2009_Preliminary_Assessment_Report_Contaminant_Investigation_Bethel_BIA_Site_YDNWR_Bethel_Services_INC.pdf

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PRELIMINARY ASSESSMENT REPORT

CONTAMINANT INVESTIGATION BETHEL BIA SITE

YUKON DELTA NATIONAL WILDLIFE REFUGE

BETHEL, ALASKA

Contract No. 701818-R-065

Bethel Services, Inc. Project No. 2008105 January 2009 Prepared for:

U.S. Fish and Wildlife Service

OWNER:

US Fish & Wildlife Service - R7 Contracting & General Services 1011 East Tudor Road, Mail Stop 171 Anchorage, Alaska 99503-6199

Prepared By:

GENERAL CONTRACTOR:

Bethel Services Inc.

620 East Whitney Road, Unit B Anchorage, Alaska 99501

Draft Preliminary Assessment Report

Contaminant Investigation Bethel BIA Site Yukon Delta National Wildlife Refuge

Prepared for

U.S. Fish and Wildlife Service

Contract No. 701818-R-065

January 2009

Tim Weglarz, Task Manager

John Spielman, Project Manager

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TABLE OF CONTENTS

ACRONYMS AND ABBREVIATIONS ................................................................................. iv

EXECUTIVE SUMMARY ...................................................................................................... vi

1.0 INTRODUCTION

1.1 STATEMENT OF PURPOSE

1.2 PROJECT DESCRIPTION

1.3 REPORT ORGANIZATION

1.4 LOCATION AND LEGAL DESCRIPTION

2.0 SITE DESCRIPTION

2.1 LAND STATUS

2.1.1 27-Acre Parcel

2.1.2 18-Acre Parcel

2.1.3 Adjacent Parcels (not under USFWS Management)

2.2 FACILITIES AND INFRASTRUCTURE

2.2.1 27-Acre Parcel

2.2.2 18-Acre Parcel

3.0 CONTAMINANT INVESTIGATION METHODS

3.1 RECORDS REVIEW

3.1.1 USFWS Offices

3.1.2 ADEC Records

3.1.3 FUDS Records

3.1.4 Online Administrative Record

3.2 AERIAL PHOTOGRAPH REVIEW

3.3 SITE VISIT

4.0 SITE HISTORY

5.0 SITE CONTAMINANTS OF CONCERN

6.0 CLEANUP LEVELS

6.1 SITE SPECIFIC CLEANUP LEVELS

7.0 PREVIOUS INVESTIGATIONS

7.1 27-ACRE SITE - POLs, PCBs AND PESTICIDES

7.1.1 Site Assessments/Site Characterizations

7.1.2 Record of Decision

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7.1.3 106,000-Gallon Fuel Spill (Bethel BIA Spill - White Alice Tank)

7.2 18-ACRE SITE - POLs and PCBs

7.2.1 1991 Preliminary Assessment

7.2.2 Level I Contaminant Survey

7.2.3 Follow-Up Monitoring

7.2.4 Location of POL-Stained Soils

7.3 ASBESTOS AND LEAD BASED PAINT

7.3.1 27-Acre Site

7.3.1.1 Asbestos Remaining After Pre-Fire Abatement

7.3.1.2 Lead Based Paint

7.3.2 POST FIRE ASSESSMENTS

7.3.2.1 Asbestos

7.3.2.2 Lead Based Paint and Arsenic

7.3.3 18-ACRE SITE

8.0 CURRENT SITE STATUS

8.1 27-ACRE PARCEL

8.2 18-ACRE PARCEL

9.0 FINDINGS AND DATA-GAPS

9.1 27-ACRE SITE

9.1.1 Composite Building 413

9.1.2 Sewage Lagoon

9.1.3 106,000-Gallon Diesel Spill (Bethel BIA Spill - White Alice Tank)

9.2 18-ACRE PARCEL

10.0 REFERENCES

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FIGURES

Figure 1 Site Location and Vicinity

Figure 2 Current & Historic Land Boundaries

Figure 3 Historical Figure - Boundary and As-Built Survey of the BIA site, July 12, 1995

Figure 4 Site Buildings

Figure 5 September 5, 1963 Aerial Photograph

Figure 6 August 4, 1990 Aerial Photograph

Figure 7 September 7, 2007 Aerial Photograph

Figure 8 Locations of Contaminants and Environmental Concerns

Figure 9 Historical Figure - Contaminated Soil Outline at the BIA Site (October 1994)

Figure 10 Historical Figure - Source Area Locations and 1993 Fuel Oil Release Data

Figure 11 Historical Figure - 1989 Site Contamination Diagram (Showing 18-Acre Site)

Figure 12 Historical Figure - Test Boring/Monitoring Well Location Map Sites 1 and 2 (Showing 18-Acre Site)

Figure 13 Historical Figure - USAF Monitoring Well Locations (Showing 18- Acre Site)

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ACRONYMS AND ABBREVIATIONS

11 CEOS USAF Civil Engineering Operations Squadron Operating Engineers 611 CES USAF 611th Civil Engineering Squadron AAC Alaska Administrative Code ACM Asbestos Containing Material ADEC Alaska Department of Environmental Conservation AK Alaska ANCSA Alaska Native Claims Settlement Act ANILCA Alaska National Interest Lands Conservation Act AR Administrative Record AST aboveground storage tank bgs below ground surface BIA Bureau of Indian Affairs biocell bioremediation treatment cell BNC Bethel Native Corporation BSI Bethel Services, Inc.

BTEX benzene, toluene ethylbenzene and xylenes CAB Cement Asbestos Board CERCLA Comprehensive Environmental Response, Compensation, and Liability Act CS Contaminated Sites cy cubic yards DDD dichloro-diphenyl-dichloroethane DDE dichloro-diphenyl-dichloroethylene DDT dichloro-diphenyl-trichloroethane DOD Department of Defense DRO Diesel Range Organics E & E Ecology and Environment, Inc.

EMCON EMCON Alaska, Inc.

EPA United States Environmental Protection Agency ESA Equitable Servitude Agreement F Fahrenheit f/cc fibers per cubic centimeter FUDS Formerly Used Defense Site GRO Gasoline Range Organics HUD U.S. Department of Housing and Urban Development IC Institutional Controls IRA Interim Remedial Action IRP Installation Restoration Program

January 2009 v Draft mg/kg milligrams per kilogram mg/L milligrams per liter ND not detected/non-detect NFRAR No Further Remedial Action Required NOAA National Oceanic and Atmospheric Administration OSHA U.S. Department of Labor Occupational Safety & Health Administration PA Preliminary Assessment PACM Presumed Asbestos Containing Material PCB Polychlorinated biphenyls PDF Portable Document Format PEL Permissible Exposure Limit (OSHA)/Probable Effects Level (NOAA) PL Public Law PLO Public Land Order POLs Petroleum, Oil, and Lubricants ppm parts per million RBCL Risk Based Cleanup Level RCRA Resource Conservation and Recovery Act ROD Record of Decision RRO Residual Range Organics RRS Radio Relay Station SARA Superfund Amendments and Reauthorization Act of 1986 sf square feet SQuiRTs Sediment Quick Reference Tables START-2 Superfund Technical Assessment and Response Team 2 SVOCs Semivolatile Organic Compounds TCLP Toxicity Characteristic Leaching Procedure TEL Threshold Effects Level TIFF Tagged Image File Format TPH Total Petroleum Hydrocarbons TWA time-weighted average USAF United States Air Force USFWS United States Fish and Wildlife Service UST Underground Storage Tank WACS White Alice Communication System YDNWR Yukon Delta National Wildlife Refuge YKHC Yukon-Kuskokwim Health Corporation

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EXECUTIVE SUMMARY

Bethel Services, Inc. (BSI) was contracted by the U.S. Fish and Wildlife Service (USFWS) under Contract Number 701818-R-065 to conduct a comprehensive literature review of all available documents relating to site assessments and environmental remediation activities that pertain to the Bethel Bureau of Indian Affairs (BIA) Site and prepare this Preliminary Assessment Report.

The purpose of this assessment is to identify the contaminants of concern at this site, their source and location, their potential to cause harm to human health and the environment, and their status with regard to current environmental regulations. In addition, this assessment identified potential data gaps in the site information that must be answered before various site actions can proceed.

The Bethel BIA site includes two tracts of land under USFWS jurisdiction; a 27-acre parcel and an 18-acre parcel which are both part of a Formerly Used Defense Site (FUDS) and are the focus of this assessment.

27-Acre Parcel This parcel contains most of the infrastructure constructed by the U.S. Air Force and later used by the BIA during their occupancy of the site, including several abandoned buildings, a closed sewage lagoon, and an undeveloped area impacted by a 1993 106,000-gallon fuel spill. Several contaminant issues have been identified and address by past investigations and remedial efforts.

The site was granted a No Further Remedial Action Required (NFRAR) decision by the Alaska Department of Environmental Conservation (ADEC) in 2000. A fire that partially destroyed the 60,000-square foot Composite Building 413 has raised new human health and environmental concerns that were unanticipated at the time of the NFRAR decision. Changes in environmental regulations and changes in planned land use and ownership also generate new data gaps.

The remaining issues requiring additional attention include:

• The closed sewage lagoon contains sediments with polychlorinated biphenyl (PCB) concentrations above the ADEC cleanup level as well detectable pesticide concentrations.

The lagoon has been dewatered, capped, and fenced off and the site has been granted a status of “Cleanup Complete – Institutional Controls” by the ADEC. Institutional Controls in the form of deed restrictions and periodic reporting have yet to be implemented.

• A sediment sample collected in 1995 down-gradient of the northwest corner of the sewage lagoon contained 7.2 milligram per kilogram (mg/kg) PCB, exceeding the current ADEC soil cleanup level of 1 mg/kg, and likely requires follow-up sampling to determine the concentration and full extent of PCBs released from the lagoon prior to closure.

• Fuel-contaminated soil was previously identified beneath and immediately adjacent to Composite Building 413. Contaminated soil was removed to the extent practicable without damaging the building, and the remaining contamination was allowed to remain in place by the ADEC under the 2000 NFRAR. However, if the Composite Building is demolished in the future, the remaining fuel-contaminated soil may require further delineation and removal since access to the contaminated soil would then be possible. A determination by the ADEC on this issue is required.

• The area impacted by the 1993 106,000-gallon fuel spill has been cleaned up to the extent practicable, but fuel-impacted soil and wetlands remain. This issue has been treated separately from the rest of the 27-acre site by the ADEC and has also been granted a status of “Cleanup Complete – Institutional Controls”. Institutional Controls in the form of deed restrictions and periodic reporting have yet to be fully implemented.

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Composite Building 413 A lack of maintenance, fire, and vandalism has lead to an ever increasing state of deterioration of Composite Building 413 and has raised the following human health and environmental concerns:

• Physical hazards to humans associated with slips, trips, falls, collapses of walls floors and ceilings, impalement, cuts, etc.

• Lead and possibly arsenic exposure to humans and the environment from fallen, loose and intact lead based paint (LBP) both inside and outside the structure; released to the environment by fire damage and general material deterioration.

• Asbestos exposure to humans and the environment from asbestos-containing materials (ACM) remaining throughout the floor and in other areas; released by fire damage, or exposed by continued deterioration of the structure.

• Possible PCBs in floor drains and greywater/sewage piping in the crawl space and above-ground pipe leading to the closed sewage lagoon (suspected due to presence of PCBs in lagoon sediments and on concrete floor surfaces in Building 413).

The data gaps identified below assume that the demolition of the Composite Building will be performed in the near future, and that all data needed to accomplish demolition and dispose of waste in accordance with pertinent laws and regulation will need to be performed. The following work should be performed to address the data gaps.

• Sampling of residue/sediment remaining in floor drains and utility trenches in the generator and transformer room, in drain pipe in the crawl space, and in above ground sewage pipe leading to the sewage lagoon, should be collected and analyzed for PCBs and pesticides. Results would be used to assess possible exposure hazard to demolition workers, and to properly characterize these components for disposal.

• Additional bulk sampling of suspected ACM on sewage pipe in the crawl space and above ground sewage pipeline leading to the former sewage lagoon.

• Total lead in soil sampling should be performed around the perimeter of the building to test whether fallen LBP chips have impacted surface soils above the 400 mg/kg cleanup level. Such testing might be best performed after demolition of the structure.

• Additional metal sampling of ash, burn debris, and the building itself, to characterize the materials for waste disposal.

Near surface and subsurface soil sampling beneath the footprint of the building to identify the location and extent of fuel-contaminated soil exceeding the risk-based cleanup level for diesel range organics established for the site. This sampling should be conducted in conjunction with, or immediately after demolition as the overlaying structure must be removed to allow access to soils beneath.

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1.0 INTRODUCTION

1.1 STATEMENT OF PURPOSE

The U.S. Fish and Wildlife Service (USFWS) has contracted Bethel Services, Inc. (BSI) under Phase 1 of Contract Number 701818-R-065 to conduct a comprehensive literature review of all available documents relating to site assessments and environmental remediation activities that pertain to the Bethel Bureau of Indian Affairs (BIA) Site and prepare this Preliminary Assessment Report. The USFWS requires the information generated by this review to identify and address any potential future or on-going environmental issues at the site so that lands under USFWS management may be managed properly and eventually conveyed to other parties. In addition to a thorough review and summary of all available reports and documentation, BSI performed a site visit and has also identified data gaps that may need to be addressed to fully evaluate the environmental issues at the site.

1.2 PROJECT DESCRIPTION

The goal of this project is to "provide the U.S. Fish and Wildlife Service a general understanding of the contaminants of concern at this site, their source and location, and their potential to cause harm to human health and the environment." This project focuses on two tracts of land currently under management by USFWS, a 27-acre parcel and an 18-acre parcel. A number of investigations, assessments, and remedial actions have been performed at the site and neighboring areas in the past 20 years, however a fire in 2001 at the former BIA Headquarters building has raised new environmental and public health concerns that have not yet been fully investigated. This report focuses on both the pre and post-fire concerns.

1.3 REPORT ORGANIZATION

The objectives of this investigation require that contaminant concerns at the 27-acre parcel and the 18-acre parcel be addressed separately so that each parcel can be managed independently.

However, many of the past investigations and remedial actions at the site do not distinguish between these two parcels, or more commonly pertain primarily to the 27-acre parcel and do not address the 18-acre parcel. Where necessary, issues specific to the 18-acre parcel are generally described in separate subheadings within each relevant section of this report.

Section 1 of this report provides the project purpose and description, discusses the report organization, and describes the site location. Section 2 provides a description of the site, discusses land status, and the facilities and infrastructure on the site. Section 3 presents investigation methodologies. Section 4 presents a chronological summary of the site history.

Section 5 describes the contaminants of concern at the site. Section 6 discusses site cleanup levels. Section 7 summarizes previous investigations and relevant results. Section 8 describes the current site cleanup status. Section 9 discusses the findings of this investigation and presents data gaps. Section 10 provides the references cited and those used to prepare this report.

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1.4 LOCATION AND LEGAL DESCRIPTION

The Bethel BIA Site is located approximately 4 miles west of the City of Bethel, Alaska and the Kuskokwim River, as shown in Figure 1. Bethel, located near the mouth of the Kuskokwim River and 340 miles west of Anchorage, is a major air and water transportation hub in the region with an estimated population of about 6,356 residents as of 2006. According to a 1992 Preliminary Assessment by the U.S. Air Force (USAF) 11th Civil Engineering Operations Squadron Operating Engineers (11 CEOS), 23% of the residents live within 1 to 2 miles of the BIA site, and the remainder of residents live more than 2 miles from the site (11 CEOS, 1992, Administrative Record [AR]03). The site is accessible year round by a gravel road that ends approximately 0.5 miles to the south of the site. Access to the site is currently restricted by an un-manned locked gate; however, snowmobile, 4-wheeler, and foot traffic can easily bypass the gate. Other off-road trails in the area also allow unrestricted access to site.

The 18-acre and 27-acre parcels are located in the west half of Section 14, Township 8 North, Range 72 West, Seward Meridian, Alaska. Average precipitation for the Bethel area is 16 inches a year including 50 inches of snow. Summer temperatures range from 42° to 62° Fahrenheit (F);

winter temperatures average -2° to 19° F.

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2.0 SITE DESCRIPTION

The Bethel BIA site, also known as the Bethel BIA Administrative Site, currently consists of two parcels of land, referred to as the 27-acre parcel and an 18-acre parcel (18.42 acres actual), which were previously pared down from a 125-acre BIA parcel, and again from a 45-acre parcel over the years. Both parcels are managed by the USFWS as part of the Yukon Delta National Wildlife Refuge (YDNWR) and have differing environmental issues, responsible parties for cleanup, and future land status plans. Figure 2 shows the boundaries of the 27- and 18-acre parcels as well as previous parcels pared down from the initial 1,467.31 acre USAF parcel which is shown in Figure 1.

The U.S. Air Force (USAF) first developed the site in 1957 and constructed facilities as part of the White Alice Communication System (WACS). The WACS facilities included a 60,000-square foot Composite Building (Building 413), numerous support structures, and a Radio Relay Station (RRS) located about 2,500 feet southwest of the Composite Building. The Composite Building was later used by the BIA from the early 1960's to the mid 1980's as their Bethel Administrative Headquarters. Use of the site by the BIA ended in 1990 and the site has remained vacant since. The condition of the abandoned facilities has continued to deteriorate over the years. The central portion of the Composite Building was destroyed by fire in August 2001. Un-burnt portions of the structure, now exposed to the elements have deteriorated significantly and, along with other derelict structures on the property, pose a physical hazard.

2.1 LAND STATUS

2.1.1 27-Acre Parcel

Public Law (PL) 102-497 enacted in 1992 directed the Secretary of the Interior to convey buildings and 27 acres of the former BIA Administrative Site to the Yukon-Kuskokwim Health Corporation (YKHC), with 18 acres reserved for the USFWS. This law also required cleanup of the 27 acre site by the USAF and the BIA, prior to conveyance.

2.1.2 18-Acre Parcel

PL 102-497 directs that the 18-acre parcel will remain in Federal ownership and under USFWS jurisdiction. However the USFWS may pursue a different land exchange following cleanup. As the site qualifies as a Formerly Used Defense Site (FUDS), cleanup responsibility for this parcel rests with the U.S. Army Corps of Engineers FUDS program.

2.1.3 Adjacent Parcels (not under USFWS Management)

Pursuant to the Alaska Native Claims Settlement Act (ANCSA), two additional land parcels totaling 80 acres were split off of the initial 125-acre BIA parcel and were transferred to Bethel Native Corporation (BNC) in July 1986 by Interim Conveyance 1201 (Ecology and Environment, Inc. [E & E], 2002). One parcel is located immediately to the north of the 27-acre parcel, and the other larger parcel occupies the area south of the 18-acre parcel and northeast of the 14.5-acre RRS USAF parcel. Figure 2 shows the location of these parcels. Discussion of environmental issues related to these parcels not under USFWS management is beyond the scope of this report

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A third 14.5-acre parcel, encompassing the Bethel RRS located about 0.5 miles south of the BIA Administrative site, was retained by the USAF. The RRS facility consisted of three sets of 60-foot tropospheric scatter arrays, one of which still remains as a visual navigation aid for the nearby Bethel airport. The parcel has history of past and on-going environmental concerns that are beyond the scope of this report. The parcel once housed a bioremediation treatment cell (biocell) and subsequent land farm to treat petroleum-contaminated soils, and currently houses 6,800 cubic yards (cy) of treated soil and asbestos and demolition debris disposal areas (EMCON Alaska, Inc. [EMCON], 1999, AR69; ADEC, Contaminated Sites [CS] Report). The ADEC Contaminated Sites Database lists this site as the Bethel Radio Relay Station with an "Open" status, Hazard ID of 2831, and File ID of 2407.38.010.

2.2 FACILITIES AND INFRASTRUCTURE

2.2.1 27-Acre Parcel

The 27-acre parcel encompasses most of the former infrastructure that once supported the BIA Administrative Site. Based on descriptions from the March 1992 Preliminary Assessment Report by the 11 CEOS (11 CEOS, 1992, AR03) and 1998 Record of Decision document (EMCON, 1998, AR56), structures currently or formerly present on this parcel include:

• 60,000-square foot Composite Building (Building 413) which contained the USAF barrack and generators

• Three former 400,000-gallon bulk above ground storage tanks (ASTs) and one former 10,000-gallon AST for fuel storage, within unlined earthen containments

• Eleven former 300 to 500-gallon ASTs for fuel storage

• Former approximately 400-foot by 200-foot sewage lagoon (north and south lagoons);

subsequently dewatered, capped and fenced off

• Aboveground sewage pipeline leading from Composite Building to sewage lagoon

• Several (currently 8) outlying wood and metal buildings/structures.

The names, function (by BIA), and square footage (sf) of the various structures as described in Appendix B of the Asbestos Abatement Activity Report prepared in 1994 by the USAF 611th Civil Engineering Squadron (611 CES), are shown below (611 CES, 1994a, AR08).

Building 413 Office and Quarters Building 60,072 sf Building 414 Water Utility Building 1,927 sf Building 415 POL Warehouse (removed) 200 sf Building 416 Warehouse (Concrete Tower) 5,781 sf Building 419 Shop (Steel Tower) 3,786 sf Building 420 Warehouse (Steel Tower) 470 sf Building 422 Shop (Concrete Tower) 4,142 sf Building 423 Warehouse (Steel Tower) 1,938 sf Building 424 former POL Pump House (removed) 182 sf

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Building 425 Sewage Lift House 179 sf Building 431 Fuel Pump House (removed) 58 sf

A Boundary and As-Built Survey of the BIA site dated July 12, 1995 was prepared by Eagle River Engineering Services and is included as Figure 3. Figure 4 shows the building identification numbers on the 1963 aerial photographs which depicts site conditions at the time the BIA began to occupy the site, and on the 2007 aerial photographs which depicts near current conditions. Although the 1998 Record of Decision (ROD) (EMCON, 1998, AR56) states that the sewage lagoon was included in the BIA's 1963 acquisition of the facility from the USAF, only the Sewage Lift House (Building 425) and sewage pipeline are present in the September 4, 1963 aerial photograph (Figures 4 and 5). The sewage pipeline appears to end in open tundra with several rivulets draining to the northwest; no sign of any kind of sewage impoundment is visible. By 1990 the south sewage lagoon impoundment was established as is clearly visible in the 1990 aerial photograph (Figure 6).

2.2.2 18-Acre Parcel

The 18 acre parcel lies immediately south of the 27-acre parcel as shown in Figure 2. A 992 sf wooden structure (Building 421) formerly used as the Education Office is still present near the northwest corner of the parcel (611 CES, 1994a, AR08). Much of the area in the southeast leg of this parcel had been cleared and bulldozed smooth as evident in the 1963 aerial photograph (Figure 5), and at least two more structures are apparent approximately 550 feet south-southeast of the Composite Building (Building 413). The smaller structure is believed to be a pump house associated with a former water well at this location. There is a large amount of metal and wood debris now dumped in this area and the area is currently overgrown with brush.

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3.0 CONTAMINANT INVESTIGATION METHODS

This contaminant investigation was accomplished through the following activities:

• A comprehensive review of related State and Federal government documents, as well numerous reports prepared by private contractors

• Internet search of State and Federal Government web sites, databases, and records

• Discussions with local workers and residents familiar with the site

• Examination of historical and recent aerial photographs

• A site visit and examination of current site conditions

3.1 RECORDS REVIEW

An extensive review of existing documents was performed by BSI in the preparation of this report. This review served as the primary means of assessing past and current environmental concerns at the site. BSI conducted searches and reviews of the following state and federal sources/records:

• USFWS Offices in Bethel and Anchorage, Alaska

• ADEC Office in Anchorage, Alaska

• ADEC Contaminated Sites Database Reports (file numbers 2407.38.007 & 2407.38.008)

• Formerly Used Defense Site (FUDS) records

• On-line Administrative Record maintained by USAF (Adminrec.com)

3.1.1 USFWS Offices

Project files related to the Bethel BIA site were reviewed in the YDNWR office in Bethel, Alaska on October 14, 2008 and photocopies were made of selected documents. Information on property boundaries for the 27-acre and 18-acre parcels was obtained from the Anchorage USFWS office, including a Geographical Information System (GIS) file showing the 27 and 18-acre parcel boundaries.

3.1.2 ADEC Records

Documents and photographs related to the Bethel BIA site were reviewed at the ADEC Division of Spill Prevention and Response office in Anchorage, Alaska and photocopies were made of selected documents.

BSI conducted on-line database reviews of the following ADEC records:

• Alaska Department of Environmental Conservation (ADEC) Contaminated Sites and

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Leaking Underground Storage Tank Sites Database (combined into one database as of September 2nd, 2008),

• ADEC Underground Storage Tank (UST) Database,

• ADEC Spills Database.

The ADEC Contaminated Sites Database lists two entries for the BIA Site 27-acre parcel;

• Bethel BIA Headquarters, Hazard ID: 2899, File ID: 2407.38.007, Status: Cleanup Complete - Institutional Controls

• Bethel BIA Spill - White Alice Tank, Hazard ID: 1868, File ID: 2407.38.008, Status: Cleanup Complete - Institutional Controls

No entries are listed for the 18-acre parcel.

3.1.3 FUDS Records

The Bethel BIA site is a Formerly Used Defense Site (FUDS) with principle cleanup responsibility resting with the U.S. Army Corps of Engineers FUDS program. The site is listed on the FUDS inventory with FUDS ID: F10AK0510 and Federal Facility ID: AK09799F699900.

3.1.4 Online Administrative Record

As required under the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA), the Department of Defense (DOD) maintains an extensive Administrative Record (AR) for the Bethel BIA Administrative Site and neighboring 14.5-acre USAF parcel (former RRS facility). The AR is indexed in chronological order and makes no distinction among the specific land parcels which have been split off from the original USAF installation over the years. The various current and former USAF lands/sites are included and are collectively referred to as the "Bethel Creek RRS Alaska". The 27-Acre BIA site is also referred to as "SS-13" in many of the AR documents. The AR for the Bethel BIA Site can be accessed online at:

http://www.adminrec.com/TOC.asp?Base=Bethel&Command=PACAF

This record is very extensive with over 107 document files including letters and correspondence by the ADEC, USAF, USFWS, United States Environmental Protection Agency (EPA), and Native Corporations, and various reports prepared by contractors and government agencies. The files are scans of original documents in Portable Document Format (PDF). Although imperfect, the optical character recognition (OCR) capabilities of ADOBE® ACROBAT® computer software used to view the files allow for limited searching and extraction of text from the documents. The AR was the primary resource used for obtaining the information used in this contaminant investigation. To simplify the citation of documents contained in the AR the following convention will be used in this report. The normal citation by author and year will be

January 2009 8 Draft followed by the AR File Number (01 to 107). An example of a citation in this format would be (611 CES, 1994a, AR08). The AR File Number is also provided in brackets at the end of each cited reference contained in the AR in the References section of this report (Section 10.0).

3.2 AERIAL PHOTOGRAPH REVIEW

Aerial photographic coverage of the Bethel BIA site area on file at Aero-Metric, Inc., Anchorage, Alaska was examined in preparation of this investigation. A series of high resolution (i.e. low altitude) photographs (i.e. contact prints) taken September 5, 1963 were obtained which document site conditions when a major portion of the facility was declared excess and use of 125 acres was granted to BIA. A contact print and an enlargement of the 18-acre parcel from August 4, 1990 were obtained documenting site conditions one year prior to the Preliminary Assessment of the BIA Administrative site. A digital aerial photograph taken September 7, 2007 was also obtained depicting near current site condition. The 2007 digital aerial photograph was obtained in Tagged Image File Format (TIFF) at 1600 pixels per inch, 0.5-foot resolution. Copies of the aerial photographs and a TIFF file of the 2007 image are included in Appendix A. Figures 5, 6, and 7 provide the respective 1963, 1990, and 2007 aerial photographs of the site.

3.3 SITE VISIT

On October 14, 2008 BSI and USFWS personnel visited the Bethel BIA Site to examine and document the current conditions at the Composite Building and other structures at the 27-acre parcel. Tim Weglarz of BSI was accompanied by Charles Grant (Regional Environmental compliance coordinator), Gene Peltola (Refuge Manager), and Hollis Twitchell (Deputy Refuge Manager). During the visit a walk-through of the Composite Building (Building 413), education office Building 421, warehouse Building 420, shop Building 422, and warehouse Building 423 was performed. Floor drains and grate-covered utility floor trenches were located in the Composite Building; and the sewage pipeline was traced from the north end of the building to the former sewage lagoon. Extensive loose and fallen paint chips were observed throughout much of the Composite Building. Numerous physical hazards, such as sharp objects, broken glass, and slip-trip and fall hazards were found throughout the Composite Building and other structures. Several inches of snow cover precluded visual observation of the ground surface at the 18-acre parcel during this visit.

BSI's asbestos and lead competent person, Thamen Barry, visited the site on September 11 and on October 7, 2008, and examined the Composite Building and the 18-acre parcel area, and took photographs of site conditions prior to the season's first significant snow fall.

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4.0 SITE HISTORY

To understand the environmental issues, cleanup responsibilities, and current land status a review of the site's history is provided. The following timeline of events was modified from the Statement of Work, USFWS documents, and various reports.

Timeline of Events:

1943: Public Land Order (PLO) 188 withdraws 238,000 acres at Bethel for military purposes

1955: PLO 1173 reduces USAF Bethel Air Force Station withdrawal to 1,482 acres (amends and revokes PLO 188)

1957: USAF constructs WACS facility; facility activated 1958

1963: Major portion of the site (1,467.31 acres) declared excess. USAF issues a permit granting use of 125-acre parcel to BIA. The parcel includes barracks (Composite Building 413), fuel tanks, outlying buildings, and upper and lower sewage lagoons.

1964: BIA remodels Composite Building to provide family living quarters, staging and operations, support, and a maintenance facility.

1966: PLO 3956 reduces the USAF withdrawal to 14.69 acres, referred to as the "White Alice Site" or "RRS", and withdraws 275 acres (of lands formerly withdrawn by PLO 1173) for BIA as an administrative site pursuant to E.O. 10355 and Act of May 31, 1938. BIA occupied the facility.

1971: ANCSA Sec. 19: revoked the withdrawal of various reserves for Native use or for administration of Native affairs, including those created under Act of May 31, 1938.

The Bethel Site officially returns to BLM until Alaska National Interest Lands Conservation Act (ANILCA). BIA continued to occupy the site, but without the benefit of specific withdrawal authority until 1985.

1979: Interim Conveyance 142 conveys land surrounding the (14.69 acre) White Alice Site and (275 acre) BIA Administrative Site to BNC. WACS deactivated.

1980: ANILCA Sec. 303: withdrew and included the revoked site in the YDNWR. BIA retained right to use the facility and retained liability for contamination.

1982: BIA created a building inventory of entire Administrative site. Regional Solicitor's opinion rendered installations, such as the BIA Bethel Administrative Site, as refuge land.

1985: ANCSA Section 3(e): determination was made on lands withdrawn by PLO 3956 (1966). About 230 acres were determined to be public lands and were conveyed to BNC; about 45 acres (smallest practicable tract) were determined to be unavailable for selection under ANCSA. The 45 acres was the smallest practicable tract actually used by the BIA, and therefore, retained.

1986 Pursuant to ANCSA, the other 80 acres were transferred to the BNC in July 1986 by Interim Conveyance 1201.

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1987: BIA determines facilities no longer suitable for use because of continued destructive vandalism. BIA files a revocation and restoration report with Government Services Association and BLM. They wish to divest responsibility for the site. BIA has abandoned the site, but still has accountability and responsibility.

1988: BLM notified the BIA that the land is under the jurisdiction of the USFWS and they needed to work with USFWS on the acceptability of lands and improvements.

1989: Department of Interior Solicitor's finds that under CERCLA, the BIA retains responsibility for cleanup of the site.

1989-90: USAF demolishes WACS (RRS) facility leaving one antenna in place as landmark/visual navigation aid. Last BIA personnel leave site.

1991: BIA and the USFWS agree that decontamination of the site is too costly and the site should be demolished. Under the USAF Installation Restoration Program (IRP), USAF conducts Preliminary Assessments (PA) of the 27-acre site and the adjacent property formerly part of WACS facility.

1992: BIA and USAF prepare to demolish facilities at the site. YKHC, a non-profit private corporation, wanted the facility for employee housing for the Bethel Public Health Service Hospital. PL 102-497 directed Secretary to convey buildings and 27 acres to YKHC. USFWS retains 18 acres of site. PL 102-497 requires the USAF and BIA to clean up the site prior to conveyance. USFWS cannot dispose this refuge land except by exchange or Act of Congress.

1992-93: An estimated 106,000 gallons of diesel fuel leaked from a 400,000-gallon storage tank when an elbow joint leading from the tank ruptured. According to the ADEC, during response actions an estimated 63,000 gallons of fuel were recovered; 15,900 gallons evaporated; and 27,100 gallons were unaccounted for. Monitoring wells were established by the USAF on the 45-acre site and on neighboring properties.

1993-95: BIA environmental contractor conducts containment and site assessment activities relating to this release.

1993: The USAF signs a Memorandum of Understanding with the BIA for asbestos removal and site restoration.

1994: USAF conducts interim removal action of approximately 6,800 cubic yards (cy) of diesel-range organics (DRO)-impacted soil from 27-acre site to stockpiles at the former WACS site.

1995: EMCON contracted by USAF to conduct site characterization, human health risk assessment, and ecological risk assessment. EMCON to construct, operate, and maintain bioremediation cell at USAF RRS 14-acre parcel.

1996: ASRC Contracting Company, Inc. (ACCI) is contracted by USAF to perform remedial actions at the sewage lagoon and four other areas at the BIA site. Areas with surface and subsurface soil contamination above risk-based DRO concentrations are either capped in place or excavated and capped.

1998: BNC International, Inc. (BNCI) contracted by USAF to complete the 1996 remedial actions at the BIA site. Completion includes dewatering the upper sewage lagoon, January 2009 11 Draft filling with material removed from the lower lagoon, decommissioning 11 monitoring wells, and removing polychlorinated biphenyl- and pesticide-contaminated soil from Composite Building 413.

1998-2000 EMCON contracted by USAF to perform annual groundwater monitoring of wells installed as part of the 1991 PA, attenuation soil sampling for the 1993 BIA spill, and Polychlorinated biphenyl (PCB) analysis on wipe samples collected from the floor of the generator room of Composite Building 413.

1999: The ADEC approved a risk-based cleanup level of 2,300 milligrams per kilogram (mg/kg) DRO to be protective of human health.

1999: USAF completes their cleanup operations.

2000: The ADEC issues a finding of No Further Remedial Action Required for the 27-acre site. ADEC states that institutional controls will need to be implemented before closure is complete.

2001: Fire destroyed part of the 60,000 square foot Composite Building 413 facilities releasing asbestos, lead and potentially other contaminants. Other unaddressed contaminants issues may also exist at the site.

2002: E & E, under contract by EPA Region 10 Superfund Technical Assessment and Response Team 2 (START-2) submitted a Preliminary Assessment Report (E & E, 2002) for BNC-owned 80-acre properties adjacent to BIA Administrative site.

2008: Site remains abandoned with little or no security.

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5.0 SITE CONTAMINANTS OF CONCERN

A number of environmental investigations, assessments, and cleanup actions have been conducted at the BIA Administrative Site and adjacent areas over the years. Environmental contaminants and concerns have included:

• Petroleum, oil, and lubricants (POLs) - spilled/leaked fuels related to ASTs, bulk above ground tanks, associated piping, and fuels, oils, asphalt and other POLs related to drum storage and handling. Specific POL related contaminants include diesel-range organics (DRO); residual-range organics (RRO); gasoline-range organics (GRO); and benzene, ethylbenzene, toluene, and xylenes (BTEX).

• Asbestos - primarily within building materials used in the interior and exterior of buildings, now mainly related to the Composite Building 413.

• Lead-based paint (LBP) - related to the Composite Building and possibly other structures.

• Polychlorinated biphenyls (PCBs) - in and near the Composite Building, former Sewage Lagoon, borrow pits/drum storage areas, and other areas.

• Pesticides - dichloro-diphenyl-trichloroethane (DDT), dichloro-diphenyl-dichloro-ethylene (DDE), and dichloro-diphenyl-dichloroethane (DDD) identified near the Composite Building, former Sewage Lagoon, and other areas.

• Other non-contaminant hazards include physical hazards associated with abandoned and damaged buildings and other structures.

The 1991 Preliminary Assessment (11 CEOS, 1992, AR03) stated that "All of the contamination found at the facility is believed to be a result of spills and leaks which may have been caused by overfills and equipment failures. There is no evidence of subsurface contamination associated with controlled waste management practices". The only known "major events" associated with contaminant releases include the 106,000-gallon diesel fuel leak over the winter of 1992-1993 and the August 2001 fire that destroyed part of the Composite Building. The proposed Notice of Environmental Cleanup and Residual Soil Contamination (included in AR document 83 along with the ADEC's No Further Remedial Action Required [NFRAP] determination letter of October 25, 2000 (AR83) makes the distinction between Pre 1993 Releases which were addressed by the joint cleanup effort by the USAF and BIA under PL 102-497, and the 1993 release. The spill response efforts by the U.S. Department of Interior (DOI) are separate from those under PL 102-497.

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6.0 CLEANUP LEVELS

The ADEC Title 18 Alaska Administrative Code (AAC) Chapter 75 (18 AAC 75) Oil and Hazardous Substances Pollution Control Regulations are the primary regulation establishing chemical-specific cleanup levels in the State of Alaska. Many aspects of these regulations, including several of the individual cleanup levels, have been recently revised as of October 9, 2008. 18 AAC 75 includes four possible methods for establishing cleanup levels for a contaminated site.

• Method One designates cleanup levels for fuel ranges Gasoline-Range Organics (GRO), Diesel-Range Organics (DRO), and Residual-Range Organics (RRO) based on a matrix score of site conditions.

• Method Two establishes tabulated soil and groundwater cleanup levels are that generally applicable at all contaminated sites in Alaska. Tables B1 and B2 list the soil cleanup levels and Table C lists the groundwater cleanup levels. Tables B1 and B2 are divided into three regions, based on the site’s annual precipitation (less than 40 inches, greater than 40 inches, and Arctic Zone) and designates a contaminant-specific cleanup level for the direct contact, outdoor inhalation, and migration to groundwater pathways, based on the ADEC’s equations and default site conditions input parameters. Method two cleanup levels are considered protective of human health; ecological protectiveness is evaluated on a site-by-site basis.

• Method Three provides for the calculation of site-specific soil cleanup levels using the ADEC online Method Three Calculator or another ADEC approved calculation tool.

• Method Four allows development of site-specific cleanup levels from site-specific risk assessments. Some site specific risk-based cleanup level (RBCL) have been developed and approved for the 27-acrea (discussed in following Section).

Method Two soil cleanup levels were used to evaluate the historical soil data in this review except for cases where a site specific RBCL has been approved. Table C groundwater cleanup levels were used to evaluate the historical groundwater data. Method Two soil cleanup levels and Table C groundwater cleanup levels are provided below; approved RBCLs are presented in Section 6.1.

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ADEC Method Two Soil Cleanup Levels (October 9, 2008) Under 40 inch Zone, Tables B1 & B2

Contaminant of Concern / Hazardous Substance

Direct Contact (mg/kg)

Outdoor Inhalation (mg/kg)

Migration to Groundwater

(mg/kg)

Maximum Allowable Concentrations

(mg/kg)

GRO 1,400 1,400 300 1,400

DRO1 10,250 12,500 250 12,500

RRO 10,000 22,000 11,000 22,000

Benzene 150 11 0.025 Toluene 8,100 220 6.5 Ethylbenzene 10,100 110 6.9 Xylenes 20,300 63 63 PCBs2 1 na

DDE 21 5.1

DDT 21 7.3

DDD 33 7.2

1 Method Two DRO cleanup levels have been superseded by risk-based cleanup level and levels specified in remedial action goals of the ROD. 2 The PCB action level previously in effect in the 1990s was 10 mg/kg.

ADEC Groundwater Cleanup Levels (October 9, 2008) - Table C

Groundwater Cleanup Level (mg/L1)

GRO 2.2

DRO 1.5

RRO 1.1

Benzene 0.005 Toluene 1.0 Ethylbenzene 0.7 Xylenes 10 PCBs 0.0005

DDE 0.0025

DDT 0.0025

DDE 0.0035

1 mg/L - milligrams per liter

6.1 SITE SPECIFIC CLEANUP LEVELS

The ROD for the BIA 27-acre parcel approved in 1998 (EMCON, 1998, AR56) jointly by the USAF, BIA, and ADEC included a surface remedial action goal of 3,000 mg/kg DRO, with clean soil cover over any soil containing more than 780 mg/kg DRO, and a subsurface remedial action goal of 6,000 mg/kg DRO. The ROD also included a PCB (Aroclor 1260) remedial action objective of <1 mg/kg in the upper 2 feet of soil and <10 mg/kg at greater depths, to allow unrestricted residential use.

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A RBCL of 2,300 mg/kg DRO was approved for the 106,000-gallon diesel spill area by ADEC in 1999 (ADEC, 1999). A summary of the site specific cleanup levels for the 27-acre parcel is provided in the table below.

Site Specific Soil Cleanup Levels for the 27-Acre Parcel

Site Specific Cleanup Level (mg/kg)

1998 ROD - Remedial Action Goal surface soils (0-2 ft bgs1) with clean soil cover over soils with >780

3,000 DRO

subsurface soils (2-6 ft bgs) 6,000 DRO surface soils (0-2 ft bgs) <1 PCBs subsurface soils (>2 ft bgs) 1 to <10 PCBs

106,000-gallon diesel spill area - Risk Based Cleanup Level soils - spill area 2,300 DRO

1bgs -below ground surface

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7.0 PREVIOUS INVESTIGATIONS

Numerous investigations and remedial actions have been performed at the Bethel BIA site from the early 1990s to the early 2000s. Those relevant to ongoing environmental concerns at the 27-acre and 18-acre parcels are discussed below. Asbestos and LBP are discussed separately from POLs, PCBs, and pesticides at the end of this section. The events are generally discussed in chronological order; however the 1992-1993 106,000-gallon fuel spill was excluded from a 1998 Record of Decision and is discussed out of order with the rest of the events for clarity. Those investigations related to the 18-acre parcel are discussed separately from the 27-acre parcel.

Figure 8 depicts the location of contaminants and environmental concerns at the 27-acre and 18-acre parcels discussed below.

7.1 27-ACRE SITE - POLs, PCBs AND PESTICIDES

7.1.1 Site Assessments/Site Characterizations

At the request of the BIA, the USAF 11 CEOS (later superseded by the 611th Civil Engineering Squadron [611 CES]) conducted a Preliminary Assessment (PA) at the BIA Administrative site in 1991. At that time the site was already abandoned by the BIA and consisted of a 125-acre parcel (included current 27-acre and 18-acre parcels) with buildings, three 400,000-gallon bulk fuel tanks (half full of fuel), one 10,000-gallon fuel tank, eleven small 300- to 500-gallon ASTs located at several buildings throughout the facility, and three pit areas used as a borrow source and drum storage areas (11 CEOS, 1992, AR03). The borrow source and drum storage areas were located to the south of the 27-acre parcel. One of the borrow source and drum storage areas was within the 18-acre parcel and is discussed later in Section 7.2. The most significant finding of the 1991 PA was the identification of several locations with BTEX and total petroleum hydrocarbons (TPH) concentrations exceeding ADEC soil cleanup levels, mostly in association with the ASTs throughout the site. Based on these findings the 611 CES conducted an Interim Removal Action (IRA) of approximately 6,800 cy of petroleum-contaminated soil (PCS) (diesel fuel-impacted) in 1994 which was stockpiled in a lined containment area about 0.25 miles south of the BIA site (611 CES, 1994b, AR11). In 1995 the 6,800 cy of PCS was placed in a bioremediation cell located at the 14-acre RRS parcel by EMCON (EMCON, 1996c, AR29).

Impacted soil beneath and in the immediate vicinity of Building 413 (Composite Building) was left in place so as not to damage the structure. Figure 9 is a historical figure from the 611 CES IRA report (611 CES, 1994b, AR11) showing the location of contaminated soils that were included in the removal action and contaminated soils that were left in place. The colored text in this and the following historical figures are explanatory comments added by BSI.

EMCON was contracted by the USACE to conduct a Site Characterization (SC) (EMCON, 1996a, AR28) and a human health and ecological risk assessment (EMCON, 1996b, AR34) of the BIA site in 1995 to document site conditions and evaluate the risks associated with contaminants at the site. EMCON also completed additional sampling and monitoring activities in 1995 and 1996 (EMCON, 1996c, AR29) to further characterize the site. In 1996, EMCON completed IRAs at the site, including soil excavation, stockpiling, filling, and capping (EMCON, 1998, AR56). EMCON's activities included installing 26 soil borings, 12 groundwater monitoring wells, 7 soil gas probes, and collecting soil, sediment, groundwater, surface water, and soil gas samples for laboratory analyses.

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Sewage Lagoon One sediment sample was collected during the 1994 IRA from the sewage lagoon area with results of 11.5 mg/kg PCB and 0.75 mg/kg DDT (EMCON, 1996c, AR29). As follow-up during the 1995 SC, EMCON collected 37 sediment samples from the sewage lagoon area following EPA PCB grid sampling guidelines (EMCON, 1996a, AR28). The PCB Aroclor-1260 was detected in sediments within the sewage lagoon at concentrations ranging from 0.15 mg/kg to 4.9 mg/kg. These PCB concentrations were below the 10-mg/kg action level in effect at that time.

The current ADEC Method Two cleanup level for PCBs is 1 mg/kg. DDT was also detected in the sediments at concentrations up to 0.89 mg/kg, below the current ADEC soil cleanup levels.

Two sediment samples were collected during the 1995 SC from locations SS11 and SS12, at tundra locations adjacent to, but downgradient from the sewage lagoon. These samples contained PCBs at concentrations of 7.2 mg/kg and 0.69 mg/kg, respectively. The SC stated that location of SS11 was immediately outside the fence line of the lagoon in a seasonal drainage that originates from the upper sewage lagoon. The SC also stated that these occurrences of PCBs appear to be a result of surface sediment transport from the sewage lagoon area (EMCON, 1996a, AR28).

Groundwater Results from the 12 groundwater monitoring wells installed on the…