2016_NORTECH_BIA_Site_Restoration_Study_v5_w__att_(1).pdf

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Juneau, AK 99801 907.586.6813

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www.nortechengr.com

May 4, 2016

Sent via email to: newton.chase@ykhc.org

Yukon Kuskokwim Health Corporation Box 528 Bethel, Alaska 99559

Attn: Newton Chase Vice President for Support Services

RE: Former BIA Site Restoration Study Bethel, Alaska

Newton:

In response to your request, NORTECH is pleased to submit this Site Restoration Study of the 27-acre former Bureau of Indian Affairs (BIA) Administration Site located in Bethel, Alaska (Site). The following is a brief synopsis of Background, Scope of Work, Methodology, Document Review, Field Inspection, Analysis, Cost Estimate and Conclusions and Recommendations where appropriate.

Background The Site was constructed in 1957 as part of a former United States Air Force (USAF) White Alice Communications System (WACS) facility and over the years has been transferred between several federal agencies. The facility was last in-use and occupied by BIA up to 1990. The property is scheduled for transfer to YKHC, subject to certain conditions as required by in Public Law (PL) 102-497.

NORTECH completed an April 2016 desktop study update of a 2002 cost estimate to abate hazardous materials and demolition of Administration Building 413 (Phukan Inc.). The desk top study did not include any other improvements on the site and uncovered a number of limitations regarding current conditions and potential concerns that requires additional historical document research and field work to address.

Scope of Work The objective and scope of work of this Site Restoration Study is to complete a site inspection to resolve the limitations identified in the Administrative Building Desktop Study, review additional historical documents known to be available and complete a similar review of the remainder of the structures and the 27-acre Site. Project efforts included consideration of reuse, recycle, and salvage of remaining structures and materials, disposal of unsalvageable buildings/materials, and remediation of environmental concerns. The study identifies and provides the preliminary restoration cost estimate of the known and visibly recognizable conditions, on and adjacent to the Site, and analyzes the risk of these liabilities to YKHC. Due to the unknowns no site sampling was included in the requested and completed scope of work. As anticipated project efforts did identify additional site sampling, primarily the need for a site survey and environmental, that is recommended to further refine actual Site Restoration

Site Restoration Study Former BIA Complex, Bethel, Alaska

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Objectives and Understanding It is understood YKHC’s overall objective for the Site Restoration effort is to reuse the site for health care facilities and/or residential housing. The Site Restoration Cost Estimate includes the demolition of site improvements and restoration of known site conditions. Specifically, Site Restoration, as scoped in the cost estimate would demolish all site improvements to grade, including foundations and remediate known contamination to applicable ADEC cleanup standards. While existing gravel pads and roads will remain asphalt pavement will be removed and disturbed areas of the site will be graded to drain and re-seeded. While not factored into the Site Restoration Cost Estimate existing improvements that may be reused, recycled or salvaged are identified separately.

Methodology Project methods involved a review of available records, interviews with knowledgeable individuals, a two day on-site visual walk about site inspection in order to characterize for demolition existing improvements, identify suspect hazardous material and site restoration conditions that will require additional sampling. All project efforts were authorized and coordinated by YKHC and completed in regulatory compliance in accordance with NORTECH’s proposal and attached Hazardous Material (v13) and Phase I ESA (v2) Standardized Methodologies by State of Alaska qualified environmental professional under the guidance and oversight of a Registered Professional Environmental Engineer utilizing standard industry practices.

Site Chronology A historical Site chronology is provided in Attachment 4. The chronology is from “Final Preliminary Assessment Report Contaminant Investigation Bethel BIA Site” written by Bethel Services Inc. for the U.S Fish and Wildlife Service in May, 2009 (pages 10-12)

Document Review There are two ADEC Contaminated Sites listing on the 27-acre BIA site:

• ADEC File Number 2407.38.007 contains information on the 27-acre site, including historical contamination prior to the 1993 above ground storage tank (AST) leak

• ADEC File Number 2407.38.008 contains information on the 1993 106,000-gallon diesel fuel spill area and subsequent remediation/investigation activities

The Site has been investigated for different purposes by a number of organizations throughout the years. In addition to records obtained from YKHC an internet search identified several site investigation and hazardous materials reports. In addition, a Freedom of Information Act (FOIA) request was submitted to ADEC on April 15, 2016 for available documents. The following documents have been reviewed and are available upon request. Brief descriptions of each report and major conclusions are provided below:

Preliminary Assessment by 11th Civil Engineering Operations Squadron (CEOS), March 1992 This site assessment includes property outside of the current 27-acre footprint of the BIA Site, and this site assessment was conducted before the major diesel fuel release in 1993. The site was investigated for hydrocarbon contamination; 43 soil borings were advanced across the project area. Most of the soil boring samples were reported non-detect for contaminants of

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Page 3Https://Nortechinc.Sharepoint.Com/00-Jobs/2015/1043ESA/Shared Documents/BIA-Complex/Site Restoration Desk Top Study/BIA Site Restoration Study V5.Docx concern. Several localized areas of petroleum, oil and lubricant (POL), volatile organic compounds (VOC), polychlorinated biphenyl (PCB) and dichlorodiphenyltrichloroethane (DDT) contamination were identified. CEOS estimated total hydrocarbon contamination in soil to be 3,378 cubic yards (CY). CEOS concluded that the contamination is a result of historic spills and not from historical waste disposal procedures. Page 322 of the Preliminary Assessment is included in Attachment 2 and illustrates localized areas of contamination.

Asbestos Abatement Activity by 611th Civil Engineering Squadron, July 1994 Asbestos containing materials (ACM) were reportedly abated from every building on the 27-acre BIA Site. Abated ACM included: gypsum wall board, joint compound, floor tiles, mastics, pipe fittings, gaskets and roof shingles. Approximately 3,266 CY of ACM waste was disposed of within an ADEC permitted asbestos monofill one half mile southwest of the site. According to the report, ACM was left in place in two areas. ACM caulking under the metal siding of Building 420 was left in place as removing the siding was the only way to abate the caulking. ACM tar/shingles utilidor covers were left in place for portions of the utilidors that ran underground (e.g. under roads).

Final Site Characterization Report: BIA Administration Site Bethel, AK by EMCON Alaska Inc., February 1996.

After 106,000 gallons of diesel fuel leaked from an above ground storage tanks pipe fitting in 1993 and subsequent remediation activities, EMCON performed a site assessment for the 27-acre Site including 26 soil borings, 12 sediment samples, seven soil gas samples, 11 surface water samples and the installation of 12 groundwater monitoring wells. EMCON did not estimate the quantity of contaminated soil at the site but EMCON Figures 11 and 17 (provided in Attachment 2) show a visual representation of contamination concentrations throughout the site.

EMCON Figure 11 indicate approximately 20%-25% of the 27-acre site had DRO contamination above ADEC standards in soil at depth 0’-6’ below ground surface and localized areas have DRO contamination deeper than 8 feet below ground surface. EMCON Figure 17 indicates more than 50% of the site groundwater was contaminated above ADEC standards in June of 1995.

EMCON compared the 1996 data with previous sample results and concluded natural attenuation was occurring and that natural attenuation of DRO is possible based on soil and groundwater nutrient analysis.

Draft Final Bethel BIA Administration Site Development of Risk Based Cleanup Levels and Corrective Action Alternatives by Ecology and Environment, May 1999 Ecology and Environment (E&E) prepared this report for ADEC to calculate risk based alternative cleanup levels (ACLS) and remediation strategies. E&E calculated ACLs for several different future land use scenarios. The ACL for residential land use was calculated to be 1,700 mg/kg DRO while the industrial land use was calculated to be 180,000 mg/kg DRO. E&E recommended in-situ remediation for the site, given the destructive nature of excavation and the lack of ecological damage to the site as a result of the 1993 diesel fuel spill.

Final Technical Report for PCB Removal at Bethel Bureau of Indian Affairs 27-Acre Administration Site, Building #413, by 611th Civil Engineering Squadron, May 2000 PCB contaminated concrete was removed from four areas in the transformer rooms adjacent to the generator rooms in Building 413. Approximately 4.5 tons of PCB contaminated concrete was removed, laboratory sampling confirmed remaining concrete to be below the PCB cleanup limit.

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Equitable Servitude by Bethel Native Corporation, Sept 2000 This Equitable Servitude between the Bethel Native Corporation and the State of Alaska is a contract between the two parties that limits the use of 37.34 acres of land parcel due to the levels of DRO contaminations stemming from the 1993 AST leak. The letter explains that ADEC established an alternative risk based clean up level of 2,300 mg/kg and contamination on site exceeds that elevated cleanup level. Prohibited activities on the site include:

a) Any use of the property that will or is reasonably likely to result in the creation of additional exposure pathways that increase the risk to human health, safety or welfare or the environment

b) Any use of suprapermafrost groundwater at the Property, by extraction through wells or other means, which involves consumption of other beneficial use of groundwater

c) Residential use of the property

d) Any excavation or other disturbance of surface cover on the property that exposed soil covered with vegetation or other material

e) Any construction of new structures at the Property

No Further Remediation Action Required by Alaska Department of Environmental Conservation, October 2000 ADEC issued this No Further Remediation Action Required determination based on prior remediation and site assessment activities. ADEC states this determination is in response to the site being cleaned up in accordance with 18 AAC 75.380 and a July 1998 Record of Decision.

ADEC concluded that “the site has been cleaned up to levels that do not pose unacceptable risk to human health, safety, welfare or the environment”. The letter explains that petroleum contamination remains underneath Building 413 and under a portion of the site affected by the 1993 AST leak.

Lead/Asbestos Report and Cost Estimate by Phukan Inc., 2002 Phukan Inc. performed a lead/asbestos assessment of Building 413. Lead paint was identified on almost every surface sampled. Two lead dust wipe samples indicated lead contaminated dust above the Housing and Urban Development (HUD) standard of 100 ug/ft2. Phukan quantified ACM identified by the USFWS: cement asbestos board (CAB) sandwiched between concrete foundations in A-C Wings, floor tile and mastic under the switch gear room, CAB on duct penetrations of A-C Wings, pipefittings and elbows in the crawlspace under A-C Wings.

Phukan performed on-site bulk sampling to confirm the following building materials to be ACM:

fire door insulation, built up roofing at the Generator Room, leveling compound in the A-Wing bathroom and metal skirting caulking in the A-Wing exterior. Phukan used this information and estimated quantities of each confirmed ACM throughout the building. Phukan estimated demolition of Building 413 would cost $1,250,596.65 in 2002 dollars.

Final Preliminary Assessment Report, Contaminant Investigation, Conceptual Site Model and Proposed Investigation Activities, by Bethel Services In., May 2009.

Bethel Services Inc. performed this literature review for the Fish and Wildlife Service. The review included available documents relating to site assessment and remediation activities of both the 27-acre parcel and 18-acre parcel south of the 27-acre parcel. Major findings include:

• The sewage lagoon has PCB contamination above current ACEC clean up levels and further investigation is required

• DRO contaminated soil remains under Building 413

• The area impacted by the 1993 diesel spill were cleaned up to the extent practical but contaminated soil and wetlands remain.

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• Lead, asbestos and possible arsenic contaminated ash remains from the Building 413 fires

• Floor drains in Building 413 have never been investigated and residue/sediment contained within them is possibly PCB/POL contaminated

Documents not reviewed:

Due to the project schedule limitations and the number of organizations involved in the site history and land ownership, accessing all historical reports was not possible. Documents known to exist from the documents reviewed but not obtained or reviewed are listed below. It is believed that data and analysis in the reports not reviewed and listed below are summarized in other investigations:

Record of Decision (ROD) by Alaska Department of Environmental Conservation, July 1998 ADEC, USAF and BIA signed a Record of Decision specifying remediation activities that need to be completed before ADEC will issue the site No Further Remediation Action Required. The ADEC Contaminated Sites Database specifies these activities to include excavation of PCB contaminated soil from the garage of Building 414, excavation of low level DDT contamination outside of Building 413, the sewage lagoon will be dewatered, capped and institutional controls will be established to limit future development over it, stock piles soils will be characterized and appropriately disposed. This ROD does not apply to the area affected by the 1993 diesel spill.

Field and Analytical Report for Interim Removal of Contaminated Soil at the Bureau of Indians Affairs BIA site, Bethel AK by 11th Civil Engineering Operations Squadron, March 1994 This report documents removal of 6,800 CY of DRO contaminated soil as a result of the 106,000-gallon diesel fuel spill in 1993.

Final Technical Report for Bethel BIA 27 Acre Administration Site Lagoon Dewatering and Capping Project “Final Phase” at Bethel Alaska by 611th Civil Engineering Squadron, May 2000 This report summarized the sewage lagoon decommissioning effort.

Field Activities NORTECH personnel John Hargesheimer and David Hooper performed a site visit of the 27-acre property on April 19 and 20, 2016. There was no snow cover and the weather was favorable for the site visit. Site assessment included inventorying site improvements and visually inspecting important areas of the site.

Road access to the site was in poor spring condition with large ruts making travel to the site difficult. The road bed was still largely frozen at the time.

All of the buildings have been heavily vandalized with graffiti and broken bottles and debris were observed throughout the property. Two major portions Administration Building 413 have been burned. Other portions of several buildings are burned and collapsing. Major portions of roofs have blown off causing water intrusion which is expediting deterioration.

The site is not restricted. The main access road is gated, however unlocked nor any significant barrier to access. During the two-day site visit the general public was observed almost continually visiting the site, including going walking and climbing through the unsafe deteriorating and collapsing buildings including climbing on roofs to see the surrounding view.

Each day five or six four wheelers were observed driving through the site.

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The sewage lagoon is secured with a fence and has thick brush growing on it. The former tank farm has large zones with no brush growth, only grasses are established. The tank farm dike is largely still in place, however, sections have been removed.

One half mile south of the site a fence and gate secure the former WACS facility which currently houses landfills for PCB and DDT contaminated soil and a monofill for asbestos containing building material. Groundwater monitoring wells were seen on the periphery of the WACS facility.

On the 27-acre Site, one monitoring well was located south of the southern property fence (see Figure 3), no information could be found about it but it is the same type of well seen closer to the WACS landfill site.

Building and Site Inventory:

Completed field inventories for all buildings and the site in general can be found in Attachment

5. Building locations and site improvements can be seen in Figure 3. Representative photographs of the site and buildings are included in Attachment 3. Below is a brief description of each building including a summary of significant observations.

Building 413 Administration Building: 57,700 square feet 33,500 square feet is utilized as the two story Sleeping A, B and C Wings, the rest of the building is single story mechanical room, 6 bay garage/transformer/dining/kitchen/office use.

Figure 4 shows key information about the building. The building has concrete fire break walls and a concrete foundation. A, B, and, C Sleeping Wings have a wood pilings supporting the concrete foundation. Two separate fires have destroyed a section of C-Wing and the western area north of the generator room. Wall, ceiling and floor finishings have been removed, leaving only the wood framing and floor underlayment.

Building 414 Water Utility Building: 2,100 square feet This is a split level wood framed rectangular building with a wood piling supported concrete foundation. Wall, ceiling and floor finishings have been removed, leaving only the wood framing and floor underlayment. The building houses a former pump room and three water treatment/storage tanks including a 90,000-gallon vertical tank. There is an 8-inch diameter water well south east of the building connected with a 100 foot above ground utilidor.

Building 416 Warehouse: 3,200 square feet This is a two story rectangular concrete building on steel pilings and a 15-foot-tall crawlspace.

The roof has concrete eight-sided five-foot overhanging eaves. Interior spaces are furred in with 3-inch by 3-inch studs. Wall, ceiling and floor finishings have been removed, leaving only the concrete structure and interior wood framing furring.

Building 419 Shop: 3,500 square feet This is a two story 12-sided steel building with steel pilings supporting a concrete foundation with insulated exterior walls constructed of corrugated exterior skin and interior flat sheet metal skin. Interior perimeter walls are furred in with 2-inch by 4-inch wood studs. Wall, ceiling and floor finishings have been removed, leaving only the concrete structure and interior wood framing firing

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Building 420 Warehouse: 900 square feet This is a two story eight-sided steel building with wood piling supported concrete foundation and fiberglass insulated exterior walls with interior and exterior sheet metal skin The concrete foundation is an unconventional design consisting of external circular ring and interior square, both 3’ thick. Wall, ceiling and floor finishings have been removed leaving only the piling/concrete foundation, steel structure, walls and decking.

Building 421 Education Building: 1,000 square feet This is a one story wood framed building with wooden piling supported concrete perimeter foundation. Walls are finished with gypsum wall board and wood paneling. Floor finishing have been removed. Survey data indicated this building is not part of the 27-acre parcel, but it is included in the inventory because of its proximity to the site.

Building 422 Shop: 3,200 square feet This is a two story rectangular concrete building on steel pilings with a crawlspace. The roof has eight-sided concrete eaves with a five-foot overhang. Interior spaces are furred in with 3-inch by 3-inch studs. Wall, ceiling and floor finishings have been removed, leaving only the concrete structure and interior wood framing firing.

Building 423 Warehouse: 1,500 square feet This is a two story 12-sided steel building with wood piling supported concrete foundation and fiberglass insulated exterior walls with interior and exterior sheet metal skin. The concrete foundation is an unconventional design consisting of external circular ring and interior square, both 3 feet thick. Wall, ceiling and floor finishings have been removed leaving only the piling/concrete foundation, steel structure, walls and decking.

Building 424 POL Pump House: 200 square feet A one story wood framed building with a metal roof on wooden cribbing. Historical site figures indicate this building used to be located about 200 feet to the east of its current location. The building has been completely stripped of equipment and finishings.

Building 425 Sewage Lift House: 170 square feet, This is a one story wood framed building with a wooden piling supported concrete foundation.

There are two floor mounted pumps associated with two 40-gallon waste water tanks.

Waste Water Lines: 1,040 linear feet of 6-inch diameter steel pipe runs from east of Building 413 through Building 425 into the sewage lagoon. The pipe is supported 6-8 feet in the air by 6-inch diameter steel pilings every 20 linear feet of pipe.

Utilidor: 640 linear feet of above ground wooden utilidors connect all the out-buildings with Building 413. Some utilidors still have soft copper fuel lines, most of the utility supplies have been removed though.

Drinking Water Supply Line: 250 linear feet of drinking water supply pipe runs from Building 414 into Building 413. The pipe is in a 2 foot by 2 foot insulated above ground utilidor.

Utility Poles: 14 utility poles with wiring remain on site.

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Hazardous Building Materials:

The majority of ACM have been abated from the buildings. However, historical hazardous material surveys provide incomplete data. Limited quantities of suspect asbestos containing building materials were identified in all buildings during the field inspection. Primarily non-friable mastics and caulking, which will require additional assessment or be abated as asbestos containing. Concrete building elements are suspect of containing gravel with naturally occurring asbestos (NOA) and will require testing for asbestos. While past assessments have confirmed elevated lead concentration in almost all paints in Building 413, paint in other buildings will required additional assessment or considered LBP during demolition. While the majority of fixtures and equipment have been removed limited amounts of universal waste (mercury containing fluorescent light bulbs, oil filled door closures, etc.) remain in the buildings and will need to be handled separately during Site Restoration building demolition.

Reuse, Recycle, and Salvage Reuse: The majority of the building foundations in general appeared to be level and in reasonably good visual condition and may be reusable pending a future need and project specific structural assessment. Administration Building 413 does not appear to have any reuse potential. Out building structures are in marginal condition for reuse and represent unconventional construction and floor plan. Any remaining reuse potential will be dependent on future use needs and further assessment.

Recycle: The following materials on site are considered recyclable.

• Structural steel

• Sheet metal exterior siding and interior wall material

• Metal roofing

• Wood framing dimensional lumber

• Steel staircases, interior and exterior

• Steel piping

• Wood piling

Salvage: There is a considerable amount of concrete in the buildings and foundations that could be salvageable and converted into a useable fill, rip rap and gravel. Sheet metal, steel I-beams, electrical wiring, and steel piping could all be salvaged as scrap metal.

Analysis

Site Conditions In 1957 the USAF constructed the facility as part of White Alice Communications System, which operated until 1979. The BIA acquired 125 acres from the USAF in 1963, BIA personnel left the site in 1990 and it has been vacant ever since. Public Law (PL) 102-497 directed the Secretary of the Interior to convey buildings and land to YKHC after the USAF and BIA clean up the site.

Currently the 27-acre parcel is under the jurisdiction of the U.S Fish and Wild Life Service.

The 27-acre parcel has been extensively investigated since it became vacant in 1990. In 1991 the USAF commissioned a Preliminary Site Assessment as part of the Installation Restoration Program, in which several areas of PCB, DRO, VOC and pesticide contamination is identified.

The report estimated 3,378 cubic yards of contaminated soil were present in 1991.

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In 1993, 106,000 gallons of diesel fuel leaked from a 400,000 gallon AST after an elbow fitting failed. According to the ADEC Contaminated Sites Database, 63,000 gallons were recovered, 15,900 gallons evaporated and 27,100 gallons were unaccounted for. In 1994 the USAF excavated 6,800 CY of contaminated soil from the 1993 spill location. A site investigation in 1995 identified POL contamination remaining on a large portion of the 27-acre site.

In 1998 the sewage lagoon was dewatered, some contaminated soils were excavated and the lagoons and contaminated soils were capped with clean fill on top of geotextile fabric. The sewage lagoons are secured with a chain-link fence. Soils under the capped lagoon contain up to 4.9mg/kg PCB, above the current ADEC cleanup limit of 1 mg/kg.

A 1999 Ecology and Environment report calculated alternative clean up levels (ACL) based on expected future land uses. The ACL for DRO in residential land use was calculated to be 1,700 mg/kg while concentrations for industrial land use was calculated to be 180,000 mg/kg. E&E recommended in-situ remediation for the site, given the destructive nature of excavation and the lack of ecological damage to the site as a result of the 1993 diesel fuel spill. Ecology and Environment concluded that natural attenuation was occurring on site.

In 1999 ADEC approved an alternative cleanup level of 2,300 mg/kg for DRO that was determined to be protective of human health. Later in 1999 ADEC issued No Further Remediation Action Required determination based on prior remediation and site assessment activities. ADEC concluded that “the site has been cleaned up to levels that do not pose unacceptable risk to human health, safety, welfare or the environment”. The letter explains that petroleum contamination remains underneath Building 413 and under a portion of the site affected by the 1993 AST leak.

In summary, PCB contamination above current ADEC cleanup limits remain in and around the sewage lagoon and are likely present under the southern portion Building 413 due to previously uninvestigated floor drains and historical spills. Diesel contaminated soil remains in subsurface soils on site due to the 1993 AST leak, previous cleanup efforts were unsuccessful at remediating the site. Additional diesel contamination remains beneath Building 413 mechanical room.

No soil, sediment or groundwater sampling has been conducted on the 27-acre parcel since 2000. Historical records indicate that naturally attenuation of POL subsurface site and groundwater contamination is occurring. It is concluded that site and groundwater conditions have likely changed in the 16 years since the last environmental assessment of the 27-acre parcel. Quantities and costs included in the Site Restoration estimate for these site conditions under Building 413 that have never been fully assessed are considered quessitimates based on out of date available information. Additional site assessment is recommended to determine the areal extent and concentration of remaining site soil and groundwater contamination.

Land Use Restrictions In 2000 an Equitable Servitude was signed by the Bethel Native Corporation and the State of Alaska to restrict land use because contamination concentrations on the site exceed the alternative clean up level of 2,300 mg/kg for DRO. The Equitable Servitude restricts use of the Site without express written approval by ADEC. Land restriction include:

a) Any use of the property that will or is reasonably likely to result in the creation of additional exposure pathways that increase the risk to human health, safety or welfare or the environment

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b) Any use of suprapermafrost groundwater at the Property, by extraction through wells or other means, which involves consumption of other beneficial use of groundwater

c) Residential use of the property

d) Any excavation or other disturbance of surface cover on the property that exposed soil covered with vegetation or other material

e) Any construction of new structures at the Property

This Equitable Servitude is assumed to be valid and still restrictive of current land development plans. ADEC must be notified and approve future land use. Future environmental site investigations must be coordinated with ADEC in the aim of targeting the investigation and developing a remediation strategy that will absolve these land use restrictions.

Building Condition The buildings have been abandoned for more than 25 years. Significant portions of the roof on Building 413 has blown off increasing water intrusion and structural damage. While some of the outbuilding foundations may be reusable Administration Building 413 which is partially burned and collapsing is considered un-reusable and will require demolition to address site contamination. Future weather deterioration will occur at an ever increasing rate as the roofs and weather proofing continue to lose their integrity. The majority of the building square footage is considered unusable, structurally unsafe and require demolition. To fully restore the site for residential development, all buildings will need to be demolished. The wooden utilidors, wastewater lines, drinking water lines, and wooden utility poles will need to be demolished as well. Roads on the Site will need improvement to make them suitable for demolition/construction activities.

Hazardous Materials In 2002 Phukan Inc. performed an asbestos/lead assessment of Building 413. Building 413 has a good inventory of current asbestos containing materials, but the other buildings on site do not.

The USAF commissioned asbestos abatement of all buildings in 1994 where the bulk of ACM was removed. In that report the USAF does not indicate they left ACM remaining in Building 413, but more recent hazmat surveys confirm ACM is present. This was confirmed while on site with the identification of additional suspect ACM materials, including all of the concrete. For the purposes of the estimate the concrete has been considered non-ACM and only a limited amount of ACM has been included in the Site Restoration estimate. Additional pre-demolition assessment of hazardous materials and building materials suspected of containing asbestos is recommended, most specifically the assumption that the concrete is non-ACM.

Public Hazard and Liability. Fires in 1987 and 2001 have destroyed large sections of building

413. Figure 4 illustrates the burned portion of Building 413. The majority of the structures are structurally unsafe, collapsing and a public safety hazard. General public visiting the site and climbing around and on top of the structures was observed almost continuously during the two-day site visit. Vehicle and four wheelers are using the site trails and access. Each building was heavily vandalized and trash was found throughout the site. The gate leading to the site was unlocked upon arrival and even if it was locked would provide inadequate security. The property is an unsecured public safety hazard and a significant owner liability.

Reuse, Recycle, Salvage The site improvements include multiple building foundations and a fewer number of structures that may be reusable depending on an identified need and project specific assessment. The eight out-buildings are on concrete foundation supported by either steel or wooden pilings that

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Page 11Https://Nortechinc.Sharepoint.Com/00-Jobs/2015/1043ESA/Shared Documents/BIA-Complex/Site Restoration Desk Top Study/BIA Site Restoration Study V5.Docx appeared to be in good condition. With assessment from a structural engineer they could potentially be reused on site for future buildings. Several buildings appeared to be in good conditions and could be reused with renovation. For example, building 419 has a steel piling foundation and steel supported structure that was in good condition. The building is an odd 12-sided shape but could be re-used. Further investigation by a structural engineer could further assess the reuse ability of foundations and buildings that would not require demolition, and reduce site restoration costs. Based on the Site Restoration estimate saving the foundations from Buildings 414, 416,419,420,422 and 423 would reduce the restoration cost by $80,000.

There is a considerable quantities of recyclable building materials including wood pilings, structural steel, sheeting decking and staircases as well as metal roofing and dimensional frame lumber. Buildings 416 and 422 both have furred in walls with 3-inch by 3-inch studs that are largely in good condition. Building 413 has a large amount of 2-inch by 4-inch studs that are in good condition. The stairwell walls in Sleeping Wings A, B, and C are built with 2 inch by 4 inch studs positioned flat-to-flat, each stairwell has 100 or more studs that could be reused. The 8-inch and 12-inch I-beams used to support steel buildings 423, 420 and 419 appear to be in good condition and could be recycled. There is a lot of potential for recyclable materials at this site, however the effort would require manual deconstruction prior to demolition.

There is a considerable amount of concrete, steel, and electrical wiring across the Site that could be salvaged. Salvage benefits are largely dependent on the local salvage market and transport and handling costs. For project design further investigation is required to identify local capability.

Cost Estimate Based on developed quantities, HMS was subcontracted to estimate the Site Restoration project costs. The cost estimate assumes the following:

• All buildings, utilities and fences will be demolished

• Construction and demolition debris will be disposed of at Bethel Landfill

• Asbestos containing materials will be transported to Anchorage for disposal

• PCB and other hazardous waste will be transported out of Bethel for disposal at approved facilities

• POL contaminated soil will be land farmed per ADEC regulation in Bethel

• Estimate is in 2017 dollars

HMS’s cost estimate for site restoration is: $4,440,951. The estimate includes recommended additional assessment, project design, competitive bid, construction administration and project close out. The estimate does not include YKHC administrative costs.

Additional Assessment The following is summary of recommended additional assessment. While total additional assessment costs are included in the Site Restoration Cost Estimate a detailed additional assessment proposal and fee estimate will be provided separately.

Site The 27-acre parcel boundary is in close proximity of several structures and site improvements.

Building 421 is located adjacent to the property and would most likely be considered in any Site

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Restoration. Portions of the lagoons appear to be off property. A site survey of the property boundary and all structures is recommended for project design and restoration.

Environmental While the 27-acre site has been extensively investigated in the past, all of the environmental data is at least 16 years old. Contaminant concentrations have likely changed in that time span.

Further investigation is required to assess the environmental conditions on the site. The required assessment should include the following:

• Soil borings to replicate 1996 EMCON data to assess contaminant degradation

• Advancement of additional soil borings in the former tank farm, north of the former tank farm, in the sewage lagoon, and around the buildings to further assess subsurface conditions

• Groundwater sampling at a selection of the soil boring locations to assess groundwater contamination

• Soil and groundwater sampling of the known POL, PCB and floor drain contamination beneath Building 413.

In order to complete the additional site investigation and in preparation of project design additional regulatory consultation is necessary to comply with the excavation prohibition, work plan approval and cleanup criteria.

Hazardous Materials A discrepancy in ACM remaining in Building 413 between the 1994 USAF report and the 2002 Phukan report casts doubt upon the 1994 USAF abatement report and whether all ACM was abated from the buildings. During the April 2016 site visit NORTECH identified suspect ACM in all of the buildings. Additional sampling is required to confirm the presence of ACM. All concrete is a suspected of containing naturally occurring asbestos (NOA) until sampled. In the cost estimate NORTECH assumed concrete to be non-ACM. This needs to be confirmed in order to avoid any potential for change order during demolition or salvage. Suspect lead based paint was also identified and due to the age of the buildings any dust and debris is likely contains lead which needs to be known in order to properly prepare project design and competitive bids.

Universal waste was identified in most of the buildings as well. Each building should have a pre demolition hazardous material survey to identify ACM, LBP and universal waste. Each building should be composite toxicity characteristic leaching procedure (TCLP) sampled to determine waste disposal requirements.

Structural Engineer Inspection A structural engineer will need to inspect and test the foundation pilings and structures to determine if they are reusable. The engineer would complete non-destructive inspection and testing to assess their capacity for reuse in a future proposed project.

Brownfield Development Alternative A Brownfield Site is a parcel of real property previously used for commercial or industrial purposes that contaminated the site with hazardous waste or pollution. Brownfield projects focus on the reuse of real property that is stigmatized by the presence of contamination.

Typically, the legal contract involves the responsible party, the project developer, regulators and usually a Brownfields state or federal grant. As this site is federally owned, the site does not qualify for specific Brownfield funding and all the restoration costs remain a federal ownership

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Page 13Https://Nortechinc.Sharepoint.Com/00-Jobs/2015/1043ESA/Shared Documents/BIA-Complex/Site Restoration Desk Top Study/BIA Site Restoration Study V5.Docx liability. Regardless, the Brownfield concept could be used at the Site to complete site restoration for less money and return the property to a valuable community asset by identifying a project developer, such as YKHC, that can use the property and potentially reuse buildings as well as recycle and reuse the materials present. Where regulatory compliant and integrated into the project development some subsurface contaminates may remain reducing remediation costs and freeing up funding for other uses. Federal ownership would be interested in the reduced cost Brownfield approach even though it would likely be necessary to indemnify YKHC for known conditions, and fund a Site Restoration scope that met YKHC’s project needs.

YKHC is an integral part of the Bethel community and developing this federal Brownfield for a health consortium project will help fulfill its mission of “Working Together to Achieve Excellent Health”. YKHC could develop a concerted community supported political awareness campaign to raise awareness of the public health hazards associated with this site with a goal of impressing upon the federal government the need for the restoration and conveyance of this land as mandated in PL 102-497.

Depending on YKHC’s development plan a Brownfield agreement between the federal government, the State and YKHC would likely reduce the cost of site restoration by reusing some of the assets on the property and decreasing the cost of remediation. If the Site can only be conveyed fully restored at the estimated cost with no integration of redevelopment objectives, it may never be conveyed nor cleaned up in the near future. Full investigation of the contamination and exposure potential for the proposed development plan will be important to developing a restoration project design strategy that remediates or control existing contamination, eliminates exposure potential and minimizes remediation costs so that the site can be developed. A brownfields approach is recommended as a feasible alternative project approach for cost effectively addressing the public safety hazard, federal ownership liability as well as YKHC’s project needs and mission.

Conclusions and Recommendations:

Based on the April 2016 site inspection and document review, NORTECH has the following conclusions and recommendations about the 27-acre BIA Administration Site in Bethel, Alaska:

• The site and buildings are unsecured, pose a significant public health hazard, are routinely accessed by the general public, and are a property owner liability

• The site has known DRO, PCB, DDT and other pesticide contamination with:

o A DRO alternative cleanup level (ACL) of 2,300 mg/kg o No Further Remediation Action Required granted by ADEC o Area wide soil and groundwater contamination with known locations of concentrations that exceed project specific alternative cleanup levels o Natural attenuation of site and groundwater conditions is known to be occurring o Site and groundwater conditions have likely changed in the 16 years since the last environmental assessment.

• The following land restrictions were put in place by ADEC because contamination remains above the ACL o Use of the property that could create additional exposure pathways o Use of suprapermafrost groundwater o Residential use of the property o Excavating or other disturbances of surface cover o New construction

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• ADEC must be consulted before future environmental investigations or other land uses

• The majority of the building square footage is considered unusable, structurally unsafe and require demolition o Limited quantities of suspect asbestos containing building materials and universal wastes and other hazardous materials remain o Concrete demolition waste is suspect of containing naturally occurring asbestos

(NOA) until tested.

• Site restoration rough order of magnitude costs including additional assessment, design, competitive bid and restoration costs is estimated to be $4,440,951.

• The site improvements include multiple building foundations and a fewer number of structures that may be reusable depending on an identified need and project specific assessment.

o Based on the Site Restoration estimate reusing six foundations would reduce the restoration cost $80,000.

o There is a considerable quantity of recyclable building materials including wood pilings, structural steel, metal sheeting, staircases, roofing and dimensional frame lumber that will require manual de-construction prior to general demolition

• Additional assessment is recommended to address known data gaps and obtain current site information that will refine Site Restoration costs and be pertinent to property transfer and project development and design

• A brownfields development approach is recommended as a feasible alternative project approach for cost effectively addressing the public safety hazard, site restoration requirements, Federal Ownership liability as well as YKHC’s project needs and mission.

We trust this meets with your needs at the present time. If you have any questions or require additional professional services or advice, please let us know. We look forward to working on developing a project design. We thank you for the opportunity to work with you on this project and appreciate your confidence in our Firm.

Sincerely, NORTECH

David Hooper, E.I. T John Hargesheimer, P.E., CIH Staff Engineer Principal

Attachments:

Attachment 1 Site Restoration Cost Estimate Attachment 2 Site Figures Attachment 3 Site Photographs Attachment 4 Site Chronology Attachment 5 Inventory Sheets Attachment 6 Methodology

HMS Project No. 16032

CONCEPT DESIGN SUBMITTAL

DEMOLITION COST ESTIMATE (REVISION 2)

YKHC FORMER BIA SITE RESTORATION

BETHEL, ALASKA

PREPARED FOR:

Nortech, Inc.

2400 College Road

Fairbanks, Alaska 99709

May 3, 2016

4103 Minnesota Drive • Anchorage, Alaska 99503 p: 907.561.1653 • f: 907.562.0420 • e: mail@hmsalaska.com

YKHC FORMER BIA SITE RESTORATION

BETHEL, ALASKA

CONCEPT DESIGN SUBMITTAL DEMOLITION COST ESTIMATE (REVISION 2)

HMS Project No.: 16032

DATE: 5/3/2016

DRAWINGS AND DOCUMENTS

Level of Documents: (3) concept design quantities and brief systems or descriptions Date: April 22, 2016 Provided By: Nortech, Inc. of Fairbanks, Alaska

RATES

Pricing is based on current material, equipment and freight costs.

Labor Rates: A.S. Title 36 working 60 hours per week Premium Time: 16.70%

BIDDING ASSUMPTIONS

Contract: Standard construction contract without restrictive bidding clauses Bidding Situation: Competitive bids assumed Bid Date: Spring 2017 Start of Construction: Summer 2017 Months to Complete: Within (7) months, including submittals, materials procurement, etc.

Demolition Time: (6) months, including sequencing and phasing for (10) work areas

WASTE DISPOSAL ASSUMPTIONS

1. Concrete and general waste disposal at Bethel landfill

2. Asbestos disposal at Anchorage landfill

3. PCB disposal out of state

4. POL contaminated soils at onsite Bethel land farm

EXCLUDED COSTS

1. Owner's administrative and management costs

NOTES REGARDING THE PREPARATION OF THIS ESTIMATE

CONCEPT DESIGN SUBMITTAL DEMOLITION COST ESTIMATE (REVISION 2)

HMS Project No.: 16032

DATE: 5/3/2016

GENERAL

When included in HMS Inc.'s scope of services, opinions or estimates of probable construction costs are prepared on the basis of HMS Inc.'s experience and qualifications and represent HMS Inc.'s judgment as a professional generally familiar with the industry. However, since HMS Inc.

has no control over the cost of labor, materials, equipment or services furnished by others, over contractor's methods of determining prices, or over competitive bidding or market conditions, HMS Inc. cannot and does not guarantee that proposals, bids, or actual construction cost will not vary from HMS Inc.'s opinions or estimates of probable construction cost.

This estimate assumes normal escalation based on the current economic climate. While the global economic downturn appears to be moderating, it remains unclear how its effects and subsequent economic recovery will affect construction costs. HMS Inc. will continue to monitor this, as well as other international, domestic and local events, and the resulting construction climate, and will adjust costs and contingencies as deemed appropriate.

Comments received on April 28, 2016 and May 2, 2016 have been incorporated into this submittal.

GROSS FLOOR DEMOLITION AREAS (INCLUDING RELATED WORK ITEMS)

Building 413 (Admin Building) 57,776 SF Building 414 (Water…