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Tribal Response Tribal Response
to Protect to Protect the the AnkauAnkau SaltchucksSaltchucksAugust 21, 2013
By: Alex James, Yakutat Tlingit Tribe and Bruno Ridolfi, RIDOLFI Inc.
History of YakutatHistory of Yakutat
• Strategically located for trade
• Rich history of Alaska Native Cultures
– Athabaskan
– Eyak
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– Eyak
– Tlingit
• Oldest archeological site is more
than 8,000 years old
“OUR BEACHES WERE OUR GARDEN…
ANKAU ALWAYS HAD THE BEST OF
EVERYTHING”
• Covers a large peninsula near
Yakutat, Alaska
• Rich estuary with abundant
clams, cockles, crab, fish,
seals, ducks, moose, deer,
berries, and useful plants
AnkauAnkau SaltchucksSaltchucks
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berries, and useful plants
• Important as a source of food
and herbal medicine
• Used all year round for
hunting and gathering of
subsistence foods
• A place where children
learned and lived the
traditional Tlingit way of lifeo Song
o Dance
AnkauAnkau SaltchucksSaltchucks Culture CampCulture Camp
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o Dance
o Storytelling
o Language
o Arts and crafts
o Preparation of traditional
subsistence foods
The Culture Camp began in 1985 and closed in 2003
due to concerns about dioxins in the soil, water, and
seafood
AnkauAnkau SaltchucksSaltchucks Culture CampCulture Camp
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Military HistoryMilitary History
• U.S. military occupied areas surrounding
Yakutat and Phipps Peninsula beginning
in 1929
• Strategic World War II Air Base from
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• Strategic World War II Air Base from
1940 to 1945
• U.S. Army, Navy, and Air Force facilities
were located in and around Yakutat
Military HistoryMilitary History
• Military Defense Facilities
– Airfield
– Ocean Cape Radio Relay Station
– Naval operations area
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– Naval operations area
• Artillery positions and associated control
and observation positions were located
along the coast of Phipps Peninsula
Military ImpactsMilitary Impacts
• U.S. Department of Defense organized
former military sites into Concern Groups
to address health and safety issues
• Primary areas of concern
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• Primary areas of concerno Yakutat Air Force Base
o Minor Naval Air Facilities (Seaplane Base)
o Point Carrew Garrison
o Ocean Cape Radio Relay Station (OCRRS)
Military Impact ConcernsMilitary Impact Concerns
• Dioxins and furans
• Polychlorinated biphenyls (PCBs)
• Diesel
• Asbestos
• Debris dumps
• Barrel dumps
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• Diesel
• Gasoline
• Oil
• Metals
• Fuel storage areas
• Firing ranges
• Septic systems
• Culverts and roads
How Mitigation of Impacts BeganHow Mitigation of Impacts Began
• Community health
concerns raised awareness
of the possibility of dioxin
exposure
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exposure
• Former military facilities
were identified as
possible sources
Responsible Parties Responsible Parties
and Sources of Fundingand Sources of Funding
• U.S. Department of Defense (DoD)
o FUDS – Formerly Used Defense Sites
o NALEMP – Native American Lands Environmental
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o NALEMP – Native American Lands Environmental
Mitigation Program
• U.S. Environmental Protection Agency (EPA)
o Tribal Response Program (TRP)
o Environmental Justice (EJ)
• USACE manages and conducts work to
investigate and clean up former military
sites
Formerly Used Defense Sites Formerly Used Defense Sites
Program (FUDS)Program (FUDS)
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sites
• There are more than 2,650 FUDS sites in
the United States that need remediation
• Annual budget is about $250 million
U.S. Department of DefenseU.S. Department of Defense
• Native American Lands Environmental
Mitigation Program (NALEMP)
• Established in 1996 to address impacts from
What is NALEMP?What is NALEMP?
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• Established in 1996 to address impacts from
former military sites to Tribal lands
• Current budget for NALEMP is $12 million per year
with $9 going to federally recognized tribes
U.S. Department of DefenseU.S. Department of Defense
• Cooperative agreements are negotiated
between federally recognized tribes and U.S.
Department of Defense (DoD)
• Tribes identify sites that are eligible for work
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• Tribes identify sites that are eligible for work
under NALEMP, develop strategic plans, and
manage the work
• U.S. Army Corps of Engineers administers
cooperative agreements for DoD
Yakutat NALEMP ObjectivesYakutat NALEMP Objectives
• Protect and provide for the health and safety of the Yakutat Tlingit Tribe
• Protect and enhance the environment
• Preserve the Yakutat Tlingit culture
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• Preserve the Yakutat Tlingit culture
• Provide employment opportunities for Yakutat Tlingit people
Protecting Tribal Resources Protecting Tribal Resources
and Cleaning Up the Landand Cleaning Up the LandFiscal Year 2006 - First NALEMP Cooperative Agreement between Yakutat Tlingit Tribe and DoD
• Developed Strategic Project Implementation Plan
• Determined that Ocean Cape Radio Relay Station
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• Determined that Ocean Cape Radio Relay Station was eligible under NALEMP
– Former military site
– Not scheduled for work by other DoD programs
• Developed Site Investigation Plan to collect and analyze samples from the site
Convincing Others Convincing Others
TThere is a Problemhere is a Problem
• Limited options under NALEMP
o Eligibility criteria
o USACE resistance
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• Limited sampling and inconclusive results from Culture Camp under FUDS
• Limited support from Alaska Department of Public Health
Strategic PlanningStrategic Planning
• What do we know?
o Compile and review existing data
• What do we need to know?
o Identify targeted sampling areas
o Compile data to strengthen the Tribe’s case
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o Compile data to strengthen the Tribe’s case
• How do we ensure high quality data?
o EPA support in developing sampling and analysis plans
o Independent data review and validation
• How can other agencies help?
U.S. Environmental Protection AgencyU.S. Environmental Protection Agency
• Funded by U.S. Environmental Protection Agency
(EPA) as part of the Brownfields Program
o Brownfields are real property that have been adversely
Tribal Response Program (TRP) Tribal Response Program (TRP)
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o Brownfields are real property that have been adversely
affected by the presence or potential presence of
contamination
o Expansion, redevelopment, or reuse may be complicated
by the presence or potential presence of a hazardous
substance, pollutant, or contaminants of concern
• Noncompetitive grants
• Site contamination can be real or perceived
• Establish and enhance tribal response programs
U.S. Environmental Protection AgencyU.S. Environmental Protection Agency
Tribal Response Program (TRP) Tribal Response Program (TRP)
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• Establish and enhance tribal response programs
o Assessment
o Cleanup
o Redevelopment of brownfields and other sites
• One-year grant periods
• Can reapply for funding yearly
U.S. Environmental Protection AgencyU.S. Environmental Protection Agency
Tribal Response Program (TRP) Tribal Response Program (TRP)
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• Can reapply for funding yearly
o If the four elements of the program are satisfied
o If the Public Record is maintained
• During 2003, 2004, and 2006, samples of soil, surface
water, sediment, and shellfish tissue were collected within
the Yakutat area
• Of the contaminants of concern detected, dioxins are of
Review of Dioxin Sampling Review of Dioxin Sampling
Conducted Under FUDSConducted Under FUDS
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• Of the contaminants of concern detected, dioxins are of
greatest concern to the Yakutat Tlingit Tribe and their
community
• The Tribe compiled and evaluated existing dioxin data that
were collected within the usual and accustomed lands of
the Yakutat Tlingit Tribe
2010 Site Investigation2010 Site Investigation
• Funded under EPA Tribal Response Program
• Built on results of previous investigations
• Soil sampling in the Culture Camp area and analysis at lower detection levels
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analysis at lower detection levelso Developed a sample profile for the dioxins
o Compared to typical source profiles
• Seafood sampling within the Ankau Saltchuckso Determined whether elevated dioxin concentrations
in tissue are localized or wide-spread
• Collected clam samples at 6 locations on the
northern portion of the Ankau Saltchucks
• Samples were collected near 2 previously
sampled locations and at 4 new locations
2010 Site Investigation2010 Site Investigation
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• Collected 2 crab samples (1 near the Culture
Camp; 1 between the camp and the bridge)
• 1 soil sample was collected in the Culture Camp
at the location of the highest previous dioxin
detection
2010 Site Investigation2010 Site Investigation
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detection
• Soil sample collected was a 9-point composite sample
centered on the previous sample location
• Dioxin result was 62.62 ng/kg
2010 Site Investigation2010 Site InvestigationCulture Camp SoilCulture Camp Soil
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• Dioxin result was 62.62 ng/kg
o About three times higher
than previous concentration
o About 14 times higher than
screening level of 4.3 ng/kg(ng = nanogram = one billionth of a gram)
• Collect additional sediment samples over a more
extensive area
• Analyze sediment samples to lower detection limits
• Collect additional shellfish samples over a more
extensive area
RecommendationsRecommendations
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extensive area
• Analyze shellfish tissue to lower analytical detection
limits
• Co-locate shellfish and sediment samples
AnkauAnkau SaltchucksSaltchucks Sediment Sediment
and Shellfish Sampling and Analysisand Shellfish Sampling and Analysis
• Designed based on results of previous investigations
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• Co-located shellfish and sediment sampleso 1 pair from location with known impacts
o 2 pairs downstream of 1984 military dumps
o 1 pair downstream of WWII military dump
Data Validation and ReportingData Validation and Reporting
• All analytical data are “validated”
– Data validation: process that extends the evaluation of
data beyond method, procedural, or contractual
compliance (i.e., data verification) to determine the
analytical quality of a specific data set
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analytical quality of a specific data set
• Determines whether a data set meets project data
quality objectives
• Key step in the assessment phase that provides
quality data for decision making
Agency for Toxic Substances Agency for Toxic Substances
and Disease Registry (ATSDR)and Disease Registry (ATSDR)
• Yakutat Tlingit Tribe petitioned ATSDR for assistance
in evaluating findings
– Working with Joe Sarcone, Environmental Health Scientist
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– Working with Joe Sarcone, Environmental Health Scientist
• ATSDR reviewed results of 2010 investigation
– Determined that quality of data
was excellent
– Identified additional data needs
ATSDR Concerns ATSDR Concerns
and Health Consultationand Health Consultation
ATSDR met with the community to compile information on subsistence use of Saltchucks and assessed:
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assessed:
1) Whether community members still gathered food from the site
2) What kinds of subsistence foods were gathered
3) How much of each subsistence food was consumed
Next Steps with ATSDRNext Steps with ATSDR
• ATSDR agreed to perform a health
consultation based on dioxin data from
investigations of Ankau Saltchucks
o 2010 shellfish and soil
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o 2010 shellfish and soil
o 2012 shellfish and crab
o 2013 shellfish and sediment
o 2013 Culture Camp soils
U.S. Environmental Protection AgencyU.S. Environmental Protection Agency
• Supports and empowers communities working on
solutions to local environmental and public health
issues
Environmental Justice (EJ) GrantEnvironmental Justice (EJ) Grant
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• Assists recipients in building collaborative
partnerships
• Understands and addresses environmental and
public health issues in their communities
Site Investigation Under EJ GrantSite Investigation Under EJ Grant
Following release of 2010 results, the community
asked whether there were dioxins in the southern
part of the Ankau Saltchucks and if crabs are
impacted
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• Collected and analyzed 5 Dungeness crab samples
– 3 crab samples collected from south end of Ankau
Saltchucks
– 2 crab samples from background reference locations
– 3 samples of cockles were collected and analyzed for dioxin
NALEMP Funding Obtained NALEMP Funding Obtained
Based on TRP and EJ InvestigationsBased on TRP and EJ Investigations
• Elevated dioxins were found in soil at the Culture Camp
• Data quality met highest standards
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• Data quality met highest standards
• Results were used to leverage funding under NALEMP for additional site investigation
o Multi-incremental sampling strategy was developed
“While Yakutat has been
developing their case to convince
DoD and USACE that there are
impacts from dioxins to the
Culture Camp and the Ankau
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Culture Camp and the Ankau
Saltchucks, we have been
cleaning up our lands.”
OCRRS Removal Actions OCRRS Removal Actions
and Site Cleanup Effortsand Site Cleanup Efforts
• The Tribe’s NALEMP team has focused on removal actions and site investigations at the Ocean Cape Radio Relay Station (OCRRS), a
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Ocean Cape Radio Relay Station (OCRRS), a former Cold War facility
• The Tribe is currently working under an 8th
Cooperative Agreement with DoD
PetroleumPetroleum--ContaminatedContaminated
Soil (PCS) RemovalSoil (PCS) Removal
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PetroleumPetroleum--ContaminatedContaminated
Soil Soil (PCS) Removal(PCS) Removal
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PetroleumPetroleum--ContaminatedContaminated
Soil Soil (PCS) Removal(PCS) Removal
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PetroleumPetroleum--ContaminatedContaminated
Soil Soil (PCS) Removal(PCS) Removal
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20132013--2014 NALEMP2014 NALEMP
• Debris removal from 5 areas at Point Carrew Garrison
• Mitigate impacts at Seaplane Base
Point Point CarrewCarrew Garrison and Garrison and
Minor Naval Air Facilities Removal ActionsMinor Naval Air Facilities Removal Actions
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• Mitigate impacts at Seaplane Base
– Close septic tanks and manholes
– Remove debris
Future Removal Actions Future Removal Actions
• Replace DoD installed culverts
• Remove debris
• Remove barrels
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Lessons LearnedLessons Learned
• Start with what you know
• Keep compiling information
• Tell your story
• Tell it again
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• Tell it again
• Keep action steps small
• Perseverance pays off