Environmental Assessment Point Barrow Long Range Radar Site Remedial Action-Cleanup and Building Demolition/Debris Removal Activities Prepared for: U.S. Department of the Interior Bureau of Land Management Arctic Field Office Fairbanks, Alaska On Behalf of: Department of the Air Force Air Force Center for Engineering and the Environment 611th Civil Engineer Squadron Joint Base Elmendorf-Richardson, Alaska Prepared by: AECOM Technical Services, Inc. Anchorage, Alaska AFCEE Contract No: FA8903-08-D-8770 February 2011 ENVIRONMENTAL ASSESSMENT Point Barrow Long Range Radar Site Remedial Action-Cleanup and Building Demolition/Debris Removal Title: Point Barrow Long Range Radar Site Debris Removal and Cleanup NEPA Document #: DOI-BLM-LLAKF010-2011-0002-CX Type of Action: NPR-A ROW Renewal Serial Number: FF081465 Land Use Plans/Acts: Northwest National Petroleum Reserve-Alaska Integrated Activity Plan/Environmental Impact Statement (IAP/EIS) dated November 2003 Applicant: United States Air Force 611th Civil Engineer Squadron Date Prepared: February 2011 Prepared by: United States Air Force 611 Civil Engineering Squadron (CES) 10471 20th Street, Suite 302 JBER, AK 99506 The proposed actions are located on lands and waters that are in the National Petroleum Reserve-Alaska (NPR-A). Lands and waters in the NPR-A were originally set aside as the Naval Petroleum Reserve #4 by Executive Order 3797 – A, dated February 27, 1923. Jurisdiction of the land was transferred to the Department of the Interior from the Department of Navy by the Naval Petroleum Reserve Production Act of April 5, 1976 (PL. 94-258, Stat. 303) (NPRPA). United States jurisdiction over coastal tidally influenced waters and associated submerged lands was affirmed in United States v. Alaska, 117 U.S. 1888, No. 84, Orig (1997). The proposed action evaluated in this environmental assessment (EA) encompasses a total acreage of approximately 267 acres. Specific legal land descriptions are all located within the Umiat Meridian. Table of Contents Acronym List ................................................................................................................................................ 4 1 PURPOSE AND NEED ............................................................................................................................. 6 1.1 Introduction ................................................................................................................................. 6 1.2 Need for Action ............................................................................................................................. 8 1.3 Purpose(s) of Action ...................................................................................................................... 9 1.4 Laws, Regulations other EAs that Influence this EA ...................................................................... 9 1.5 Decision to be Made ................................................................................................................... 10 1.6 Scoping and Issues ...................................................................................................................... 10 1.7 Summary .................................................................................................................................... 12 2 Alternatives including the No Action .................................................................................................. 12 2.1 Introduction ............................................................................................................................... 12 2.2 Description of the Alternatives ................................................................................................... 12 2.2.1 Alternative A: No Action ..................................................................................................... 12 2.2.2 Alternative B: Proposed Action ........................................................................................... 13 2.2.3 Remedial Action-Cleanup .................................................................................................... 13 2.2.4 Building Demolition/Debris Removal Air Terminal Area Activities ..................................... 15 2.2.5 Building Demolition/Debris Removal Camp Area Activities ............................................... 17 2.2.6 Schedule .............................................................................................................................. 18 2.3 Description of Options Considered but Eliminated from Detailed Study ................................... 19 2.3.1 Vehicle Fueling Station Area ............................................................................................... 19 2.3.2 Radome Area and Transformer Stand Areas ...................................................................... 19 2.3.3 Vehicle Maintenance Facility Area ...................................................................................... 20 2.3.4 Air Terminal Area ................................................................................................................ 20 3 Affected Environment ......................................................................................................................... 20 3.1 Cultural Resources ...................................................................................................................... 20 3.1.1 Archaeological Resources: .................................................................................................. 20 3.1.2 Historic Cold War Resources ............................................................................................... 21 3.2 Subsistence ................................................................................................................................ 22 3.3 Environmental Justice ................................................................................................................. 22 3.4 Wastes (Hazardous/Solid) ........................................................................................................... 22 3.5 Threatened and Endangered Species ......................................................................................... 24 3.5.1 Eiders .................................................................................................................................. 24 3.5.2 Polar Bears .......................................................................................................................... 24 4 Environmental Impacts ....................................................................................................................... 25 4.1 Direct and Indirect Effects .......................................................................................................... 25 4.1.1 Cultural Resources .............................................................................................................. 26 4.1.2 Subsistence ......................................................................................................................... 26 4.1.3 Environmental Justice ......................................................................................................... 27 4.1.4 Wastes (Hazardous/Solid) ................................................................................................... 27 4.1.5 Threatened and Endangered Species ................................................................................. 28 4.2 Cumulative Effects ...................................................................................................................... 29 4.3 Mitigation and Monitoring .......................................................................................................... 30 4.3.1 Mitigation ............................................................................................................................ 30 4.3.2 Monitoring .......................................................................................................................... 31 4.4 Summary of Environmental Consequences ................................................................................ 31 5 Consultation and Coordination ........................................................................................................... 32 5.1 Agencies, Organization and Persons Consulted .......................................................................... 32 5.2 List of Preparers .......................................................................................................................... 32 6 Bibliography ....................................................................................................................................... 32 Appendices Appendix A – Figures Figure 1-1 Site Overview Figure 1-2 Air Terminal Area Figure 1-3 Camp Area Appendix B – NW AIP/EIS ROD Required Operating Procedures Appendix C – Polar Bear Interaction Plan Appendix D – ESA Section 7 Consultation Appendix E – Best Management Practices ACRONYM LIST AAC Alaska Administrative Code ACM asbestos containing material ADEC Alaska Department of Environmental Conservation ANILCA Alaska National Interest Lands Conservation Act AST above-ground storage tank BLM Bureau of Land Management BMP Best Management Practices BTEX benzene, toluene, ethylbenzene, and xylenes CERCLA Comprehensive Environmental Response, Compensation, and Liability Act CES Civil Engineer Squadron CFR Code of Federal Regulations COC Contaminant of concern CWA Clean Water Act cy cubic yard DEW Distant Early Warning DR Decision Record ea each EA Environmental Assessment EIS Environmental Impact Statement EO Executive Order ERP Environmental Restoration Program ESA Endangered Species Act FONSI Finding of No Significant Impact FS Feasibility Study gal gallon HABS Historic American Buildings Survey IAP Integrated Activity Plan lf linear feet INRMP Integrated Natural Resource Management Plan LRRS Long Range Radar Site MAR Minimally Attended Radar MOA Memorandum of Agreement NARL Naval Arctic Research Laboratory NEPA National Environmental Policy Act NHPA National Historic Preservation Act NOAA National Oceanic and Atmospheric Administration NORAD North American Aerospace Defense NPR-4 Naval Petroleum Reserve 4 NPR-A National Petroleum Reserve-Alaska NRHP National Register of Historic Places NSB North Slope Borough PCB polychlorinated biphenyls ppm part per million RAB Resource Advisory Board RA-C Remedial Action-Cleanup RCRA Resource Conservation and Recovery Act RI Remedial Investigation ROP Required Operating Procedure ROW Right-of-Way sf square feet SHPO State Historic Preservation Officer T&E Threatened and Endangered U.S. United States U.S.C. U.S. Code UIC Upkeagvik Inupiat Corporation USAF U.S. Air Force USDOI U.S. Department of the Interior USFWS U.S. Fish and Wildlife Service ENVIRONMENTAL ASSESSMENT Point Barrow LRRS 1 PURPOSE AND NEED 1.1 Introduction This Environmental Assessment (EA) has been prepared to disclose and analyze the environmental consequences of proposed demolition and disposal of excess buildings, structures, and surface debris, and disposal of environmental contamination on the Point Barrow Long Range Radar Site (LRRS). The EA is a site-specific analysis of potential impacts that could result with the implementation of a proposed action or alternatives to the proposed action. The proposed action evaluated in this EA encompasses a total acreage of approximately 267 acres. The EA assists the Department of the Interior Bureau of Land Management (BLM or Bureau) and the United States Air Force (USAF or Air Force) in project planning and ensuring compliance with the National Environmental Policy Act (NEPA), and in making a determination as to whether any “significant” impacts could result from the analyzed actions. “Significance” is defined by NEPA and is found in regulation 40 CFR 1508.27. An EA provides evidence for determining whether to prepare an Environmental Impact Statement (EIS) or a statement of “Finding of No Significant Impact” (FONSI). If the decision maker determines that the proposed action has significant impacts following the analysis in the EA, then an EIS would be prepared for the proposed action. If it is determined that the proposed action would not cause significant impacts, a Decision Record (DR) may be signed for the EA approving the selected alternative, whether the proposed action or another alternative. A DR, including a FONSI statement, documents the reasons why implementation of the selected alternative would not result in significant environmental impacts (effects) beyond those already addressed in Northwest National Petroleum Reserve-Alaska (NPR-A), Integrated Activity Plan/Environmental Impact Statement (IAP/EIS). Point Barrow LRRS is the northern most Minimally Attended Radar (MAR) installation in Alaska. Prior to it becoming a LRRS in the late 1980’s, Point Barrow was a Distant Early Warning (DEW) station. Point Barrow LRRS occupies about 267 acres of land situated at approximately 8 to 25 feet above mean sea level on the north coast of Alaska on the Barrow Peninsula. The installation is located in an area predominately influenced by coastal erosion and thaw lake processes. It is bordered on the west by a large freshwater thaw lake (Imikpuk Lake) and on the east by a saltwater lagoon (North Salt Lagoon). The North Salt Lagoon has an outlet on the northeast side to the larger Elson Lagoon, which is connected to the Beaufort Sea. The entire area is part of the NPR-A, which was formerly Naval Petroleum Reserve 4 (NPR-4). The Point Barrow DEW station was constructed in 1953 and became operational in 1957. The installation was one of two “main stations” for the DEW System in Alaska. Current facilities include two module building trains connected with an overhead bridge and equipped with rotating radar. The trains contain living quarters and radar operations. In addition, there is a garage, warehouse, gas meter facility, fuel pump station, and air terminal. The facility includes a lighted, perforated-steel plate runway and apron. The airstrip, owned by the Ukpeagvik Inupiat Corporation (UIC), is inactive. The station is accessed by sea via barge or through the village of Barrow. The Point Barrow LRRS is component of a USAF radar/communications network, part of the overall North American Aerospace Defense (NORAD) Command mission. The station is permitted by a right-ofway (ROW) from the BLM and is adjacent to the former Naval Arctic Research Laboratory (NARL). The Air Force’s land interest at Point Barrow is through a ROW from the BLM, who plays an active role in land management. The USAF is the agency responsible for managing these facilities and has identified the need for environmental cleanup and abandonment of obsolete infrastructure. The current ROW grant for the site was established in 1986 to manage for continued radar and defense monitoring which expired in April 2006. “Upon termination of the grant, structures and buildings shall be removed and the land rehabilitated to the satisfaction of the Arctic Area Manager”, and “[a]ll trash and debris associated with operations under this grant must be removed to an approved solid waste disposal site.” The proposed action is part of the USAF’s process in meeting this stipulation. Environmental studies and assessments have been conducted at Point Barrow LRRS since the early 1980s. However, very little sampling and analysis of soil or water samples was performed until a Remedial Investigation (RI)/Feasibility Study (FS) was conducted in 1993 (ICF Technology Inc., 1996). In 2000, a Clean Sweep environmental survey was conducted to verify and refine a list of facilities identified for demolition (USAF, 2001). The Clean Sweep Program combines Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA)-governed remediation along with non-CERCLA building demolition and environmental restoration of facilities and structures at installations no longer required by the Air Force. To prepare for the USAF’s Clean Sweep Program, a second RI was conducted in 2007 to fill data gaps necessary for planning and decision making and to identify, quantify, and remedy problems associated with past management, disposal, and spills of hazardous substances at USAF facilities (USAF, 2008). In 2010, the USAF completed a FS identifying appropriate remedial alternatives for contaminants and detailed analysis of the alternatives for selection of appropriate remedial remedies for implementation (USAF, 2010). A Final Proposed Plan was completed in July 2010 that identified the USAF preferred cleanup option for the four areas with contaminated soil and for the single site with contaminated surface water (USAF, 2010). Community feedback on remedy alternatives was solicited and a public meeting held in Barrow on August 12, 2010 (USAF, 2010). Under the proposed action the USAF would conduct environmental restoration activities in accordance with its Environmental Restoration Program (ERP), which is consistent with CERCLA guidelines for investigation, remediation, and site closure. The ERP is designed to identify, quantify, and remedy problems associated with past management, disposal, and spills of hazardous substances at USAF facilities. 1.2 Need for Action The USAF desires to conduct removal actions on properties used by the USAF at the Point Barrow LRRS. The need for the USAF action is to remove wastes and materials from the lands and waters in accordance with State regulations and BLM ROW grant stipulations. BLM’s need for the proposed action is to concur that the USAF request for removal actions on public lands administered by the BLM near Point Barrow, Alaska is in compliance with ROW grant stipulations. The specific objectives of this project are to demolish, remove, and dispose of excess buildings and structures and surface debris at the Point Barrow LRRS Camp and Air Terminal Areas (see Figure 1-1 in Appendix A), and excavate, treat, or dispose of xylene and polychlorinated biphenyls (PCB) contaminated soils to meet Alaska Department of Environmental Conservation (ADEC) regulations. The proposed action includes the following activities. Remedial Action-Cleanup (RA-C) activities include: • Excavation and off-site disposal for the four areas in the Camp area (also referred to as ERP Site SS002 or Garage Area as identified in the 2007 RI and 2010 FS reports) with contaminated soil to meet ADEC regulations. The estimated types and volumes of soil to be excavated and disposed are: Site Volume (cy1) Contaminant (ppm2) Vehicle Fueling Station 70 Xylenes > 63 Radome Area 25 PCB > 1 Transformer Stand Area 16 PCB > 1 Vehicle Maintenance Facility 178 PCB > 1 1cy – cubic yard, 2ppm – part per million • Institutional controls, natural attenuation, and long-term monitoring of contaminated surface water (total aromatic hydrocarbons or total BTEX) at the Air Terminal Area (also referred to as ERP Site SS003 as identified in the 2007 RI and 2010 FS reports). The USAF proposes to demolish, remove and dispose of the following structures located at the Camp and Air Terminal Areas: • Air Terminal Area (see Figure 1-2 in Appendix A): o Remaining Jet Fuel Tanks and Stand . Tanks 4, 5, 6, 7, 8, and 9 – 18,300 gal ea. . Tank 10 – 23,000 gal o Float Plane Fuel Dock o Air Terminal o Storage Yard Debris o Transmission Lines/Utility Poles o Marston Matting • Camp Area (see Figure 1-3 in Appendix A): o Remaining Diesel Storage Tanks (berm area) . Tanks 1, 28, and 29 – 550 gallon (gal) each . Tank 2 – 6,000 gal . Tank 11 – 65,000 gal . Tank 12 – 50,000 gal . Tanks 22, 23, 24, 25, 26, and 27 – 275 gal each . Tank 30 – 1,000 gal o Antenna and Support Structures o Liquid Fueling Pump Station Tanks/Circulation Pump o Gas Meter Facility o Vehicle Fueling Station If no action is taken then the wastes and materials would remain in the land and waters at the site near Point Barrow. These would continue to pose a risk to human health and the environment, and the risk would increase over time. The proposed action would allow the USAF to remove the contamination and debris which would result in a beneficial effect to the environment. 1.3 Purpose(s) of Action The purpose of the proposed action is to remove debris and clean up contaminants at Point Barrow LRRS to reduce the risk to human health and the environment through implementation of efficient, legally compliant, and cost-effective response actions. The objective of the proposed action is to demolish and dispose of inactive buildings and structures, remove surface debris, and treat or dispose of environmental contamination in compliance with BLM ROW stipulations and required operating procedures. 1.4 Laws, Regulations other EAs that Influence this EA Although the proposed action and alternative are not specifically mentioned in the Northwest NPR-A, IAP/EIS, approved in January 2004, within the Record of Decision, the proposed action is consistent with the plan’s objectives, goals and decisions as the proposed action relates to the protection of resources and human uses and the protection of subsistence resources and access (USDOI BLM, 2004). The proposed action is based upon and tiered to, when appropriate, the following laws, regulations, policies, decisions and opinion: • 18 AAC 75, Oil and Other Hazardous Pollution Control Regulations - Discharge Reporting, Cleanup, and Disposal of Oil and Other Hazardous Substances; • National Historic Preservation Act (NHPA) of 1966, as amended; • Endangered Species Act (ESA) of 1973, as amended; • Alaska National Interest Lands Conservation Act (ANILCA) of 1980, as amended; • Executive Order (EO) 11988: Floodplain Management; • EO 11990: Protection of Wetlands; • EO 12898: Environmental Justice • Record of Decision, Northwest NPR-A, IAP/EIS, January 22, 2004; • Biological Opinion for BLM for the Northern Planning Areas of the NPR-A, July 2008; 1.5 Decision to be Made The USAF will consider whether to continue with the cleanup and if so, decide what terms and conditions are necessary to mitigate adverse impacts, if any. 1.6 Scoping and Issues The USAF has gone through a lengthy planning and public participation process in addressing remediation needs at the Point Barrow LRRS through regular Barrow Resource Advisory Board (RAB) meetings and project specific meetings. In July 2008, the USAF released the Final RI Report for the Point Barrow LRRS. On August 12, 2010, the USAF held a public meeting in Barrow to seek public comments on the Final Proposed Plan and on November 9, 2010 held an agency scoping meeting on the proposed action in Fairbanks that included representatives from the North Slope Borough (NSB). The U.S. Fish and Wildlife Service (USFWS), BLM and ADEC commented on the FS, Proposed Plan, and rough drafts of the work plans for the proposed action. Comments received were incorporated into contractor scope of work per USAF contracting obligations. The proposed action was announced on the BLM Arctic Field Office NEPA Register on (http://www.blm.gov/ak/st/en/info/nepa/fdo_nepa_register/arctic_nepa_reg.html). BLM guidelines include a list of issues that are addressed, where applicable, in NEPA EAs (USDOI BLM, 2008). Some elements are not present in the project area and are therefore not discussed any further. A summary of related issues considered by the USAF and BLM Arctic Field Office is provided in Table 1-1. Table 1-1 Issues Considered in Evaluating Impacts Issue Considered Determination1 Basis of Determination (See Note ) Air Quality No Impact Protections provided by: State of Alaska Air Non-Point and Mobile Program and regulations [18 Alaska Administrative Code (AAC) 50] Cultural Resources Adverse Effect Protections provided by: Section 106 of the National Historic Preservation Act, Effects mitigated through 2005 Memorandum of Agreement (MOA) between USAF and Alaska State Historic Preservation Office (SHPO), Required Operating Procedure (ROP) E-13 Subsistence Potentially Affected Protections provided by: Alaska National Interest Lands Conservation Act (ANILCA), ROP H-1, I-1 Environmental Justice Potentially Affected Protections provided by: EO 12898 Waste (Hazardous/Solid) Potentially Affected – basis for proposed Protections provided by: CERCLA, Resource Conservation and Recovery Act (RCRA), 18 Issue Considered Determination1 Basis of Determination (See Note ) action AAC 30, 60, 62, 63, 72, and 75; ROPs A-1, A- 2a, A-3, A-4, and A-5 Water Resources Minimally Affected Protections provided by: Clean Water Act (CWA), Safe Drinking Water Act, ROPs A-4, A-5, B-1, B-2, C-3 Flood Plains/Wetlands and Riparian Zones Minimally Affected Protections provided by: EO 11988, EO 11990, ROPs A-4, A-5, C-2, C-3 Native American Religious Concerns Not Present Protections provided by: American Indian Religious Freedom Act Recreation No Impact Protections provided by: ROPs A-1, A-4, A- 5, C-2, C-3, H-1, I-1 Public Health Minimally Impacted Protections provided by: ROP A-1, A-4 Sociocultural Systems Minimally Impacted Protections provided by: ROP H-1, I-1 Vegetation No Impact Protections provided by: ROP C-2 Visual Resource Management No Impact Protections provided by: ROPs A-1, A-4, A- 5, C-2, C-3 Wild & Scenic Rivers Not Present Protections provided by: Wild and Scenic Rivers Act Wilderness Not Present Protections provided by: Federal Land Policy and Management Act, Wilderness Act Threatened & Endangered Species (T&E) Eiders Potentially Affected Protections provided by: Section 7 of the Endangered Species Act (ESA) (J), ROP A-4, A-5, C-1, E-9 Polar Bears Potentially Affected Protections provided by: Section 7 of the ESA (J), ROP A-4, A-5, C-1, E-9 Fish Not Present Protections provided by: Magnuson- Stevens Act, ROPs A-3, A-4, A-5, B-1, B-2, C- 2, C-3, C-4 non-T&E birds Minimally Impacted Protections provided by: EO 131186, ROPs A-2a, A-4, A-5, C-2, E-9, E-10 non-T&E mammals Minimally Impacted Protections provided by ROPs: A-2a, A-4, A- 5, C-1 1Explanation of Determinations (USDOI BLM, 2008) Potentially Affected: The proposed action or alternative could result in potential impacts to resource or issues to the level that additional mitigation may be required, or there is a need to evaluate potentially significant issues. Minimally Impacted: Resources or issues would not be affected to a degree requiring further analysis because either the expected impacts from the proposed action and alternative would be minimal, or standard protections (e.g., ROPs and Stipulations from overriding BLM plans or other legal protections) would reduce impacts. Minimally impacted resources or issues will not be analyzed further in this EA. Not Present: Resources or issues are not expected to be affected by the proposed action or alternatives because activities would occur at a different time or place. Resource or issues not present will not be analyzed further in the EA. 1.7 Summary This chapter has presented the purpose and need of the proposed project, as well as the relevant issues, i.e., those elements of the human environment that could be affected by the implementation of the proposed action: • Cultural and paleontological resources • Subsistence • Environmental justice • Wastes (hazardous and solid) • Threatened & Endangered species o Eiders o Polar bears In order to meet the purpose and need of the proposed action in a way that resolves the issues, the USAF has considered alternatives. The action and no action alternatives are presented in Chapter 2. The potential environmental impacts or consequences resulting from the implementation of each alternative are then analyzed in Chapter 4 for each of the identified issues. 2 ALTERNATIVES INCLUDING THE NO ACTION 2.1 Introduction This chapter both describes the alternatives (potential actions) and compares the alternatives in terms of their environmental impacts and their achievement of objectives. 2.2 Description of the Alternatives 2.2.1 Alternative A: No Action Under the No Action Alternative, contaminated soil would remain on site—negatively impacting human health and the environment, further creating navigational hazards and environmental liabilities. Ongoing responses/repairs would likely be needed in order to maintain compliance with state and federal regulations, resulting in increased costs to the USAF. Risks to human health and the environment would remain because exposure routes to contaminants would still exist, resulting in damaging effects to subsistence resources. Unnecessary buildings and related structures would not be demolished and disposed and surface debris would remain and terms of BLM ROW grant stipulations would not be met. This alternative does not meet the project need of disposing or treating contaminated soil and surface water in order to prevent contamination from entering the environment, however inclusion of the No Action Alternative is required by the NEPA. The No Action Alternative is not protective of human health and the environment, does not meet cleanup objectives, and would not remove potential risks to the community. 2.2.2 Alternative B: Proposed Action The purpose of the proposed action is for building demolition, debris removal, and remedial actioncleanup. The need for the action is to remove wastes and materials in accordance with BLM ROW grant stipulations and to protect human health and the environment from exposure to contaminants; particularly Stipulation 5 – All trash and debris associated with operations under this grant must be removed to an approved solid waste disposal site. This project has several aspects including removal and off-site disposal of PCBs and xylene contaminated soils, and demolition and disposal of tanks, antenna structures, buildings, miscellaneous debris, and utility lines and poles. A 2007 RI conducted by the USAF found petroleum hydrocarbon contamination present in the soil and subsurface water (pore water) throughout most of the Air Terminal Area, located north of the main installation on the western shore of North Salt Lagoon. A FS for the Air Terminal Area and the Vehicle Maintenance Facility, including the Vehicle Fueling Station Area, the Radome Area, and the Transformer Stand Area, was completed in April 2010 based on results obtained during the 2007 RI and the Vehicle Maintenance Facility Remedial Action and Site Characterization. The USAF has conducted studies at the Point Barrow LRRS under the ERP to identify, quantify, and remedy problems associated with past and current management of hazardous substances and hazardous waste at USAF facilities. According to the 2011 Winter Work Plan for Environmental Restoration and Demolition Activities at Point Barrow LRRS prepared by SIKU Construction, LLC dated December 10, 2010; the Statement of Work for Environmental Restoration and Demolition Activities at Point Barrow LRRS, FA8903-10-C-8121 dated September 14, 2010; and the 2010 Final Proposed Plan for Two ERP Sites at Point Barrow LRRS, the USAF proposes to conduct the following activities described below. 2.2.3 Remedial Action-Cleanup The USAF proposes excavation and off-site disposal of xylene and PCB contaminated soils to meet ADEC Method Two clean up levels at ERP Site SS002 which include the Radome Area, Transformer Stand Area, Vehicle Maintenance Facility, and Vehicle Fueling Station Area. Institutional controls, natural attenuation and long-term monitoring are proposed at the Air Terminal Area, ERP Site SS003. 2.2.3.1 Radome Area The Radome Area, located below the radome at the west end of Module Train A, encompasses the gravel pad in the vicinity of the stairs. The area has an estimated 25 cy of soil exceeding ADEC cleanup level for PCBs. PCBs are a CERCLA Hazardous Substance and are also regulated by the ADEC. The horizontal extent of soil with PCBs above Method Two cleanup levels is 440 square feet (sf) although the lateral extent of contamination is likely larger based on recurring flooding and human activity in the area which serves to disperse the fine grained soil. Soil with contaminants above health-based cleanup levels would be excavated and placed in Super Sacks that would be temporarily staged on the south side of the Hangar until such time the contaminated soils would be loaded onto barges and shipped to the approved Waste Management Facility in Arlington, Oregon for disposal. The excavated area would be backfilled with clean soil. 2.2.3.2 Transformer Stand Area The Transformer Stand Area is located adjacent to the south side of Module Train B, west of the catwalk connecting the two module trains. Two transformers are situated on a raised wooded platform. The area has an estimated 16 cy of soil exceeding ADEC cleanup level for PCBs. The estimated horizontal extent of soil with PCBs above Method Two cleanup levels is approximately 274 sf. However, the total volume may be greater due to the fine-grained soils below the transformer stand which are susceptible to dispersion from foot traffic and seasonal runoff. Soil with contaminants above health-based cleanup levels would be excavated and placed in Super Sacks that would be temporarily staged on the south side of the Hangar until such time the contaminated soils would be loaded onto barges and shipped to the approved Waste Management Facility in Arlington, Oregon for disposal. The excavated area would be backfilled with clean soil. 2.2.3.3 Vehicle Maintenance Facility The Vehicle Maintenance Facility (also referred to as the Garage), located west of Module Train A, is an approximately 90-foot by 40-foot building elevated about three feet above the tundra and surrounded by a gravel pad on the north, south, and east sides. The building is used for vehicle maintenance and storage. Floor drains in the building discharged directly onto the tundra beneath the structure. The discharge may have included vehicle maintenance waste. The flood drains were sealed by the USAF in July 1993 to prevent possible future releases of contaminants. During the summer of 2006 a total of 63.1 tons of PCB contaminated soil was excavated to permafrost from the area adjacent to the west end of the garage, placed in Super Sacks, stockpiled in the hangar, and barged offsite during 2007 to the lower 48 for disposal. The excavation was covered with geofabric and covered with clean fill. A berm was constructed to prevent further migration of contamination from under the garage building. Confirmation sampling showed that PCBs remain on the southern portion of the excavation with concentrations exceeding the ADEC cleanup level. PCB contaminated soil estimated volume is approximately 178 cy which includes both the gravel pad and tundra surrounding the garage building. Soil with contaminants above health-based cleanup levels would be excavated and placed in Super Sacks that would be temporarily staged on the south side of the Hangar until such time the contaminated soils would be loaded onto barges and shipped to the approved Waste Management Facility in Arlington, Oregon for disposal. Areas of the tundra that have known contamination would be removed as part of this cleanup action. The excavated area would be backfilled with clean soil. Additional characterization would be required to ensure complete removal of the PCB contaminated soil. PCB contamination located directly beneath the garage building will not be removed at this time. This contamination would be documented in the USAF and BLM property records to ensure that intrusive activities would not be permitted in this area. Signage would be installed and maintained to alert people to the contamination beneath the building. Skirting such as chain link fencing would be installed along the foundation of the building and maintained to prevent human and animal contact with contaminated soil beneath the building. 2.2.3.4 Vehicle Fueling Station Area The Vehicle Fueling Station is a former gasoline fueling station that consists of a gravel bermed containment area surrounded by tundra and a gravel pad/access road to the west. The area has an estimated 70 cy of soil exceeding the ADEC cleanup levels for xylenes resulting from minor, historic gasoline spills associated with vehicle fueling activities. Soil with contaminants above health-based cleanup levels would be excavated, placed in Super Sacks that would be temporarily staged on the south side of the Hangar until such time the contaminated soils would be loaded onto barges and shipped to the approved Waste Management Facility in Arlington, Oregon for disposal. The excavated area would be backfilled with clean soil. Remaining wooden and metal supports within the lined gravel containment area would be removed. 2.2.3.5 Air Terminal Area The Air Terminal Area (ERP Site SS003) is located north of the main installation on the western shore of the North Salt Lagoon. A road along to the west edge of the area connects the Air Terminal Area to the main installation located to the south. The area extends from just north of the hangar building, south to the curve in the main installation road, east to the North Salt Lagoon, and west to the boundary between USAF and NARL properties that generally follows the main area access road. The Air Terminal Area is made up of gravel pads and access roads, tundra, and ponded water. Activities at the NARL area adjacent to the Air Terminal Area are believed to have contributed to contaminants found in the area. The Air Terminal Area has surface water adjacent to the Navy property border with total BTEX above cleanup levels. All or most of the contamination on the USAF property is believed to be due to migration from upgradient sources located on Navy property. Because the USAF cannot address the source of the contamination at this site, most treatment options are not likely to be effective until the contaminant source is treated as well. Therefore, the USAF proposes natural attenuation with longterm monitoring. The components would include the following: • Placement of signs at the site to notify people where surface water contamination is at concentrations above cleanup levels protective of human health. • Placement of notice on property records to inform current and future property owners of the presence of surface water contamination. Restrictive covenants would also be put in place to prevent the use of contaminated water. • Allow natural processes to break down contaminants in surface water. • Perform surface water monitoring by collecting samples each year for five years, and then every five years thereafter to assess changes in surface water contaminant concentrations over time. Site inspections would also occur at the same frequency as the sampling to inspect signs and maintain them as needed. Monitoring would be performed until the source contamination has been cleaned up and surface water sample results show that contaminants are below cleanup levels. 2.2.4 Building Demolition/Debris Removal Air Terminal Area Activities 2.2.4.1 Remaining Jet Fuel Tanks and Stand Remaining tanks 4, 5, 6, 7, 8, 9, and 10 would be transported to the UIC gravel pit (located approximately 1,500 feet south of the NSB landfill and approximately 9 miles from the Point Barrow LRRS accessed via NSB maintained roads) and staged for demolition activities. Tanks 4 through 9 are each 18,300-gal tanks while tank 10 has a 23,000-gal capacity. Tanks would be inspected for any loose paint that could fall off during transport. If present, the area would be covered with visqueen and the perimeter duct taped. Plastic and tape would be removed once tanks are set on geotextile fabric at demolition area. Tanks would be lifted out of the berm area with crane or loader and the tank bottom visually inspected for presence of lead-based paint. If none present, tanks would be towed to UIC gravel pit using loaders rigged to the front and back of the tank. If lead paint is present on bottom of tank, the tank would be loaded onto a trailer and hauled to the UIC gravel pit and stored until spring. Tanks staged at the UIC gravel pit would be cut into pieces approved for burial by the NSB. Tanks would be disposed of in the NSB landfill located adjacent to the UIC gravel pit. Soil confirmation sampling would be performed following tank removals. Soil will be excavated, placed in Super Sacks that would be temporarily staged on the south side of the Hangar until such time the contaminated soils would be loaded onto barges and shipped to the approved Waste Management Facility in Arlington, Oregon for disposal. The geotextile liner will be removed and disposed at the landfill and the berm will be collapsed and graded. 2.2.4.2 Float Plane Fuel Dock The fuel tank would be removed from the stand using a telehandler forklift. The stand framework would be cut in pieces acceptable to NSB landfill using hand tools. Remaining piling would be removed using a steam generator unit mounted to a skid trailer which is towed by dozer. The loader would be attached to the above ground portion of piling and pulled from thawed ground. Holes would be backfilled using clean native soils hauled to location from the UIC gravel pit. Demolition debris would be loaded into approximately two dump trucks and hauled to the NSB landfill for disposal. 2.2.4.3 Storage Yard Debris Miscellaneous debris present on the gravel pad during the 2007 investigation included abandoned tanks, tubing, metal piping, and wooden dunnage. Debris not requiring excess snow removal efforts and easily accessible would be removed using loader and forklifts, loaded into dump trucks, and hauled to the NSB landfill for disposal. Remaining items would be removed in the summer 2011. 2.2.4.4 Transmission Line/Utility Poles Transmission line/utility poles would be accessed by constructing a temporary heavy equipment snow and ice trail along the utility poles from the Air Terminal to the Camp area. The ice trail would be graded using a grader and dozer. Depressions would be filled with snow and water slurry using a loader and insulated water truck. The grading and filling process would be repeated until trail is adequate for heavy equipment. The local electric utility would verify all utility cables are abandoned and de-energized. All cabling/wires would be disconnected and dismantled from poles using qualified personnel in a forklift with a man basket and dropped to the ground. Sections of utility line would be cut into pieces, consolidated and loaded into dump trucks using a loader and forklift, and hauled in approximately six dumptruck loads to the NSB landfill for disposal. Utility poles would be cut down at three to four feet above ground surface using a chainsaw and the remainder of the poles would be removed using steam to thaw ground, and pulled from ground using loader. Poles and related debris would be consolidated, loaded and hauled in approximately seven dump truck loads to the NSB landfill for disposal. Holes would be backfilled using clean native soils hauled from the UIC gravel pit. 2.2.4.5 Air Terminal Building The Air Terminal Building would be demolished in the spring. All asbestos containing material (ACM), loose/flaking lead/PCB paint, and regulated/hazardous waste present in the building would be removed. The types and quantities of ACM that would need to be abated from the Air Terminal Building prior to demolition include: a) ACM flooring – 402 sf b) Covebase with brown mastic - 88 linear feet (lf) c) Cement wall board – 1, 1,116 sf d) Exhaust stack insulation – 15’ diameter x 11’ long e) Gray coating on exterior metal siding and roof – Building approximately 2,747 sf ACM would be removed and loaded into containers for shipment to lower 48 disposal sites. Demolition of the remaining structure would include steaming existing pilings for removal with a similar process utilized for utility pole removal described above. All remaining debris generated from the building demolition process would be disposed of at the NSB landfill. 2.2.4.6 Marston Matting Hazards Pieces of metal Marston matting (perforated steel matting material) located directly north of the hangar protrude above the ground surface and create a hazard. Protruding pieces would be removed and disposed of at the NSB landfill. 2.2.5 Building Demolition/Debris Removal Camp Area Activities 2.2.5.1 Remaining Diesel Storage Tanks The Diesel Storage Tanks Area is an inactive tank farm that consists of multiple above-ground storage tanks (ASTs) located within a lined and bermed gravel containment area. Some of the tanks have been relocated from other installation locations. Low levels of hydrocarbon contamination were detected during the 2007 investigation. There are no contaminants of concern (COCs) at this site, as no compounds exceeded ADEC Method Two soil cleanup levels for the Arctic Zone. The remaining storage tanks in the bermed area (1, 2, 28, 29, 12, 22, 23, 24, 25, 26, 27 and 30) would be transported to the UIC gravel pit and staged for demolition activities. Tanks less than 6,000 gal would be loaded into a dump truck and hauled directly to the NSB Landfill for disposal. Tanks staged at the UIC gravel pit would be cut into pieces acceptable for burial by the NSB and disposed of at the NSB landfill, located adjacent to the UIC gravel pit. The tank cutting area would be prepared by surrounding the tank with geotextile fabric preventing contamination due to cutting activities. Tank pieces cut to acceptable NSB landfill parameters would be lifted from the tank cutting area and transported directly into a dump truck and hauled to the NSB landfill for disposal. When all tanks have been disposed of the tank cutting area geotextile fabric liner and debris would be loaded into a dump truck and disposed of in the NSB landfill. Soil confirmation sampling would be conducted following tank removals. Soil will be excavated, placed in Super Sacks that would be temporarily staged on the south side of the Hangar until such time the contaminated soils would be loaded onto barges and shipped to the approved Waste Management Facility in Arlington, Oregon for disposal. The berm will be collapsed and graded. 2.2.5.2 Antenna and Support Structures Antennas and support structures would be dismantled into pieces acceptable to NSB landfill using a 50- ton hydraulic crane and qualified workers. Dismantled sections of the tower would be loaded onto tractor trailers and into dump trucks using the crane, loaders and forklifts. Foundation pilings would be removed using steam to thaw frozen ground. Holes left from piling removal would be backfilled with clean native soils. Clean frozen native soils would be hauled from UIC gravel pit. Holes would be shovel filled with slight mounds to compensate for subsidence caused by ground thaw in the spring. Haul would be conducted using approximately 8 dump truck loads and 12 trailer loads. 2.2.5.3 Liquid Fueling Pump Station Tanks/Circulation Pumps Liquid fuel pump station tanks and circulation pumps would be prepared for demolition by removing ACM which would be loaded into containers for shipment to approved lower 48 disposal sites. Remaining wooden supports in a gravel containment area would be removed using the same process described below for utility poles in section 2.2.5.4. 2.2.5.4 Gas Meter Facility The Gas Meter Facility consists of a 64 sf metal building with a concrete floor located on skids. The contractor would ensure gas mains are not pressurized. The metal structure, concrete slab, and skids would be dismantled into pieces acceptable to the NSB landfill, loaded into dump trucks and hauled to the landfill for disposal. If no action is taken then the wastes and materials would remain in the land and waters at the site near Point Barrow. These would continue to pose a risk to human health and the environment, and the risk would increase over time. The proposed action would allow the USAF to remove the debris and contamination which would result in a beneficial effect to the environment. 2.2.6 Schedule The USAF proposes to accomplish the scope of activities by conducting all heavy equipment use in sensitive tundra area during winter season 2011 and completing the remaining work through the spring and summer of 2011. • Late February – demolish fuel station and dock area and remove utility poles • Early April – demolish antenna towers and remove tanks from camp and air terminal areas • Mid April – abate air terminal ACM • Early May – demolish air terminal • Mid May – remove air terminal area debris • Early July – excavate, treat, or dispose of contaminated soils • Late August – mobilize barge service • Early August – load barge • Mid August – dispose of regulated waste • Late September – secure disposal certificates 2.3 Description of Options Considered but Eliminated from Detailed Study The USAF evaluated cleanup options for CERLCA contaminants to address contamination at five Point Barrow LRRS areas. The cleanup options were evaluated against nine criteria to compare the alternative and select the preferred cleanup option. The first two criteria, “overall protection of human health and the environment” and “compliance with regulations” were threshold criteria that must be met in order for a cleanup option or alternative to be considered. The remaining seven criteria are described in the 2010 FS study. The opions considered are shown in Table 2-1 below: Table 2-1 Options Considered by Location Description of Option Options Evaluated at Point Barrow LRRS Areas Vehicle Fueling Station Area (xylenes in soil) Radome & Transformer Sand Areas (PCBs in soil) Vehcile Maintenance Facility Area (PCBs in soil) Air Terminal Area (BTEX in surface water) Institutional Controls, Engineering Controls, & Natural Attenuation with Long-term Monitoring va Institutional Controls, Capping, and Long-term Monitoring v v Excavation, On-Site Treatment, and On-Site Disposal v v Excavation, Off-Site Treatment, and Disposal v Excavation, Ex-Situ Treatment, and Disposal va Ex-Situ Treatment va In-Situ Treatment va va v- Option evaluated to address contamination at the area a - Option evaluated as non-CERCLA action regulated by ADEC Following are the reasons for not selecting the above options at each area: 2.3.1 Vehicle Fueling Station Area Because of the depth of the contamination (extends to permafrost) combined with the cold climate and frozen soil conditions for much of the year at Point Barrow, the Natural Attenuation and In-Situ Treatment options would take an extraordinarily long time to reach cleanup goals. The Ex-Situ Treatment (land farming) was not selected because of concern about the amount of space that would be needed to spread soil to a depth of 12-24 inches, and the increased risk of short-term exposure of the contaminated soil to residents, workers, and wildlife. 2.3.2 Radome Area and Transformer Stand Areas The Capping option does not meet cleanup objectives for these areas. The On-Site Treatment option (soil washing) involves large quantities of chemicals that must be transported and stored on-site, generates a large amount of contaminated waste after the chemicals have been used for treatment and is not cost effective. The Off-Site Treatment option (incineration) is not easy to implement due to the difficulty of finding a permitted disposal facility that can properly incinerate PCB contaminated soil. 2.3.3 Vehicle Maintenance Facility Area The Capping option does not meet cleanup objectives for this area. The On-Site Treatment option (soil washing) involves large quantities of chemicals that must be transported and stored on-site, generates a large amount of contaminated waste after the chemicals have been used for treatment, and is not cost effective. 2.3.4 Air Terminal Area Without addressing the contamination source, both the In-Situ and Ex-Situ Treatment options would take an extraordinarily long time to reduce contaminant concentrations at the Air Terminal Area. These options would also become extremely expensive as they continued over a long period of time. 3 AFFECTED ENVIRONMENT Environmental characteristics of the general project area have been extensively described in the 2003 NW NPR-A IAP/EIS (Vol. 1, Chapter 3), to which this analysis is tiered, with some site-specific features described below. Based on the proposed project and the issues analysis in Section 1.6, the following discussion of the affected environment covers 1) Cultural Paleontological Resources, 2) Subsistence, 3) Environmental Justice, 4) Wastes, Hazardous and Solid, and 5) Threatened and Endangered Species-Polar Bear and Eiders. The affected environment for the area of the proposed action is discussed in greater detail in the following documents: • Record of Decision, Northwest National Petroleum Reserve-Alaska, Integrated Activity Plan/Environmental Impact Statement, January 22, 2004; • Biological Opinion for Bureau of Land Management for the Northern Planning Areas of the National Petroleum Reserve-Alaska, July 2008; and • USAF Integrated Natural Resources Management Plan and Appendices, Alaska Radar System, Alaska, Short and Long Range Radar Sites, 2007. 3.1 Cultural Resources 3.1.1 Archaeological Resources: About 400 cultural resource sites have been identified within the Northwest NPR-A. Multiple archeological and ethnographic/land use surveys have been conducted on, and around, Point Barrow. Several archeological sites have been documented for the village of Barrow and the Pt. Barrow LRRS area. According to the Integrated Cultural Resources Management Plan Distant Early Warning (DEW) System, Alaska (USAF, 2006), four different archeological and ethnographic/land use surveys have been conducted at the installation and adjacent areas. Surveys began in 1959, with the most recent being in 2000. The surveys concluded that there are no known sites within installation boundaries, but there are several recorded sites within a 5-mile radius. The Birnik site is located northeast of North Salt Lagoon. The site was discovered by the Stefansson-Anderson expedition of 1912 and was subsequently excavated in 1959. It consists of 16 mounds with artifacts dating to approximately A.D. 500. There is a late prehistoric/historic site on Brant Point consisting of a sod House ruin, several graves, and other features. There are also several sites in Browerville and Barrow including a complex of prehistoric mounds, a historic period Eskimo settlement, a trading/whaling post, and two multiple burial sites. 3.1.2 Historic Cold War Resources The Point Barrow DEW station (BAR-041) has been recommended as eligible for listing on the National Register of Historic Places (NRHP) as an element of the DEW System. The entire DEW System has been determined eligible for listing on the NRHP under Criterion A and Criteria Consideration G for its association with events important in the history of the Cold War and the history of the development of the state of Alaska according to the Final Historic building Inventory and Evaluation for DEW System (USAF, 1999). There are eight recorded buildings and/or structures at Point Barrow, all of which were constructed during the DEW period of significance (1953-1969). DEW System facilities include two 25- module building trains connected with overhead bridges and equipped with rotating radar and support buildings (BAR-00048), a vehicle maintenance shop (BAR-00050), an air freight terminal (BAR-00051), a supply and equipment warehouse (BAR-00047), a gas meter facility (BAR-00051), and a fuel pump station (XBP-00052). In addition to the extant facilities, the Point Barrow LRRS road system (BAR-00053) and gravel pad system (BAR-00054) are still intact. All extant DEW buildings/structures at Point Barrow are considered eligible for nomination to the NRHP as part of the DEW System. A 1996 MOA addressed the conversion of Point Barrow from manned to MAR site. In accordance with the MOA, the DEW System buildings and structures at Point Barrow were to be documented to Historic American Buildings Survey (HABS) Level 1 requirements. The proposed undertaking was later determined to have no adverse effect on the extant buildings/structures and the documentation never occurred (USAF, 2000). When installations of the DEW System were inventoried and evaluated in the Final Historic Building Inventory and Evaluation for Distant Early Warning (DEW) System, the report recommended no further documentation for Point Barrow buildings/structures (USAF, 1999). The report reasoned that there were two DEW System “main stations” constructed in Alaska (Point Barrow and Barter Island) and that DEW System “main stations” are nearly identical in layout and construction. Since Barter Island has been documented to HABS Level 1 requirements, no further documentation was recommended for Point Barrow. A 2005 MOA between the USAF and the Alaska State Historic Preservation Officer (SHPO) mitigates the adverse effects of environmental restoration and demolition activities on DEW System facilities including Point Barrow, satisfying the requirements of taking into account the effects of the Clean Sweep Environmental Restoration of former DEW sites on historic properties and compliance with Section 106 of the NHPA 3.2 Subsistence Subsistence can be defined as “hunting, fishing, and gathering for the primary purpose of acquiring traditional food” (USDOI BLM, 2003). Subsistence activities are a culture base and provide a sense of identity to the Inupiat people. Subsistence resources supply not only nutritional value, but are also used for clothing, tools, and transportation. Cultural and family ties are preserved through obtaining, sharing, and bartering such resources (USDOI BLM, 2003). There is a wide range of species hunted throughout the year in the NPR-A region for local subsistence purposes. These include whale, seal, walrus, bear, birds, caribou, furbearers, small mammals, and fish. Species such as seals, polar bears, and caribou are hunted throughout the entire year in the Barrow area. Fresh and salt-water fish, and small mammals are hunted or trapped in the late spring and summer months. Caribou, whales, walrus are typically hunted or fished in late summer and early fall. Berries and other flora are normally gathered in early to mid-fall. The Barrow area is located within the historical and/or current subsistence use area for the communities of Point Lay, Wainwright, and Barrow (USDOI BLM, 2003). The primary resources used for subsistence in the area include whales, caribou, walrus, fish, and waterfowl. Bowhead whale, caribou, walrus, and whitefish account for about 85 percent of Barrow’s annual subsistence harvest in terms of edible pounds (Braund and Associates, 2004). 3.3 Environmental Justice Environmental justice is an initiative that culminated with President Clinton’s 1994 EO 12898 “Federal Actions to Address Environmental Justice in Minority Populations and Low-Income Populations”. This executive order’s intent was to promote fair treatment to people of all races, so no person or group of people bears a disproportionate share of the negative environmental impacts from the country’s domestic and foreign programs. As documented in the 2003 BLM IAP/EIS, the Inupiat is recognized Alaska Native minorities group (the Barrow community consisting of 64% Alaska Native or part Native) and thus afforded protection relative to EO 12898. Scoping meetings held during the preparation of the 2003 BLM IAP/EIS identified several concerns that would be germane to this project: the need to protect subsistence areas, cleaning up contaminated sites, and preventing fish contamination from contaminated sites. 3.4 Wastes (Hazardous/Solid) There are no known landfills at the LRRS (USAF, 2007). All solid waste generated at the facility is transported to the Barrow community landfill, operated by the NSB. A variety of past uses at the state have resulted in environmental contamination. The USAF has investigated and remediated past sources of contamination through the ERP. Past activities potentially resulting in contaminant releases are as follows: • Transfer of fuels in and out of storage tanks; • Leaking of fuel lines, tanks, and drums; • Vehicle and equipment maintenance activities at the garage, hangar, and other areas; • Operation of facilities using PCB-containing transformers or other electrical equipment resulting in leaks or spills to the environment; and • Disposal of wastes with hazardous substances. The USAF conducted RI/FS in 1993 and 2007 to investigate locations that had potential for environmental contamination based on historical activities or use and to prepare for Clean Sweep Program activities. Soil, sediment, and water samples were collected at identified sites and analyzed for appropriate compounds based on the site conditions and suspected contaminants of concern. The sampling results were screened for ADEC Method Two cleanup levels for the Arctic Zone, which are protective of unrestricted site use, including residential site use. A brief description of the 2007 RI findings and recommendations are summarized below. As discussed in Section 2.2.3.5, the Air Terminal Area (or ERP Site SS003) encompasses the area between the main installation road and the North Salt Lagoon, and extends north to the hangar and south to the installation access road intersection. Petroleum hydrocarbon contamination is present in the soil and subsurface water throughout most of the site however the concentrations of petroleum hydrocarbons in the soil are weathered, lack volatiles, and are well below Method Two cleanup levels for the Arctic Zone over the entire site. Contaminant concentrations in the site soils and surface and active zone water do not indicate there is sufficient risk to human health or ecological receptors to warrant a cleanup action given current site uses. The RI recommended monitoring of petroleum hydrocarbon related compounds in surface water and pore water to document that natural attenuation is occurring and to determine when Alaska Water Quality Standards are no longer exceeded. Other areas of interest were investigated to determine whether or not COCs were present, and if additional investigation or cleanup action was warranted. The three areas recommended for further action or study were: the Vehicle Fueling Station, Radome Area, and Transformer Stand Area. The only soil COC is total xylenes found at the Vehicle Fueling Station. Based on exceedances of ADEC Method Two soil cleanup levels for the Arctic Zone and on cumulative risk calculations, the site poses low risk to human health and the environment. Method Two cleanup levels for the Arctic Zone are protective of surface water at this location due to the lack of surface water bodies and low potential for petroleum migration. No further investigation or cleanup under CERCLA is recommended for this site however, remedial action is warranted under 18 AAC 75 based on the ADEC Method Two soil cleanup level exceedances of total xylenes and the likelihood that the natural attenuation process would likely be slow, especially in the subsurface. PCB is a CERCLA contaminant with levels below Toxic Substances Control Act regulations at the Radome Area and the Transformer Stand Area that present a low risk to human health and the environment. However, cleanup action under state regulations would be necessary because PCBs at both locations exceed the ADEC Method Two cleanup levels for unrestricted site use. 3.5 Threatened and Endangered Species Threatened, endangered, and candidate species occurring in the project area are shown in Table 3-1 below. Table 3-1 Protected Species Occurring in Project Area Species Status Occurrence Bowhead whale Endangered Chukchi & Beaufort Seas Polar bear Threatened Barrow area Spectacled eider Threatened Barrow area Steller’s eider Threatened Barrow area Yellow-billed loon Candidate Arctic coastal plain Bearded seal Proposed Threatened Bering, Chukchi & Beaufort Seas Ringed seal Proposed Threatened Arctic Basin incl. Bering Sea Pacific walrus Petition to List as Threatened or Endangered Bering & Chukchi Seas (USFWS NOAA Fisheries, 2010) The endangered bowhead whale has been observed in the Chukchi and Beaufort Seas (USAF, 2007). The polar bear, spectacled eider, and Steller’s eider are listed threatened species and are known to occur in the Barrow area (USFWS NOAA Fisheries, 2010). The yellow-billed loon was listed as a candidate species in 2009 and has been observed on the Point Barrow LRRS during waterfowl surveys conducted in 2002 (Ritchie, et al., 2003). On December 3, 2010, the National Oceanic and Atmospheric Administraiton (NOAA) Fisheries announced a proposal to list the ringed seal and bearded seal as threatened (NOAA, 2010). Ringed seals are found in the Arctic Basin (including the Bering Sea) and throughout most of its range, the Arctic ringed seal does not come ashore. The bearded seal occurs in the Bering, Chukchi and Beaufort Seas where areas where seasonal sea ice occurs over relatively shallow waters. The Pacific walrus occurs in the continental shelf waters of the Bering and Chukchi seas and in low numbers in the Beaufort Sea. On September 10, 2009 the USFWS initiated a status review of the Pacific walrus to determine if listing was warranted (USFWS, 2009) however it is currently not listed. 3.5.1 Eiders Both the spectacled eider and Alaska-breeding population of the Steller's eider are listed as threatened under the federal ESA however the USFWS has not designated critical habitat on the North Slope for either species (USFWS, 2010). No Spectacled Eider nests have been located at Point Barrow LRRS during USFWS ground surveys since at least 1999 (USAF, 2007). No Steller’s eiders nests were recorded at Point Barrow during the three years of ground-based surveys conducted by ABR (1994, 2000, and 2002) (Schick, et al., 2004). 3.5.2 Polar Bears The polar bear was listed as a threatened species, range wide, under the Endangered Species Act in 2008. The Department of the Interior Fish and Wildlife Service announced its final designation of polar bear critical habitat on November 24, 2010. The critical habitat included in the final rule exempts the Point Barrow LRRS based on the USAF’s 2007 Integrated Natural Resource Management Plan which includes measures to protect polar bears occurring in habitats within or adjacent to the facility. Additionally, the Native community of Barrow was excluded from the final designation as well as all existing manmade structures (regardless of land ownership status) (USFWS, 2010). Polar bears have been seen using riverbanks and shore-fast ice for maternity dens during between October and April in areas throughout the NPR-A coastal region, primarily east of Barrow. The polar bear population which includes the Alaskan Beaufort Sea coast within its range dens primarily in the Arctic National Wildlife refuge. Radio tagged bears have denned within 40 miles of Barrow and Point Barrow LRRS. Polar bears have developed a habit of gathering at the butchering sites of bowhead whales that are harvested by local Natives during spring and autumn whaling seasons and sightings of polar bears are possible in the Barrow area. In Barrow, whales are hauled to the Marston-matting airstrip north of the LRRS where they are butchered (Davidson, 2007). Carcasses are then hauled to Point Barrow in an effort to keep polar bears out of the community. 4 ENVIRONMENTAL IMPACTS Because the proposed activities are not substantially different from those previously evaluated, and because no significant new scientific information or analyses have been developed since the most recent related evaluation (i.e., NW NPR-A IAP/EIS, November 2003), this NEPA analysis will focus on impacts due to the project-specific/site-specific differences of the proposed action. 4.1 Direct and Indirect Effects This EA is tiered from the following documents with a more in-depth discussion of potential effects: • Northwest National Petroleum Reserve-Alaska, Integrated Activity Plan/Environmental Impact Statement, 2003, Volume 2, Section 5; and • Biological Opinion for Bureau of Land Management for the Northern Planning Areas of the National Petroleum Reserve-Alaska, July 2008. Issues specifically identified in Section 1.6 for further analysis in this EA are discussed below. This section provides the evaluation of direct, indirect and cumulative environmental impacts of the Proposed Action. Impacts may be to society, the economy, or the environment. Any issues or concerns raised by the USAF and BLM are discussed below. If these resulted in any measures to mitigate the environmental impacts, those measures are also discussed in this section. Finally, any residual impacts to the environment, despite applications of mitigation measures are identified here. Clean Sweep activities generally have a positive effect on natural resources. However, care must be taken with timing of demolition and debris removal to not adversely affect wildlife. Site restoration strives to return the surroundings to its original state, contouring terrain and using native species for revegetation. 4.1.1 Cultural Resources 4.1.1.1 Alternative A: No Action Under the No Action Alternative, there would be no impacts to cultural and paleontological resources because no building demolition would occur. 4.1.1.2 Alternative B: Proposed Action The Proposed Action Alternative could result in disturbance to undiscovered archaeological sites encountered during soil excavation operations. Although no cultural resources are likely to be present at the site according to the USAF 2006 Integrated Cultural Resource Management Plan for Distant Early Warning (DEW) System, Alaska, all site employees will be oriented to the Cultural Resources Protection Plan prior to conducting work at the site. Site employees will be trained to identify and avoid any cultural resources encountered during the project activities. The Cultural Resources Protection Plan would outline the procedures to be followed in the event that cultural resources are discovered. Following these procedures will ensure that even if cultural resources are discovered, no significant impacts to cultural resources will occur as a result of this action. All extant DEW buildings/structures at Point Barrow are considered eligible for nomination to the NRHP as part of the DEW System. The USAF proposes to remove original material from historic properties determined eligible for the NRHP which constitutes an adverse effect. A 2005 MOA between the USAF and the Alaska SHPO mitigates the adverse effects of environmental restoration and demolition activities on DEW System facilities including Point Barrow, satisfying the requirements of taking into account the effects of the Clean Sweep Environmental Restoration of former DEW sites on historic properties and compliance with Section 106 of the NHPA (USAF, 2006). 4.1.2 Subsistence 4.1.2.1 Alternative A: No Action Under the No-Action Alternative, the USAF would not remediate the Point Barrow LRRS site and continued risk to human health and environment would remain from continued exposure of contaminants to subsistence resources. No activity would occur within the subsistence use areas for the communities of Barrow, therefore, no potential displacement of resources from the area would occur. 4.1.2.2 Alternative B: Proposed Action The Proposed Action Alternative over the long term will result in a positive effect to subsistence resources. Over the short term, the Proposed Action Alternative may temporarily impact furbearer and small mammal hunting and trapping due to the possibility of the temporary displacement of these animals during removal activities, including equipment noise and human presence in the immediate Point Barrow LRRS area and along the road to the staging areas and NSB landfill. To minimize noise and other disturbances, a maximum of five pieces of equipment would be operating at the site at any given time. Barge transportation is required for disposal of contaminated materials in August, which may affect some hunting or fishing activities. Any displacement or disruption in subsistence activities would be temporary. Although the work will occur during active fishing, hunting, and trapping seasons, the work should not have a significant effect on these activities because there are hunting, trapping, or fishing harvest periods which extend outside of the fieldwork season for every species listed. In order to ensure no further contamination is exposed or spread that could potentially impact subsistence hunting in the excavation areas or along the haul road, best practices for waste removal and transport, as outlined in the 2010 Point Barrow LRRS Work Plan would be followed (Siku, 2010). These include excavating to clean boundaries to ensure no contaminants are exposed which are not removed during the RA-C. Also, all contaminated soil would be placed in Super Sacks prior to transport to eliminate the possibility of a spill along the haul road. Solid metal waste would be transported in covered dump-truck loads. These measures would ensure that the impacts to subsistence hunting in the area would only be temporary noise/disturbance impacts during removal and transport activities, and that no additional impacts to the land or animals will occur. 4.1.3 Environmental Justice 4.1.3.1 Alternative A: No Action The No Action Alternative would not remedy contamination or cleanup debris however the continued exposure to local populations or subsistence resources is not disproportionate to minority, low income, or tribal populations. 4.1.3.2 Alternative B: Proposed Action The Proposed Action Alternative will have the following temporary negative effects including temporary noise to users of the site (however, not be audible to the village), temporary air quality impacts in the vicinity of the site, and temporary visual effects. The loss of potential use of the air terminal would negatively impact the community as local entities have expressed interest in using the building as an activity center in the future. These impacts would not be disproportionate to minority, low income or tribal populations. The removal of contamination and debris and potential increase in local employment during implementation would benefit all populations. All stakeholders, regardless of race, have been involved in the planning process. Their concerns have been addressed and minority, low income or tribal populations are not being asked to take on an unequal proportion of the environmental impacts of this action. In addition, the proposed action serves to remove contaminated soil, hazardous materials, and solid waste from the area instead of leaving it there to negatively impact the local population. 4.1.4 Wastes (Hazardous/Solid) 4.1.4.1 Alternative A: No Action The No Action Alternative would result in wastes and materials remaining in the land and waters and continue to pose a risk to human health and the environment. Current or future exposure to contaminated media consisting of surface soil and surface water would remain. 4.1.4.2 Alternative B: Proposed Action As described in Section 4.1.2.2 best practices for waste removal and transport would be followed (Siku, 2010). Confirmation sampling of excavated areas would be conducted. Tanks would be transported to the UIC gravel pit and staged for demolition. Tanks would be visually inspected for loose paint prior to transport to the staging area and if present, the perimeter area would be covered with visqueen and taped. Plastic would be removed once tanks are placed on geotextile fabric located at demolition area. During antenna and support structure demolition, the work area will be barricaded to protect workers, traffic, and pedestrians from overhead work hazards. Traffic impacts from debris and soil haul will be minimal. The USAF Project Manager would be notified of required traffic pattern changes and schedule two week priors to the start of work to minimize impacts to facility roads used year-round by NOAA, U.S. Geological Survey (USGS), and the U.S. Department of Energy for research activities. Beneficial impacts include improve wildlife habitat from reduced or eliminated exposure to contaminants, elimination of potential bird strikes and predator nesting by removal of vertical antenna structures, and removal of navigation hazards caused by miscellaneous debris. 4.1.5 Threatened and Endangered Species The USAF conducted informal consultation with the USFWS pursuant to section 7 of the ESA for the proposed cleanup activities at Point Barrow LRRS and the record is included in Appendix C. In their analysis the USFWS found the likelihood that Steller’s eiders would nest in the limited tundra habitat available in the project area to be very low and consequently, determined adverse effects to nesting Steller’s eiders would be discountable because they are extremely unlikely to occur. The USFWS also expect the removal of overhead transmission lines and utility poles would be beneficial to eiders by reducing collision risks to birds flying in or through the area, including breeding, postbreeding, and migrating eiders. In addition, annual surveys conducted in the vicinity of the Point Barrow LRRS indicate that spectacled eiders do not use the surrounding habitat, and the likelihood of disturbance to this species would be very low and that adverse effects would be discountable. Following the same logic presented for Steller’s eiders above, they determined effects to spectacled eiders to be discountable, insignificant, or beneficial. In regards to polar bears, the USFWS stated the following, “Given that 1) proposed work at Point Barrow LRRS will occur within the footprint of previously disturbed land, 2) polar bears are not known to regularly use the habitat immediately surrounding the project area, and 3) risks associated with polar bear encounters will be managed by following USAF and UIC human–polar bear interaction plans and safety training, we expect that effects to polar bears will be minimized to an extent that take will not occur. We therefore expect that adverse effects to polar bears will be insignificant and conclude that the proposed action is not likely to adversely affect polar bears.” In summary, the USFWS determined the proposed activities are not likely to affect listed eiders or polar bears. There is no designated critical habitat for listed eiders within the project area. Point Barrow LRRS is exempted from the polar bear critical habitat designation because the site is covered by an approved INRMP that provides a benefit to the species. 4.2 Cumulative Effects Cumulative impacts result from the incremental addition of past, present, and reasonably foreseeable actions. Each action may be individually minor by itself, but when added to others could become significant over a period of time. The 2003 Northwest NPR-A IAP/EIS, Volume 1, Section IV.F analyzing cumulative effects is incorporated by reference. Past, present and future impacts in the region include infrastructure use at the site and in the village of Barrow, oil and gas exploration, recreation and subsistence activities. The analysis concludes there would be minimal cumulative effects to resources identified and analyzed in this EA, as well as to other important issues and resources identified in the IAP/EIS. The time frame for the proposed action for the project area is from the 1950’s to thirty years into the future, assuming that the relatively low level of activity and management would remain at about the same level as present. Due to the limited scope and intensity of the proposed action, potential effects to the geographic area would be limited within one mile of the proposed use areas. Additional past, present, and future activities in the area include recreation, subsistence, research and monitoring. While the level of such activities may increase slightly within the next thirty years, there are no development proposals that would substantially add to the current levels. The incremental addition of the proposed action would be short-term and dispersed, which should not add to increased cumulative effects. The proposed action is not anticipated to result in increased incremental cumulative effects to the identified issues in this EA due to the remoteness of the portion of the area where the activity would occur and the low impact levels associated with the activity. The sites have been previously disturbed by human activity and the proposed action would result in decreased long-term impacts to subsistence, environmental justice, wastes (hazardous/solid), polar bears, and eiders. The proposed action could result in adverse cumulative effects to cultural sites because once these sites are disturbed or destroyed, their integrity is permanently lost. Nevertheless, much of the sites have been disturbed by decades of past human activities and the risk of damaging undiscovered archaeological sites is relatively small. The proposed action is not likely to adversely affect listed eiders or polar bears however; some combination of oil and gas exploration, subsistence activities, clean-up activities, and research and monitoring activities by scientists, industry, and agency personnel may cumulatively cause an incremental increase in disturbance to listed species. There would be no incremental increase in human activity with the no action alternative. The proposed action will likely improve habitat for listed species and other wildlife by removing contaminated materials from the area. 4.3 Mitigation and Monitoring 4.3.1 Mitigation Mitigation strategies generally include the following Best Management Practices (BMPs), which are presented in the preferred order for implementation, and were established in accordance with CEQ regulations. • Avoid the impact altogether by stopping or modifying the proposed action. • Minimize impacts by limiting the degree of magnitude of the action and its implementation. • Rectify the impact by repairing, rehabilitating, or restoring the affected environment. • Reduce or eliminate the impact over time through use of preservation and maintenance operations during the life of the action. • Compensate for the impact by replacing resources or providing substitute resources. This EA has determined that mitigation is not required to avoid or compensate for significant impacts. However, the USAF has indentified BMPs to minimize impacts to the environment and reduce health and safety risks. Additionally, the USAF follows standard construction BMPs (such as silt fencing and hay bales) to help minimize movement of materials from construction sites, and has a Spill Control and Countermeasures Plan in place to minimize the risks of spills and associated impacts. 4.3.1.1 Cultural Resources All operations would be conducted in such a manner as not to cause damage or disturbance to any historical or archaeological sites and artifacts. The Antiquities Act (1906), Archaeological Resources Protection Act (1979), Federal Land Policy and Management Act (1976), and general United States property laws and regulations, all prohibit the appropriation, excavation, injury, or destruction of any historic or prehistoric ruin or monument, or any other object of antiquity situated on lands owned or controlled by the United States (16 U.S.C. 470; 16 U.S.C. 432; 43 U.S. 1733(a); 18 U.S.C. 1361; 18 U.S.C. 641; 43 CFR 8365.1). Such items include both prehistoric stone tools and sites, refuse dumps, and other such features. In accordance with the 2005 MOA between the USAF and the Alaska SHPO, if a previously unknown historic or prehistoric property is encountered during the undertaking, all work that might adversely affect the property would cease until: a. The property is evaluated for eligibility for inclusion in the National Register in consultation with Alaska SHPO; and b. The agreed-upon mitigation measures have been completed. Consultation with the Alaska SHPO would be carried out in an expeditious manner to avoid unnecessary delays to the project. The Alaska SHPO may provide the USAF with initial comments by telephone and would follow up with a letter within 30 days of USAF’s request for comments. c. If needed, the USAF would consult with affected federally-recognized tribes pursuant to the Native American Graves and Repatriation Act. d. If the previously unknown historic property is determined to be of Native-American affiliation, the appropriate federally-recognized tribes would be consulted as per the terms of the MOA stipulation. 4.3.1.2 Wastes (Hazardous/Solid) A copy of the BMP’s developed specifically for the proposed action is provided in Appendix E and includes the following: • Material handling and waste management, • Sanitary and septic waste management, • Equipment/vehicle fueling and maintenance practices, • Spill prevention controls and countermeasures, • Training, • Preservation of existing vegetation, and • Threatened and endangered species protection. 4.3.1.3 Eiders A nesting survey will be completed by the USAF to ensure that there are no nesting of listed eiders has occurred within the project area. Should a nest be located within the project area, USFWS will be immediately notified and appropriate protection measures will be incorporated. 4.3.1.4 Polar Bears The USAF will manage risks associated with polar bear encounters by following USAF and UIC humanpolar bear interaction plans and safety training. A copy of the North Slope Operations Bear & Pacific Walrus Avoidance and Human Encounter/Interaction Plan (UIC, 2005) is provided in Appendix D. 4.3.2 Monitoring Surface water monitoring in the Air Terminal Area will be conducted by the USAF by collecting samples each year for five years, and then every five years thereafter to assess changes in surface water contaminant concentrations over time. Site inspections would also occur at the same frequency as the sampling to inspect signs and maintain them as needed. Monitoring would be performed until the source contamination has been cleaned up and surface water sample results show that contaminants are below cleanup levels. Compliance inspections shall take place during the period of the proposed activities to ensure all mitigation measures and required operating procedures are in compliance. 4.4 Summary of Environmental Consequences The proposed action is likely to result in no adverse impacts to only minor short-term adverse impacts to cultural and paleontological resources, subsistence activities, environmental justice, wastes (hazardous and solid), water resources, flood plans/wetlands and riparian zones and eiders as a listed threatened species. The proposed action will ultimately result in improving the overall quality of the area’s environment, prevent future releases of contamination, and protect human health and safety. 5 CONSULTATION AND COORDINATION 5.1 Agencies, Organization and Persons Consulted Public notification of this EA will be on file at the BLM Arctic Field Office and was posted on the BLM Arctic Field Office NEPA Register on January 11, 2011. A summary of the USAF’s public participation activities is provided in Section 1.6. USAF consulted with the Alaska SHPO and federally-recognized tribes regarding removal of historic properties at Point Barrow LRRS and signed a 2005 MOA with the SHPO in satisfaction of its NHPA Section 106 responsibilities. The USAF conducted informal consultation with the USFWS pursuant to section 7 of the ESA. The USFWS determined the proposed action not likely to adversely affect listed eiders or polar bears on January 21, 2011. A record of the consultation is included in Appendix C. 5.2 List of Preparers Lori Roy, Remedial Project Manager, USAF 611 Civil Engineering Squadron Matt Moran, Natural Resource Program Manager, USAF 611 Civil Engineering Squadron Bill Burke, Project Manager, AECOM Katrina Moss, NEPA/Permitting Specialist, AECOM 6 BIBLIOGRAPHY Braund and Associates. 2004. Traditional Land Use Survey Characterizations for Remote Air Force Facilities in Alaska. Anchorage : University of Alaska Anchorage, 2004. Davidson, F.L. 2007. Barrow Whale Hunt October 2007. 2007 Fall Whale Hunt. [Online] 2007. [Cited: October 7, 2010.] http://web.newsguy.com/floyd_davidson/whales2007/index.html. ICF Technology Inc. 1996. Final Remedial Investigation and Feasibility Study, Point Barrow RAdar Installation, Alaska. 1996. NOAA. 2010. NOAA Proposes Listing Ringed and Bearded Seals as Threatened Under Endangered Species Act . U.S. Departmemt of Commerce National Oceanic and Atmospheric Administration. [Online] December 3, 2010. [Cited: January 10, 2011.] NOAA Proposes Listing Ringed and Bearded Seals as Threatened Under Endangered Species Act . Ritchie, R.J., Schick, C.T. and Shook, J.E. 2003. Spectacled and Steller's Eiders Surveys and Habitat Mapping at Remote U.S. Air Force Sites in Northern Alaska, 2002. Fairbanks, AK : Prepared for U.S. Fish and Wildlife Service and U.S. Air Force by ABR, Inc. Environmental Research and Services, 2003. p. 46. Schick, C.T., Frost, G.V. and Ritchie, R.J. 2004. Spectacled and Steller's Eiders Surveys and Habitat Mappin gat U.S. Air Force Radar Sites in Northern Alaska, 2003. Fairbanks : ABR, In. Environmental Research & Services, 2004. Siku. 2010. 2011 Winter Work Plans for Environmental Restoration and Demolition Activities at Former NARL Facility and Point Barrow LRRS - Draft. Barrow, AK : Siku Construction, LLC, 2010. UIC. 2005. North Slope Operations Bear & Pacific Walrus Avoidance and Human Encounter/Interaction Plan. Barrow, AK : Ukpeagvik Inupiat Corporation, 2005. USAF. 2008. 2007 Remedial Investigatoin Report, Point Barrow Long Range Radar Station, Alaska. s.l. : July, 2008. —. 2010. Barrow Proposed Plan Meeting Minutes - Draft. s.l. : August, 2010. —. 2001. Clean Sweep Environmental Survey Report - Final for Point Barrow LRRS. s.l. : U.S. Air Force Environmental Restoration Program, 2001. —. 2000. Cultural Resources Management Plan, Distant Early Warning (DEW) System. Elmendorf AFB : U.S. Air Force 611th Civil Engineer Squadron, 2000. —. 2010. Final Feasibility Study, Point Barrow Long Range Radar Station, Alaska. s.l. : July, 2010. —. 1999. Final Historic Building Inventory and Evaluation for Distant Early Warning (DEW) System. Elmendorf AFB : U.S. Air Force 611 Civil Engineer Squadron, 1999. —. 2010. Final Proposed Plan for Two ERP Sites at Point Barrow LRRS, Point Barrow, Alaska. s.l. : July, 2010. —. 2006. Integrated Cultural Resources Management Plan Distant Early Warning (DEW) System, Alaska. Fort Collins, CO : Center for Environmental Management of Military Lands, 2006. —. 2007. Integrated Natural Resources Management Plan, Alaska Radar Sites, Alaska, Short and Long Range Radar Sites. Elmendorf AFB, AK : 611 ASG CES ASS, 2007. USDOI BLM. 2008. National Environmental Policy Act Handbook H-1970-1. Washington DC : BLM/WO, 2008. —. 2003. Northwest National Petroleum Researve-Alaska Integrated Activity Plan/Environmental Impact Statement. Anchorage : U.S. Department of the Interior, 2003. —. 2004. Record of Decision, Northwest National Petroleum Researve-Alaska Integrated Activity Plan/Environmental Impact Statement. s.l. : U.S. Department of the Interior, Bureau of Land Management, 2004. USFWS. 2010. Designation of Critical Habitat for Spectacled Eiders and Steller's Eiders. Alaska Region - Fish & Ecological Services. [Online] 2010. [Cited: 11 17, 2010.] http://alaska.fws.gov/fisheries/endangered/SpSt_FinalDesignation.htm. USFWS NOAA Fisheries. 2010. Endangered, Threatened, Proposed, Candidate, and Delisted Species in Alaska. Endangered, Threatened and Candidate Species in Alaska. [Online] November 24, 2010. [Cited: January 10, 2011.] http://alaska.fws.gov/fisheries/endangered/pdf/consultation_guide/4_Species_List.pdf. USFWS. 2010. Polar Bear Critical Habitat. Alaska Fish and Wildlife Service. [Online] 11 2010. [Cited: 12 7, 2010.] http://alaska.fws.gov/fisheries/mmm/polarbear/pdf/critical_habitat_factsheet_11_2010.pdf. —. 2009. Walrus and the Endangered Species Act - 90-day Finding. U.S. Fish and Wildlife Marine Mammals Management. [Online] September 15, 2009. [Cited: January 10, 2011.] http://alaska.fws.gov/fisheries/mmm/walrus/esa.htm. APPENDICES Appendix A – Figures Appendix B – NW IAP/EIS ROD Required Operating Procedures Required Operating Procedures A. Waste Prevention, Handling, Disposal; Spills, and Public Safety A-1 Required Operating Procedure Objective: Protect the health and safety of oil field workers and the general public by avoiding the disposal of solid waste and garbage near areas of human activity. Requirements/Standard: Areas of operation shall be left clean of all debris. A-2 Required Operating Procedure Objective: Minimize impacts on the environment from non-hazardous waste generation. Encourage continuous environmental improvement. Protect the health and safety of oil field workers and the general public. Avoid human-caused changes to predator populations. Requirement/Standard: Lessees/permittees shall prepare and implement a comprehensive waste management plan for all phases of exploration and development, including seismic activities. Management decisions affecting waste generation shall be addressed in the following order of priority: 1) prevention and reduction, 2) recycling, 3) treatment, and 4) disposal. The plan shall be submitted to the AO for approval, in consultation with Federal, State and North Slope Borough regulatory and resource agencies, as appropriate (based on agency legal authority and jurisdictional responsibility), as part of a plan of operations or other similar permit application. The plan shall consider and take into account the following requirements: a) Methods to avoid attracting wildlife to food and garbage: All feasible precautions shall be taken to avoid attracting wildlife to food and garbage. (A current list of approved precautions, specific to type of permitted use, can be obtained from the AO.) b) Disposal of putrescible waste: Current requirements prohibit the burial of garbage. Lessees and permitted users shall have a written procedure to ensure that the handling and disposal of putrescible waste will be accomplished in a manner that prevents the attraction of wildlife. All putrescible waste shall be incinerated, backhauled, or composted in a manner approved by the AO. All solid waste, including incinerator ash, shall be disposed of in an approved waste-disposal facility in accordance with U.S. Environmental Protection Agency (EPA) and Alaska Department of Environmental Conservation (ADEC) regulations and procedures. The burial of human waste is prohibited except as authorized by the AO. c) Disposal of pumpable waste products: Except as specifically provided, BLM requires all pumpable solid, liquid, and sludge waste be disposed of by injection in accordance with EPA, ADEC, and the Alaska Oil and Gas Conservation Commission regulations and procedures. On-pad temporary muds and cuttings storage, as approved by ADEC, will be allowed as necessary to facilitate annular injection and/or backhaul operations. d) Disposal of wastewater and domestic wastewater: BLM y prohibits wastewater discharges or disposal of domestic wastewater into bodies of fresh, estuarine, and marine water, including wetlands, unless authorized by the National Pollution Discharge Elimination System (NPDES) or State permit. A-3 Required Operating Procedure Objective: Minimize pollution through effective hazardous-materials contingency planning. Requirement/Standard: For oil- and gas-related activities, a Hazardous-Materials Emergency- Contingency Plan shall be prepared and implemented before transportation, storage, or use of fuel or hazardous substances. The plan shall include a set of procedures to ensure prompt response, notification, and cleanup in the event of a hazardous substance spill or threat of a release. Procedures applicable to fuel and hazardous substances handling (associated with transportation vehicles) may consist of Best Management Practices if approved by the AO. The plan shall include a list of resources available for response (e.g., heavy-equipment operators, spill-cleanup materials or companies), and names and phone numbers of Federal, State, and NSB contacts. Other Federal and Stipulations and Required Operating Procedures Appendix B-3 Northwest NPR-A Integrated Activity Plan/Environmental Impact Statement State regulations may apply and require additional planning requirements. All staff shall be instructed regarding these procedures. A-4 Required Operating Procedure Objective: Minimize the impact of contaminants on fish, wildlife, and the environment, including wetlands, marshes and marine waters, as a result of fuel, crude oil and other liquid chemical spills. Protect subsistence resources and activities. Protect public health and safety. Requirement/Standard: Before initiating any oil and gas or related activity or operation, including field research/surveys and/or seismic operations, lessees/permittees shall develop a comprehensive spill prevention and response contingency plan per 40 CFR 112 (OPA). The plan shall consider and take into account the following requirements: a) On-site clean-up materials. Sufficient oil-spill-cleanup materials (absorbents, containment devices, etc.) shall be stored at all fueling points and vehicle-maintenance areas and shall be carried by field crews on all overland moves, seismic work trains, and similar overland moves by heavy equipment. b) Storage Containers. Fuel and other petroleum products and other liquid chemicals shall be stored in proper containers at approved locations. Except during overland moves and seismic operations, fuel, other petroleum products, and other liquid chemicals designated by the AO in excess of 1,320 gallons in storage capacity, shall be stored within an impermeable lined and diked area or within approved alternate storage containers such as overpacks, capable of containing 110 percent of the stored volume. c) Liner Materials. Liner material shall be compatible with the stored product and capable of remaining impermeable during typical weather extremes expected throughout the storage period. d) Permanent Fueling Stations. Permanent fueling stations shall be lined or have impermeable protection to prevent fuel migration to the environment from overfills and spills. e) Proper Identification of Containers. All fuel containers, including barrels and propane tanks, shall be marked with the responsible party's name, product type, and year filled or purchased. f) Notice of Reportable Spills. Notice of any reportable spill (as required by 40 CFR 300.125 and 18 AAC 75.300) shall be given to the AO as soon as possible, but no later than 24 hours after occurrence. A-5 Required Operating Procedure Objective: Minimize the impact of contaminants from refueling operations on fish, wildlife, and the environment. Requirement/Standard: Refueling of equipment within 500 ft of the active flood plain of any fishbearing waterbody and 100 ft from non-fish-bearing water bodies is prohibited. Small caches (up to 210 gallons) for motorboats float planes, ski planes, and small equipment, e.g. portable generators and water pumps, will be permitted. The AO may allow storage and operations at areas closer than the stated distances if properly designed to account for local hydrologic conditions. A-8 Required Operating Procedure Objective: Minimize conflicts resulting from interaction between humans and bears during leasing and associated activities. Requirement/Standard: Oil and gas lessees and their contractors and subcontractors will, as a part of preparation of lease operation planning, prepare and implement bear-interaction plans to minimize conflicts between bears and humans. These plans shall include measures to: a) Minimize attraction of bears to the drill sites. b) Organize layout of buildings and work areas to minimize human/bear interactions. c) Warn personnel of bears near or on drill sites and identify proper procedures to be followed. d) Establish procedures, if authorized, to deter bears from the drill site. e) Provide contingencies in the event bears do not leave the site or cannot be deterred by authorized personnel. f) Discuss proper storage and disposal of materials that may be toxic to bears. g) Provide a systematic record of bears on the site and in the immediate area. B. Water Use for Permitted Activities B-1 Required Operating Procedure Objective: Maintain populations of, and adequate habitat for, fish and invertebrates. Requirement/Standard: Water withdrawal from rivers and streams during winter is prohibited. B-2 Required Operating Procedure Objective: Maintain natural hydrologic regimes in soils surrounding lakes and ponds and maintain populations of, and adequate habitat for, fish and invertebrates. Requirement/Standard: Water withdrawal from lakes may be authorized on a site-specific basis depending on size, water volume, depth and fish population and species diversification. Current water withdrawal requirements specify: a) Water withdrawals from any fish bearing lake 7 feet or deeper shall be limited to 15 percent of the estimated free water volume located beneath the ice. b) Water withdrawals from lakes with depths between 5 and 7 feet that contain only ninespine stickleback and/or Alaska blackfish are limited to up to 30 percent of the under-ice volume. c) Water withdrawal may be authorized from any lake if the proponent demonstrates that no fish exist in the lake. d) A water-monitoring plan may be required to assess draw down and water quality changes before, during, and after pumping any fish-bearing lake. e) The removal of naturally grounded ice may be authorized from lakes and shallow rivers on a site specific basis depending upon its size, water volume, depth, and fish population and species diversification. f) Removed ice aggregate shall be included in the 15 percent or 30 percent (whichever is the appropriate case) withdrawal limits, unless otherwise approved. g) Any water intake structures in fish-bearing waters shall be designed, operated and maintained to prevent fish entrapment, entrainment, or injury. h) Compaction of snow cover or snow removal from fish-bearing water bodies shall be prohibited except at approved ice road crossings, water pumping stations on lakes or areas of grounded ice. C. Winter Overland Moves and Seismic Work The following stipulations and ROP's apply to overland moves, seismic work, and any similar crosscountry vehicle use of heavy equipment on non-roaded surfaces during the winter season. These restrictions do not apply to the use of such equipment on ice roads after they are constructed. C-1 Required Operating Procedure Objective: Protect grizzly bear, polar bear, and marine mammal denning and/or birthing locations. Requirement/Standard: Cross-country use of heavy equipment and seismic activities are prohibited within ½ mile of occupied grizzly bear dens identified by Alaska Department of Fish & Game (ADF&G) unless alternative mitigation measures are approved by the AO in consultation with ADF&G. Cross-country use of heavy equipment and seismic activities are prohibited within 1 mile of known or observed polar bear dens or seal birthing lairs. Operators shall consult with the U.S. Fish and Wildlife FWS (FWS) and/or NOAA Fisheries, as appropriate, before initiating activities in coastal habitat between October 30 and April 15. C-2 Required Operating Procedure Objective: Protect stream banks, minimize compaction of soils, and minimize the breakage, abrasion, compaction, or displacement of vegetation. Requirement/Standard: a) Ground operations shall be allowed only when frost and snow covers are at sufficient depths to protect the tundra. Ground operations shall cease when the spring snowmelt begins, approximately May 5 in the foothills area where elevations reach or exceed 500 ft, and approximately May 15 in the northern coastal areas. The exact dates will be determined by the AO. b) Only low-ground-pressure vehicles shall be used for on-the-ground activities off ice roads or pads. A list of approved vehicles can be obtained from the AO. Limited use of tractors equipped with wide tracks or "shoes" will be allowed to pull trailers, sleighs, or other equipment with approved undercarriage. (Note: This provision does not include the use of heavy equipment such as front-end loaders and similar equipment required during ice road construction.) c) Bulldozing of tundra mat and vegetation, trails, or seismic lines is prohibited; however, on existing trails, seismic lines or camps, clearing of drifted snow is allowed to the extent that the tundra mat is not disturbed. d) To reduce the possibility of ruts, vehicles shall avoid using the same trails for multiple trips unless necessitated by serious safety or superseding environmental concern. This provision does not apply to hardened snow trails for use by low-ground-pressure vehicles such as Rolligons. e) The location of winter ice roads shall be designed and located to minimize compaction of soils and the breakage, abrasion, compaction, or displacement of vegetation. Offsets may be required to avoid using the same route or track in the subsequent year. C-3 Required Operating Procedure Objective: Maintain natural spring runoff patterns, avoid flooding, prevent streambed sedimentation, protect water quality and protect stream banks. Requirement/Standard: Crossing of waterway courses shall be made using a low-angle approach. Snow and ice bridges shall be removed, breached or slotted before spring breakup. Ramps and bridges shall be substantially free of soil and debris. E. Facility Design and Construction E-9 Required Operating Procedure Objective: Avoidance of human-caused increases in populations of predators of ground nesting birds. Requirement/Standard: Lessee shall utilize best available technology to prevent facilities from providing nesting, denning, or shelter sites for ravens, raptors, and foxes. The lessee shall provide the AO with an annual report on the use of oil and gas facilities by ravens, raptors and foxes as nesting, denning, and shelter sites. E-13 Required Operating Procedure Objective: Protect cultural and paleontological resources. Requirement/Standard: Lessees shall conduct a cultural and paleontological resources survey prior to any ground-disturbing activity. Upon finding any potential cultural or paleontological resource, the lessee or their designated representative shall notify the AO and suspend all operations in the immediate area of such discovery until written authorization to proceed is issued by the AO. H. Subsistence Consultation for Permitted Activities H-1 Required Operating Procedure Objective: Provide opportunities for participation in planning and decision-making to prevent unreasonable conflicts between subsistence uses and oil and gas and related activities. Requirement/Standard: Lessee/permittee shall consult directly with affected communities using the following guidelines. a) Before submitting an application to the BLM, the applicant shall consult with directly affected subsistence communities, the North Slope Borough, and the NPR-A Subsistence Advisory Panel to discuss the siting, timing and methods of proposed operations. Through this consultation, the applicant shall make every reasonable effort, including such mechanisms as conflict avoidance agreements and mitigating measures, to ensure that proposed activities will not result in unreasonable interference with subsistence activities. b) The applicant shall submit documentation of consultation efforts as part of its operations plan. Applicants should submit the proposed plan of operations to provide an adequate time for review and comment by the NPR-A Subsistence Advisory Panel and to allow time for formal government-togovernment consultation with Native Tribal Governments. The applicant shall submit documentation of its consultation efforts and a written plan that shows how its activities, in combination with other activities in the area, will be scheduled and located to prevent unreasonable conflicts with subsistence activities. Operations plans must include a discussion of the potential effects of the proposed operation, and the proposed operation in combination with other existing or reasonably foreseeable operations. c) A subsistence plan addressing the following items must be submitted. 1. A detailed description of the activity(ies) to take place (including the use of aircraft). 2. A description of how the lessee/permittee will minimize and/or deal with any potential impacts identified by the AO during the consultation process. 3. A detailed description of the monitoring effort to take place, including process, procedures, personnel involved and points of contact both at the work site and in the local community. 4. Communication elements to provide information on how the applicant will keep potentially affected individuals and communities up-to-date on the progress of the activities and locations of possible, short-term conflicts (if any) with subsistence activities. Communication methods could include holding community meetings, open house meetings, workshops, newsletters, radio and television announcements, etc. 5. Procedures necessary to facilitate access by subsistence users to conduct their activities. 6. In the event that no agreement is reached between the parties, the AO shall consult with the directly involved parties and determine which activities will occur, including the timeframes. 7. During development, monitoring plans must be established for new permanent facilities, including pipelines, to assess an appropriate range of potential effects on resources and subsistence as determined on a case-by-case basis given the nature and location of the facilities. The scope, intensity, and duration of such plans will be established in consultation with the AO and Subsistence Advisory Panel. I. Orientation Programs Associated with Permitted Activities I-1 Required Operating Procedure Objective: Minimize cultural and resource conflicts. Requirement/Standard: All personnel involved in oil and gas and related activities shall be provided information concerning applicable stipulations, required operating procedures, standards, and specific types of environmental, social, traditional, and cultural concerns that relate to the region. The lessee/permittee shall ensure that all personnel involved in permitted activities shall attend an orientation program at least once a year. The proposed orientation program shall be submitted to the AO for review and approval and should: a) Provide sufficient detail to notify personnel of applicable stipulations and required operating procedures as well as inform individuals working on the project of specific types of environmental, social, traditional and cultural concerns that relate to the region. b) Address the importance of not disturbing archaeological and biological resources and habitats, including endangered species, fisheries, bird colonies, and marine mammals, and provide guidance on how to avoid disturbance. c) Include guidance on the preparation, production, and distribution of information cards on endangered and/or threatened species. d) Be designed to increase sensitivity and understanding of personnel to community values, customs, and lifestyles in areas in which personnel will be operating. e) Include information concerning avoidance of conflicts with subsistence, commercial fishing activities, and pertinent mitigation. f) Include information for aircraft personnel concerning subsistence activities and areas/seasons that are particularly sensitive to disturbance by low flying aircraft. Of special concern is aircraft use near traditional subsistence cabins and campsites, flights during spring goose hunting and fall caribou and moose hunting seasons, and flights near North Slope communities. g) Provide that individual training is transferable from one facility to another, except for elements of the training specific to a particular site. h) Include on-site records of all personnel who attend the program for so long as the site is active, though not to exceed the 5 most recent years of operations. This record shall include the name and dates(s) of attendance of each attendee. i) Include a module discussing bear interaction plans to minimize conflicts between bears and humans GENERAL STIPULATIONS All operations will be conducted in such a manner as not to cause damage or disturbance to any fish or wildlife and subsistence resources. No chasing by vehicles or buzzing by aircraft of any wildlife. Particular attention will be given to not disturbing caribou. Holder shall prohibit the feeding of wildlife. Garbage or other potentially edible items which would attract wildlife shall be kept in covered containers while awaiting incineration. All operations shall be conducted with due regard for good resource management and in such a manner as not to block any stream, or drainage system, or change the character or course of a stream, or cause the pollution or siltation of any stream or lake. All activities shall be conducted so as to avoid or minimize disturbance to vegetation. Cultural and Paleontological Resources. Any cultural or Paleontological resource (historic or prehistoric site or object) discovered by the holder, or any person working on his behalf, on public or Federal land shall be immediately reported to the authorized officer. Holder shall suspend all operations in the immediate area of such discovery until written authorization to proceed is issued by the AO. An evaluation of the discovery will be made by the AO to determine appropriate actions to prevent the loss of significant cultural or scientific values. The Holder will be responsible for the cost of evaluation and any decision as to the proper mitigation measures will be made by the AO after consulting with the Holder. Black water shall be kept separate from grey wash and kitchen waste water. Grey wash water and kitchen waste water may be filtered to remove the solids and the liquid discharged to the land surface. All solids and sludges shall be incinerated. All solid wastes shall be removed from the public lands to Alaska State DEC approved solid waste disposal facilities. Solid waste combustibles may be incinerated. All non-combustible solid waste, including ash from incineration and fuel drums, shall be removed for approved disposal. There will be no burial of garbage or human wastes. All fuel spills will be cleaned up immediately, taking precedence over all other matters, except the health and safety of personnel. Spills will be cleaned up utilizing absorbent pads or other Alaska State DEC approved methods. As soon as possible, but not later than 24 hours, notice of any such discharge of oil or hazardous substance as defined in AS 46.03.755, 18 AAC 75.300-.307, will be given to the Authorized Officer and any other Federal and State officials as are required by law. ADEC approved oil spill cleanup materials (absorbents) will be carried by each field crew and stored at all fueling points and vehicle maintenance areas. State and Federal safety standards for fuel handling will be followed. No fuel storage or refueling of equipment will be allowed within the flood plain of a river or lake. Drip basins or absorbent diapers will be placed under all non dry-disconnect-type fuel line couplings and valves. Fuel and other petroleum products storage of 55 gallons or greater must have secondary containment with 110% of the capacity of the primary storage. The secondary containment, such as lined and bermed systems, must meet local, State and federal codes and regulations. Above ground storage of fuels or other petroleum products in excess of 660 gallons, or an aggregate above ground storage capacity of greater than 1320 gallons; or any facility which, due to location, could reasonably expect spilled fuels to reach waters of the United States or adjoining shorelines must prepare and maintain a Spill Prevention Control and Countermeasure (SPCC) Plan in accordance with 40 CFR 112 regulations. All fuel containers, including barrels and propane tanks, shall be marked with Permittee's name, product type, and year filled or purchased (e.g., Company Name, Hydraulic Fluid, 1994). Appendix C – Section 7 Consultation Record United States Department of the Interior U.S. FISH AND WILDLIFE SERVICE Fairbanks Fish and Wildlife Field Office 101 12th Avenue, Room 110 Fairbanks, Alaska 99701 January 21, 2011 Colonel Robyn Burk United States Air Force 611 ASG/CC 9480 Pease Ave Ste 123 JBER, AK 99506-2200 Re: Point Barrow Long Range Radar Site debris removal and cleanup Dear Col. Burk: Thank you for requesting informal consultation, pursuant to section 7 of the Endangered Species Act of 1973, as amended (Act), for proposed cleanup activities at Point Barrow Long Range Radar Site (LRRS). The U.S. Fish and Wildlife Service (Service) has reviewed the proposed project in relation to section 7 of the Act to determine if it will adversely affect listed species under the our jurisdiction. Three species listed as threatened under the Act may occur in the project area: spectacled eiders (Somateria fischeri), Alaska-breeding Steller’s eiders (Polysticta stelleri), and polar bears (Ursus maritimus). There is no designated critical habitat for listed eiders within the project area. Point Barrow LRRS is located within the boundaries of polar bear critical habitat Unit 2, terrestrial denning habitat (50 CFR 17.95 (a)); however, the LRRS is specifically exempted from polar bear critical habitat (75 FR 76086; Figure 1) under section 4(a)(3)(B) of the Act because it is covered by an approved Integrated Natural Resources Management Plan (INRMP; USAF 2009) that provides a benefit to the species. Proposed Action Based on information provided in the Preliminary Draft Environmental Assessment (USAF 2011), 2011 Winter Work Plans (SIKU Construction 2010), and additional phone and e-mail communications with Matthew Moran, Natural Resource Program Manager, 611 CES/CEAN, we understand that the United States Air Force (USAF) is proposing to demolish, remove, and dispose of unused buildings and structures and surface debris at the Point Barrow LRRS Camp and Airstrip Areas, and excavate, treat, or dispose of xylene and polychlorinated biphenyls (PCB) contaminated soils to meet Alaska Department of Environmental Conservation regulations. Work will be completed January 2011–February 2012 by SIKU Construction, LLC under AFCEE Contract Number FA8903-10-C-8121. The proposed action includes the following activities: . Remedial Action-Cleanup (RA-C) activities at Point Barrow LRRS • Excavation and off-site disposal of 25–178 cu yd contaminated soil from 4 areas, o Vehicle fueling station o Radome area o Transformer stand area o Vehicle maintenance facility • Institutional controls, natural attenuation, and long-term monitoring of contaminated surface water at the Air Terminal Area . Demolition, removal, and disposal of designated structures located at Camp and Airstrip Areas at Point Barrow LRRS • Camp Area o Remaining diesel storage tanks (berm area; 13 tanks; each 275–65,000 gal) o Antenna and support structures o Liquid fueling pump station tanks/circulation pump o Gas meter facility o Vehicle fueling station • Airstrip Area o Remaining jet fuel tanks and stand (15, 300-gal each; one 23,000 gal) o Float plane fuel dock o Airstrip terminal o Storage yard debris o Transmission lines/utility poles o Marston matting (removal of pieces that pose a safety hazard) Activities that will occur on undisturbed tundra include removal of transmission lines and utility poles and excavation of contaminated soils. Transmission lines/utility poles will be accessed using a snow and ice trail along the pole line in winter 2011 and removal will be completed by March 2011. Undisturbed tundra may be excavated immediately adjacent to gravel pads during remedial action-cleanup activities, but will be limited to a small volume of soil (= 1.5 cu yd). The USAF will conduct a survey for eider nests in the project area during summer 2011. Steller’s Eiders In Alaska, Steller’s eiders breed almost exclusively on the Arctic Coastal Plain (ACP). Nesting on the ACP is concentrated in tundra wetlands near Barrow, AK (Figure 2). Steller’s eiders arrive in small flocks of breeding pairs on the ACP in early June. Long-term studies of Steller’s eider breeding ecology near Barrow indicate periodic non-breeding by the entire local breeding population. In non-breeding years, birds arrive in the area but do not establish nests. In nesting years, Steller’s eiders initiate nesting in the first half of June (Quakenbush et al. 2004) and hatching occurs in mid-July though early August (Rojek 2006, 2007, 2008). Observations of known-age ducklings indicate that fledging occurs 32–37 days post hatch. Increased levels of activity associated with summer work tasks at Point Barrow LRRS could result in disturbance to breeding pairs, nesting eiders, and hens with broods. Consequently, these activities could discourage nest initiation; flush hens from their nests, which would increase the risk of depredation or abandonment of nests; or interfere with foraging by broods. Steller’s eiders are known to occupy and nest on the tundra surrounding Point Barrow LRRS at very low densities. The Service conducts annual foot surveys (1999–2010) for Steller’s eider breeding pairs and nests near Barrow, including a portion of the tundra within the boundaries of the Point Barrow LRRS (Figure 3). However, the border of the study area does not extend into the project area. Steller’s eiders were observed at the Point Barrow LRRS in 2000 and 2008 southeast of the project area (USFWS Barrow Eider Ecology Database). Nests have not been observed on the property and the closest recorded nest was > 450 m southwest of the Camp Area. Additionally, no Steller’s eiders or nests were found during a survey of the entire Point Barrow LRRS property by Oasis Environmental, Inc. (2008) in early July 2007, which was a nesting year. A brood was observed foraging at the Point Barrow LRRS along the eastern edge of Imikpuk Lake in 2008 (Neesha Stellrecht, USFWS, pers. com.) Because available data indicate very low use of the surrounding area by Steller’s eiders, we expect that the likelihood that they would nest in the limited tundra habitat available in the project area is very low. Consequently, we expect that adverse effects to nesting Steller’s eiders will be discountable because they are extremely unlikely to occur. A brood may occasionally enter the area; however, broods can easily move away from local disturbances and we expect that a hen with a brood would move to a perceived safe distance from project activities. We anticipate adverse effects to hens with broods to be insignificant because they would be experienced at a minimal level where take will not occur. We expect removal of overhead transmission lines and utility poles to be beneficial to eiders by reducing collision risks to birds flying in or through the area, including breeding, postbreeding, and migrating eiders. Because we expect effects to Steller’s eiders to be discountable, insignificant, or beneficial, the Service concludes that the proposed action is not likely to adversely affect Steller’s eiders. Spectacled Eiders Although spectacled eiders nest in the vicinity of Barrow, they do not appear to use the tundra immediately surrounding the Point Barrow LRRS. Observations of spectacled eiders during annual USFWS breeding pair surveys (1999–2010) near Barrow have been > 1.5 km from the project area (Figure 3) and spectacled eiders have nested several kilometers south of the project area over the past 12 years (Figure 2). No spectacled eider nests have been detected north of latitude 71.26° in the Barrow area (USFWS Barrow Eider Study Database). Additionally, no spectacled eiders or nests were found during a survey of the Point Barrow LRRS by Oasis Environmental, Inc. (2008) in early July 2007. Because annual surveys in the vicinity of the Point Barrow LRRS indicate that spectacled eiders do not use the surrounding habitat, the likelihood of disturbance to this species is very low and adverse effects are discountable. Following the same logic presented for Steller’s eiders above, we expect effects to spectacled eiders to be discountable, insignificant, or beneficial. Therefore, the Service concludes that the proposed action is not likely to adversely affect spectacled eiders. Polar Bears The project area is located within the range of polar bears along the eastern Chukchi Sea. Proposed activities at Point Barrow LRRS will occur within 1.5 km of the coast. We do not anticipate maternal dens to occur in the project area because the site lacks suitable topographic relief. However, polar bears occasionally enter developed coastal areas in the vicinity of Barrow and could be subject to disturbance from cleanup activities at Point Barrow LRRS. To minimize the risk of negative human–bear interactions and respond to potential encounters with polar bears, all operations will follow the USAF Polar Bear Interaction Management Plan, May 2008 (Ohms 2008) and the North Slope Operations Bear and Pacific Walrus Avoidance and Human Encounter/Interaction Plan (Ukpeagvik Iñupiat Corporation [UIC] 2005). Additionally, the contractor will provide bear awareness and safety training by a qualified bear hazer from UMIAQ. We understand that the contractor plans to stop work if a bear enters the project area and that hazing activities are not planned at this time. Given that 1) proposed work at Point Barrow LRRS will occur within the footprint of previously disturbed land, 2) polar bears are not known to regularly use the habitat immediately surrounding the project area, and 3) risks associated with polar bear encounters will be managed by following USAF and UIC human–polar bear interaction plans and safety training, we expect that effects to polar bears will be minimized to an extent that take will not occur. We therefore expect that adverse effects to polar bears will be insignificant and conclude that the proposed action is not likely to adversely affect polar bears. Conclusion The Service has reviewed the proposed project in relation to section 7 of the Act and determined the proposed activities are not likely to adversely affect listed eiders or polar bears. There is no designated critical habitat for listed eiders within the project area. Point Barrow LRRS is exempted from the polar bear critical habitat designation because the site is covered by an approved INRMP that provides a benefit to the species. Please report any observations of listed species at Point Barrow LRRS to Kaiti Ott (kaithryn_ott@fws.gov) at the USFWS Barrow Office at (907) 852-2058. Preparation of a Biological Assessment or further consultation under section 7 of the Act regarding this project is not necessary. This letter applies only to endangered and threatened species under our jurisdiction. It does not preclude the need to comply with other environmental legislation or regulations such as the Migratory Bird Treaty Act. Literature Cited OASIS Environmental, Inc. 2008. Spectacled and Steller’s Eider Ground-based Nest Surveys and Avian Inventory at Six U.S. Air Force Radar Sites in Northern Alaska. Unpublished report prepared for U.S. Air Force, 611th Civil Engineer Squadron, Natural Resources, Elmendorf AFB, AK. Ohms, H. 2008. Polar Bear Interaction Management Plan, May 2008. A final revised plan for the Department of Defense, U.S. Air Force contract number FA5000-06-FA019. Prepared for 611th Air Support Group, 611th Civil Engineer Squadron/Environmental Flight, Elmendorf AFB, AK by OASIS Environmental Inc., Anchorage, AK. Quakenbush, L., R. Suydam, T. Obritschkewitsch, and M. Deerling. 2004. Breeding biology of Steller‘s eiders (Polysticta stelleri) near Barrow, Alaska, 1991–99. Arctic 57:166–182. Rojek, N.A. 2006. Breeding biology of Steller‘s eiders nesting near Barrow, Alaska, 2005. U.S. Fish and Wildlife Service, Fairbanks Fish and Wildlife Field Office, Fairbanks, Alaska. Technical Report. Rojek, N.A. 2007. Breeding biology of Steller‘s eiders nesting near Barrow, Alaska, 2006. U.S. Fish and Wildlife Service, Fairbanks Fish and Wildlife Field Office, Fairbanks, Alaska. Technical Report. Rojek, N.A. 2008. Breeding biology of Steller‘s eiders nesting near Barrow, Alaska, 2007. U.S. Fish and Wildlife Service, Fairbanks Fish and Wildlife Field Office, Fairbanks, Alaska. Technical Report. SIKU Construction. 2010. 2011 Winter work plans for environmental restoration and demolition activities at former NARL facility and Point Barrow LRRS. December 2010. Ukpeagvik Iñupiat Corporation. 2005. North Slope Operations Bear and Pacific Walrus Avoidance and Human Encounter/Interaction Plan. USAF. 2009. Integrated Natural Resources Management Plan, 2007 Revision—2009 Update, Annual Review, Alaska Radar System, Alaska Short and Long Range Radar Sites, Alaska 611th Air Support Group USAF. 2011. Preliminary draft environmental assessment, Point Barrow Long Range Radar Site debris removal and cleanup. January 2011. Figure 1. Exclusion map for polar bear critical habitat in the vicinity of Barrow, AK. Chukchi Sea Point Barrow LRRS Project Area Barrow Figure 2. Observations of Steller’s eiders and spectacled eiders during USFWS breeding pair and nest foot surveys at Barrow, AK (1999–2010; Steller’s eider nest locations 1991–2010) relative to location of project area at Point Barrow LRRS. Camp Area Air Terminal Area Figure 3. Observations of Steller’s eiders and spectacled eiders during USFWS breeding pair and nest foot surveys relative to project areas at Point Barrow LRRS (1999–2010; Steller’s eider nest locations 1991–2010). Appendix D – Polar Bear Interaction Plan Appendix E – SIKU Best Management Practices SIKU BEST MANAGEMENT PRACTICES FOR ENVIRONMENTAL RESTORATION AND DEMOLITION ACTIVITIES AT FORMER NARL AND POINT BARROW LRRS Material Handling and Waste Management All waste management activities will be performed in accordance with the contract specifications and all applicable Alaska Department of Environmental Conservation (ADEC) regulations and in accordance with the project Waste Management Plan and the project Cleanup Plan. Waste streams expected to be generated during field activities include grubbing materials, trash, concrete, dirt, and construction debris. Suspected waste characterization will be performed on any questionable debris items, soil, and water. Waste derived during this project will be disposed of in accordance with ADEC regulations. All waste materials, as identified in the contract documents, will be collected and disposed in the Barrow Landfill. Hazardous material containers will meet federal, state, and international shipping regulations. Only non-hazardous construction debris and ADEC approved hazardous materials will be disposed in the Barrow Landfill. Hazardous waste materials will be stored in appropriate and clearly marked containers and segregated from other non-hazardous waste materials. Secondary containment will be provided for all waste materials in the on site materials storage area. Additionally, all hazardous waste materials will be transported to a regulated treatment, storage, and disposal facility. Materials such as paint chips and friable asbestos will be handled to minimize discharge of particulates offsite. Fuel tanks will be encapsulated with a layer of ice to eliminate particles from chipping off during transport. During building demolition, friable material will be coated with water to contain and prevent spread. These activities will be implemented as needed once demolition activities have been initiated. Loads with friable debris will be covered during transportation to prevent migration from wind and water. Sanitary and Septic Waste Management One temporary sanitary facility (portable toilet) will be provided during the construction operations. The portable toilet will be brought to the site once a designated area has been established. The portable toilet will be inspected weekly for evidence of leaking holding tanks. The portable toilet will be located away from a concentrated flow paths and traffic flow. Equipment/Vehicle Fueling and Maintenance Practices All hazardous waste materials such as oil filters, petroleum products, and equipment maintenance fluids will be stored and disposed of in accordance with Siku standard policy and procedures. Vehicles will be maintained offsite in the Siku maintenance garage or a maintenance facility in Barrow and not in the project area. The project will have small volumes of fuel and oil on site for use in gas powered tools such as chainsaws and cutoff saws. Equipment will be fueled and oiled over secondary spill containment devices (duck ponds) with spill equipment readily available. All fuel and oil products will be labeled correctly and stored in accordance with federal, state, and municipal regulations. Best Management Practices (BMP) implemented for equipment and vehicle maintenance and fueling activities will begin at the start of the project. Vehicles and equipment will be inspected each day before startup or before entering the project area. Leaks will be repaired immediately, or the problem vehicle(s) or equipment will be removed from the project site. Ample supply of spill and cleanup materials will be kept on site and materials will be disposed properly. Duck ponds will be placed under idling or parked equipment on site. Duck ponds may also be strapped to the undercarriage of equipment to prevent any spills in the event of a catastrophic failure or small leak. The project will have equipment on the job requiring fuel delivery. All equipment fueled on site will require a duck pond to catch any drips or spills that may occur during the fueling process. Spill kits will be located on the fuel truck as well as through out the project area. All equipment fueling will take place at least 100 feet away from any waterway or wetland and above the high water elevation to ensure the protection wetlands and water bodies. Work trucks and other vehicles will be fueled off-site. Spill Prevention Controls and Countermeasures Preventing accidental contamination of the environment is an integral part of Siku operations. Operations or activities which might contribute to the contamination of air, soil, uncontaminated materials, equipment, other surfaces or water resources by discharge or spilling of waste materials will be eliminated or restricted and monitored throughout this project. Standard operating procedures to be employed for prevention and control of potential onsite spills or releases during construction activities are described in the Health & Safety Plan developed for this project. These procedures cover control of detected spills, potential non detected spills, and the protection of human and ecological receptors during spills. A project Health & Safety Plan will be developed and a copy will be available at the Siku Anchorage Office, Siku Project Site Office, and the UIC Corporation Office in Barrow. If a spill occurs, the following procedures will be followed: 1. Prevent spilled material from migrating 2. Evaluate safety and health risks (ref. Material Safety Data Sheet) 3. Notify Project Superintendent 4. If applicable, report spill to ADEC 5. Enact spill containment measures 6. Cleanup spill as directed per State regulations 7. Complete Spill Report 8. Follow up on spill with investigation Emergency Phone Numbers: Siku Construction Superintendent Mobile 907-301-4708 Direct: 907-852-3944 UIC 24-Hour Duty Manager 907-229-6567 ADEC 1-800-478-9300 Chemtrec 1-800-424-9300 National Response Center (USEPA) 1-800-424-8802 EMERGENCY #911 Reporting Procedures: In the event a spill occurs, the North Slope Borough will be notified. A spill report will be filed with the North Slope Borough and other agencies they deem necessary. Full cooperation by Siku is assured. Manufacturers of material recommendations will be followed in all spill cases. OSHA regulations will be followed as well. Control Actions: Siku will take responsibility of a spill related to the scope of work and control this plan to ensure proper actions are taken. This means that if a tanker truck driving though the job has a structural failure and spills an unknown chemical we will notify authorities and the producer/transporter will be responsible. Equipment and vehicles will be equipped with absorbent pads and containment tools to begin control of spill. All supervisor personnel will have phone communications for quick response to spills. Spill Cleanup kits will be on site from start to finish. These kits will be located in a conspicuous place and in a recognizable drum. Siku will maintain their equipment properly and inspect all equipment daily for leaks. A duck pond or similar device will be placed underneath equipment that may have fuel or other leaks, until proper maintenance can be performed to stop the leak. If any spill occurs, the waste will be disposed of per ADEC regulations. Absorbent pads, spill brooms and other containment materials will be properly disposed of. All spills will be logged and submitted to the North Slope Borough and the ADEC in a timely manner. The spill prevention and control procedures will be implemented once the project begins on-site. Training Daily health, safety, and environment meetings will be held with workforce regarding proper procedures for; • hazardous waste disposal, • non-hazardous waste disposal of trash and demolition debris, • site safety • spill prevention and control, and • erosion and sediment control. The Project Superintendent who manages day-to-day site operations will be responsible for seeing that these procedures are followed. Preservation of Existing Vegetation Minimize disturbance of existing vegetation within the project area. A portion of the project will be conducted on the tundra during winter months. When frozen, tundra is able to resist disturbance by maintaining vegetative qualities that would otherwise be destroyed. Tundra access will be by the use of a snow and ice trail. The snow and ice trail will be built by grading the snow pack. Water will be added to form ice, only when additional support is needed for the construction equipment. The other portion of the project will be conducted using field crews. Field crews will walk out on the tundra to remove debris. Debris will be removed and placed in super sacks for later removal. Care will be taken to not impact vegetation surrounding the removed debris to the greatest extent practicable. Field crews will work in a manner that does not create trails or frequently disturbed areas of the tundra. Threatened & Endangered Species Guidelines Siku will follow all regulations as set forth in the United States Fish & Wildlife Service Threatened & Endangered (T&E) species consultation for this project. Under the Endangered Species Act, it is illegal to harass or harm T&E species. Siku will follow necessary procedures, guidelines, and Polar Bear/Human Interaction Plans to reduce impacts related to activities for this project.