial Action Alternatives Table 2-2 Cost Summary of Remedial Action Alternatives

List of Figures List of Figures Figure 2-1 Former Fort Glenn Location Map Figure 2-2 OB/OD Area Details Figure 2-3 OB/OD Area RI Visual Survey Results Figure 2-4 OB/OD Area RI Results Figure 2-5 MEC Conceptual Site Model, OB/OD Area (MRS-04) Figure 2-6 MC Conceptual Site Model, OB/OD Area (MRS-04)

List of Appendices List of Appendices Appendix A Public Participation

Decision Document iii Former Fort Glenn, Umnak Island, Alaska F10AK029804 Table of Contents

Acronyms and Abbreviations Acronyms and Abbreviations ADEC Alaska Department of Environmental Conservation ARAR applicable or relevant and appropriate requirement ASR Archive Search Report bgs below ground surface BIP blown in place BLM Bureau of Land Management CAFB Cape Air Force Base CELMS Corps of Engineers, St. Louis CEPOA Corps of Engineers Pacific Ocean, Alaska CERCLA Comprehensive Environmental Response, Compensation, and Liability Act of 1980 CFR Code of Federal Regulations COPC chemical of potential concern CSM conceptual site model DD Decision Document DDESB Department of Defense Explosives Safety Board DMM discarded military munitions DoD Department of Defense EOD Explosive Ordnance Disposal ESS Explosives Safety Submission FS Feasibility Study DGM digital geophysical mapping EM Engineering Manual EMM earth moving machinery INPR Inventory Project Report LUC land use control MC munitions constituents MD munitions debris MEC munitions and explosives of concern mm millimeter MMRP Military Munitions Response Program

Decision Document iv Former Fort Glenn, Umnak Island, Alaska F10AK029804 Table of Contents

MRS Munitions Response Site MRSPP Munitions Response Site Prioritization Protocol NCP National Oil and Hazardous Substances Pollution Contingency Plan NWI National Wetlands Inventory O&M operation and maintenance OB/OD Open Burning/Open Detonation PP Proposed Plan RAC Risk Assessment Code RAO remedial action objective RCRA Resource Conservation and Recovery Act RI Remedial Investigation RRD range-related debris SI Site Inspection SUXOS Senior UXO Supervisor TBC to be considered TNT trinitrotoluene TPP Technical Project Planning URS URS Group, Inc. USACE United States Army Corps of Engineers USEPA United States Environmental Protection Agency UU/UE unlimited use and unrestricted exposure UXO unexploded ordnance UXOQCS UXO Quality Control Specialist UXOSO UXO Safety Officer

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Decision Document vi Former Fort Glenn, Umnak Island, Alaska F10AK029804 1 Declaration

SECTIONONE Declaration

1.1 SITE NAME AND LOCATION

Site Name: OB/OD Area (MRS-04)

Location: Umnak Island, Alaska

1.2 STATEMENT OF BASIS AND PURPOSE

In accordance with the Defense Environmental Restoration Program (DERP)-FUDS (10 USC 2700 et seq.), this Decision Document (DD) presents the United States (U.S.) Army Corps of Engineers (USACE) selected remedy for the Open Burning/Open Detonation (OB/OD) Area (Munitions Response Site [MRS]-04) at the former Fort Glenn, Umnak Island, Alaska. The selected remedial action was chosen in accordance with the Comprehensive Environmental Response, Compensation, and Liability Act of 1980 (CERCLA), as amended by the Superfund Amendments and Reauthorization Act of 1986, and the National Oil and Hazardous Substances Pollution Contingency Plan (NCP).

1.3 ASSESSMENT OF SITE

The selected remedy in this DD for the OB/OD Area (MRS-04) is necessary to protect the public health or welfare or the environment from actual or threatened releases of hazardous substances, pollutants, or contaminants from these sites, which may present an imminent and substantial endangerment to public health or welfare.

1.4 DESCRIPTION OF SELECTED REMEDIES

This DD addresses munitions and explosives of concern (MEC) at the OB/OD Area (MRS-04). USACE will be responsible for implementing, maintaining, and monitoring the remedial actions identified for the duration of the remedies selected in this DD. With regard to the implementation of certain Land Use Controls (LUCs), USACE may only act within its authorities and may only assist with implementation of certain suggested controls as described below. It will exercise this responsibility under the DERP statute and in accordance with CERCLA and the NCP.

Based on information currently available, USACE believes the selected remedy meets the threshold criteria and provide the best balance of tradeoffs among the other alternatives with respect to the balancing and modifying criteria. USACE expects the selected remedy to satisfy the requirements of CERCLA by protecting human health and being cost-effective.

The selected remedy for the OB/OD Area (MRS-04) is Alternative 5 – Surface Removal, Focused Subsurface Removal, and LUCs.

1.4.1 Remedy Components

The remedy for the OB/OD Area (MRS-04) will include the following general components:

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• MEC detection, demolition, and off-site disposal of munitions debris (MD) will reduce potential interaction with human receptors. In addition, LUCs will further reduce the potential for receptor interaction with potential MEC that may remain.

1.4.2 Remedy Performance Criteria

The remedy will have the following performance criteria at the OB/OD Area (MRS-04): • Reduce the potential for direct contact with MEC by human receptors, considering the current and future land use.

Performance metrics for the remedy criterion will be included in the remedial design.

1.5 STATUTORY DETERMINATIONS

The selected remedy for the OB/OD Area (MRS-04) is protective of human health and the environment, complies with federal and state requirements that are legally applicable or relevant and appropriate to the remedial action, and utilizes permanent solutions to the maximum extent practicable.

Because the remedy at the OB/OD Area (MRS-04) will not remove all sources of hazardous substances (i.e., MEC below the depth of detection and MEC covered by lahar deposition) below levels that would allow unlimited use and unrestricted exposure (UU/UE), a statutory review will be completed within 5 years after initiation of the remedial action to ensure that the remedy remains protective of human health and the environment. Subsequent reviews will be conducted at least once every five years until the site is acceptable for UU/UE.

1.6 DATA CERTIFICATION CHECKLIST

The following information is addressed for the OB/OD Area (MRS-04) in Section 2 of this DD: • How source materials constituting principal threats are addressed • Current and reasonably anticipated future land use assumptions and current and potential future beneficial uses of groundwater • Land and groundwater use that will be available at the site as a result of the selected remedy • Total capital cost, annual and total operation and maintenance (O&M) cost, total periodic cost, overall total cost, total present value, and the number of years over which the remedy cost estimates are projected • Key factors that led to selecting the remedy (i.e., describe how the selected remedy provides the best balance of trade-offs with respect to the balancing and modifying criteria, highlighting criteria key to the decision)

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1.7 AUTHORIZING SIGNATURE

This DD presents the Selected Remedy of surface removal over 337 acres, a focused subsurface . removal over 30 acres, and LU Cs at the OB/OD Area (MRS-04) of the Fort Glenn Formerly Used Defense Site (FUDS) located on Umnak Island, Alaska. This DD will be incorporated into the Administrative File for the OB/OD Area, Fort Glenn FUDS which is available for public review. The USA CE is the lead agency under the Defense Environmental Restoration Program at the Fort Glenn FUDS, and has developed this DD consistent with CERCLA, as amended, and the NCP. This document, presenting a selected remedy with a present worth cost estimate of less than $10 million, is approved by the undersigned, pursuant to Memorandum, DAIM-ZA, September 9, 2003, Subject: Policies for Staffing and Approving Decision Documents (DDs) and Engineer Regulation 200-3-1, Formerly Used Defense Sites Program Policy.

For the United States Army Corps of Engineers:

Chief, Environm tal Division Directorate of Military Programs

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Decision Document 1-4 Former Fort Glenn, Umnak Island, Alaska F10AK029804 2 Decision Summary

SECTIONTWO Decision Summary

2.1 SITE NAME, LOCATION, AND DESCRIPTION

The former Fort Glenn is located on the eastern end of Umnak Island in the Fox Islands of the Aleutian Island Chain of Alaska (Figure 2-1). Umnak Island lies approximately 50 miles southwest of Dutch Harbor and 850 miles southwest of Anchorage, Alaska. The Fort Glenn installation has been abandoned since it was excessed to the Department of the Interior in 1955 as described in paragraph 2.2, and remnants of hundreds of structures are scattered over the 102,000 acres of the former installation. There is a system of cinder roads throughout the former installation, some of which are in reasonably good shape for vehicular traffic. Three cinder runways are also present, one of which was re-graded during the Remedial Investigation (RI) and is suitable for light aircraft. The only occupants at the former installation are employees of the Bering Pacific Ranches Limited, which has leased the property since 1993. Their ranch house and slaughtering facility is located in the middle of the former Fort Glenn installation. Although Umnak Island is remote with no towns or cities on the eastern end of the island, public access is not restricted and is open in many areas. There is a landing beach on the east coastline at Otter Bight.

The OB/OD Area is located in the southeastern portion of the former Fort Glenn installation (Figure 2-2). Based on the Remedial Investigation recommendations, USACE completed an administrative delineation of the Fort Glenn OB/OD Munitions Response Area (MRA) (2,076 acres) for project management purposes. The delineation supports the DoD requirement to maintain an accurate inventory of sites suspected of containing munitions and explosives of concern (MEC) or munitions debris (MD). The original OB/OD Area was divided into 2 separate projects consisting of the OB/OD Area (337 acres) which is the subject of this Decision Document, and the Remaining OB/OD Area (MRS-14) (1,739 acres) which is addressed under a separate Decision Document. The entire 2,076-acre OB/OD Area and Remaining OB/OD Area are currently owned by the State of Alaska Department of Transportation and Public Facilities. The site vicinity consists of small gently rolling hills on the northeast and southwest sides with a small valley in the center. Two distinct clusters of suspected demolition craters were identified in historical aerial photographs. The largest craters are located at approximately N 53° 22′ 56″ W 167° 56′ 51″, and the other craters are located approximately 0.5 mile to the southeast. These two clusters of demolition clusters are identified as the Focus Area and consist of approximately 30 acres (Figure 2-2).

2.2 SITE HISTORY AND REGULATORY ACTIVITIES

Fort Glenn was established in 1942 as a 102,062-acre Army Airfield and defense garrison to support the United States Naval Base at Dutch Harbor. In June 1942, Fort Glenn helped defend Dutch Harbor against a Japanese attack. The Fort Glenn facility consisted of numerous structures including quonsets, revetments, metal sheds, hangars, reinforced concrete buildings, pump houses, ammunition magazines, and three runways. The main cantonment area included three volcanic cinder runways surrounded by hangars and hardstands to park planes. The hardstands were shielded from high winds by large horseshoe-shaped earthen berms and/or they were constructed below the surrounding grade. Most structures at Fort Glenn utilized one of these forms of wind

Decision Document 2-1 Former Fort Glenn, Umnak Island, Alaska F10AK029804 SECTIONTWO Decision Summary

protection. Twelve camps, north and east of the runways, were part of the main cantonment area. These camps were used by infantry, field artillery, coast artillery, medical corps, finance department, ordnance department, quartermaster corps, chemical corps, chaplain corps, and the Army Air Forces. Warehouse storage, ammunition magazines, concrete bunkers, a Post Exchange, theater, hospital, and technical support facilities were also located within the main cantonment area.

Fort Glenn was placed in caretaker status by late 1944 after the Japanese were driven from the Aleutian Islands. On September 18, 1948, Fort Glenn was officially redesignated as Cape Air Force Base (CAFB). The new mission of CAFB was to provide facilities, services, and assistance for transient aircraft and personnel, air communications services, and weather squadrons.

Fort Glenn was relinquished to the Department of Interior, Bureau of Land Management between 1952 and 1955 and subsequently transferred to numerous owners including the State of Alaska, Department of Transportation and made available for selection by native entities under the Alaska Native Claims Settlement Act of 1981. Currently, the property is owned by the Aleut Corporation, the St. George Tanaq Corporation, the State of Alaska Department of Transportation and Public Facilities, and the United States Fish and Wildlife Service. The former Fort Glenn is currently listed on the National Register of Historic Places.

In 2008, an eruption of Mount Okmok resulted in lahar being deposited across the former Fort Glenn, including approximately 70 acres of the OB/OD Area. Lahar thickness ranges from a few inches to over 4 feet.

2.3 PREVIOUS INVESTIGATIONS

The following sections identify previous work completed at the former Fort Glenn and the OB/OD Area.

2.3.1 Inventory Project Report

The Inventory Project Report (INPR) was completed by the Corps of Engineers Pacific Ocean, Alaska (CEPOA), which established Formerly Used Defense Site eligibility on April 3, 1992 (USACE 1992). The INPR established a site boundary and assigned Property Number F10AK0298. The INPR states that 102,062 acres were acquired by transfer from the public to the War Department by Executive Order in April 1942. Improvements included quonsets, single and two-story wood framed buildings, reinforced concrete buildings, metal sheds, ammunition magazines, concrete bunkers, revetments, docks, hangars, fuel storage tanks, support facilities, and air strips.

2.3.2 Archive Search Report

The Archive Search Report (ASR) was completed by the Corps of Engineers, St. Louis (CELMS) in September 2001 following their review of available records, photographs, and site history reports. The ASR is the source of most available historical information pertinent to site operations

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and history. The ASR confirmed that the military occupied over 102,000 acres at Fort Glenn for defense purposes during World War II. Some of the property was relinquished to the BLM in 1952, and the remaining property was transferred to BLM in 1955. A field visit was conducted during the ASR. Practice bombs and .50-caliber ammunition were identified at several locations, and a large amount of ordnance-related scrap was found throughout the site.

2.3.3 2001 Fort Glenn Remedial Investigation/Interim Removal Action Report

The 2001 Fort Glenn RI/Interim Removal Action Report was completed by Jacobs Engineering Group, Inc. for CEPOA (Jacobs 2003). The RI presented results and findings of field activities performed during July, August, and October 2001. Field activities included site reconnaissance, RIs, and limited interim removal actions at eight operable units. The RI established ambient soil concentrations for metals in the Fort Glenn area based on seven samples.

2.3.4 Disposal/Removal Action

An Explosive Ordnance Disposal (EOD) response occurred in July 2002. The EOD team, comprised of Staff Sergeants Tom Ferris and John Bliven, recovered and disposed a number of MEC items. The list of MEC items, coordinates, and photographs are provided with the incident report (Ferris and Blivens 2002).

2.3.5 Archives Search Report Supplement

The ASR Supplement was completed in 2004 by the CELMS as an addition to the 2001 ASR (CELMS 2004). This document applied standard range configurations to the site, yielding specific range boundaries for each target area. The ASR Supplement also developed a list of MEC that may be found within each range area. No site visit was conducted in support of the ASR Supplement. Risk Assessment Code (RAC) scores in the ASR Supplement assigned each MRS a score from 1 to 5, indicating the highest and lowest hazard potentials, respectively. This document identified eight MRSs (with subranges) at the former Fort Glenn site, assigned their RAC scores, and listed the types of munitions potentially used at each MRS. The Demolition Area MRS (i.e., the OB/OD Area) was given a RAC score of 3 (medium risk).

2.3.6 Site Inspection Report

The Site Inspection (SI) report was completed as a Revised Final version by Parsons on September 5, 2008 (Parsons 2008). The SI was conducted from May 17 through May 23, 2007. The objective of the SI was to discern the presence or absence of MEC and munitions constituents (MC) within the eight designated MRSs, one of which was the OB/OD Area. The OB/OD Area was identified as the “Demolition Area” in the SI. The SI work included gathering samples and analysis for MC. The SI team also conducted a qualitative reconnaissance by traversing the sites to gather general information about potential surficial presence of MEC and to assess the overall site conditions with regard to the logistical requirements for implementation of a potential RI/Feasibility Study (FS). In addition to the eight MRSs, three additional Areas of Concern were identified for SI field

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evaluation by the Technical Project Planning (TPP) team. The SI recommended an RI/FS for the Demolition Area (i.e., the OB/OD Area).

2.3.7 Remedial Investigation

In June and July 2011, a Remedial Investigation (URS 2012) was completed at the OB/OD Area to determine the nature and extent of MEC and MC contamination, and to assess the potential risks to human health and the environment. The RI fieldwork included a visual reconnaissance survey, a lahar boundary survey to determine areal extent, digital geophysical mapping (DGM) of 9.04 acres, intrusive investigation of 293 anomalies, and collection of 68 soil samples and one groundwater seep sample. During the RI, 102 MEC items were found and demolished (including the nine unfired 75 millimeter (mm) projectiles identified during the SI), and 425 MD items were found and shipped off-site for destruction by smelting.

Based on the RI results, it was recommended that the boundary of the OB/OD Area should be reduced from 2,076 acres to 337 acres, and an FS for MEC/MD and MC at the OB/OD Area should be completed using the proposed new boundary.

2.3.8 Feasibility Study

The FS (URS 2014a) evaluated the possible alternatives in detail and completed a comparative analysis based on criteria outlined in the NCP.

During the development of the FS report, further clarifications to the recommended OB/OD Area boundary were made. The 2,076-acre OB/OD Area was recommended to be split into two new MRSs. The OB/OD Area (MRS-04) (337 acres) was recommended for a response action and the Remaining OB/OD Area (MRS-14) (1,739 acres) was recommended for no further action. Further incidental MC investigation at OB/OD Area (MRS-04) was not recommended in the FS report because MC risks to current or future residential receptors were determined to be biased high and resulted from localized detections around discovered MEC items.

2.3.9 Proposed Plan

A Proposed Plan (PP) (URS 2014b) was completed for the OB/OD Area (MRS-04) and the Remaining OB/OD Area (MRS-14). The PP documented the preferred alternatives for each MRS to address MEC/MD hazards.

2.4 COMMUNITY PARTICIPATION

The FS (URS 2014a) and PP (URS 2014b) were made available to the public in April 2014 at the Alaska Resources Library and Information Services in Anchorage, Alaska and at the Unalaska Public Library in Unalaska, Alaska. URS Group, Inc. (URS) published a public notice of availability for documents in the Anchorage Daily News on April 27, 2014 and in the Bristol Bay Times/Dutch Harbor Fisherman on May 1, 2014. A public comment period was held from May 1 to June 2, 2014. In addition, public meetings were held at the Z.J. Loussac Public Library on May

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6, 2014, and at the Unalaska Public Library on May 7, 2014, to present the PP to a broader community audience than those who had already been involved at the site. At these meetings, representatives from USACE, Alaska Department of Environmental Conservation (ADEC), and URS were available to answer questions about the sites and the proposed remedial alternatives/remedies. One public comment was received via e-mail during the public review period. Summaries of the public meetings and the e-mail correspondence during the public comment period are included in Appendix A.

2.5 SCOPE AND ROLE OF RESPONSE ACTION

This DD documents the selected response action for the OB/OD Area (MRS-04). USACE intends to reduce the explosive hazards at the OB/OD Area (MRS-04) by removing MEC to prevent potential future exposure. LUCs will also be implemented at the OB/OD Area (MRS-04) to increase awareness of potential risks remaining in the subsurface and greater area through administrative and institutional controls.

2.6 SITE CHARACTERISTICS

This section summarizes site characteristics for Umnak Island and the former Fort Glenn, including climate, topography, geology, hydrogeology, and hydrology. This section also documents the nature and extent of MEC and MC and presents the conceptual site model (CSMs) for the OB/OD Area (MRS-04).

2.6.1 Climate

The climate on Umnak Island is characterized by persistently overcast skies, high winds, and frequent, often violent cyclonic storms originating in the northern Pacific Ocean and Bering Sea. Weather can be localized, with conditions of fog, low ceilings, precipitation, and clear weather all possible concurrently within a distance of a few miles. Storms occur all year, with the most frequent and severe storms during the winter. Wind speeds during the winter storms can reach 100 knots. Summer wind speeds average 13 knots. High temperatures in the summer range from 50 to 55 degrees Fahrenheit and during the winter range from 20 to 36 degrees Fahrenheit. The average annual rainfall at Nikolski (west end of Umnak Island) is approximately 57 inches and at Unalaska is approximately 60 inches.

2.6.2 Topography

The former Fort Glenn is situated in the United States Geological Survey Umnak and Unalaska quadrangles. The site lies just southeast of the Mount Okmok, which reaches a rim height of 3,516 feet. The topography surrounding Mount Okmok slopes radially away from the rim. The former Fort Glenn property is generally situated between 0 feet (sea level) to approximately 1,000 feet above sea level at its northwestern edge. The terrain ranges from flat with gentle slopes to sheer rock faced bluffs, and is bisected by streams with very steep banks. Some streams have cut ravines into the easily eroded surface to depths of 100 feet and greater.

Decision Document 2-5 Former Fort Glenn, Umnak Island, Alaska F10AK029804 SECTIONTWO Decision Summary

2.6.3 Geology

Umnak Island is part of the Alaska-Aleutian physiographic province. Umnak Island is the third largest island in the Aleutian Arc, a narrow belt of east-west trending ridges that extend from the Alaskan Peninsula to Attu Island. Approximately 80 major volcanoes lie in this arc, of which at least 36 have been active since 1760.

Umnak Island was formed by volcanoes including Okmok Volcano, which now stands as a caldera after the collapse of its summit. Okmok Volcano lies on Tertiary volcanic rocks and consists of three basic rock layers. The pre-caldera shield complex (the bottom layer) contains basalt, andesite, rhyolite, tuff, tuff-breccia, and pyroclasts. The middle layer consists of pyroclastic deposits, including ash-flow tuffs, airfall ash, and pumice from the two major caldera forming eruptions. The upper layer consists of ash and basalt from the post-caldera field of small cinder cones and lava flows that include historically active vents within the caldera. The rim of the Mount Okmok caldera is approximately 6 miles in diameter and reaches an elevation of over 3,000 feet. Over time, the land has been eroded by glacier action and streamflow.

A thin mantle of till, volcanic ash, humus, and soil discontinuously veneers the island surface. In general, the soils are progressively less compact and humic upward and more clayey downward. The clay layers range in color from yellowish gray to orange, reddish brown, olive gray, and bluish gray. Bluish-gray clays are commonly associated with till in the region. The ash and cinder layers are medium gray to yellowish gray to orange (CELMS 2001).

The latest eruption from Mount Okmok was in 2008, with resulting lahar impacting the former Fort Glenn area, including the OB/OD Area.

2.6.4 Hydrogeology

Approximately 50 percent of the groundwater needs on many of the larger Aleutian Islands, including Umnak Island, can be met with wells drilled into unconsolidated deposits. The remaining groundwater is derived from bedrock aquifers. Bedrock aquifers could supply water to a significant number of wells on Umnak Island. The water from these wells would typically be of a chemical quality suitable for most uses (CELMS 2001).

According to the Alaska Department of Natural Resources Well Log Tracking System (http://www.navmaps.alaska.gov/welts), the only well listed for Umnak Island is a 6-foot deep well in Umnak Lake, Nikolski Village. There are no listed wells on the eastern side of Umnak Island. The residents of the Bering Pacific Ranch obtain their drinking water from a spring located north of the ranch house; they use the same spring and distribution system from which the former Fort Glenn received its potable water.

2.6.5 Hydrology

Surface water in eastern Umnak Island consists of swift moving streams that drain radially off the Mount Okmok and Tulik Volcano. Thirty Three Creek runs easterly along the northern edges of

Decision Document 2-6 Former Fort Glenn, Umnak Island, Alaska F10AK029804 SECTIONTWO Decision Summary the OB/OD Area, eventually draining into Idak Cove. Average estimated flow for Thirty Three Creek is 10 cubic feet per second. Marsh Creek is located north of the main runway and runs easterly for approximately 2.5 miles before joining with Thirty Three Creek. Camp Creek runs southeasterly along the southwestern edge of the OB/OD Area and drains into the Pacific Ocean southwest of the main runway. Lake Manila is a predominant surface water feature on the east side of the installation.

The United States Fish and Wildlife Service Wetlands Online Mapper (USFWS 2006), through the National Wetlands Inventory (NWI), was used to identify if wetlands have been defined at the former Fort Glenn site. Currently, no wetlands data is available through the NWI; however, during the ASR site visit it was noted that vegetation in many areas was indicative of wetlands and that the soil remains saturated most of the year. Thirty Three Creek and Marsh Creek would likely be classified as Palustrine moss-lichen wetlands (CELMS 2001).

2.6.6 Nature and Extent of Contamination

This section presents the nature and extent of MEC and MC contamination in the OB/OD Area.

2.6.6.1 Nature and Extent of MEC

The OB/OD Area (MRS-04) boundary encompasses the estimated extent of MEC contamination, and is based on visual reconnaissance, surface clearance, geophysical data, and intrusive investigations. The results of the visual survey completed during the RI are shown in Figure 2-3.

The boundary covers two distinct areas, the main area that includes the OB/OD craters and kick- outs and a smaller area to the northeast that includes an erosional feature found to contain range- related debris (RRD). The MRS boundary around the main area (approximately 332 acres) was established by first plotting the MD identified within the OB/OD Area. Based on discussion with the TPP Team, the southern portion of this boundary was set at the northern edge of a steep embankment of an incised perennial stream. This stream and associated topography is a significant barrier to DGM activities and also reduces access to the south and west. MD finds past this barrier were infrequent and widely scattered. The western, eastern, and northern portions of the boundary were chosen to encompass all of the higher concentrations of MD throughout the MRS, while maintaining an overall smooth outline. The main area boundary has been extended to the north beyond a cache of discarded military munitions (DMM) (high explosive incendiary 20mm MK 3 projectiles) identified during the RI field activities and a 200-foot buffer around that cache. The boundary around the smaller area (approximately 5 acres) covers a 25-foot-wide swath centered on an erosional feature where temporary storm water flows have exposed a partially buried pile of M106 fuze shipping containers (identified as RRD) and washed some of the fuze containers downstream. The total area encompassed by the OB/OD Area (MRS-04) boundary is approximately 337 acres.

Within the MRS boundary, the Focus Area (encompassing the northwest and southeast craters) was delineated during the RI as shown in Figure 2-4. The Focus Area covers approximately 30 acres and encompasses all the craters and the immediately surrounding areas with the highest

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estimated anomaly densities. All of the craters were plotted and a 200-foot buffer was then drawn around each OB/OD crater, resulting in a boundary for the Focus Area. This boundary was visually inspected and smoothed resulting in minor adjustments of the boundaries outward. The intention of defining the Focus Area is to group together the locations most likely to have MEC hazards associated with former OB/OD activities at the OB/OD craters. A 200-foot buffer around each crater was chosen because it aligns well with MEC and MD finds identified through intrusive investigations during the RI field effort. It also is similar to buffers used on other OB/OD sites and Military Munitions Response Program (MMRP) sites elsewhere in the Aleutian Islands. All but one of the intrusive investigations that resulted in a MEC find lies within the Focus Area. This sole exception is a cache of DMM that is not related to the OB/OD activities associated with the MRS.

2.6.6.2 Nature and Extent of MC

In MC screening at the OB/OD Area (MRS-04), three constituents (trinitrotoluene [TNT], copper, and lead) were identified as a COPC for human health and three constituents (copper, lead, and zinc) were identified as a chemical of potential ecological concern for ecological evaluation. All were from discrete sampling locations. No chemicals of concern were identified in incremental sampling locations.

Discrete samples were focused on specific locations where MEC was identified. These are localized areas, so contamination is expected to be localized around the MEC item and not widespread. TNT was detected in two of 14 discrete samples, only one of which exceeded a screening level (OBOD-SB010-3.0). For metals in surface soils, concentrations above background and screening levels were associated with the following locations: • Copper - OBOD-SS003-2.0, OBOD-SB009-3.0 • Lead - OBOD-SS003-2.0 • Zinc - OBOD-SS003-2.0, OBOD-SB006-1.5, OBOD-SS007-0.5

These represent locations where concentrations exceeded screening levels and background levels. TNT, copper, and lead were determined to be COPCs for human health receptors based on a future residential scenario. Risks associated with TNT, copper, and lead are considered to be low for future residential receptors and result from localized detections around discovered MEC items. Copper, lead, and zinc were detected above ecological screening levels, but were considered unlikely to pose potential risk to ecological receptors.

2.6.7 Conceptual Site Model

A CSM is a representation of a site and its environment that is used to facilitate understanding of the site and the potential contaminant exposure pathways that might be present. The CSM describes potential contamination sources and their known or suspected locations, human and/or ecological receptors present, and the possible interactions between them. The CSM summarizes which potential receptor “exposure pathways” for contamination are (or may be) “complete” and

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which are (and are likely to remain) “incomplete.” An exposure pathway is considered incomplete unless all of the following elements are present: (a) contamination; (b) a receptor that might be affected by that contamination; and (c) a method for the receptor to be exposed to (i.e., come into contact with) the contamination. If all of these elements are present, an exposure pathway is considered complete.

The MEC and MC CSMs for the OB/OD Area (MRS-04) are shown on Figure 2-5 and Figure 2- 6, respectively. Because MEC in surface and subsurface soil was observed at OB/OD Area (MRS- 04) during previous investigations, complete pathways exist for current and future residents, site workers, and recreational users. Because potential sources of MC contamination exist (e.g., MEC), pathways for current and future residents, site workers, recreational users, and ecological receptors are considered potentially complete.

2.7 CURRENT AND POTENTIAL FUTURE LAND AND RESOURCES USES

Current activities at the site include agricultural (free range cattle grazing), recreational (hunting), and nearby residential. Potential future activities are the same, with the addition of residential use within the site boundary. For the current activities, potential exposure to MEC or MC would primarily be at the surface. For the future residential scenario, exposure to subsurface soil or MEC items during excavation activities is also possible.

2.8 SUMMARY OF SITE RISKS

2.8.1 Human Health Risks

Based on historical data and RI field observations, potential MEC hazards have been identified at the OB/OD Area (MRS-04) (337 acres).

Risks were evaluated for human receptors (site worker, recreational user, and future resident) scenarios. COPCs included TNT, copper, and lead in soils. For the site worker and recreational user, carcinogenic risk did not exceed 1x10-6, and noncarcinogenic hazard was less than 1.0. For the future resident, potential carcinogenic risks of 3.3x10-5 were estimated based on detection of TNT at a single sample location, a noncarcinogenic hazard of 2.7 also was estimated based on copper at a single sample location, and lead slightly exceeded the residential soil cleanup level of 400 milligrams per kilogram at a single location. The TNT and copper results were deeper than 2.0 feet below ground surface (bgs), so the exposure is beyond the typical residential contact with surface soils (0 to 2 feet bgs). Therefore, risk is considered unlikely.

All discrete sample concentrations were measured at the source of MEC items (i.e., adjacent to or directly below the MEC item, with the exception of 3 demolition craters that were not sampled due to safety concerns), any surrounding concentrations would be reduced via attenuating transport mechanisms. Sampling in conjunction with isolated MEC items indicates a highly localized source, with the exposure concentration (maximum detected) biased high because the sample collected was in association with a small, single source item at depth. The actual exposure

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concentration can reasonably be expected to be substantially lower than the maximum concentration detected, and similarly, the associated risk or hazard would be substantially lower as well. As a result, because the exposure concentration is biased high, and would be much less if combined with surrounding samples consistent with a representative residential exposure, no further action for MC in soil is warranted.

Exposure pathways to groundwater in the OB/OD Area are considered to be potentially complete but insignificant based on both the screening results from the groundwater seep and the low frequency/localized nature of detected soil contamination that could be the source of groundwater contamination. Therefore, groundwater is no longer considered a medium of concern.

A MEC hazard assessment was completed using the United States Environmental Protection Agency (USEPA) 2008 method, which takes into account the severity, accessibility, and sensitivity of potential explosives hazards. The OB/OD Area (MRS-04) has a baseline MEC hazard assessment score of 865 (out of 1,000), which results in a Hazard Level of 1 (the highest hazard level out of four levels). The primary factors leading to this high level are the presence of high and low explosive filler in fragmenting bombs, the accessibility of the site, the former use of the site for OB/OD, and the possibility of MEC including unexploded ordnance (UXO) items at the surface.

Data used to complete the USEPA MEC hazard assessment and human health and ecological risk assessments were also used to complete Munitions Response Site Prioritization Protocol (MRSPP) tables. In 2005, the DoD published the MRSPP as a Federal Rule (32 CFR Part 179) to assign a relative risk priority to each defense site in the MMRP Inventory for response activities. Risk is based on the overall conditions at each MRS taking into consideration various factors related to explosive safety (i.e., MEC hazards) and environmental hazards (i.e., MC contamination). In accordance with the DoD MRSPP Primer (DoD 2007), each MRS is assigned an MRSPP Priority ranging from 1 to 8. Priority 1 indicates the highest potential hazard and Priority 8 indicates the lowest potential hazard. The overall MRSPP priority score is 3 for the OB/OD Area (MRS-04) (337 acres).

2.8.2 Ecological Risks

Potential ecological risks were also evaluated during the RI, and it was concluded that it is unlikely that MC pose potential risks to ecological receptors.

2.9 REMEDIAL ACTION OBJECTIVES AND ARARS

A remedial action objective (RAO) is a site-specific goal to protect human health and the environment. RAOs specify the contaminants and media of interest, exposure pathways, and preliminary remediation goals, which are developed on the basis of chemical-specific applicable or relevant and appropriate requirements (ARARs) or site-specific risk factors.

ARARs are identified on a site-specific basis. Based on USEPA guidance (USEPA 1988), ARARs are categorized as chemical-specific, action-specific, or location-specific:

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• Chemical-specific ARARs are based on health- or risk-based concentration limits or discharge limitations in environmental media (i.e., air, soil, or water) for specific hazardous chemicals. The requirements may be used to set cleanup levels for the chemicals of concern in the designated media, or to set a safe level of discharge (e.g., air emission or wastewater discharge) where a discharge occurs as a part of the remedial action. • Action-specific ARARs generally set performance, design, or other similar operational controls or restrictions on particular activities related to management of hazardous substances or pollutants. These requirements address specific activities that are used to accomplish a remedy. Action-specific requirements do not in themselves determine the remedial action; rather, they indicate how a selected remedial action alternative must be designed, operated, or managed. • Location-specific ARARs are restrictions placed on the types of activities that may occur in particular locations. The location of a site may be an important characteristic in determining its impact on human health and the environment. Location-specific ARARs include federal requirements for wetlands protection and floodplain restrictions on management of hazardous waste.

2.9.1 OB/OD Area (MRS-04) Remedial Action Objective The RAO for OB/OD Area (MRS-04) is to reduce the potential for direct contact with MEC by human receptors, considering the current and future land use.

2.9.2 ARARs The Resource Conservation and Recovery Act (RCRA) Subpart X – Miscellaneous Units, Section 264.601 Environmental Performance Standards (40 CFR 264) is a relevant and appropriate requirement for the use of consolidated shots to dispose of MEC at the OB/OD Area (MRS-04). Following pursuit of RCRA Subpart X, soil confirmation samples will be collected after disposal/removal/treatment of damaged MEC items and analyzed for TNT, copper, lead, and zinc. Analytical results will be compared to 18 AAC 75.341, Table B1, direct contact, over 40 inch zone cleanup levels to evaluate if soil cleanup may be required.

2.10 DESCRIPTION OF ALTERNATIVES A range of general response actions were identified, evaluated, and screened to develop a list of possible remedial alternatives for the OB/OD Area (MRS-04). These general response actions were (a) LUCs, (b) MEC removal, (c) containment, (d) demolition, and (e) disposal. Various technology options for these general response actions were evaluated based on screening criteria that included effectiveness, implementability, and cost. Methods deemed to be viable were combined into possible remedial alternatives for the OB/OD Area (MRS-04). Alternative 5 – Surface Removal, Focused Subsurface Removal, and LUCs was selected for the OB/OD Area (MRS-04). A detailed description of the alternative development process is provided in the FS report (URS 2014a).

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An alternative to achieve UU/UE was not proposed in the FS. MEC items are confirmed at depths greater than 4 feet and are possible at depths greater than 20 feet due to lahar flows and substantial demolition craters. Non-intrusive technologies to detect MEC at these depths are not available. A large-scale removal of overburden to identify and remove all MEC poses unacceptable environmental risks and hazards that outweigh the potential hazards presented by MEC at this site. In addition, it would be cost-prohibitive to complete such a large-scale removal to depths greater than 4 feet over the entire 337 acres at the OB/OD Area (MRS-04). Alternative 6 was included to evaluate a complete surface and subsurface removal over the entire 337 acres, but was not considered a UU/UE alternative because known MEC items may be present at depths greater than 4 feet and up to 20 feet under lahar areas. Thus, five-year reviews would still be required. Eight remedial alternatives were developed during the FS for the OB/OD Area (MRS-04). A description of each of the eight alternatives developed for consideration is presented in the following subsections.

2.10.1 Alternative 1 – No Action Total Capital Cost: $0 Recurring 5-Year Review Costs for 30 Years: $0 Total Cost of Alternative: $0 The No Action Alternative assumes no further action would be taken regarding MEC in the OB/OD Area (MRS-04). No administrative or physical LUCs would be implemented. This method would have no associated costs. This alternative is required by the NCP for baseline comparison purposes (40 CFR 300.430[e][6]).

2.10.2 Alternative 2 – LUCs Capital Cost: $428,553 Recurring 5-Year Review Costs for 30 Years: $102,446 (per event) Total Cost of Alternative: $1,043,229

LUCs would increase awareness of potential risks at the OB/OD Area (MRS-04) through administrative and institutional controls. This alternative does not allow UU/UE, thus this alternative would be subject to review not less than every 5 years.

The administrative controls would consist of an educational awareness program for munitions safety. The educational awareness information (e.g., 3Rs safety pamphlet) would be shared with local stakeholders including the current landowner, adjacent landowners, and lessees. The administrative controls would be maintained every 5 years by mailings to the identified parties, queries to address potential land use changes, and updates of the contact list. The landowner will also be requested to implement a notice of environmental contamination which documents the area which may contain residual MEC items. USACE will provide the landowner with available data and assist with implementation. Institutional controls will include placing and maintaining warning signs around the OB/OD Area (MRS-04) and along access roads to inform people of the presence of MEC.

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Five-year reviews would be conducted to evaluate the continued effectiveness and protectiveness of the administrative and institutional controls. A site inspection would be conducted as part of each five-year review to make sure site conditions had not changed. The five-year reviews would be documented and the Fort Glenn Administrative Record would be updated.

2.10.3 Alternative 3 – Focused Surface Removal and LUCs Capital Cost: $1,240,725 Recurring 5-Year Review Costs for 30 Years: $102,446 (per event) Total Cost of Alternative: $1,855,401

Alternative 3 includes all components of Alternative 2 and a focused removal of surface MEC. The surface removal would involve removal, inspection, and disposal of MEC located on the surface within the Focus Area of the OB/OD Area (MRS-04) (approximately 30 acres). Surface removal in this section of the OB/OD Area (MRS-04) would reduce the risk of commercial, agricultural, or recreational users encountering surface MEC within the Focus Area. This alternative does not address surface MEC outside of the Focus Area, or subsurface MEC in the MRS. This alternative does not address MEC migration to the surface through erosion or frost heave. LUCs would address surface MEC within the MRS but outside of the Focus Area and subsurface MEC within the MRS, which would remain in place.

The lahar covers approximately 6 acres of the northwestern Focus Area, and the top of the lahar would be considered the surface for removal. At the time of implementation, the entire lahar surface within the Focus Area would be checked for MEC; however, little to no MEC is expected on the surface of the lahar. The effectiveness and protectiveness of this surface removal would be evaluated with future site inspections, which are included every 5 years after the surface removal action.

Administrative controls (an educational awareness program) and institutional controls (warning signs) would be implemented the same as described under Alternative 2.

Vegetation removal (i.e., mowing) may or may not be required, depending on the time of year and location on the OB/OD Area (MRS-04). The surface removal would be completed at the MRS by qualified UXO technicians using hand-held detectors, and metal visible on the ground surface or found to protrude through the mineral soil layer into vegetation would be removed. A typical removal process involves partitioning the MRS into 100-foot by 100-foot grids and placing survey grid stakes at the four corners. A systematic surface sweep of the grid would be accomplished to remove the surface metal debris from the grid. Conducting a surface removal requires a Senior UXO Supervisor (SUXOS) responsible for planning and directing removal operations, a UXO Safety Officer (UXOSO) to ensure that work is performed safely and a UXO Quality Control Specialist (UXOQCS) to ensure the work is performed in accordance with rules, regulations, and planning documents. It is estimated that 15 MEC items would require disposal, based on a density of 1 MEC item for every 2 acres.

Recovered MEC and MD would be handled, stored, destroyed, shipped, and demilitarized in accordance with the guidance set forth in the approved Explosives Safety Submission (ESS),

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Department of Defense Explosives Safety Board (DDESB) Guidance for Clearance Plans (DDESB 1998), and Engineering Manual (EM) 1110-1-4009 (USACE 2007). MEC would be inspected by a UXO Technician III and UXO Technician II to determine the explosive hazard and appropriate demolition method. MEC that is unacceptable to move would be blown in place (BIP) and MEC that is determined acceptable to move would be consolidated by qualified UXO technicians at a secure location for later disposal.

Alternative 3 field activities would be completed in approximately 2 weeks. Five-year reviews would be conducted to evaluate the continued effectiveness and protectiveness of the alternative.

2.10.4 Alternative 4 – Surface Removal and LUCs Total Capital Cost: $4,844,519 Recurring 5-Year Review Costs for 30 Years: $102,446 (per event) Total Cost of Alternative: $5,459,195

Alternative 4 includes all of the components of Alternative 2 and a complete MEC surface removal. The surface removal would involve removal and disposal of surface MEC including MEC located within the OB/OD Area (MRS-04) (337 acres). The surface MEC removal would reduce the risk of commercial, agricultural, or recreational users encountering MEC. LUCs would address subsurface MEC which would remain in place. This alternative does not allow UU/UE, thus this alternative would be subject to review not less than every 5 years.

The lahar covers approximately 70 acres of the surface removal area, and the top of the lahar would be considered the surface for removal. At the time of implementation, the entire lahar surface within the OB/OD Area (MRS-04) would be checked for potential MEC; however, little to no MEC is expected on the surface of the lahar. The protectiveness of this surface removal would be evaluated with future site inspections, which are included every 5 years after the surface removal action.

Administrative controls (an educational awareness program) and institutional controls (warning signs) would be implemented the same as described under Alternative 2.

Vegetation removal (i.e., mowing) may or may not be required, depending on the time of year and location on the OB/OD Area (MRS-04). The surface removal would be conducted at the MRS by qualified UXO technicians using hand-held detectors, and metal visible on the ground surface or found to protrude through the mineral soil layer into vegetation would be removed. A typical removal process involves partitioning the MRS into 100-foot by 100-foot grids and placing survey grid stakes at the four corners. A systematic surface sweep of the grid would be accomplished to remove the surface metal debris from the grid. Conducting a surface removal requires a SUXOS responsible for planning and directing removal operations, a UXOSO to ensure that work is performed safely and a UXOQCS to ensure the work is performed in accordance with rules, regulations, and planning documents. It is estimated that 90 MEC items would require disposal based on a density of 1 item for every 2 acres in the Focus Area and 1 item for every 4 acres outside the Focus Area.

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Recovered MEC and MD would be handled, stored, destroyed, shipped, and demilitarized in accordance with the guidance set forth in the approved ESS, DDESB Guidance for Clearance Plans (DDESB 1998), and EM 1110-1-4009 (USACE 2007). MEC would be inspected by a UXO Technician III and UXO Technician II to determine the explosive hazard and appropriate demolition method. MEC that is unacceptable to move would be BIP and MEC that is determined acceptable to move would be consolidated by qualified UXO technicians at a secure location for later disposal.

It is anticipated that field activities would take approximately 1 to 2 months. Five-year reviews would be conducted to evaluate the continued effectiveness and protectiveness of the alternative.

2.10.5 Alternative 5 – Surface Removal, Focused Subsurface Removal, and LUCs Total Capital Cost: $8,905,275 Recurring 5-Year Review Costs for 30 Years: $102,446 (per event) Total Cost of Alternative: $9,519,951

Alternative 5 includes all of the components of Alternative 4 and a focused subsurface removal. For the purposes of this alternative, it is assumed the response action would be completed to the depth of detection within the Focus Area. Surface and subsurface removals would significantly reduce the risk of encountering MEC in the OB/OD Area (MRS-04).

The lahar covers approximately 70 acres of the surface removal area and 6 acres of the subsurface removal area. The top of the lahar would be considered the surface for removal outside the Focus Area. Within the Focus Area, comprehensive DGM coverage would allow for detection of MEC up to the depth of detection, which depends on the size and orientation of the item. In general, the depth of detection is expected to be 4 feet or less. Therefore, the subsurface removal beneath the lahar would remove most of the MEC located on the former ground surface, but MEC located deeper (such as within the lahar-covered craters) would not be removed. Although the removal of MEC to depth would have a high long-term reliability, some MEC may remain on site so the protectiveness of this alternative would be evaluated with future site inspections, which are included every 5 years after the removal action.

Administrative controls (an educational awareness program) and institutional controls (warning signs) would be implemented the same as under Alternative 2.

The approximate surface removal action area is 337 acres. The approximate subsurface removal action area (Focus Area) is 30 acres. The total number of subsurface anomalies was estimated from information obtained during the RI geophysical survey. The average anomaly density is estimated at 288 anomalies per acre within the Focus Area for a total estimate of approximately 8,600 anomalies. Approximately 3 percent of the anomalies for the Focus Area are assumed to be MEC based on intrusive investigation results from the RI.

Vegetation removal may or may not be required, depending on the time of year and location on the OB/OD Area (MRS-04). The surface removal would be conducted at the MRS by qualified UXO technicians using hand-held detectors. A typical removal process involves partitioning the

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MRS into 100-foot by 100-foot grids and placing survey grid stakes at the four corners. A systematic surface sweep of the grid would be accomplished to remove the surface metal debris from the grid. Conducting a surface removal requires a SUXOS responsible for planning and directing removal operations, a UXOSO to ensure that work is performed safely and a UXOQCS to ensure the work is performed in accordance with rules, regulations, and planning documents.

A subsurface removal would be conducted at the Focus Area by qualified UXO technicians using hand-held detectors, shovels, and/or earth moving machinery (EMM). A typical removal process involves using 100-foot by 100-foot grids, collecting DGM data, acquiring targets, and digging targets. Completing a subsurface removal requires a SUXOS responsible for planning and directing removal operations, a UXOSO to ensure that work is performed safely and a UXOQCS to ensure the work is performed in accordance with rules, regulations, and planning documents.

Potential MEC items would be removed to the depth of detection in the Focus Area (30 acres) (Figure 2-4) using manual and machine assisted removal techniques (e.g., shovels, hand equipment, and EMM to remove overburden). RI intrusive data indicate that the majority of MEC lies between 0 and 2 feet bgs in areas not impacted by lahar.

Recovered MEC and MD would be handled, stored, destroyed, shipped, and demilitarized in accordance with the guidance set forth in the approved ESS, DDESB Guidance for Clearance Plans (DDESB 1998), and EM 1110-1-4009 (USACE 2007). MEC would be inspected by a UXO Technician III and UXO Technician II to determine the explosive hazard and appropriate demolition method. MEC that is unacceptable to move would be BIP and MEC determined acceptable to move would be consolidated by qualified UXO technicians at a secure location for later disposal.

It is estimated that this alternative could be completed in 3 to 4 months. This length of time is based on the assumptions that four 7-man UXO teams would complete the intrusive investigation of an estimated 8,600 anomalies over 30 acres, that each team can investigate 55 anomalies per day, and that they can only work 5-days per week. Five-year reviews would be conducted to evaluate the continued effectiveness and protectiveness of the alternative.

2.10.6 Alternative 6 – Surface Removal, Subsurface Removal, and LUCs Total Capital Cost: $31,475,343 Recurring 5-Year Review Costs for 30 Years: $102,446 (per event) Total Cost of Alternative: $32,090,018

Alternative 6 includes all of the components of Alternative 4 and a subsurface removal from the entire site. For the purposes of this alternative, it is assumed the response action would be

Decision Document 2-16 Former Fort Glenn, Umnak Island, Alaska F10AK029804 SECTIONTWO Decision Summary completed to the depth of detection for the entire OB/OD Area (MRS-04). Surface and subsurface removals would significantly reduce the risk of encountering MEC in the OB/OD Area (MRS-04). The lahar covers a total area of approximately 70 acres within the subsurface removal area. The depth of removal under the lahar would be the same as described under Alternative 5 and some MEC may remain on site following this removal so the effectiveness and protectiveness would be evaluated with future site inspections, which are included every 5 years after the removal action.

The approximate removal action area is 337 acres. The total number of subsurface anomalies was estimated from information obtained during the RI geophysical survey. The average anomaly density across the entire 337 acres is 167 anomalies per acre for a total estimate of approximately 56,000 anomalies. Approximately 1 percent of the anomalies for the total site are assumed to be MEC based on intrusive investigation results from the RI.

Administrative controls (an educational awareness program) and institutional controls (warning signs) would be implemented the same as described under Alternative 2.

Vegetation removal (i.e., mowing) may or may not be required, depending on the time of year and location on the OB/OD Area (MRS-04). A surface removal would be conducted at the MRS by qualified UXO technicians using hand-held detectors. A typical removal process involves partitioning the MRS into 100-foot by 100-foot grids and placing survey grid stakes at the four corners. A systematic surface sweep of the grid would be accomplished to remove the surface metal debris from the grid. Conducting a surface removal requires a SUXOS responsible for planning and directing removal operations, a UXOSO to ensure that work is performed safely and a UXOQCS to ensure the work is performed in accordance with rules, regulations, and planning documents.

Following the completion of the surface removal, a subsurface removal would be conducted. The subsurface removal activities would include a comprehensive geophysical survey in order to acquire subsurface anomalies potentially representing MEC. Geophysical data would include RI DGM survey data, additional DGM survey data, and analog geophysical data where vegetation and terrain inhibit the quality of DGM surveying. Pending the results of a pilot test, Metal Mapper will be used to further discriminated target anomalies, which reduces the total number of anomalies requiring intrusive investigation.

A subsurface removal would be conducted at the MRS by qualified UXO technicians using hand- held detectors, shovels, and/or EMM. A typical removal process involves using 100-foot by 100- foot grids, collecting DGM data, acquiring targets, and digging targets. Completing a subsurface removal requires a SUXOS responsible for planning and directing removal operations, a UXOSO to ensure that work is performed safely and a UXOQCS to ensure the work is performed in accordance with rules, regulations, and planning documents.

Potential MEC items would be removed to the depth of detection in the OB/OD Area (MRS-04) (337 acres) (Figure 2-4) using manual and machine assisted removal techniques (e.g., shovels, hand equipment, and EMM to remove overburden). RI intrusive data indicates that the majority of MEC lies between 0 and 2 feet bgs in areas not impacted by lahar.

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Recovered MEC and MD would be handled, stored, destroyed, shipped, and demilitarized in accordance with the guidance set forth in the approved ESS, DDESB Guidance for Clearance Plans (DDESB 1998), and EM 1110-1-4009 (USACE 2007). MEC would be inspected by a UXO Technician III and UXO Technician II to determine the explosive hazard and appropriate demolition method. MEC that is unacceptable to move would be BIP and MEC determined acceptable to move would be consolidated by qualified UXO technicians at a secure location for later disposal.

It is estimated that this alternative would require up to three field seasons, assuming 4-month-long field seasons. The length of time is based on the assumptions that four 7-man UXO teams would complete the intrusive investigation of an estimated 56,000 anomalies over 337 acres, that each team can investigate 55 anomalies per day, and that they can only work 5 days per week. Five- year reviews would be conducted to evaluate the continued effectiveness and protectiveness of the alternative.

2.10.7 Alternative 7 – Surface Removal, Focused Soil Cover, and LUCs Total Capital Cost: $10,384,877 Recurring 5-Year Review Costs for 30 Years: $102,446 (per event) Total Cost of Alternative: $10,999,553

Alternative 7 includes all of the components of Alternative 4 with the addition of a 2-foot-thick soil cover over the Focus Area. The surface removal would reduce the risk of commercial, agricultural, or recreational users encountering MEC on the surface. The soil cover would reduce the potential for MEC to migrate to the surface in the Focus Area. LUCs would address subsurface MEC, which would remain in place with the potential to migrate (predominantly outside of the Focus Area). This alternative does not allow UU/UE, and the long-term effectiveness and protectiveness would require periodic reviews not less than every 5 years.

The lahar covers approximately 70 acres of the surface removal area, and the top of the lahar would be considered the surface for removal. At the time of implementation, the entire lahar surface within the Focus Area would be checked for potential MEC; however, little to no MEC is expected on the surface of the lahar. The effectiveness and protectiveness of this surface removal would be evaluated with future site inspections, which are included every 5 years after the surface removal action.

Administrative controls (an educational awareness program) and institutional controls (warning signs) would be implemented the same as described under Alternative 2.

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responsible for planning and directing removal operations, a UXOSO to ensure that work is performed safely and a UXOQCS to ensure the work is performed in accordance with rules, regulations, and planning documents. It is estimated that 90 MEC items would require disposal based on a density of 1 item for every 2 acres in the Focus Area and 1 item for every 4 acres outside the Focus Area.

Prior to construction, a topographic survey would be required to form the basis for the design of the soil cover. It is assumed that the topographic survey would be completed immediately after surface clearance. The survey would be conducted by a three-man team consisting of a survey chief and helper, with a UXO Technician II escort. It is assumed that the time required to complete the design, with reviews, would extend beyond the initial field season, so a second field season to construct the soil cover has been assumed.

The soil cover would be installed to form a minimum 2-foot-thick soil barrier over the 30-acre Focus Area. An estimated 114,800 compacted cubic yards would be required, which includes an estimated 18,000 cubic yards to fill the craters to existing grade. It is assumed that a borrow pit could be opened within 1 mile of the site and that this area would be properly graded and vegetated at the completion of the work. A crew of 12 operators (for excavation, hauling, and compaction equipment) would be able to place approximately 5,800 loose cubic yards per 12-hour day, which equates to 4,640 compacted cubic yards per 12-hour day assuming a 25-percent compaction factor. The soil cover would be completed in an estimated 45 12-hour work days. Following final grading, the soil cover will seeded with native vegetation. The soil cover will be installed under the escort of a qualified UXO Technician II.

It is anticipated that field activities would take approximately 3 months; however, this alternative is assumed to require two field seasons to allow time for the soil cover design and review. Five- year reviews would be conducted to evaluate the continued effectiveness and protectiveness of the alternative.

2.10.8 Alternative 8 – Focused Surface Removal, Focused Subsurface Removal, and LUCs Total Capital Cost: $7,454,649 Recurring 5-Year Review Costs for 30 Years: $102,446 (per event) Total Cost of Alternative: $8,069,325

Alternative 8 includes all of the components of Alternative 3 and a focused subsurface removal. For the purposes of this alternative, it is assumed the response action would be completed to the

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depth of detection within the Focus Area. Surface and subsurface removals in the Focus Area would significantly reduce the risk of commercial, agricultural, or recreational users encountering MEC within the Focus Area. This alternative does not address surface or subsurface MEC contamination outside of the Focus Area. LUCs would address MEC contamination outside of the Focus Area, which would remain in place.

The lahar covers approximately 6 acres of northwestern Focus Area, and the top of the lahar would be considered the surface for removal. At the time of implementation, the entire lahar surface within the Focus Area would be checked for potential MEC; however, little to no MEC is expected on the surface of the lahar. Comprehensive DGM coverage would allow for detection of MEC to the depth of detection, which depends on the size and orientation of the item. In general, the depth of detection is expected to be 4 feet or less. Based on the RI results, the subsurface removal would remove most of the MEC located on the former ground surface, but MEC located deeper (such as within the lahar-covered craters) would not be removed. Although the removal of MEC to depth would have a high long-term reliability, some MEC may remain on site so the effectiveness and protectiveness of this alternative would be evaluated with future site inspections, which are included every 5 years after the removal action.

Administrative controls (an educational awareness program) and institutional controls (warning signs) would be implemented the same as described under Alternative 2.

The approximate removal action area is 30 acres. The total number of subsurface anomalies was estimated from information obtained during the RI geophysical survey. The average anomaly density is estimated at 288 anomalies per acre within the Focus Area for a total estimate of approximately 8,600 anomalies. Approximately 3 percent of the anomalies for the Focus Area are assumed to be MEC based on intrusive investigation results from the RI.

Vegetation removal (i.e., mowing) may or may not be required, depending on the time of year and location on the OB/OD Area (MRS-04). The surface removal would be completed at the MRS by qualified UXO technicians using hand-held detectors, and metal visible on the ground surface or found to protrude through the mineral soil layer into vegetation would be removed. A typical removal process involves partitioning the MRS into 100-foot by 100-foot grids and placing survey grid stakes at the four corners. A systematic surface sweep of the grid would be accomplished to remove the surface metal debris from the grid. Conducting a surface removal requires a SUXOS responsible for planning and directing removal operations, a UXOSO to ensure that work is performed safely and a UXOQCS to ensure the work is performed in accordance with rules, regulations, and planning documents. It is estimated that 15 MEC items would require disposal, based on a density of 1 MEC item for every 2 acres.

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Recovered MEC and MD would be handled, stored, destroyed, shipped, and demilitarized in accordance with the guidance set forth in the approved ESS, DDESB Guidance for Clearance Plans (DDESB 1998), and EM 1110-1-4009 (USACE 2007). MEC would be inspected by a UXO Technician III and UXO Technician II to determine the explosive hazard and appropriate demolition method. MEC that is unacceptable to move would be BIP and MEC determined acceptable to move would be consolidated by qualified UXO technicians at a secure location for later disposal.

2.11 SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES

The following subsections describe how each alternative performs in relation to each of the nine criteria prescribed by the NCP. A summary of the detailed analysis of the remedial action alternatives is presented in Table 2-1.

2.11.1 Overall Protection of Human Health and the Environment

Alternative 1 (No Action) would not be protective of human health and the environment under current conditions.

Alternative 2 (LUCs) provides protection from MEC hazards by increasing awareness of potential risks at the OB/OD Area (MRS-04) with institutional controls. The institutional controls (i.e., signage) would assist and increase the effectiveness of the administrative controls (e.g., educational awareness programs). However, this alternative does not remove the hazards and does not provide a physical barrier.

Alternative 3 (Focused Surface Removal and LUCs) protects human health and the environment. It involves removal of surface MEC, which presents a potential risk to human health. Alternative

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3 does not totally remove the risk associated with surface MEC or subsurface MEC. There may still be MEC exposure outside of the focus area and within the subsurface. This alternative does not provide a physical barrier to prevent exposure. However, it provides for LUCs that would ensure adequate protection.

Alternative 4 (Surface Removal and LUCs) protects human health and the environment. It involves removal of surface MEC from the entire MRS. Alternative 4 does not remove the risk associated with subsurface MEC, but addresses it with the use of LUCs to warn site visitors (signage) and provide periodic site inspections.

Alternative 5 (Surface Removal, Focused Subsurface Removal, and LUCs) protects human health and the environment. It removes risk to human health associated with subsurface MEC in the focus area. Subsurface risk outside of the focus area would be addressed by LUCs.

Alternative 6 (Surface Removal, Subsurface Removal, and LUCs) protects human health and the environment. It removes the most MEC of all the alternatives under consideration. LUCs would still have to be incorporated for MEC that are beyond our ability to detect.

Alternative 7 (Surface Removal, Focused Soil Cover, and LUCs) protects human health and the environment. It involves surface removal alone (Alternative 4) and installing a barrier to subsurface MEC in the focus area. Alternative 7 does not remove the risk associated with subsurface MEC but addresses it with the use of LUCs to warn site visitors (signage) and provide periodic site inspections.

Alternative 8 (Focused Surface Removal, Focused Subsurface Removal, and LUCs) protects human health and the environment. It involves removal of subsurface MEC, which presents a potential risk to human health. Alternative 8 does not remove the risk associated with surface or subsurface MEC outside of the focus area, but addresses it with the use of LUCs to warn site visitors (signage) and provide periodic site inspections.

2.11.2 Compliance with ARARs Alternatives 3 through 8 would comply with RCRA Subpart X – Miscellaneous Units, Section 264.601 Environmental Performance Standards (40 CFR 264). In addition, soil confirmation samples will be collected after disposal/removal/treatment of damaged MEC items and analyzed for TNT, copper, lead, and zinc. Analytical results will be compared to 18 AAC 75.341, Table B1, direct contact, over 40 inch zone cleanup levels to evaluate if soil cleanup may be required.

2.11.3 Long-Term Effectiveness and Permanence

Alternative 1 does not provide long-term effectiveness because MEC remains in the MRS and potential exposure pathways exist.

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Alternative 2 provides some long-term effectiveness through the implementation of LUCs that increase awareness about potential risks, completion of five-year reviews, and incorporation of guidelines for any potential future intrusive activities.

Alternative 3 provides greater long-term effectiveness against MEC hazards than Alternative 2 because a limited removal of surface MEC in the Focus Area reduces the risk to human health and the environment. This alternative does not address the potential MEC that may remain on the surface outside of the Focus Area. Additionally, this alternative does not address subsurface MEC that may migrate to the surface through erosion or frost heave. The long-term effectiveness will be monitored through the implementation of LUCs, completion of five-year reviews, and incorporation of guidelines for any potential future intrusive activities.

Alternative 4 offers a greater long-term effectiveness against MEC than Alternative 3 through a complete removal of surface MEC from the entire MRS, implementation of LUCs, completion of five-year reviews, and incorporation of guidelines for any potential future intrusive activities.

Alternative 5 includes a surface removal and focused subsurface removal of MEC to the depth of detection. Alternative 5 provides the second highest long-term effectiveness against MEC, as the risks to human health and the environment are drastically reduced in the Focus Area. However, there is still a potential for subsurface hazards to human health and the environment outside of the Focus Area. There is also a potential for subsurface hazards to human health and the environment due to depth limitations of detection technology. Therefore potential hazards would not be completely eliminated or completely removed. The long-term effectiveness will be monitored through the implementation of LUCs, completion of five-year reviews, and incorporation of guidelines for any potential future intrusive activities.

Alternative 6 includes removal of surface and subsurface MEC to the depth of detection. Alternative 6 provides the highest long-term effectiveness of the eight alternatives against MEC, as the risks to human health and the environment are drastically reduced. However, there is still a potential for hazards due to depth limitations of detection technology. Therefore potential hazards would not be completely eliminated or completely removed. The long-term effectiveness will be monitored through the implementation of LUCs, completion of five-year reviews, and incorporation of guidelines for any potential future intrusive activities.

Alternative 7 offers increased long-term effectiveness over Alternative 4 through the installation of the soil cover. The soil cover will reduce potential MEC migration inside the Focus Area but not outside of the Focus Area. The effectiveness will be monitored through the implementation of five-year reviews. The long-term effectiveness will be monitored through the implementation of LUCs, completion of five-year reviews, and incorporation of guidelines for any potential future intrusive activities.

Alternative 8 provides greater long-term effectiveness against MEC hazards than Alternative 3 because subsurface MEC in the Focus Area would be removed and therefore, reduces the risk to human health and the environment. Alternative 8 provides greater long-term effectiveness against MEC than Alternative 4 based on the RI results that indicate that MEC is most likely to be

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discovered in the Focus Area. However, there is still risk to human health because this alternative does not address the potential MEC that may remain outside of the Focus Area or deeper than the depth of detection in the Focus Area. The long-term effectiveness will be monitored through the implementation of LUCs, completion of five-year reviews, and incorporation of guidelines for any potential future intrusive activities.

2.11.4 Reduction of Toxicity, Mobility, or Volume through Treatment

Alternatives 1 and 2 do not provide any reduction in the volume of MEC. Alternatives 3, 4, and 7 include reduction in the volume of surface MEC via detonation; however, there is no reduction in the volume of subsurface MEC. Alternative 5 removes subsurface MEC via detonation in the Focus Area to the depth of detection but not outside of the Focus Area, as well as all surface MEC. Alternative 6 completely removes identified surface and subsurface MEC via detonation to the depth of detection. Alternative 8 removes surface and subsurface MEC via detonation in the Focus Area only.

2.11.5 Short-Term Effectiveness

This criterion evaluates the length of time needed to implement an alternative and the risks the alternative poses to workers, residents, and the environment during construction and operation of the remedy until cleanup levels are achieved. Workers conducting remedial actions are required to wear protective clothing and equipment as appropriate to minimize potential exposure.

Alternative 1, no action, would not be an effective alternative because current risk to the local community from direct exposure to surface and subsurface MEC and UXO would continue to exist. The remedial action objectives would not be achieved.

Alternative 2 has relatively higher short-term risks due to the need for site inspections within the OB/OD Area (MRS-04) associated with five-year reviews. Approximately one year would be needed to achieve remedial action objectives, but surface and subsurface MEC and UXO would remain. Workers who inspect the site would be potentially exposed to surface and subsurface MEC, but UXO escorts and MEC avoidance procedures lower risk of MEC contact. The duration of worker exposure to potential safety hazards is relatively low because the site inspection would be completed in approximately 1 week. Local ranchers and visitors would be notified during installation of warnings to prevent exposure during installation but the exposure pathway remains intact. Alternative 2 could be implemented with minimal disturbance to the environment because no remediation will occur.

Alternatives 3, 4, and 7 pose moderate potential short-term risks to site workers and the environment from handling of MEC during surface removal actions and MEC disposal. The use of UXO technicians further reduces risk during removal. Alternatives 3 and 4 would require approximately one year to achieve remedial action objectives, and Alternative 7 would require approximately two years. The duration of worker exposure to potential safety hazards is relatively low because each alternative would be completed in a relatively short timeframe (1 to 4 months). Remedial activities will have limited impact on the local community because the risk from the

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surface MEC is immediately removed thru the remedial action over the 337 acres thus immediately eliminating the primary risk to receptors at the site. To minimize the impact on the community from exposure of additional MEC, local ranchers and visitors would be notified of activities, and an Explosives Safety Submission would establish exclusion zones for community protection. Alternative 3 could be accomplished with a moderate amount of disturbance to the environment within the focus area. Alternative 4 would have slightly more disturbance due to the larger removal area footprint. Alternative 7 would have the most disturbances to the environment due to installation of the soil cover and removal of soil from an on-site borrow source.

Alternatives 5, 6, and 8 pose the highest potential short-term risks to site workers and the environment from the handling of MEC (during surface and subsurface removal actions) and MEC disposal. Alternatives 5 and 8 would require approximately one year to achieve remedial action objectives, and Alternative 6 would require approximately three years. The duration of worker exposure to potential safety hazards is relatively high because work duration is 3 to 13 months and involves excavation to remove MEC. Remedial activities pose moderate potential short-term risk to the community because the removal actions could create additional exposure pathways. To minimize the impact on the community, local ranchers and visitors would be notified of activities, and an Explosives Safety Submission would establish exclusion zones for community protection. Disturbance to the environment would be similar to Alternative 4, but the depth would be greater due to subsurface removal. The disturbed area for Alternative 8 would be the same as Alternative 3, but the depth would be greater due to subsurface removal.

2.11.6 Implementability

Alternative 1 does not include any construction or operation and is the easiest to implement. Alternative 2 includes institutional and administrative controls requiring periodic maintenance to maintain the integrity of signage and occasional educational sessions; all aspects of the remedy are feasible but there is no on-site land manager to ensure controls are implemented at all times. Alternatives 3 through 8 involve the use of specialized equipment and specially-trained personnel for removal activities. Specialized equipment and personnel increase the difficulty of implementability of these alternatives. Alternatives 3 and 4 include surface removals that only require one field season to complete. Alternatives 5, 6, and 8 each include subsurface removals and would be the most difficult to implement due to the number and type of required procedures, personnel, and longer duration. Alternative 6 would require the biggest effort and longest duration to complete. All the alternatives require considerable planning and coordination because of the remote nature of the site, and Alternatives 6 and 7 require multiple field seasons.

2.11.7 Cost

The alternatives are listed below from lowest to highest total cost. A summary of the costs is presented in Table 2-2.

• Alternative 1, No Action ($0) – This alternative has no associated costs.

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• Alternative 2, LUCs ($1.04 million) – Capital costs include labor and materials for the installation of signage and implementation of a public awareness program. Periodic costs for five-year reviews include site inspection and Administrative Record review. There are high costs associated with mobilization and logistics. • Alternative 3, Focused Surface Removal and LUCs ($1.85 million) – The expense of this alternative is due to the costs associated with the specialized personnel necessary for the surface removal, heavy equipment needs associated with removal and support activities, extensive support, and extensive logistics. Periodic costs for five-year reviews are similar to Alternative 2. • Alternative 4, Surface Removal and LUCs ($5.46 million) – The expense of this alternative is due to the costs associated with the specialized personnel necessary for the surface removal, heavy equipment needs associated with removal and support activities, extensive support, and extensive logistics. Periodic costs for five-year reviews are similar to Alternative 2. • Alternative 8, Focused Surface Removal, Focused Subsurface Removal, and LUCs ($8.06 million) – The expense of this alternative is due to the costs associated with the specialized personnel necessary for the surface and subsurface removal, heavy equipment needs associated with removal and support activities, extensive support, and extensive logistics. Periodic costs for five-year reviews are similar to Alternative 2. • Alternative 5, Surface Removal, Focused Subsurface Removal, and LUCs ($9.52 million) – The expense of this alternative is due to the costs associated with the specialized personnel necessary for the surface and subsurface removal, heavy equipment needs associated with removal and support activities, extensive support, and extensive logistics. Periodic costs for five-year reviews are similar to Alternative 2. • Alternative 7, Surface Removal, Focused Soil Cover, and LUCs ($10.9 million) – The expense of this alternative is due to the costs associated with the specialized personnel necessary for the surface removal and soil cover construction, heavy equipment needs associated with removal and support activities, extensive support, extensive logistics, and need for two field seasons to complete the work. Periodic costs for five-year reviews are similar to Alternative 2. • Alternative 6, Surface Removal, Subsurface Removal, and LUCs ($32.0 million) – The expense of this alternative is due to the costs associated with the extensive field work required, duration of work, specialized personnel necessary for the surface removal, heavy equipment needs associated with removal and support activities, extensive support, extensive logistics, and need for three field seasons to complete the work. Periodic costs for five-year reviews are similar to Alternative 2.

2.11.8 Regulatory Agency Acceptance

This criterion evaluates whether the State of Alaska agrees with the analysis and recommendations resulting from the RI, FS, and the PP. The ADEC has fully participated throughout the process at this site. ADEC expressed their support of Alternative 5, Surface Removal, Focused Subsurface

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Removal, and LUCs in comments received on the Proposed Plan. The ADEC will provide a final determination regarding the selected remedy under a separate cover.

2.11.9 Community Acceptance

There were numerous comments offered at the two public meetings; however, only one written comment was received during the public comment period (see Appendix A). Public comments received on the Proposed Plan and associated USACE responses (see Part 3 of this Decision Document) indicate the community accepts the selected remedy.

2.12 PRINCIPAL THREAT WASTES

The principal threat concept refers to the source materials at a CERCLA site considered to be highly toxic or highly mobile that generally cannot be reliably controlled in place or present a significant risk to human health or the environment should exposure occur. A source material is material that contains hazardous substances, pollutants, or contaminants that act as a reservoir for migration of contamination to groundwater, surface water, or air, or that acts as a source for direct exposure. No principal threat waste has been identified at OB/OD Area (MRS-04).

2.13 SELECTED REMEDY

The selected remedy for OB/OD Area (MRS-04) is Alternative 5 – Surface Removal, Focused Subsurface Removal, and LUCs. This preferred alternative will satisfy the RAO by reducing the potential for direct contact with MEC by human receptors, considering current and future land use.

2.13.1 Description of the Selected Remedy

The selected remedy for the OB/OD Area (MRS-04) consists of a surface removal over the entire 337 acres (100-percent coverage), a focused subsurface removal to the depth of detection over 30 acres, and LUCs to increase awareness of potential risks through administrative and institutional controls.

The surface removal will be completed by UXO technicians qualified in accordance with Technical Paper (TP) 18 (DDESB 2004) using hand-held detectors, and metal visible on the ground surface or found to protrude through the mineral soil layer into vegetation would be removed. Vegetation removal (i.e., mowing) may or may not be required, depending on the time of year and density of vegetative cover.

The subsurface removal would be to the depth of detection of the metal detector selected for the response action. Reliable depths of detection range from a few inches for small, 20-millimeter rounds to several feet for larger projectiles and bombs. Subsurface removal activities would include a comprehensive geophysical survey in order to acquire subsurface anomalies potentially representing MEC. Geophysical data would include RI digital geophysical mapping (DGM) survey data, additional DGM survey data, and analog geophysical data where vegetation and

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terrain inhibit the positioning quality of DGM surveying. The subsurface removal would be conducted by UXO technicians qualified in accordance with TP 18 (DDESB 2004) using hand- held detectors, shovels, and/or earth-moving machinery.

For the surface and subsurface removals, recovered MEC and MD would be managed, stored, disposed of by detonation with consolidated shots, shipped, and demilitarized in accordance with the approved project plans and safety submittals. Typically, MEC would be destroyed on-site through controlled demolition and MD would be shipped off-site for destruction and recycling. Soil confirmation sampling will be conducted during the MEC removal activities to verify the identified COPCs (TNT, copper, and lead) do not present a risk.

USACE will be responsible for implementing, maintaining, and monitoring the selected remedies. However, the landowner will also be requested to implement a notice of environmental contamination which documents the area which may contain residual MEC items. USACE will provide the landowner with available data and assist with implementation. The landowner must implement this voluntary action and it would be maintained under the appropriate land records. USACE will exercise this responsibility under the DERP statute and in accordance with CERCLA and the NCP.

Based on information currently available, USACE believes the selected remedy for the OB/OD Area (MRS-04) meets the threshold criteria and provides the best balance of tradeoffs among the other alternatives with respect to the balancing and modifying criteria. USACE expects the selected remedy to satisfy the requirements of CERCLA by protecting human health and the environment and being cost-effective.

2.13.2 Remedy Cost Estimate Summary

The estimated capital cost, O&M costs, periodic costs, total cost, and total present value for all remedial action alternatives are presented in Table 2-2. The total cost for Alternative 5 for the OB/OD Area (MRS-04) is $9.52 million. Changes in the remedy’s cost elements are likely to occur as a result of new information and data collected during the engineering design of the remedial alternatives.

2.13.3 Expected Outcomes of Selected Remedy

Following implementation of the selected remedy, risks to human health and the environment will be reduced greatly by removing MEC at the OB/OD Area (MRS-04).

2.14 STATUTORY DETERMINATIONS

Based on the information currently available, the selected remedy for the OB/OD Area (MRS-04) is protective of human health and the environment and satisfies the statutory requirements of CERCLA §121(b) with regard to the former use of the site by the DoD. The selected remedy complies with federal and state requirements that are applicable or relevant and appropriate to the

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2.15 DOCUMENTATION OF SIGNIFICANT CHANGES

The selected remedy of Alternative 5 described in this DD for the OB/OD Area (MRS-04) is unchanged from the selected remedy presented in the Final PP (URS 2014b).

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TABLE 2-1 DETAILED ANALYSIS OF REMEDIAL ACTION ALTERNATIVES Alternative 1 Alternative 2 Alternative 3 Alternative 4 Alternative 5 Alternative 6 Alternative 7 Alternative 8 Surface Removal, Focused Surface Removal, Focused Surface Removal, Focused Surface Removal Surface Removal and Subsurface Removal, and Subsurface Removal, and Surface Removal, Focused Focused Subsurface Evaluation Criterion No Action Land Use Controls and LUCs LUCs LUCs LUCs Soil Cover, and LUCs Removal, and LUCs OVERALL PROTECTION OF HUMAN HEALTH AND THE ENVIRONMENT Human Health Would not reduce risk to Provides overall Provides overall protection Provides overall protection Provides overall protection Provides overall protection Provides overall protection Provides overall protection Protection human receptors. protection of human of human receptors with a of human receptors with a of human receptors with a of human receptors with of human receptors with a of human receptors with receptors with an MEC surface removal in the MEC surface removal from MEC surface removal from MEC surface and subsurface MEC surface removal from MEC surface and subsurface educational awareness focus area and LUCs as the entire OB/OD Area the entire OB/OD Area removal from the entire the entire OB/OD Area removal in the focus area program and posting of indicated in Alternative 2. (MRS-04) and LUCs as (MRS-04), a subsurface OB/OD Area (MRS-04) and (MRS-04), a 2-foot soil and LUCs as indicated in warning signs. indicated in Alternative 2. MEC removal from the LUCs as indicated in cover in the focus area, and Alternative 2. focus area, and LUCs as Alternative 2. LUCs as indicated in indicated in Alternative 2. Alternative 2. Environmental Would not reduce risk to Same as Alternative 1. Protects ecological receptors Protects ecological receptors Same as Alternative 4. Same as Alternative 4. Same as Alternative 4. Same as Alternative 4. Protection ecological receptors or the and the environment in the and the environment, as long environment. Focus Area, as long as as future inspections/ future inspections/removals removals (if needed) are (if needed) are completed. completed. COMPLIANCE WITH ARARs Compliance with ARARs No applicable ARARs were Same as Alternative 1. Consolidated shots would Same as Alternative 3. Same as Alternative 3. Same as Alternative 3. Same as Alternative 3. Same as Alternative 3. identified. comply with RCRA Subpart X – Miscellaneous Units, Section 264.601 Environmental Performance Standards (40 CFR 264) LONG-TERM EFFECTIVENESS AND PERMANENCE Magnitude of Residual Risks to potential future Risks to potential future Risks to potential future Similar to Alternative 3, Residual risk is less than Residual risk is the lowest of Similar to Alternative 4, Residual risk is less than Risk receptors would remain receptors would remain receptors would remain for except residual risk is lower Alternative 4 because all the alternatives evaluated although additional risk Alternative 3 because indefinitely. indefinitely. Some risk intrusive activities. Some because MEC is removed subsurface MEC is removed because subsurface MEC is mitigation through soil subsurface MEC is removed reduction from future risk of MEC located on the from surface over entire site. to the depth of detection removed to the depth of cover. to the depth of detection maintenance of warning surface would still exist within the Focus Area. detection from the entire within the Focus Area. signs and continued outside of the Focus Area. MRS. Some risk to MEC located educational awareness There is a risk of MEC on the surface and in the program. resulting from erosion and subsurface would still exist frost heave. outside of the Focus Area. Adequacy and Reliability Not applicable. Adequacy and reliability Adequacy and reliability of Similar to Alternative 3, Adequacy and reliability of Similar to but a higher level Similar to Alternative 4, Adequacy and reliability of of Controls of alternative is low surface removal within the except higher level of surface removal (entire site) than Alternative 5. except higher level of surface and subsurface because it does not Focus Area is high as long adequacy and reliability and subsurface removal adequacy and reliability removal (Focus Area) is physically restrict access as future inspections and because MEC is removed (Focus Area) is somewhat because the soil cover adds a somewhat higher than to the site and an on-site removals (if needed) are from surface over entire site. higher than Alternative 4, as 2-foot thick barrier to MEC Alternative 3, as long as land manager is not completed on a periodic long as future inspections in the Focus Area, which future inspections and present to provide basis. For the area outside and removals (if needed) are will also help to limit MEC removals (if needed) are continuous monitoring of of the Focus Area, the completed on a periodic migration to the surface completed on a periodic access. adequacy and reliability is basis. through erosion and frost basis. similar to Alternative 2. heave.

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TABLE 2-1 DETAILED ANALYSIS OF REMEDIAL ACTION ALTERNATIVES Alternative 1 Alternative 2 Alternative 3 Alternative 4 Alternative 5 Alternative 6 Alternative 7 Alternative 8 Surface Removal, Focused Surface Removal, Focused Surface Removal, Focused Surface Removal Surface Removal and Subsurface Removal, and Subsurface Removal, and Surface Removal, Focused Focused Subsurface Evaluation Criterion No Action Land Use Controls and LUCs LUCs LUCs LUCs Soil Cover, and LUCs Removal, and LUCs REDUCTION OF TOXICITY, MOBILITY, AND VOLUME Treatment Process Used None. None. Disposal of MEC by Same as Alternative 3. Same as Alternative 3. Same as Alternative 3. Same as Alternative 3. Same as Alternative 3. detonation. Reduction of TMV None. None. The volume of MEC on the Similar to Alternative 3, Similar to Alternative 4, Similar to Alternative 5, Similar to Alternative 4, Similar to Alternative 3, surface of the Focus Area with additional reduction of with additional reduction of with additional reduction of with additional reduction of with additional reduction of would be removed, and the MEC. MEC. MEC. MEC mobility to the MEC. MEC would be destroyed by surface. detonation. SHORT-TERM EFFECTIVENESS Time Required to Not applicable. 1 year. 1 year. 1 year. 1 year. 3 years. 2 years. 1 year. Achieve Remedial Action Objectives Protection of Community Not applicable. Local ranchers and other Similar to Alternative 2. Similar to Alternative 3. Similar to Alternative 4. Similar to Alternative 5. Same as Alternative 4. Similar to Alternative 3. During Remedial Action island visitors would be ESS would establish Need for protection Need for protection Need for protection Need for protection notified during exclusion zones for increases because more increases because more increases because more increases because more installation of warning community protection. MEC is destroyed. MEC is destroyed. MEC is destroyed. MEC is destroyed. signs to prevent exposure during installation. Protection of Workers Not applicable. Workers would follow an Similar to Alternative 2. Similar to Alternative 3. Similar to Alternative 4. Similar to Alternative 5. Similar to Alternative 4. Similar to Alternative 3. During Remedial Action Accident Prevention Plan ESS would establish Need for protection Need for protection Need for protection Requires MEC avoidance Need for protection and Site Safety and exclusion zones during increases because more increases because more increases because more during construction of soil increases because more Health Plan, which remedial actions. MEC is destroyed. MEC is destroyed. MEC is destroyed. cover. MEC is destroyed. includes an Anomaly/MEC Avoidance Plan and Unexploded Ordnance Technician Escort. Protection of Not applicable. Alternative 2 could be Alternative 3 could be Alternative 4 could be The disturbed area for The disturbed area for Alternative 7 could be The disturbed area for Environment During implemented with very accomplished with a accomplished with slightly Alternative 5 is the same as Alternative 6 is the same as accomplished with slightly Alternative 8 is the same as Remedial Action little disturbance to the moderate amount of more disturbance to the for Alternative 4. Because for Alternative 4. Because more disturbance to the for Alternative 3. Because environment. Workers disturbance to the environment than subsurface removal is added, subsurface removal is added, environment than other subsurface removal is added, would follow an environment within the Alternative 3 because the some additional disturbance some additional disturbance alternatives due to some additional disturbance Environmental Protection Focus Area. footprint of the removal area to the environment at depth. to the environment at depth. installation of soil cover and to the environment at depth. Plan for this and all other is larger. removal of soil from on-site alternatives. borrow source.

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Decision Document 2-34 Former Fort Glenn, Umnak Island, Alaska F10AK029804 SECTIONTWO Decision Summary

TABLE 2-2 COST SUMMARY OF REMEDIAL ACTION ALTERNATIVES Alternative 1 Alternative 2 Alternative 3 Alternative 4 Alternative 5 Alternative 6 Alternative 7 Alternative 8 Focused Surface Surface Removal, Surface Surface Removal, Focused Focused Removal, Removal, Focused Surface Surface Subsurface Subsurface Focused Soil Subsurface Removal and Removal and Removal, Removal, Cover, and Removal, Cost Summary of Remedial Land Use Land Use Land Use and Land and Land Land Use and Land Action Alternatives No Action Controls Controls Controls Use Controls Use Controls Controls Use Controls Description Total Project Duration (Years) 0 30 30 30 30 32 31 30 Capital Cost $0 $429,000 $1,240,000 $4,840,000 $8,910,000 $31,500,000 $10,400,000 $7,450,000 Periodic Cost (Site Inspections and 5-Year Reviews) Incurred $0 $102,000 $102,000 $102,000 $102,000 $102,000 $102,000 $102,000 Every 5 Years Present Value of Periodic Cost (Site Inspections and 5-Year $0 $510,000 $510,000 $510,000 $510,000 $499,000 $504,000 $510,000 Reviews) Total Cost of Alternative $0 $1,040,000 $1,860,000 $5,460,000 $9,520,000 $32,100,000 $11,000,000 $8,070,000 Total Present Value of $0 $938,000 $1,750,000 $5,350,000 $9,420,000 $32,000,000 $10,900,000 $7,960,000 Alternative

Decision Document 2-35 Former Fort Glenn, Umnak Island, Alaska F10AK029804 SECTIONTWO Decision Summary

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Decision Document 2-36 Former Fort Glenn, Umnak Island, Alaska F10AK029804 Canada Russia

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Legend

Former Fort Glenn Remaining OB/OD OB/OD Area (MRS-04) (337 acres) Area (MRS-14) Remaining OB/OD Area (MRS-14) (1,739 acres) Focus Area (30 acres)

OB/OD Area (MRS-04)

Drainage Feature with range-related debris

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_ 2. Aerial photo source: GeoEye-1, captured 8/2/2011 P P _ S F _ e l b a r e v i l e 0 750 1,500 3,000 D \ n n Feet e l ¹ G t r o F \ :

Z OB/OD Area Details Former Fort Glenn Umnak Island, Alaska

Drawn By: Date: JZ 1/16/2015 Checked By: Project No: Figure 2-2 JB 16170581 Bering Sea

Raised foundation/ gravel pad

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k a Inanudak n Bay m Copyright:© 2014 Esri U Legend Former Fort Glenn OB/OD Area (MRS-04) (334 acres) Focus Area (30 acres) Visual Reconnaissance Track FG Crater E Crater Filled with Lahar GF MEC "S Fuze Container E E E E "S !( Site Feature FG E E Cantonment Area GFFG GF Partially buried fuze container pile FG "S"S"S"S "S"S "S

Northwest cluster of craters, 3 craters visible FG FG Notes: GFGFG FG FG 1. NAD83 Alaska State Plane Zone 10, US Survey Feet FGFGFGFG FGFG 2. Aerial photo source: GeoEye-1, captured 8/2/2011 GFG FGF 3. Cantonment area consists of dilapidated buildings, revetments, quonsets, and covered magazines. d x

m FG No evidence of OB/OD activities or burial pits . v r u were were discovered in this area, but DMM and s _ s i buried RRD trash pits were discovered. v _ d 4. RRD trash pile consisted of M106 Fuze o b Southeast cluster of o

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3 craters, 16 craters visible - 2 g i f \ D D \ D D

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Drawn By: Date: JZ 1/16/2015 Checked By: Project No: Figure 2-3 BP 16170581 Bering Sea

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Recreational Residents Site Worker Users MEC at Surface

Handle/Tread    Access Redeposition Underfoot Available Erosion Frost Heave Intrusive    Volcanic Activity

OB/OD MEC in Area Subsurface

No Access

Complete Pathway Incomplete Pathway  Potentially Complete Pathway

MEC Conceptual Site Model, OB/OD Area (MRS-04) Date: Project No. Former Fort Glenn 6/3/2014 16170581 Figure 2-5 Umnak Island, Alaska

Decision Document Former Fort Glenn, Umnak Island, Alaska F10AK029804 Release Exposure Exposure Source Area Source Media Human and Ecological Receptors Mechanisms Media Routes

Recreational Ecological Residents Site Worker Users Receptors

Vegetation Uptake by Biota Domestic Animals Game/Fish/Prey

Surface Water/ Ingestion Runoff Sediment Dermal Contact

OB/OD Soil Area

Ingestion  Leaching Groundwater Dermal Contact  Inhalation (Vapor)

Ingestion  Subsurface Soil Dermal Contact   (>2 ft) Inhalation (Dust) 

Ingestion   Surface Soil Dermal Contact   (0-2 ft) Inhalation (Dust)  

Complete Pathway  Potentially Complete Pathway  Potentially Complete But Insignificant Pathway Incomplete Pathway

MC Conceptual Site Model, OB/OD Area (MRS-04) Date: Project No. Former Fort Glenn 6/3/2014 16170581 Figure 2-6 Umnak Island, Alaska

Decision Document Former Fort Glenn, Umnak Island, Alaska F10AK029804 3 Responsiveness Summary

SECTIONTHREE Responsiveness Summary

3.1 STAKEHOLDER ISSUES AND LEAD AGENCY RESPONSES

The FS report relating to the evaluation at the OB/OD Area (MRS-04) was submitted to ADEC for review and comment. The PP that summarized the alternatives evaluation and recommended the preferred alternatives was also submitted to ADEC for review and comment. ADEC formally disagreed with the recommendation of Alternative 8 in the PP for the OB/OD Area (MRS-04) and suggested Alternative 5 as the preferred alternative. USACE agreed with ADEC’s suggestion of Alternative 5.

USACE also made the PP available for public comment between May 1 and June 2, 2014. This public comment period was announced through a notice that was placed in the Anchorage Daily News and the Bristol Bay Times/Dutch Harbor Fisherman newspapers. Public comments were received during the public meeting held on May 6, 2014, at the Z.J. Loussac Public Library in Anchorage, Alaska and during the public meeting held on May 7, 2014 at the Unalaska Public Library in Unalaska, Alaska. Summaries of the public meetings and documentation of the one public comment are included in Appendix A.

One written comment was received via e-mail from Steve Sumida of the Tanadgusix Native Corporation on May 8, 2014. Mr. Sumida’s e-mail indicated that a lack of invitation or notification preceding the public meetings was an oversight concern that should be forwarded up the USACE chain of command in order to discuss funding for increased participation by the Tanadgusix Native Corporation. Mr. Sumida also expressed concern that the Tanadgusix Native Corporation interests (i.e., land ownership, reindeer operations, subsistence uses, presence of Nikolski subsistence, traditional ancestral values) were not included in any documents or discussed at the public meetings. Finally, Mr. Sumida stated that there was “no reference to the impact or knowledge of the existence of mustard gas or its associated stabilizing chemicals as a consideration in this project as either a concern in limiting subsurface removal or investigations, and what impact that might have on this process.”

Valerie Palmer from USACE-Alaska District sent an e-mail to Mr. Sumida on May 19, 2014 thanking him for his participation at the public meeting in Anchorage on May 6, 2014. Ms. Palmer explained that his concerns had been forwarded to superiors at the USACE-Alaska Division and USACE Headquarters. Ms. Palmer indicated that the Tanadgusix Native Corporation will be added to the list of interested stakeholders. Ms. Palmer indicated that the entire project team is aware of the cultural, archaeological, and anthropologic significance for the Tanadgusix Native Corporation shareholders and the immediate subsistence and environmental importance. Ms. Palmer added that USACE has not yet received funding to complete the investigation of potential chemical warfare materials (mustard gas) and that the “potential presence of these items will not interfere with the execution of work at the two projects discussed in the Proposed Plan.” Ms. Palmer concluded that it is the mission of the USACE Formerly Used Defense Site program to reduce and/or eliminate environmental risks caused by the DoD at eligible sites, and that the funding mechanism by Congress does not allow finances to be spent for participation or oversight by land owners or adjacent landowners.

Decision Document 3-1 Former Fort Glenn, Umnak Island, Alaska F10AK029804 SECTIONTHREE Responsiveness Summary

3.2 TECHNICAL AND LEGAL ISSUES

There were no significant technical or legal issues raised in the process of developing this DD.

Decision Document 3-2 Former Fort Glenn, Umnak Island, Alaska F10AK029804 4 References

SECTIONFOUR References

Code of Federal Regulations (CFR). Revised 2011. Applicable sections of Title 40, Part 300, National Oil and Hazardous Substances Pollution Contingency Plan.

Department of Defense (DoD). 2007. Munitions Response Site Prioritization Protocol Draft Primer, Office of the Deputy Under Secretary of Defense Installations and Environment, Office of Environmental Management. April.

Department of Defense Explosives Safety Board (DDESB). 1998. DDESB Memorandum, Subject: Guidance for Clearance Plans. 27 January.

DDESB. 2004. Technical Paper 18, Minimum Qualifications for Unexploded Ordnance (UXO) Technicians and Personnel. December.

Ferris and Bivens. 2002. SSG Tom Ferris & SGT John Bivens. 24-29 July 2002 Combined Incident to Kodiak and Fort Glenn, Alaska. July.

Jacobs Engineering Group (Jacobs). 2003. 2001 Fort Glenn Remedial Investigation/Interim Removal Action Report, Umnak Island, Alaska. Final. September.

Parsons. 2008. Site Inspection: Former Fort Glenn, Umnak and Unalaska Islands, Alaska. Final Revision 3. 5 September.

United States Army Corps of Engineers (USACE). 1992. Inventory Project Report: Fort Glenn, Umnak Island, Alaska. April.

USACE. 2007. Engineering Manual 1110-1-4009. Military Munitions Response Actions. June.

United States Army Corps of Engineers, St. Louis District (CELMS). 2001. Archives Search Report Findings for Fort Glenn, Umnak Island, Alaska. September.

CELMS. 2004. Archives Search Report Supplement Findings for Fort Glenn, Umnak Island, Alaska. November.

United States Environmental Protection Agency (USEPA). 1988. Guidance for Conducting Remedial Investigations and Feasibility Studies under CERCLA, Interim Final. EPA/540/G-89/004. OSWER Directive 9355.3-01. October.

USEPA. 2008. Technical Working Group. Interim Munitions and Explosives of Concern Hazard Assessment Methodology. October.

United States Fish and Wildlife Service (USFWS). 2006. Wetlands Mapper.

URS Group, Inc. (URS). 2012. Final, Remedial Investigation of OB/OD Area, Former Fort Glenn, Umnak Island, Alaska. 23 March.

Decision Document 4-1 Former Fort Glenn, Umnak Island, Alaska F10AK029804 SECTIONFOUR References

URS. 2014a. Final (Revision 2), Feasibility Study of OB/OD Area, Former Fort Glenn, Umnak Island, Alaska. January.

URS. 2014b. Final, Proposed Plan, OB/OD Area (MRS-04) and Remaining OB/OD Area (MRS- 14), Military Munitions Response Program, Former Fort Glenn, Umnak Island, Alaska, FUDS Project Numbers: F10AK029804 and F10AK029814. April.

Decision Document 4-2 Former Fort Glenn, Umnak Island, Alaska F10AK029804 APPENDIXA Public Participation

Appendix A Public Participation

Decision Document Former Fort Glenn, Umnak Island, Alaska F10AK029804 APPENDIXA Public Participation

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Decision Document Former Fort Glenn, Umnak Island, Alaska F10AK029804 Public Review Period Documentation - FINAL Proposed Plan, Former Fort Glenn, Umnak Island, Alaska

Date: June 13, 2014

To: Administrative Record

From: Craig Johnson, URS Project Manager

Subject: Public Review Period Documentation

Introduction

The purpose of this memorandum is to document the public review of the Proposed Plan (PP) for the Open Burn/Open Detonation (OB/OD) Area (Munitions Response Site [MRS]-04) and Remaining OB/OD Area (MRS-14).

Public Review Period

A public review period for the PP was conducted from May 1 to June 2, 2014. The PP and related documents (i.e., Remedial Investigation [RI] Report and Feasibility Study [FS] Report) were made available to the public at the following locations:

Alaska Resources Library & Information Services Library Building, Suite 111 3211 Providence Drive Anchorage, Alaska 99508

Unalaska Public Library 64 Eleanor Street Unalaska, Alaska 99685

The availability of these documents was published in the Anchorage Daily News and The Bristol Bay Times/Dutch Harbor Fisherman newspapers on April 27 and May 1, 2014, respectively (Attachment 1).

Public Meetings

Public meetings were held on May 6 and 7, 2014 to present the PP to a broader community audience than those that had already been involved at the site. At these meetings, the public was invited to pose questions and/or comments about the Proposed Plan to the United States Army Corps of Engineers (USACE), the Alaska Department of Environmental Conservation (ADEC), and URS Group, Inc. (URS). The public meetings were held from 6:30 – 7:30 p.m. at two separate locations:

Decision Document A-1 Former Fort Glenn, Umnak Island, Alaska F10AK029804 Public Review Period Documentation - FINAL Proposed Plan, Former Fort Glenn, Umnak Island, Alaska

Z.J. Loussac Public Library 3600 Denali Street Anchorage, Alaska 99503 May 6, 2014

Unalaska Public Library 64 Eleanor Street Unalaska, Alaska 99685 May 7, 2014

Informational flyers announcing the details of the public meetings were produced and distributed, as appropriate, by the USACE, Alaska District (Attachment 2). A list of public meeting attendees is provided below. The sign-in sheet for each public meeting is provided in Attachment 3:

Public Meeting List of Attendees – May 6, 2014 Name Affiliation Email Chris Roe Anchorage Resident [email protected] Kimberly Kashevarof St. George Tanaq Corp [email protected] Vinera Erickson DOT Leasing [email protected] Colette Foster DOT Av Leasing [email protected] Deb Caillouet ADEC [email protected] Steve Sumida TDX Not provided Lisa Geist USACE, Alaska [email protected] Valerie Palmer USACE, Alaska [email protected] Lindsey Miller USACE, Huntsville [email protected] Craig Johnson URS [email protected] Piama R. Oleyer Anchorage Resident [email protected]

Public Meeting List of Attendees – May 7, 2014 Name Affiliation Email Josh Stamm Bearing Pacific Ranch [email protected] Roger Deffendall Unalaska Resident [email protected] Billie Jo Gehring Unalaska Resident [email protected] Lauren Rosenthal KUCB 89.7 FM [email protected] Lisa Geist USACE, Alaska [email protected] Valerie Palmer USACE, Alaska [email protected] Lindsey Miller USACE, Huntsville [email protected] Craig Johnson URS [email protected] Deb Caillouet ADEC [email protected]

Transcript of Public Meeting

The following is a record of the public meetings, with questions/responses organized in chronological order as they were discussed during the meeting.

Decision Document A-2 Former Fort Glenn, Umnak Island, Alaska F10AK029804 Public Review Period Documentation - FINAL Proposed Plan, Former Fort Glenn, Umnak Island, Alaska

May 6, 2014 – Z.J. Loussac Public Library (Wilda Marston Theater) in Anchorage, Alaska The meeting started at 6:30 p.m. Copies of the presentation slides and the PP for the OB/OD Area were made available to interested attendees. Mr. Craig Johnson welcomed everyone and thanked them for attending. USACE representatives and meeting attendees introduced themselves. Ms. Valerie Palmer is the overall project manager for the Fort Glenn project. Ms. Lindsey Miller is a project manager with the Huntsville District of USACE and provides oversight of the munitions contract with URS. Ms. Lisa Geist provides technical support for the Alaska District. Ms. Deb Caillouet is the regulatory project manager from ADEC and reviews all project documents for compliance with state regulations. Two representatives from the Alaska Department of Transportation, Aviation Leasing office, Ms. Vinera Erickson and Ms. Colette Foster, were in attendance. Additional attendees included Ms. Kimberly Kashevarof, representing St. George Tanaq Corporation, and Mr. Steve Sumida, representing TDX Corporation, both landowners on Umnak Island. Two local Anchorage residents also attended, Ms. Piama Oleyer and Mr. Chris Roe.

Mr. Johnson provided instructions for submitting comments on the PP. He indicated that attendees may ask questions after or during the presentation, submit written comments using the comment forms within the document, or e-mail/call Ms. Valerie Palmer using the contact information in the presentation slides packet. Comments will be recorded and responses to significant comments will be included in the responsiveness summary section of the Decision Document (DD).

Mr. Johnson gave an overview of the project location. Fort Glenn is located on the eastern end of Umnak Island in the Aleutian Islands chain, approximately 850 miles southwest of Anchorage. Fort Glenn is a formerly used defense site (FUDS) which has undergone several previous investigations since the 1990s. The most recent investigations were an RI and FS, which were initiated in 2010. The OB/OD Area (2,076 acres) was investigated for potential munitions and explosives of concern (MEC) and munitions constituents (MC). MEC includes conventional munitions items which may pose an explosive hazard. MC are chemicals such as explosive filler (e.g., TNT) or metals that may impact surrounding media if the munitions item was damaged or leaked.

Fort Glenn was one of the last outposts to defend the United States during World War II. Construction began in March 1942 of a 102,062 acres Army airfield and defense garrison to accommodate 100,000 troops. On June 3 and 4, 1942, fighter planes stationed at Fort Glenn defended Dutch Harbor from attack by the Japanese. In 1944, Fort Glenn was placed in caretaker status after the Japanese were driven from the Aleutian Islands. On September 18, 1948, Fort Glenn was officially redesignated as Cape Air Force Base in honor of Lt. John J. Cape, who was killed in action over Umnak Island. From 1952 to 1955, Fort Glenn was transferred from Department of Defense ownership to public and private ownership.

The former Fort Glenn is currently owned by the Aleut Corporation, St. George Tanaq Corporation, State of Alaska Department of Transportation and Public Facilities (ADOT&PF), and the United States Fish and Wildlife Service. The ADOT&PF owns the entire area covered

Decision Document A-3 Former Fort Glenn, Umnak Island, Alaska F10AK029804 Public Review Period Documentation - FINAL Proposed Plan, Former Fort Glenn, Umnak Island, Alaska

by the OB/OD Area. Land use is currently agricultural (free range cattle grazing) and recreational (seasonal hunting), with nearby residential. There was a volcanic eruption from Mount Okmok in 2008 that resulted in the deposition of lahar at the former Fort Glenn. Ms. Kashevarof expressed concern that other landowners were not properly listed on the slide. Mr. Sumida also stated that TDX Corporation owned land on Umnak and should be included. Ms. Palmer explained that the listed landowners pertained to the OB/OD Area only, and not the larger Fort Glenn property. Ms. Palmer agreed the slides could be clarified. Ms. Palmer also explained that the land ownership was complicated by different surface and subsurface land estate rights.

Mr. Johnson continued to describe the types of conventional munitions stored at Fort Glenn, some of which were disposed of at the OB/OD Area including projectiles, fuzes, grenades, bombs, and blasting caps. An attendee asked about the chemical warfare munitions (CWM) project and expressed concern that project was not moving forward first. Ms. Palmer responded that decisions about CWM project funding were made at a much higher level in Headquarters and was beyond her control.

The site investigation has followed the Comprehensive Environmental Response Compensation and Liability Act (CERCLA) regulatory process. The site is currently in the “Proposed Plan” stage, with a DD to follow the public comment period, then remedial design and remedial action. The previously completed phases include a preliminary assessment, site inspection, RI, and FS. The ADEC is the lead regulatory agency for this project. The previous investigations at Fort Glenn included an inventory project report which established FUDS eligibility in 1992. An Archives Search Report (ASR) reviewed historical photographs, maps, and site reports. A supplement to the ASR developed a list of MEC that may be found within each range. A Site Inspection determined the presence or absence of MEC and MC, and recommended the OB/OD Area for further RI.

The objective of the RI was to evaluate historical aerial photography of the OB/OD Area for evidence of potential demolition craters and verify their presence through visual reconnaissance and collect GPS coordinates of the lahar flows. The objectives included evaluation of the presence and extent of surface and subsurface MEC in demolition craters and kickout areas; characterization of the nature and extent of potential MC; and collection of background data sets for surface soil. The RI activities included development of planning documents, a public involvement plan, mobilization plan, explosives siting plan, technical project planning meetings (3 total), fieldwork, and development of the Final RI Report.

The RI fieldwork in 2011 included geophysics to find subsurface anomalies that could represent a munition item. Anomalies were selected for further investigation by digging, either by hand or by machine. If conventional unexploded items were encountered, they were disposed by detonation. Munitions debris (MD) was hauled off the island for proper disposal. Ms. Kashevarof asked if all the previously identified munitions (MEC/MD) were removed. Mr. Johnson replied that during the RI all items uncovered were removed. Ms. Kashevarof also expressed concern about the local reindeer on Umnak Island – could their movements trigger

Decision Document A-4 Former Fort Glenn, Umnak Island, Alaska F10AK029804 Public Review Period Documentation - FINAL Proposed Plan, Former Fort Glenn, Umnak Island, Alaska

MEC to explode? Mr. Johnson acknowledged the concern and stated it was highly unlikely that reindeer would be exposed to MEC items or cause them to detonate.

The RI fieldwork also included environmental sampling of soil and a groundwater seep. Analyses included explosives and metals. URS attempted to install monitoring wells; however, drilling equipment met refusal and groundwater was not encountered within 36 feet of the ground surface. An attendee asked for clarification on why the groundwater was not sampled, why was there no future plan to test the groundwater again? The attendee stated that groundwater at Amchitka was contaminated even though the surface soils didn’t identify contamination. Ms. Caillouet explained that the drilling equipment reached refusal and groundwater was not encountered. To the best of our knowledge, there is no groundwater in this area which could be impacted. Ms. Geist also clarified that the OB/OD Area is just one portion of the overall Fort Glenn site and there is a lot more RI work to be completed at other areas. USACE is aware of former tank farm locations, potential petroleum contamination, and other areas of concern.

Ms. Palmer stated that the OB/OD Area was just one of 14 different projects identified at Fort Glenn. There are 12 additional munitions projects, as well as a hazardous/toxic waste project, and a containerized waste (tanks) project. However, Ms. Palmer cautioned that since Fort Glenn is a designated national historic place, future investigations and cleanup efforts will involve a lot of coordination and planning.

The RI results showed that digital geophysical mapping (DGM) was completed over 9.04 acres, intrusive investigation of 293 anomalies, collection of 68 soil samples and one groundwater seep sample, recovery and demolition of 102 MEC items, recovery and off-site shipment of 425 MD items for smelting were completed. MEC items discovered included: 75 millimeter (mm) projectiles, 20mm high explosive incendiary cartridges, MkII hand grenade, fragmentation bombs and components, Explosive D (ammonium picrate) residue, trinitrotoluene, and fuzes. The depths of MEC ranged from 0 to 4 feet below ground surface. The estimated lateral extent of MEC encompasses a 337-acre area. The RI concluded that the boundary of the OB/OD Area should be reduced from 2,076 acres to 337 acres. The RI also recommended an FS for MEC/MD and MC should be completed using the proposed new boundary. Ms. Kashevarof asked why only 9.04 acres were investigated using DGM. Mr. Johnson explained that the investigation involved laying out transects across the area at certain intervals.

The FS developed a Remedial Action Objective (RAO) for the OB/OD Area, which includes reducing the potential for direct contact with MEC by human receptors. Achieving this objective considered the current and future land use, and alternatives were designed to satisfy the RAO for the OB/OD Area. A total of eight alternatives were developed which included: • Alternative 1 – No Action • Alternative 2 – Land Use Controls (LUCs) • Alternative 3 – Focused Surface Removal and LUCs • Alternative 4 – Surface Removal and LUCs • Alternative 5 – Surface Removal, Focused Subsurface Removal, and LUCs

Decision Document A-5 Former Fort Glenn, Umnak Island, Alaska F10AK029804 Public Review Period Documentation - FINAL Proposed Plan, Former Fort Glenn, Umnak Island, Alaska

• Alternative 6 – Surface Removal, Subsurface Removal, and LUCs • Alternative 7 – Surface Removal, Focused Soil Cover, and LUCs • Alternative 8 – Focused Surface Removal, Focused Subsurface Removal, and LUCs

An attendee asked for clarification on the meaning of the “Focused Area”. Mr. Johnson explained that based on the RI results, the majority of the munitions items were located close to the demolition craters in a smaller area of the site. An attendee also asked how far the airstrip was located from the OB/OD Area. Mr. Johnson stated the airstrip was about 1 mile to the east of the OB/OD Area and at the end of the presentation showed a vicinity map from the RI Report. An attendee asked about the definition of “surface” and “subsurface”. Mr. Johnson clarified that surface clearance would be visual removal using a hand-held magnetomer. Subsurface clearance would utilize DGM technology which can detect anomalies up to 4 feet below the surface, typically.

The total cost of the remedial alternatives ranged from $0 for no action, $938,325 for LUCs, $1,750,496 for Focused Surface Removal, to $31,974,050 for complete Surface and Subsurface Removal.

The FS determined that risk associated with incidental MC were low for human and ecological receptors based on risk assessments (i.e., further remedial action to address MC was not warranted in the FS). The 2,076-acre OB/OD Area was split into two MRSs after the RI: the 337-acre OB/OD Area (MRS-04) and the 1,739-acre Remaining OB/OD Area (MRS-14). No site risks were identified for the Remaining OB/OD Area during the RI. Attendees asked for clarification on how and why the area was reduced from 2,076 to 337 acres. Mr. Johnson explained that based on the RI results, few anomalies were found along the transects outside the smaller area. Ms. Caillouet also clarified that the 337-acre area included the demolition craters which had the highest concentration of MEC items. Mr. Johnson agreed to provide copies of the RI report, FS, and PP on a CD for those who requested it.

The PP summarizes the alternatives considered in the FS and describes the preferred alternative. It undergoes public review and allows public the opportunity to comment on the preferred alternative, as well as alternative plans under consideration, and to participate in the selection of remedial action. The DD records the decision making process and documents the final remedy. It also incorporates input from stakeholders (landowners, regulators, interested Alaska Native Tribes, and the public).

The Preferred Alternative for the OB/OD Area (MRS-04) is Alternative 5 - Surface Removal, Focused Subsurface Removal, and LUCs. The total present value of this alternative is $9,415,046. Alternative 5 provides the best balance of trade-offs with respect to the balancing and modifying criteria. Balancing criteria include: short- and long-term effectiveness; reduction of volume, toxicity, and mobility; implementability; and cost. Modifying criteria include: state and community acceptance. The Preferred Alternative for the Remaining OB/OD Area (MRS- 14) is Alternative 2 – LUCs.

Decision Document A-6 Former Fort Glenn, Umnak Island, Alaska F10AK029804 Public Review Period Documentation - FINAL Proposed Plan, Former Fort Glenn, Umnak Island, Alaska

The PP is available at the two public information repositories located in Anchorage (Alaska Resources Library and Information Services) and Unalaska (Public Library). The public comment period ends on June 2, 2014. Written comments should be submitted to:

U.S. Army Corps of Engineers – Alaska District Attn: Ms. Valerie Palmer PO Box 6898 (PM-ESP-FUDS) JBER, Alaska 99506-0898 Phone: (907) 753-2578 Email: [email protected]

The final DD is anticipated to be completed and approved by September 2014.

An attendee asked if the meeting presenters (USACE, ADEC, and URS) had talked to any elders who worked at the base during operations? Ms. Palmer responded that those interviews occurred during the ASR phase. An attendee asked if the air particles would be toxic to human health or ecological receptors when they were doing the blow-in-place or consolidated shots to detonate the munitions items? Mr. Johnson replied that was highly unlikely, because the shots rapidly dissipate and the combustion is complete.

Ms. Caillouet stated that some warning signs were installed around 2002 and asked if additional signs were desired? An attendee asked if there was a map or pictures of where the signs are located? Ms. Palmer stated those signs were installed before she became involved in the project, but information would likely be in the Site Inspection report from 2008. Ms. Palmer also stated that educational information packets were recently sent to the Alaska Volcano Observatory. An attendee also stated that they were concerned with trophy hunters on Umnak Island, and the meeting presenters (USACE, ADEC, and URS) should be aware of the reindeer herd as well as the cattle ranching.

The meeting concluded at 8:00 p.m.

May 7, 2014 – Unalaska Public Library, Anchorage, Alaska The meeting started at 6:30 p.m. Mr. Johnson introduced himself. The USACE representatives and ADEC also introduced themselves. Attendees included Josh Stamm, an employee of the Bering Pacific Ranch on Umnak Island, Roger Deffendall, and Billie Jo Gehring, Unalaska residents, and Lauren Rosenthal, from the local radio station KUCB 89.7 FM.

Mr. Johnson gave an overview of the site history, the PP and CERCLA process, and proceeded through the presentation slides. Several questions were raised during the meeting. Mr. Stamm asked if fieldwork would be conducted this summer? Ms. Palmer stated the plan is to complete the public review of the PP, and then prepare a DD based on comments received. The DD is scheduled to be completed and approved by September 2014. Once USACE has an approved DD, funding can be requested from Congress to implement the selected remedy. Therefore, any fieldwork would not happen until the 2015 or 2016 field seasons.

Decision Document A-7 Former Fort Glenn, Umnak Island, Alaska F10AK029804 Public Review Period Documentation - FINAL Proposed Plan, Former Fort Glenn, Umnak Island, Alaska

Ms. Gehring asked for clarification on the “present value” cost of the alternatives and the 30-year timeframe for LUCs? Ms. Caillouet explained that under CERCLA, the USACE is required to evaluate the remedy every 5 years and for planning purposes must estimate those reviews happening for 30 years. However, in reality, their liability may continue indefinitely if the site has restrictions on future use. Ms. Geist explained that the cost of each alternative is estimated for both construction costs to implement the remedy and future costs for the periodic reviews. The LUCs portion of the costs includes future costs for periodic reviews (i.e., once every 5 years for a total of six 5-year reviews over 30 years), as well as continued education (e.g., pamphlets), or potential warning signs. Ms. Palmer asked if the locals wanted additional signs posted near the Bering Pacific Ranch or would they become target practice, attractive nuisance (i.e., encourage people to look for munitions items), get blown away, or become debris? Mr. Stamm replied that many of the old signs had become novelty items around the ranch and were not in place anymore.

An attendee asked about the underwater investigation the Navy was conducting in the area and wondered if we knew the results. Ms. Palmer stated she knew the project he was referring to and would try to find a Navy point of contact for him.

Ms. Rosenthal asked for a summary of the concerns raised at the public meeting on Tuesday night. Ms. Geist explained that some of the adjacent landowners raised concerns over their level of participation and notification and confusion over the depiction of their lands in relation to the OB/OD Area in particular. Other general concerns included the lack of groundwater at the site, safety of the local reindeer herd, and the timing of the two projects (conventional munitions and the CWM project).

Finally, Ms. Geist stated that there was military munitions safety information available in the back of the room – brochures on the 3 R’s – Recognize, Retreat, Report, coloring books, and stickers. Please pass along to your friends!

The meeting concluded around 7:30 p.m.

Public Comments

Public comments received on the Proposed Plan are included in Attachment 4.

Decision Document A-8 Former Fort Glenn, Umnak Island, Alaska F10AK029804 Public Review Period Documentation - FINAL Proposed Plan, Former Fort Glenn, Umnak Island, Alaska

Attachment 1 – Affidavits

Decision Document Former Fort Glenn, Umnak Island, Alaska F10AK029804 319415 0001010827 $ 149.40 AFFIDAVIT OF PUBLICATION

STATE OF ALASKA THIRD JUDICIAL DISTRICT

Jaleesa Stepetin being first duly sworn on oath deposes and says that he is a representative of the Anchorage Daily News, a daily newspaper. """1 That said newspaper has been approved ~ PUBLIC NOTICE by the Third Judicial Court, Anchorage, Proposed Plan Public Comment Period and Meeting Alaska, and it now and has been published Former Fort Glenn in the English language continually as a . Formerly Used Defense Site . 1~0 u.S. 'Army CQip!101 E"umnoro lllSAGEl. 8!jJ'1 O\ljl~1tmonl oj • Oel~nse EXeiful/vo f\p~nl for lhP Oelooi ~ daily newspaper in Anchorage, Alaska, a.vironm•mnl Ras\Orulkln Pfllllrnm - FO!ll\P~fllillltl OafM'it! Sillll!.. 1tnnol!ntoi;11ie0,~~11fty of 1ni. Pi!l~~d PIM and it is now and during all said time was fnr pObl J ~qmnm~nL ,'Tiie 1"~1>

Notary P lie in and for The State of Alaska. Third Division Anchorage, Alaska MY COMMISSION EXPIRES /JS//(P REMIT TO: Ala51ta McdlJ, LLC P. o. Box 241.582 BriSt:ol Bay Times .. Anchorage, AK 99524 "Dutd111atb<.-ltfshennan Ph: (907) 770.0820 CASE/PO/AJO: URS Corporatlon F~x : (907) 770-0822 ADii or Identifier: Publlc Notice Proposed Plan Public INVOICE(S): 8790 Comment Period & Meeting Former Ft Glenn

AFFIDAVIT OF PUBLICATION

UNITED Sl ATES OF AMERICA ATIACH PROOF OF PUBLICATION HERE SlATE Of ALASKA, THIRD DISTRICT BEFORE ME, THE UNDERSIGNED, A NOTARY PUBLIC THIS DAY PERSONALlY APPEARED Mark Allred WHO, BEING FIRST DULY SWORN, ACCORDING TO LAW, SAYS THATS/HE IS General Manager Of The Bristol 8av Times/Dutch Harbor Fisherman PU9USHW AT 500 W International Airport Rd. Ste!", Anchorage,.A!L IN SAID THIRD DISTRICT AND STATE OF ALASKA AND THAT THE ADVERTISEMENT, OF WHICH THE ANNEXED OR An ACHED IS A TRUE COPY, WHICH WAS PUBLISHED IN SAID PUBLICATION __S/1/14_.AND THEREAFTER FOR A TOTAL OF _1_ CONSECUTIVE ISSUE(S), THE LAST PUBLICATION APPEARING ON ____S/1/14. ___ _ _ ;tit. MARK AlLRED GENERAL MANAGER SUBSCRIBED ANO SWORN BEfORE M£ THIS 1'1 DAV OF

STATE OF ALASKA NOTAHY PUBLIC ~ Kathleen L. Seward 'lJ7 '111 ColMllsmi ~Feb 1, 2011

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Copy 3/3 Public Review Period Documentation - FINAL Proposed Plan, Former Fort Glenn, Umnak Island, Alaska

Attachment 2 – Informational Flyers

Decision Document Former Fort Glenn, Umnak Island, Alaska F10AK029804 PUBLIC MEETING

Proposed Plan at the former Fort US Army Corps of Engineers Glenn Alaska District

The U.S. Army Corps of Engineers will host a public meeting to discuss the Proposed Plan for the OB/OD Area and Remaining OB/OD Area at the former Fort Glenn on Umnak Island, Alaska. Fort Glenn is a Formerly Used Defense Site established in 1942 as an Army Airfield and defense garrison to support the United States Naval Base at Dutch Harbor. The Proposed Plan presents alternatives to address munitions and explosives of concern at the OB/OD Area and the Remaining OB/OD Area. This meeting will provide details of the preferred alternatives selected for the OB/OD Area and the Remaining OB/OD Area and allow public, federal, tribal, state, and local stakeholders the opportunity to have questions answered and concerns addressed; and involve stakeholders in the decision-making process.

Tuesday, May 6 6:30 – 7:30 pm Z.J. Loussac Public Library 3600 Denali Street Anchorage, Alaska 99503

For more information, please call 907-753-2578 PUBLIC MEETING

Proposed Plan at the former Fort US Army Corps of Engineers Glenn Alaska District

Wednesday, May 7 6:30 – 7:30 pm Unalaska Public Library 64 Eleanor Street Unalaska, Alaska 99685

For more information, please call 907-753-2578 Public Review Period Documentation - FINAL Proposed Plan, Former Fort Glenn, Umnak Island, Alaska

Attachment 3 – Public Meeting Sign-In Sheets

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Attachment 4 – Public Comments

Decision Document Former Fort Glenn, Umnak Island, Alaska F10AK029804 From: Palmer, Valerie Y POA To: "[email protected]" Subject: RE: Need for Direct participation by adjacent Native Corp surface owner in Ft Glenn FUDS (UNCLASSIFIED) Date: Monday, May 19, 2014 11:19:00 AM

Classification: UNCLASSIFIED Caveats: NONE

Hello Mr. Sumida,

Thank you for attending the U.S. Army Corps of Engineers (USACE) public meeting held in Anchorage on May 6, 2014 regarding the USACE Proposed Plan for the Fort Glenn Formerly Used Defense Site (FUDS) Open Burn/Open Detonation (OB/OD) and Remaining OB/OD projects. We appreciate your participation and the follow-up e-mail we received with your concerns on behalf of Tanadgusix Native Corporation (TDX), which we have forwarded to both our Division and Headquarters. Per your comments, we have added TDX to our list of interested stakeholders.

We recognize that this site has cultural, archaeological, and anthropologic significance for your shareholders as well as immediate subsistence and environmental importance. Such issues will be considered through our planning and execution processes. Your comments will also be captured in the responsiveness summary of the Decision Document.

As was discussed at the meeting, USACE did not receive funding to conduct the investigation of any potential chemical warfare materials (mustard gas). The investigation will occur once funding is provided. The potential presence of these items will not interfere with the execution of work at the two projects discussed in the Proposed Plan.

It is the mission of the USACE FUDS program to conduct environmental remediation to reduce and/or remove environmental risks that were left by the Department of Defense (DoD) at eligible sites. We understand you would like funding to more fully participate in and provide oversight for the cleanup process. The environmental funding authority established by Congress for the FUDS program does not allow us to expend funds to land-owners nor to adjacent landowners to pay for their participation or oversight. Nonetheless, we highly encourage the continued participation by TDX and we will continue to welcome your comments during this process.

Thank you, Valerie Palmer Project Manager U.S. Army Corps of Engineers, Alaska District 907-753-2578 (ph) 907-753-2829 (fax) [email protected]

-----Original Message----- From: Steve Sumida [mailto:[email protected]] Sent: Thursday, May 08, 2014 9:54 AM To: POA Fuds Program POA Cc: Kim Kashevarof; Ron Philemonoff Subject: [EXTERNAL] Need for Direct participation by adjacent Native Corp surface owner in Ft Glenn FUDS

Tanadgusix Corporation was neither invited nor notified in advance of the Public Meetings regarding Umnak Island on May 6, 2014. Tanadgusix Corporation, an adjacent surface land owner to the site of MRS-14 and successor in title to approximately half of the Former Fort Glenn site as designated on COE Proposed Plan for FUDS Project numbers F10AK029804 and F10AK029814. Tanadgusix Corporation only received notification by another participant during the course of the meeting. We request that this oversight concern be elevated to a command level where discussions can be implemented to provide funding to Tanadgusix to more fully participate in these processes to better safeguard our interests as an adjacent MEC site surface landowner. As a Native Village corporation TDX was delegated these lands through ANCSA as our shareholder’s ancestors came from these islands before being forcibly relocated to the Pribilofs. Umnak was a relatively heavily inhabited area by our Pribilof Ancestors and Tanadgusix has significant continuing interests in the archeology/anthropology of the detonation site as well as our immediate subsistence and environmental interests.

We note with concern that Tanadgusix was not mentioned in either of the documents provided at the above meeting, and that our reindeer operations and ownership were not mentioned in any of the planning documents along with a failure to recognize the guiding operations, APICDA presence, subsistence uses, presence of Nikolski subsistence, or the above mentioned traditional ancestral values that may be implicated in the project.

Finally there is no reference to the impact or knowledge of the existence of mustard gas or its associated stabilizing chemicals as a consideration in this project as either a concern in limiting subsurface removal or investigations, and what impact that might have on this process.

We believe that fundamental issues justifies DOD supporting contracts to fund the adjacent Native Corporation surface estate landowners presence onsite and at all significant stages of this process.

Please elevate this request to command.

Thank you.

Classification: UNCLASSIFIED Caveats: NONE

Classification: UNCLASSIFIED Caveats: NONE Staffing Matrix for FUDS Records of Decision / Decision Documents / Action Memoranda

Decision Document Title: OB/OD Area (MRS-04) Former Fort Glenn (F10AK029804), Umnak Island, Alaska

Phone Organization Staff Activity POC Name Office Symbol FAX Number Email Address Number

FUDS Program Mgr. Ken Andraschko CEPOA-ESP-PM 907-753-5647 907-753-2829 [email protected] PM District Counsel Kyle Davis CEPOA-OC 907-753-2532 [email protected]

Public Affairs Tom Findtner CEPOA-PA 907-753-2522 [email protected]

Technical/Environmental Lisa K. Geist CEPOA-EC-EE 907-753-5742 [email protected]

Design Center 1 Lindsey Miller CEHNC-OE-CW 256-895-1297 [email protected]

MM or RCWM EM CX John Sikes CEHNC-EMM 402-895-1334 [email protected] Design Center / EM CX / USATCES / USATCES 2 Jim Langley JMAC-EST 918-420-8767 [email protected] USACHPPM USA MEDCOM PHC

(US) 3

Division FUDS Program Manager Hudson Kekaula CEPOD-PDM 808-835-4632 [email protected]

CEMP-CE Christopher Evans CEMP-CED 202-761-0338 [email protected] HQUSACE

Counsel Phil Steffen CECC-E 202-761-0026 [email protected]

Public Affairs Gene Pawlik CEPA-S/CW PID 202-761-7690 [email protected]

OACSIM N/A HQDA OAGC N/A

Army Public Affairs N/A

OTSG N/A

ODASA (ESOH) N/A

Army Safety Office N/A

1. To be completed and forwarded with ROD/DD/AM where the present cost of the selected remedy (RA-C and RA-O phases) exceeds $2 million. 2. For MMRP projects with explosives risk, USATCES coordination requirement is satisfied by providing opportunity for review and comment of the draft EE/CA or draft Proposed Plan. 3. For HTRW projects, USACHPPM coordination requirement is satisfied by providing opportunity for approval of human health risk assessments and review of ecological risk assessments developed during the RI/FS. [AR 200-1, 1-18.a.(3)] USACHPPM coordination not required for removal responses.

1. MM or RCWM Design Center staffing required for all MMRP and MMRP/CWM projects. 2. For MMRP projects with explosives risk, USATCES coordination requirement is satisfied by providing opportunity for review and comment of the draft EE/CA or draft PP. 3. For HTRW projects, USACHPPM coordination requirement is satisfied by providing opportunity for approval of human health risk assessments and review of ecological risk assessments developed during the RI/FS. [AR 200-1, 1-18.a.(3)] USACHPPM coordination not required for removal responses.

DEPARTMENT OF THE ARMY US ARMY DEFENSE AMMUNITION CENTER 1 C TREE ROAD MCALESTER OK 74501-9053

REPLY TO ATTENTION OF JMAC-EST 20 January 2015

MEMORANDUM FOR Department of the Army, Alaska District, U.S. Army Corps of Engineers, CEPOA-PM-ESP (MS Valerie Palmer), P.O. Box 6898, JBER, Alaska 99506-0898

SUBJECT: Review of Decision Document OB/OD Area (MRS-04) and Remaining OB/OD Area (MRS-14) Military Munitions Response Program, Fort Glenn Formerly Used Defense Site, Umnak Island, Alaska, November 2014.

1. References: a. Memorandum, CEPOA-PM-ESP, dated 12 December 2014, subject: Decision Document OB/OD Area (MRS-04) and Remaining OB/OD Area (MRS-14) Military Munitions Response Program, Fort Glenn Formerly Used Defense Site, Umnak Island, Alaska, November 2014.

b. DoD 6055.09-M, Ammunition and Explosives Safety Standards, date varies by Volume, Administratively Reissued 4 August 2010. c. Telephone call with Mr. Andrew Sorum and MS Valerie Palmer, Alaska District Corps of Engineers on 13 January 2015.

2. The U.S. Army Technical Center for Explosives Safety has completed the review of the decision document for OB/OD Area (MRS-04) and Remaining OB/OD Area (MRS-14) Military Munitions Response Program, Fort Glenn Formerly Used Defense Site, Umnak Island, Alaska 3. After much deliberation, evaluation, and research it was concluded that the best course of action for the U.S. Army and the taxpayer is alternative 5 for MRS-04 and alternative 1 for MRS-14. 4. Per reference 1.b paragraph V7.E4.3.1.1 this decision document must be evaluated and concurred to by the Department of Defense Explosives Safety Board, however per reference 1.c this document is being returned to the Alaska District of the Corps of Engineers for revision before submitting through Army channels to DDESB. 5. Before surface removal of MEC is allowed at MRS-04 an explosives safety submission is required by Army regulation. Both MRS-04 and MRS-14 must be revaluated in five years for any changes that increase risk or hazard to human health or the environment. 6. If at any time a munition with an unknown fill or chemical warfare material is encountered, any and all work will cease pending U.S. Army assessment of the need to submit a Chemical JMAC-EST Subject: Review of Decision Document OB/OD Area (MRS-04) and Remaining OB/OD Area (MRS-14) Military Munitions Response Program, Fort Glenn Formerly Used Defense Site, Umnak Island, Alaska, November 2014.

Safety Submission, evaluation of environmental impact, and notification of the incident will be reported in accordance with U.S. Army Pamphlet 50-6 requirements. 7. This memorandum does not constitute U.S. Army approval to remove, store, handle, or transport military explosives, ammunition, or chemical warfare materiel only that this office agrees the alternatives described in the reviewed submission is seen as the best possible action based on the information available.

8. Point of contact for this submission is the undersigned, email: [email protected].

Digitally signed by CUMMINS.PAUL CUMMINS.PAULA.1231883122 DN: c=US, o=U.S. Government, ou=DoD, ou=PKI, ou=USA, . .1 231 8831 22 cn=CUMMINS.PAUL.A.1231883122 A Date: 2015.01.20 14:22:04-06'00' PAUL A. CUMMINS Chief, Risk Management Division, US Army Technical Center for Explosives Safety DEPARTMENT OF THE ARMY ALASKA DISTRICT, U.S. ARMY CORPS OF ENGINEERS P.O. BOX 6898 JBER, AK 99506-0898

MAY 11 2016 CEPOA-DE

MEMORANDUM THRU U.S. Army Corps of Engineers (CEPOD-PDM/Hudson Kekaula) Commander, Pacific Ocean Division, Building 525, RM A314, Fort Shafter, HI 96858

FOR HQUSACE (CEMP-CED/Christopher Evans) Commander, 441 G Street N.W., Washington, DC 20314-1000

SUBJECT: Defense Environmental Restoration Program - Formerly Used Defense Sites (DERP-FUDS) Decision Document for Fort Glenn (F1 OAK029804), OB/OD MRS- 04, Umnak Island, Alaska

1. Reference Engineer Regulation (ER) 200-3-1, Environmental Quality, Formerly Used Defense Sites (FUDS) Program Policy, Department of the Army, U.S. Army Corps of Engineers, Washington, D.C., 20314, 10 May 2004.

2. This memorandum transmits the Decision Document for the Open Burn/Open Detonation (OB/OD) Area (Munitions Response Site [MRS]-04) at the former Fort Glenn FUDS, Umnak Island, Alaska. The selected remedy is Alternative 5: surface removal, focused subsurface removal, and land use controls. Based on information currently available, the selected remedy meets the threshold criteria and provides the best balance of tradeoffs among the other alternatives with respect to the balancing and modifying criteria. The selected remedy is expected to satisfy the requirements of the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) by protecting human health and being cost-effective. The selected remedy has a present worth cost estimate of less than $10 million.

3. The Alaska Department of Environmental Conservation (ADEC) was provided the opportunity for regulatory review of the Decision Document. ADEC expressed concern that the land use controls are not sufficiently described in the Decision Document, requested additional action for munitions constituents during the remedial action, and believes the focused subsurface removal area boundaries need to be flexible and ultimately determined based on findings during the implementation of the remedy. The Alaska District believes these issues can be resolved during the remedial design and construction phases.

4. This Decision Document has been coordinated with the USACE Environmental and Munitions Center of Expertise and the U.S. Army Technical Center for Explosives Safety. All review comments have been resolved. CEPOA-DE SUBJECT: Defense Environmental Restoration Program - Formerly Used Defense Sites (DERP-FUDS) Decision Document for Fort Glenn (F1 OAK029804), OB/OD MRS-04, Umnak Island, Alaska

5. I request you approve this Decision Document under the DERP-FUDS Program. If you have any questions, please contact Mr. Ken A aschko, A ska FUDS Program Manager, at (907) 753-5647 or kenneth.r.andrasc m .mil.

3 Encls 1. Decision Document 2. Staffing Matrix 3. Memorandum JMAC-EST

2 U.S. ARMY CORPS OF ENGINEERS ALASKA DISTRICT 1. CONTROL# 2. Suspense 2016-05-13 POA STAFF ACTION SUMMARY PM-16-078 HQUSACE Staff Action Handbook. the proponent is the Executive Office 3. Today's Date 2016-05-02

4. Subject Fort Glenn Formerly Used Defense Site - Decision Document for Munitions Response Site 04

5. Office Symbol 6. Action Officer 7. Telephone# 8. E-mail PM-ESP Valerie Palmer 907-753-2578 [email protected]

COORDINATION 9. Division 10. Name 11. Concur/Nonconcur 12. Comments 13. Date D DC Brooks V0- J)~[~ DOC De Rocchi .flih D - JO J..IIJ~ ,, DPM Bowker D (Zt\> - s-(0il16 EA D - E&C D - 14. Routing ~DC ~DOC ~DMP DEA D E&C 15. For: 0 Information 0 Read-Ahead 0 Decision D Approval ~Signature 16. PURPOSE/BOTTOM LINE/DISCUSSION :

1. PURPOSE: Obtain District Commander's approval and signature on transmittal memorandum for the Decision Document for MRS-04 (OB/OD Area) at the Fort Glenn FUDS - FlOAK0298.

2. BOTTOM LINE: This Decision Document presents the selected remedy for the Open Burning/Open Detonation (OB/OD) Area (MRS-04) at the former Fort Glenn, Umnak Island, Alaska. The selected remedy is Alternative 5: surface removal, focused subsurface removal, and land use controls. The present worth cost of the selected remedy is greater than $2 million but less than $10 million and therefore requires approval at HQUSACE.

3. DISCUSSION: Attached Decision Document presents the USA CE selected remedy of surface removal, focused subsurface removal, and land use controls for the MRS-04. The selected remedy for the OB/OD Area (MRS-04) is necessary to protect the public health or welfare or the environment from actual or threatened releases of hazardous substances, pollutants, or contaminants from these sites, which may present an imminent and substantial endangerment to public health or welfare. This Decision Document has been coordinated with the USACE Environmental and Munitions Center of Expertise and the U.S. Army Technical Center for Explosives Safety (USATCES). USACE continues to seek Alaska Department of Environmental Conservation's (ADEC) concurrence for the selected remedy.

4. RESOURCE IMPACT: Minimal. ADEC has indicated they have concerns with certain provisions within the selected remedy and may pursue dispute resolution through the DSMOA process. The Commander's time may be needed for the initial dispute resolution process and elevate if necessary. POD, EMCX, and HQUSACE are aware of ADEC's concern but currently agree with this course of action and the selected remedy.

5. ROUTING: Routing for the Commander will be done through the PM-ESP Branch Chief, PAO, OC, DPM, and DDC.

r . I I Ii - J 17. Releaser: (3) Larry M. Phyfe, Branch Chief, PM-ESP ~/l{~b_ 3 f!CA.<1 ~/(p iv;~.i.--3-; JJ u - 18. Recommendation: Signature ~ • uI 19. Action: I Approved DI See Me DI Other D POA FORM 1, NOV 2015 PREVIOUS EDITIONS ARE OBSOLETE . COORDINATION (cont.) 20. Division 21. Name 22. Concur/Nonconcur 23. Comments 24. Date

oc /_ J9;_~ sl K. D ~ , D RM D CT D RE D RD D LM D IR D so D SEC D PAO tD~ Findtner D.o. - S/y/11._p D SB D EEO D cPAC D ACE-IT D EM D HR (2) FUDS Andraschko

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POA FORM 1, NOV 20 15 PREVIOUS EDITI ON S ARE OBSOLETE