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1 June 2018 Army National Guard Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) Activities at Camp Grayling, Michigan 5 June 2018

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Page 1: Army National Guard Comprehensive Environmental Response ...€¦ · CERCLA - Comprehensive Environmental Response, Compensation, and Liability Act *Preliminary Assessment *Site Inspection

1 June 2018

Army National Guard

Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA)

Activities at

Camp Grayling, Michigan

5 June 2018

Page 2: Army National Guard Comprehensive Environmental Response ...€¦ · CERCLA - Comprehensive Environmental Response, Compensation, and Liability Act *Preliminary Assessment *Site Inspection

2 June 2018

Who Is Involved?

• Michigan Army National Guard (MIARNG) • ARNG – Installation and Environment Division (IED), Cleanup & Restoration

Branch• US Army Corps of Engineers • Michigan Department of Environmental Quality (MDEQ), Remediation &

Redevelopment Division• AECOM Technical Services, Inc. (Germantown, MD)

• Restoration Advisory Board: Formal public avenue for input into CERCLA process

Page 3: Army National Guard Comprehensive Environmental Response ...€¦ · CERCLA - Comprehensive Environmental Response, Compensation, and Liability Act *Preliminary Assessment *Site Inspection

3 June 2018

ARNG Preliminary Assessment (PA)/ Site Inspection (SI) Overview

Work Phases

CERCLA - Comprehensive Environmental Response, Compensation, and Liability Act

*Preliminary Assessment

*Site Inspection

Remedial Investigation

Feasibility Study

Proposed Plan

Decision Document

Remedial Design

Remedial Action

CERCLA Process*Current stage of activity

Notes: • An interim removal action can be conducted or a No Further Action

determination can be made at any phase• Restoration Advisory Board is typically solicited at RI/FS phase

Page 4: Army National Guard Comprehensive Environmental Response ...€¦ · CERCLA - Comprehensive Environmental Response, Compensation, and Liability Act *Preliminary Assessment *Site Inspection

4 June 2018

Grayling Army Air Field (GAAF)PA Findings

• Reviewed available data and conducted a 3-day site visit February 27-March 1, 2018

• Interviewed current and former Camp Grayling personnel– Environmental staff– Former firefighting personnel– Grayling City Fire Department Chief– Michigan Department of Natural Resources personnel

• Completed visual inspections at Areas of Interest and documented with photographs

• Areas of Interest -“Fire Training Areas” and “Non-Fire Training Areas”

• Final Preliminary Assessment Report becomes part of the Administrative Record that will be available to the public

Page 5: Army National Guard Comprehensive Environmental Response ...€¦ · CERCLA - Comprehensive Environmental Response, Compensation, and Liability Act *Preliminary Assessment *Site Inspection

5 June 2018

Overall GAAF PA Findings &

Areas of Interest (AOI)

Bivouac Area

Northwestern end of Runway 14/32

Building 1194 Ramp

Building 1160

Taxiway D

Southeastern end of Runway 14/32

Between Former MATES and Runway 14/32

Former MATES Location

Camp Grayling Fire Department

Notes: Aqueous Film Forming Foam (AFFF) was used extensively by the military to train for and fight aircraft fires.

Page 6: Army National Guard Comprehensive Environmental Response ...€¦ · CERCLA - Comprehensive Environmental Response, Compensation, and Liability Act *Preliminary Assessment *Site Inspection

6 June 2018

SI Objectives (Sampling)

• Primary Objectives– Confirm the presence/ absence of a release at each potential AOI– Gather data to better understand groundwater flow direction(s)

• Additional Objectives– Presence has been confirmed at the GAAF boundary – Sampling of drinking water is on-going through MDEQ– Check for alternate contamination sources--none known at GAAF

Page 7: Army National Guard Comprehensive Environmental Response ...€¦ · CERCLA - Comprehensive Environmental Response, Compensation, and Liability Act *Preliminary Assessment *Site Inspection

7 June 2018

GAAF Conceptual Site Model

Comparison of AOIs to MDEQ Perfluorooctanesulfonic Acid

(PFOS) and Perfluorooctanoic Acid (PFOA) Heat Map

Source (Heat Map): MIDEQ Tracking Report- Grayling area 05-24-2018 (ppt)

Page 8: Army National Guard Comprehensive Environmental Response ...€¦ · CERCLA - Comprehensive Environmental Response, Compensation, and Liability Act *Preliminary Assessment *Site Inspection

8 June 2018

CERCLA Timeline & Next Steps

CERCLA - Comprehensive Environmental Response, Compensation, and Liability Act

*Preliminary Assessment

*Site Inspection

Remedial Investigation

Feasibility Study

Proposed Plan

Decision Document

Remedial Design

Remedial Action

July 2018: Final Report

Winter 2018: SI Kickoff

Remedial Investigation-Begins Oct 2018• Sampling to achieve a three dimensional

picture of releases• Solicit for Restoration Advisory Board• Risk Assessment

Page 9: Army National Guard Comprehensive Environmental Response ...€¦ · CERCLA - Comprehensive Environmental Response, Compensation, and Liability Act *Preliminary Assessment *Site Inspection

9 June 2018

Contacts

• LTC Adel Johnson– Email: [email protected]– Phone: (703) 601-6818

• Bonnie Packer– Email: [email protected]– Phone: (703) 607-7977

Page 10: Army National Guard Comprehensive Environmental Response ...€¦ · CERCLA - Comprehensive Environmental Response, Compensation, and Liability Act *Preliminary Assessment *Site Inspection

10 June 2018

QUESTIONS?