tribal response to protect to protect the the...

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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.

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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

History of YakutatHistory of Yakutat

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Preserving Food Preserving Food

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AnkauAnkau SaltchucksSaltchucks

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“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


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Ankau Saltchucks Culture CampAnkau Saltchucks Culture 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 AreasMilitary Impact Areas

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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

Ocean Cape Radio Relay Station Ocean Cape Radio Relay Station 1982

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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



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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



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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

Previous InvestigationsPrevious Investigations

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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


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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


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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

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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

CoCo--located Shellfish and Sedimentlocated Shellfish and Sediment

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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


• 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

Site Investigation ActivitiesSite Investigation Activities

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AsbestosAsbestos--Wrapped Pipe RemovalWrapped Pipe Removal

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Diesel AST RemovalDiesel AST Removal

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Water Pumphouse AST RemovalWater Pumphouse AST Removal

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Garage RemovalGarage Removal

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PetroleumPetroleum--ContaminatedContaminated

Soil (PCS) RemovalSoil (PCS) Removal

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PetroleumPetroleum--ContaminatedContaminated

Soil Soil (PCS) Removal(PCS) Removal

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After PCS After PCS RRemovalemoval

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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

QUESTIONSQUESTIONSANDAND

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ANDAND

DISCUSSIONDISCUSSION

tribal response to protect to protect the the...

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