/JJMtpr Primed on Recycled PaperUNITED STATES ENVIRONMENTAL PROTECTION AGENCYREGION 101200 Sixth AvenueSeattle, WA 98101Reply ToAttn Of: ECL-115Gerald Soonagrook Sr., PresidentNative Village of GambellP.O. Box 90Gambell, Alaska 99742RE:Govemment-to-Govemment Consultation for the NE Cape Air Force Facility,St. Lawrence IslandDear President Soonagrook:We appreciated the opportunity to meet with you in Anchorage on August 8, 2001. Thismeeting provided a good opportunity for EPA to gain a better understanding of your concernsover the NE Cape site as well as the other Formally Used Defense (FUD) site at Gambell. Wefound this meeting to play a valuable role in our govemment-to-govemment consultationconcerning the NE Cape site. The purpose of this letter is to acknowledge many of the concernsyou raised and to outline the next steps EPA will take concerning the NE Cape site.The Villages raised many concerns about the current work being conducted by the U.S.Army Corps of Engineers (ACOE). These concerns include:•The site clean up at the NE Cape site needs to occur much more quickly. Whilethere are many studies being done on the NE Cape site, little is being done toactually clean up the site.•The cancer rates among the native people on St. Lawrence are quite high. Thereis concern that these cancer rates are associated with the NE Cape site.•There is concern that the food supply is contaminated. Of particular concern isthat the fish collected from the Suqi River were contaminated with PCBs, and thatthey might migrate to other areas and be consumed by marine mammals where thePCBs would bioaccumulate. Marine mammals make up a large part of the nativepeople’s diet.•The Native Villages do not have adequate input to the ACOE’s planning for theNE Cape site. Sample plans are almost in their final version when they are madeavailable for comments.•The technical reports produced by the ACOE are difficult for the Villagersunderstand. Without that understanding, the Villagers cannot participate fully in discussions wUSEPA 8F1687171•The Restoration Advisory Board (RAB) meetings are quite long and atinconvenient times. It is also questionable if the ACOE is really trying to addressconcerns.•Nothing is being done about debris that is underground unless there is a release ofhazardous substances, which is difficult to prove.•There is a FUD site at Gambell which includes a lot of buried debris. Some ofthis debris is now at the surface and is posing a safety problem. There is alsoconcern that new homes are being built on top of the debris and it is not known ifthis debris contains hazardous substances.•The ACOE has been unable to locate unexploded ordinance deposited by themilitary in Troutman Lake, at Gambell.In response to these concerns, ERA has agreed to review and evaluate existing reportsand plans on the NE Cape site that were prepared by the ACOE. Because of the limits of ourauthority, our review and evaluation will focus the ACOE’s hazardous waste cleanup activities,not debris removal, health evaluations or petroleum contamination. Once this review iscomplete, EPA will provide a written evaluation to the Villages of Gambell and Savoonga. It isestimated that this will take two to three months. EPA will discuss the ongoing cleanupactivities with the ACOE to determine the schedule for site clean up. EPA will also inquire withthe Alaska Department of Environmental Conservation (ADEC), the current agency overseeingthe ACOE, to learn their perspective on the ACOE’s activities at the NE Cape site.EPA has reevaluated the NE Cape site using the Hazard Ranking System (HRS). Whilethe numerical score did indicate that this site could qualify for the NPL, EPA will need toconsider additional factors to determine whether placement on the NPL is the best approach forcleaning up the site. For the NE Cape site, it will be necessary to determine if EPA involvementwill improve the current activities at the site and promote a quicker cleanup. As was mentionedduring the meeting, even if EPA were to list the site on the NPL, EPA could not provideadditional funding for site investigation and cleanup. The ACOE must continue to provide thefunding for cleanup. The effect of NPL listing is that EPA, with ADEC, would oversee theACOE’s cleanup work at NE Cape.As a federal agency, like EPA, the ACOE also has a unique legal relationship withTribal governments. While EPA is encouraged that the Villages of Gambell and Savoonga havehad the opportunity to interact with the ACOE through the RAB meetings, we encourage theVillages to pursue formal Government to Government Consultations with the ACOE.Again, we appreciated the opportunity to meet with you. Should you have any additionalquestions or concerns regarding consultation or the site please do not hesitate to call me at (206)553-1234, or Michelle Pirzadeh, Associate Director of the Office of Environmental Cleanup, at(206) 553-1272. Joanne LaBaw, the staff person assigned to the site, can be reached at (206)553-2594.Sincerely,-▼Ron KreizenbeckDeputy Regional Administratorcc:Scott Sufficool, EPAMarcia Combes, EPA, Alaska Operations OfficeRichard Porter, EPA Alaska Operations OfficeJerald M. Reichlin, Fortier & Mikko