final environmental assessment, finding of no …...project number: 55829 location: latitude 53.8945...

Unalaska Airport

Safety Improvements

Project Number: 55829

Location: Latitude 53.8945°N, Longitude 166.5408°W Section 34, Township 72 S, Range 117 W

Seward Meridian, USGS Quad Unalaska C-2

Final Environmental Assessment, Finding of No Significant Impact,

and Section 4(f) Individual Evaluation

December 2014

HABS AK, 1-UNAK, 2-C--2 (1985)

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Department of Transportation Federal Aviation Administration

FINDING OF NO SIGNIFICANT IMPACT Unalaska Airport Safety Improvements

DOT&PF Project No. 55829

Purpose and Need The purpose of the proposed project is to mitigate safety risks to people and property caused by flying debris from the Torpedo Building at the Unalaska Airport. The building has deteriorated to the point that debris flies off the building during incidents of severe weather. In addition to the danger from flying material, the exterior walls of the building, which make up most of the flying debris, were constructed out of asbestos-coated metal sheeting. The sheeting is worn down to the point where the asbestos paper is exposed and is creating an additional safety hazard. See the attached photo sheet for progression of building deterioration. Requested Federal Action The Federal action requested by the DOT&PF is FAA approval of the Airport Layout Plan (ALP). The current ALP was conditionally approved on April 10, 2012, and shows the building as “to-be-removed”. However, the conditional approval was limited to the runway safety area, runway extension and runway rehabilitation projects. The approval did not include any other elements in the ALP, including removal of the Torpedo Building.

Proposed Action The Alaska Department of Transportation and Public Facilities (DOT&PF), in cooperation with the Federal Aviation Administration (FAA), is proposing to mitigate safety risks to people and property caused by unsecured debris flying off the Torpedo Bombsight and Utility Shop (Torpedo Building) at the Unalaska Airport. The Unalaska Airport is located on Amaknak Island in the Aleutians, about 800 miles southwest of Anchorage: Section 34, Township 72 S, Range 17 W, Seward Meridian, USGS Quad Unalaska C-2 (Figure 1).

The Proposed Action would consist of the following: • Abatement of hazardous materials including asbestos and lead based paint • Demolition and removal of all building contents, including walls, roof, exterior sheathing,

structural frame, pipes, electrical apparatuses, and other building components (excludes the concrete floor, foundation and underground utilities )

• Fill of any voids below finish floor grade to make the floor level • Removal of all debris from the lot

Reasonable Alternatives Two alternatives, No-Build and Build Alternative, were evaluated in the Final EA for the proposed project. The No-build Alternative would leave the Torpedo Building as-is. The building would continue to deteriorate and remain a safety risk. The continued existence of the Torpedo Building in its current condition would not meet the purpose and need.

Unalaska Airport Safety Improvements December 2014 Finding of No Significant Impact Project No. 55829

The Build Alternative is the Proposed Action. Other alternatives (Section 2.3 of the Final EA) were also considered but dismissed from further consideration because they were infeasible and would not meet the stated purpose and need.

Impact Assessment The Final EA analysis indicates that the Proposed Action would not have significant adverse effects on the resource categories listed in FAA Orders 1050.1B and 5050.4B. The Proposed Action would result in the use, as defined by Section 4(f) of the US Department of Transportation Act, of the Torpedo Building which is a contributing element to the Dutch Harbor Naval Operating Base (NOB) & Fort Mears National Historic Landmark (NHL). The FAA conducted an Individual Section 4(f) Evaluation and determined that the Proposed Action is the only prudent and feasible alternative. The Proposed Action would also result in an adverse effect on the NHL per Section 106 of the National Historic Preservation Act. To mitigate the Section 4(f) use and Section 106 adverse effect, the FAA developed a Memorandum of Agreement (MOA) with the State Historic Preservation Officer (SHPO), and DOT&PF. The National Park Service (NPS), as managers of the NHL, are concurring parties on the MOA. The Proposed Action would result in the disturbance and generation of hazardous waste due to existing contamination in the groundwater, concrete, and siding. A work plan would be developed by the construction contractor and implemented during construction to safely remove and dispose of contaminated material. This waste would be disposed of in accordance with state and federal regulations.

Mitigation and Environmental Commitments The mitigation measures and commitments below would be met to minimize impacts during and after construction of the proposed project. General • The Contractor is responsible for obtaining all necessary permits and clearances for material

sites, disposal sites, and staging areas unless DOT&PF has obtained all necessary permits.

• The Contractor is responsible for creating a traffic control plan and providing advance notice to the public and businesses of construction activities that could cause delays, detours, or affect access to adjacent properties.

Air Quality • Air quality would be maintained through the use of best management practices such as

watering, sweeping, stabilizing construction entrances/exits, and use of equipment emission control devices.

Bald and Golden Eagles • If active bald or golden eagle nests are found within the project area, a primary zone of a

minimum 330 feet will be maintained as an undisturbed habitat buffer around nesting eagles. If topography or vegetation does not provide an adequate screen or separation, the buffer will be

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Unalaska Airport Safety Improvements December 2014 Finding of No Significant Impact Project No. 55829

extended to 0.25 mile, or a sufficient distance to screen the nest from human activities. Within the secondary zone (between 330 and 660 feet), no obtrusive facilities or major habitat modifications shall occur. If nesting occurs in sparse stands of trees, treeless areas, or where activities would occur within line-of-site of the nest, this buffer shall extend up to 0.5 miles. No blasting, logging, or other noisy, disturbing activities within the primary or secondary zones should occur during the nesting period (February 1 – August 31).

Hazardous Materials • All hazardous material will be disposed of in accordance with state and federal laws.

Historic Properties • DOT&PF shall develop Design and Maintenance Guidelines for the remaining contributing

properties of the Dutch Harbor NOB & Fort Mears NHL to aid DOT&PF in the stewardship of historic properties on DOT&PF property.

• DOT&PF shall produce an interpretive display, through coordination with SHPO and NPS, which describes the historic function of the Torpedo Building and compliments other displays in the NHL.

• If cultural, archaeological, or historic sites are discovered during project construction, all work that may impact these resources would stop until DOT&PF consults with SHPO to determine the appropriate corrective action.

Noise • The contractor will make every reasonable effort to minimize construction noise through

abatement measures such as proper maintenance of construction equipment. Storm Water • DOT&PF will prepare an Erosion and Sediment Control Plan during project design and

provide it to the Contractor.

• A DOT&PF approved Storm Water Pollution Prevention Plan, Hazardous Materials Control Plan, and Spill Prevention, Control, and Countermeasure Plan (if applicable) would be implemented in accordance with contract specifications and the Alaska Pollutant Discharge Elimination System Construction General Permit.

Permits and Approvals The following approvals have been obtained:

• Section 106 consultation with SHPO, tribes, and other consulting parties (SHPO concurrence received September 19, 2014)

• Individual Section 4(f) Evaluation Prior to construction, the following must be developed:

• ADEC approved Work Plan to dispose of hazardous material

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Unalaska Airport Safety Improvements December 2014 Final Environmental Assessment Project No. 55829

Table of Contents 1 Proposed Action .................................................................................................................. 1

1.1 Proposed Action .................................................................................................................. 1

1.2 Purpose and Need ............................................................................................................... 1

1.3 Identification of Federal Action .......................................................................................... 1

2 Alternatives ......................................................................................................................... 1

2.1 No-build Alternative ........................................................................................................... 1

2.2 Build Alternative ................................................................................................................. 1

2.3 Alternatives Dropped from Further Consideration ............................................................. 2

2.4 Alternatives Comparison .................................................................................................... 2

3 Affected Environment and Environmental Consequences ................................................. 4

3.1 US Department of Transportation Act Section 4(f) ............................................................ 4

3.2 Hazardous Materials, Pollution Prevention, and Solid Waste ............................................ 5

3.3 Historical, Architectural, Archeological, and Cultural Resources ...................................... 6

4 Summary of Environmental Commitments ........................................................................ 7

5 Scoping ............................................................................................................................... 9

6 List of Preparers .................................................................................................................. 9

7 References ......................................................................................................................... 11

List of Tables Table 1 Alternative Comparison Summary Table 6 List of Preparers List of Figures Figure 1 Location and Vicinity Map Photo Sheet Progression of Building’s Deterioration List of Appendices Appendix A Individual Section 4(f) Evaluation and US DOI Concurrence Appendix B Memorandum of Agreement Appendix C Section 106 Consultation Documents Appendix D Agency and Public Scoping Documents

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Acronyms and Abbreviations

ALP Airport Layout Plan DOT&PF Department of Transportation and Public Facilities FAA Federal Aviation Administration HPC City of Unalaska Historic Preservation Commission MOA Memorandum of Agreement NEPA National Environmental Policy Act NHL National Historic Landmark NHPA National Historic Preservation Act NPS National Park Service NOB Naval Operating Base SHPO State Historic Preservation Office US DOT US Department of Transportation USGS US Geological Survey

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1 Proposed Action 1.1 Proposed Action The Alaska Department of Transportation and Public Facilities (DOT&PF), in cooperation with the Federal Aviation Administration (FAA), is proposing to mitigate safety risks to people and property caused by unsecured debris flying off the Torpedo Bombsight and Utility Shop (Torpedo Building) at the Unalaska Airport. The Unalaska Airport is located on Amaknak Island in the Aleutians, about 800 miles southwest of Anchorage: Section 34, Township 72 S, Range 117 W, Seward Meridian, USGS Quad Unalaska C-2 (Figure 1).

1.2 Purpose and Need The purpose of the proposed project is to mitigate safety risks to people and property caused by flying debris from the Torpedo Building at the Unalaska Airport. The building has deteriorated to the point that debris flies off the building during incidents of severe weather. In addition to the danger from flying material, the exterior walls of the building, which make up most of the flying debris, were constructed out of asbestos-coated metal sheeting. The sheeting is worn down to the point where the asbestos paper is exposed and is creating an additional safety hazard. See the attached photo sheet for progression of building deterioration.

1.3 Identification of Federal Action The Federal action requested by the DOT&PF is FAA approval of the Airport Layout Plan (ALP). The current ALP was conditionally approved on April 10, 2012, and shows the building as “to-be-removed”. However, the conditional approval was limited to the runway safety area, runway extension and runway rehabilitation projects. The approval did not include any other elements in the ALP, including removal of the Torpedo Building.

2 Alternatives 2.1 No-build Alternative The National Environmental Policy Act (NEPA) and Council on Environmental Quality regulations in 40 CFR 1502.14(d) require the inclusion of a No-build Alternative in the analysis for the environmental document. The No-build Alternative would leave the Torpedo Building as-is. The building would continue to deteriorate and remain a safety risk. The continued existence of the Torpedo Building in its current condition would not meet the purpose and need.

2.2 Build Alternative The Build alternative would consist of the following:

• Abatement of hazardous materials including asbestos and lead based paint • Demolition and removal of all building contents, including walls, roof, exterior

sheathing, structural frame, pipes, electrical apparatuses, and other building components (excludes the concrete floor, foundation and underground utilities )


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2.3 Alternatives Dropped from Further Consideration After thorough consideration of various alternatives, the DOT&PF and FAA determined that the only alternative that would meet the project purpose and need is the Build Alternative. Although the alternatives below were determined feasible in 2003, a structural survey in 2014 concluded that the building has likely deteriorated beyond the point of rehabilitation or even stabilization and any alternatives beyond demolition would not meet the purpose and need of mitigating safety risks.

• Short-term stabilization: focus on removing hazardous material and alleviating flying debris with structural stabilization

• Building treatment and reuse: rehabilitation of building for contemporary use while maintaining historic integrity

• Long-term stabilization: this alternative would follow the short-term stabilization

alternative to further protect the integrity of the building’s remains

• Building relocation- reconstruction: demolition of the original site and reconstruction at another location

• Building relocation- ruin: this alternative would be the same as the relocation

alternative above except that it would relocate the building materials as a ruin to another location

• Building demolition (Build Alternative): demolition of the building down to the

concrete foundation slab

• Mid-term stabilization: this alternative would be done after the short-term stabilization if it appeared that long-term stabilization would not immediately follow and would take steps to protect the structural frame and foundation

2.4 Alternatives Comparison Through the NEPA process, alternatives can be measured against each other by comparing how each alternative meets the purpose and need, the potential environmental impacts, and types of permits or approvals required. The analysis in Section 3 evaluates each alternative’s potential impacts to the resource categories listed in FAA Orders 1050.1E independently. Table 1 provides a side-by-side comparison of those impacts for the No-Build and Build alternatives.

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Table 1: Alternatives Comparison Summary

Measure No-Build Alternative Build Alternative

Does the Alternative meet the Purpose and Need? No Yes

Would the proposed project cause a significant impact to the following resources?

Section 4(f) Properties No, however site would continue to deteriorate at an increased rate

No, this alternative would use a protected resource but all measures to minimize harm would be taken.

Hazardous Material No, however material would remain onsite and would continue to be a health and safety risk.

No, all hazardous material would be removed and disposed of in accordance with state and federal laws.

Historic Properties No, however site would continue to deteriorate

No, adverse impacts to the site would be mitigated through the development of a Memorandum of Agreement (MOA).

What permits and/or approvals would be required?

No permits required. Future maintenance activities could require Section 106 and 4(f) approvals.

No permits required. Approvals would be:

• Section 106 and MOA • Section 4(f)

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3 Affected Environment and Environmental Consequences

This section of the EA analyzes the environmental resources affected by and the consequences of each alternative as defined by FAA’s resource categories listed in FAA Orders 1050.1E and 5050.4B. The purpose of the analysis is to determine the potential environmental impacts that each alternative may cause and whether the impacts would be significant. The alternative is measured against the significance thresholds for each resource category as defined by FAA in FAA Orders 1050.1E and 5050.4B. The context and intensity, or significance, of an alternative’s impacts is also measured by comparing the alternative with the No-action Alternative, which serves as a baseline. The following list of resource categories have been determined to be non-issues because they do not exist within the proposed project area or have no potential to be impacted by the proposed action:

• Air Quality • Coastal Resources • Compatible Land Use • Construction Impacts • Farmlands • Floodplains • Natural Resources, Energy Supply, and

Sustainable Energy Noise

• Light Emissions and Visual Impacts • Secondary (Induced) Impacts • Socioeconomic Impacts, Environmental

Justice, and Children’s Environmental Health and Safety

• Water Quality • Wetlands • Wild and Scenic Rivers

3.1 US Department of Transportation Act: Section 4(f) Applicable statutes and executive orders for this resource category include:

• US Department of Transportation (DOT) Act, Section 4(f)

3.1.1 Affected Environment Section 4(f) of the US DOT Act protects publicly owned recreation lands and historic sites, including National Historic Landmarks (NHL) from “use” by federal transportation projects and programs. According to 23 CFR 774.17, “use” of a Section 4(f) property occurs:

(1) When land is permanently incorporated into a transportation facility; (2) When there is a temporary occupancy of land that is adverse in terms of the

statute’s preservation purpose as determined by the criteria in Section 774.13(d); or (3) When there is a constructive use of a Section 4(f) property as determined by the

criteria in Section 774.15. If a project would result in the use of a Section 4(f) property it has to be shown that there is no prudent and feasible alternative to using the property and that the project includes all possible planning to minimize harm resulting from the use. The Torpedo Building is a contributing element to the Dutch Harbor Naval Operating Base (NOB) & Fort Mears NHL. The NOB was the farthest west US Navy base and was the location

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of the most serious air attack on North America in history (NPS, 2014). Additional information on the historical context of the Torpedo Building and NHL can be found in Section 3.3.1. For NHLs, the SHPO and NPS are the Section 4(f) officials with jurisdiction.

3.1.2 Environmental Consequences

No-Build Alternative The No-Build Alternative would not result in a use of the Torpedo Building as defined in 23 CFR 774.17.

Build Alternative Through consultation under Section 106 of the National Historic Preservation Act (NHPA), further discussed in Section 3.3, the FAA found, and the State Historic Preservation Officer (SHPO) concurred, that the proposed project would adversely affect a contributing element of the Dutch Harbor NOB and Fort Meyers NHL. The adverse effect would be permanent in nature and therefore constitutes a permanent incorporation of a Section 4(f) property. In a separate Individual Section 4(f) Evaluation, concurrent with the preparation of this EA, FAA determined that there are no prudent and feasible avoidance alternatives and that all measures to minimize harm were included in the planning and design of the proposed project (Appendix B). The safety issues that would result from prolonging the evaluation process, causing the project to not meet the stated need, also make any option besides immediate demolition not prudent. On November 25, 2014, the US Department of Interior concurred that there is no feasible and prudent alternative to the proposed use of the NHL. During the Section 106 consultation process it was resolved that the most appropriate way to minimize harm to the NHL would be to prepare a Memorandum of Agreement (MOA) between FAA, SHPO, and DOT&PF. The National Park Service (NPS), as managers of the NHL, and the other consulting parties were invited to be concurring parties on the MOA. Only NPS elected to participate. The terms of the MOA include the following commitments:

• DOT&PF shall develop Design and Maintenance Guidelines for the remaining contributing properties of the Dutch Harbor NOB & Fort Mears NHL to aide DOT&PF in the stewardship of historic properties on this DOT&PF property

• DOT&PF shall produce an interpretive display, through coordination with SHPO and NPS, that describes the historic function of the Torpedo Building and compliments other displays in the NHL

A copy of the MOA can be found in Appendix B.

3.2 Hazardous Materials, Pollution Prevention, and Solid Waste Applicable statutes and executive orders for this resource category include:

• Comprehensive Environmental Response, Compensation, and Liability Act, as amended • Resource Conservation and Recovery Act of 1976, as amended • EO 12088, Federal Compliance with Pollution Control Standards

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3.2.1 Affected Environment The soil and groundwater on site at the Torpedo Building (Hazard ID 1328) is contaminated by diesel-range petroleum hydrocarbons and the concrete floor contains leachable lead (ADEC, 2014). In 2001 a large amount of contaminated sediment was removed from the site. The 2003 structural assessment also found that the exterior walls and siding are made from asbestos-coated metal. At the time of the report, the siding material was in poor condition and was worn down to the asbestos paper on the exterior of the walls. The 2001 clean-up did not abate hazardous building materials such as the asbestos and lead paint.


No-Build Alternative The No-Build Alternative would not generate, disturb, transport or treat, or dispose of hazardous waste. The existing safety issue of on-site hazardous material would remain and would not be abated. Future maintenance may be required to remove hazardous materials.

Build Alternative The Build Alternative would result in the disturbance and generation of hazardous waste due to existing contamination in the groundwater, concrete, and siding. A work plan would be developed and implemented during construction to safely remove and dispose of contaminated material. This waste would be disposed of in accordance with state and federal regulations.

3.3 Historical, Architectural, Archeological, and Cultural Resources Applicable statutes and regulations for this resource category include:

• National Historic Preservation Act (NHPA), as amended • EO 13175 Consultation and Coordination with Indian Tribal Governments

3.3.1 Affected Environment The Torpedo Building is a contributing element to the Dutch Harbor NOB & Fort Mears NHL. The NOB was the farthest west Navy base and was the location of the most serious air attack on North America in history (NPS, 2014). The Torpedo Building was constructed in 1942 and was operational during the campaign against the Japanese attacks on the Aleutian Islands (Hyer, 2004). The Torpedo Building was constructed as part of a contract that included work at three Alaska Navy bases and is one of two remaining World War II torpedo buildings in the state of Alaska designed by internationally-renowned German-immigrant architect Albert Kahn. The building was only used for its original purpose for 11 months, until the Dutch Harbor NOB was reclassified as a Naval Air Facility and then decommissioned in 1947.


No-Build The No-Build Alternative would have no effect on the Torpedo Building or Dutch Harbor NOB & Fort Mears NHL. The Torpedo Building will continue to deteriorate if left in its current condition.

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Build Alternative Coordination with the NPS, a consulting party, was ongoing prior to and throughout the project development process. Prior to formal consultation as required by state and federal law, DOT&PF hosted numerous meetings with SHPO and NPS to discuss the current condition of the building and the best way to move forward with the proposed project. During these meetings it was acknowledged by both SHPO and NPS that regardless of the method selected to improve airport safety, any work or modification of the building would result in an adverse effect to a historic property. It was agreed that the best way to mitigate impacts would be through the development of an MOA and that the best mitigation measure within the MOA would be for DOT&PF to develop Design and Maintenance Guidelines. In February 2014, DOT&PF formally consulted with the Alaska Office of History and Archeology and other consulting parties (National Park Service, Unalaska Historic Preservation Commission, Qawalangin Tribe, and Ounalashka Corporation) under the Alaska Historic Preservation Act (AS 41.35.070) on the removal of the Torpedo Building as a state-funded project. It was determined that the demolition of the Torpedo Building would have an adverse effect on the NHL. In cooperation with OHA and the NPS, DOT&PF developed a MOA to mitigate adverse effects on the NHL that would result from the demolition of the torpedo building. The Ounalashka Corporation was involved in the review of the MOA yet declined to be a concurring party. At the time of the consultation with OHA and preparation of the MOA, it was anticipated that FAA would not be involved in the undertaking. It was later determined , before the MOA could be signed, that the proposed project is a Federal action as it requires FAA approval, constitutes and undertaking as defined in 36 CFR 8020.16(y), and further consultation under Section 106 of the NHPA was required. On August 24, 2014, FAA, in cooperation with DOT&PF, submitted a finding of adverse effect per Section 106 of the NHPA to SHPO, the Advisory Council of Historic Places (ACHP), and the other consulting parties. On September 19, 2014, SHPO concurred with the finding and on September 23, 2014, ACHP declined to participate in the resolution of the adverse effect. The FAA, DOT&PF, SHPO, and NPS moved forward with developing the MOA. See Section 3.1.2 for additional information on the MOA. All Section 106 consultation documents can be found in Appendix C. A copy of the MOA can be found in Appendix B.

4 Summary of Environmental Commitments The mitigation measures and commitments below would be met to minimize impacts during and after construction of the proposed project. These conditions apply only to the Build Alternative as the No-Build Alternative does not require construction activities and does not require environmental commitments or mitigation. All commitments will be part of the construction contract specifications. General • The Contractor is responsible for obtaining all necessary permits and clearances for materials

sites, disposal sites, and staging areas unless DOT&PF has obtained all necessary permits.

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• The Contractor is responsible for creating a traffic control plan and providing advance notice to the public and businesses of construction activities that could cause delays, detours, or affect access to adjacent properties.

Air Quality • Air quality would be maintained through the use of best management practices such as

watering, sweeping, stabilizing construction entrances/exits, and use of equipment emission control devices.

Bald and Golden Eagles • If active bald or golden eagle nests are found within the project area, a primary zone of a

minimum 330 feet will be maintained as an undisturbed habitat buffer around nesting eagles. If topography or vegetation does not provide an adequate screen or separation, the buffer will be extended to 0.25 mile, or a sufficient distance to screen the nest from human activities. Within the secondary zone (between 330 and 660 feet), no obtrusive facilities or major habitat modifications shall occur. If nesting occurs in sparse stands of trees, treeless areas, or where activities would occur within line-of-site of the nest, this buffer shall extend up to 0.5 miles. No blasting, logging, or other noisy, disturbing activities within the primary or secondary zones should occur during the nesting period (February 1 – August 31).

Hazardous Materials • All hazardous material will be disposed of in accordance with state and federal laws.

Historic Properties • DOT&PF shall develop Design and Maintenance Guidelines for the remaining contributing

properties of the Dutch Harbor NOB & Fort Mears NHL to aide DOT&PF in the stewardship of historic properties on DOT&PF property.

• DOT&PF shall produce an interpretive display, through coordination with SHPO and NPS, which describes the historic function of the Torpedo Building and compliments other displays in the NHL.

• If cultural, archaeological, or historic sites are discovered during project construction, all work that may impacts these resources would stop until DOT&PF consults with SHPO to determine the appropriate corrective action.

Noise • The contractor will make every reasonable effort to minimize construction noise through

abatement measures such as proper maintenance of construction equipment. Storm Water • DOT&PF will prepare an Erosion and Sediment Control Plan during project design and

provide it to the Contractor.

• A DOT&PF approved Storm Water Pollution Prevention Plan, Hazardous Materials Control Plan, and Spill Prevention, Control, and Countermeasure Plan (if applicable) would be

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implemented in accordance with contract specifications and the Alaska Pollutant Discharge Elimination System Construction General Permit.

5 Scoping Throughout the environmental process, federal, state and local regulatory agencies, local governments, tribal organizations, and the public were consulted to identify concerns or questions regarding the environmental effects and the project design. This section does not include formal discussions required by other environmental special purpose laws such as Section 106. See Appendix D for all agency and public scoping documents.

5.1 Agency Scoping The Section 106 Finding of Adverse Effect letters discussed in Section 3.3.2 included language requesting additional information from state, federal, and local agencies on the proposed project. On September 25, 2014, in response to the scoping efforts, The City of Unalaska Historic Preservation Commission (HPC) passed a resolution (2014-01) supporting the demolition of the Torpedo Building to mitigate safety risks. The HPC suggested mitigation adverse effects on the NHL by 1) an interpretive marker for the Torpedo Building and 2) salvaging any materials of historic significance for preservation and public display. These suggestions were considered in the development of the MOA. The HPC also sent a copy of the City of Unalaska Resolution 2014-26, approved February 25, 2014, in which the City requested that the State of Alaska remove the building.

5.2 Public Scoping A Notice of Intent to Begin Engineering and Environmental Studies was posted in the Alaska Dispatch News (September 5, 2014) and the Bristol Bay Times- Dutch Harbor Fisherman (September 14, 2014). The notice was also posted on the DOT&PF Online Public Notices Website on September 2, 2014.

5.3 Draft EA and Section 4(f) Review The Draft EA was made available to the public and resource agencies for review. A Notice of Availability was published on the DOT&PF Online Public Notice website, and in the Bristol Bay Times- Dutch Harbor Fisherman and Alaska Dispatch News. An email was also sent to resource agencies. A link to the online Draft EA was provided in both the public and agency notices of availability. Copies of the Draft EA were sent to the City of Unalaska and the Alaska Resource Library & Information Services at the University of Alaska Anchorage campus. Copies of the document are available for review in the DOT&PF Preliminary Design and Aviation Design sections. Both the public and agencies were provided a 30 day comment opportunity from the date of posting and notice of availability. The US DOI submitted comments on the Draft EA with their concurrence on the Section 4(f) evaluation on November 25, 2014. Their only comment was that the Range in the project location details needed corrected from 17 to 117 W. No other comments were received on the Draft EA.

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6 List of Preparers The people primarily responsible for developing or the review of this EA are listed below in Table 6.0.

Table 6.0 List of Preparers

Name Title and Role Contribution Relevant Experience

TaraLyn Stone Environmental Protection Specialist, FAA

Primary Author 4 years environmental impact analysis experience

Aaron Hughes, P.E. Project Manager, DOT&PF

Design Support 8 years aviation design experience

Brian Elliott Regional Environmental Manager

Content Review 12 years environmental impact analysis experience

Kathleen Shea Environmental Impact Analyst, DOT&PF


Katrina Moss Community Planner, FAA


Leslie Grey Lead Environmental Protection Specialist, FAA

Content Review and Environmental Compliance

19 years environmental impact analysis experience

Lita Lubitish-White Drafter, DOT&PF Figures 20+ years drafting experience

Patrick Zettler, P.E. Engineering Project Manager, FAA

Content Review 25 years engineering and project management

Valerie Gomez Cultural Resource Specialist, DOT&PF

Content Review 9 years Cultural Resource Management experience

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7 References Alaska Department of Environmental Conservation (ADEC), 2014. Spill Prevention and Response Contaminated Sites Database: Cleanup Chronology Report for Dutch Hbr-Airport Torpedo Building (Hazard ID 1328). Accessed: August 19, 2014 Hyer, 2003. Building Condition Assessment/Materials Investigation: Torpedo Bombsite and Utility Shop, Unalaska Airport, Dutch Harbor, Alaska. Unpublished. Hyer, 2004. Historic Investigation and Preservation Alternatives Report: Torpedo Bombsite and Utility Shop, Unalaska Airport, Dutch Harbor, Alaska. Unpublished. National Parks Service, 2014. National Historic Landmarks Program: Dutch Harbor NOB and For Mears. http://tps.cr.nps.gov/nhl/detail.cfm?ResourceId=1913&ResourceType=District. Accessed: August 19, 2014 PDC, Inc, 2014. Unalaska Airport Torpedo & Bombsite Workshop: Structural Condition

Assessment of Existing Torpedo Building. Unpublished. Appended to Section 4(f) Evaluation in Appendix A.

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Figures

Figure 1 Location and Vicinity Map

Photo Sheet: Progression of Building’s Deterioration

Photo Sheet Progression of Building’s Deterioration

Unalaska Airport Safety Improvements: Torpedo Bombsight and Utility Shop\

Images 1 and 2: HABS AK, 1-UNAK, 2-C-(3 of 4) and (4 of 4), origional building design

Image 3: HABS AK, 1-UNAK, 2-C—3; building condition in 1985

Image 4: Building condition 2013


Image 6: Wind damage 2014


Image 8: DOT&PF Maintenance and Opperations removing loose debris from the building in August 2014

Image 9: Building after debris was removed in August 2014

Appendix A Individual Section 4(f) Evaluation

And US DOI Concurrence

Individual Section 4(f) Evaluation Unalaska Airport Safety Improvements

DOT&PF Project No. 55829

December 2014

Prepared for and by: US Department of Transportation Federal Aviation Administration

222 West 7th Avenue Anchorage, AK 99513-7587

On behalf of the sponsor: State of Alaska

Department of Transportation and Public Facilities Central Region

P.O. Box 196900 Anchorage, AK 99519-6900

Unalaska Safety Improvements Individual Section 4(f) Evaluation Project No. 55829 December 2014

Table of Contents 1.0 Project Description........................................................................................................... A-1

1.1 Section 4(f) Background ................................................................................................. A-1 1.2 Proposed Action .............................................................................................................. A-1

2.0 Purpose and Need ............................................................................................................ A-1 3.0 Description of Section 4(f) Property ................................................................................ A-2

3.1 Historic Context and Applicability ................................................................................. A-2 3.2 Structural Integrity .......................................................................................................... A-2

4.0 Alternatives Analysis ....................................................................................................... A-3 4.1 Section 4(f) Use .............................................................................................................. A-3 4.2 Avoidance Alternatives ................................................................................................... A-3

5.0 Measures to Minimize Harm ........................................................................................... A-4 6.0 Coordination with Officials with Jurisdiction.................................................................. A-5 7.0 References ........................................................................................................................ A-6 Figures and Images Figure 1: Location and Vicinity Map Photo Sheet: Progression of Building Deterioration Attachments Airport Torpedo & Bombsite Workshop: Structural Condition Assessment of Existing Torpedo Building (2014)

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1.0 Project Description

1.1 Section 4(f) Background Section 4(f) of the Department of Transportation Act of 1996 (as amended), 49 United States Code (U.S.C.) §303(c), states:

The Secretary (Secretary of Transportation) may approve a transportation program or project (other than any project for a park road or parkway under Section 204 of Title 23) requiring the use of publicly owned land of a public park, recreation area, or wildlife and waterfowl refuge of national, State, or local significance, or land of an historic site of national, State, or local significance (as determined by the Federal, State, or local officials having jurisdiction over the park, area, refuge, or site) only if:

(1) There is no prudent and feasible alternative to using that land; and (2) The program or project includes all possible planning to minimize

harm to the park, recreation area, wildlife and waterfowl refuge, or historic site resulting from the use.

The purpose of this Individual Evaluation is to show that the proposed project satisfies these two conditions. To complete this evaluation, the Federal Aviation Administration (FAA) uses Federal Highway Administration (FHWA) regulations (23 Code of Federal Regulations [CFR] 774) as guidance on implementing Section 4(f) impact analysis and documentation.

1.2 Proposed Action The Alaska Department of Transportation and Public Facilities (DOT&PF), in cooperation with the Federal Aviation Administration (FAA), is proposing to mitigate safety risks caused by flying debris by demolishing the Torpedo Bombsight and Utility Shop (Torpedo Building) at the Unalaska Airport. The Unalaska Airport is located on Amaknak Island in the Aleutians, about 800 miles from Anchorage: Section 34, Township 72 S, Range 117 W, Seward Meridian, USGS Quad Unalaska C-2 (Figure 1). Work associated with the removal of the Torpedo Building would consist of the following:

• Abatement of hazardous materials including asbestos and lead based paint • Demolition and removal of all building contents, including walls, roof, exterior

sheathing, structural frame, pipes, electrical apparatuses, and other building components (excludes the concrete floor, foundation and underground utilities )


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2.0 Purpose and Need The purpose of the proposed project is to mitigate safety risks to people and property caused by flying debris from the Torpedo Building at the Unalaska Airport. The building has deteriorated to the point that debris flies off the building during incidents of severe weather. In addition to the danger from flying material, the exterior walls of the building, which make up most of the flying debris, were constructed out of asbestos-coated metal sheeting. The sheeting is worn down to the point where the asbestos paper is exposed and is creating an additional safety hazard. See the attached photo sheet for progression of building deterioration.

3.0 Description of Section 4(f) Property

3.1 Historic Context and Applicability As stated above, Section 4(f) applies to historic sites of national, State, or local significance. The Torpedo Building is a contributing element to the Dutch Harbor Naval Operating Base (NOB) & Fort Mears National Historic Landmark (NHL). The NOB was the farthest west Navy base and was the location of the most serious air attack on North America in history (NPS, 2014). The building was constructed in 1942 and was operational during the campaign against the Japanese attacks on the Aleutian Islands (Hyer, 2004). The Torpedo Building was constructed as part of a contract that included work at three Alaska Navy bases and is one of two remaining World War II torpedo buildings in the state of Alaska designed by internationally-renowned German-immigrant architect Albert Kahn. The building was only used for its original purpose for 11 months, until the Dutch Harbor NOB was reclassified as a Naval Air Facility and then decommissioned in 1947.

3.2 Structural Integrity The Torpedo Building was left to the elements and not maintained after its period of significance (for a full chronology of building ownership and uses after 1942 see the Hyer 2004 Historic Investigation report). In 1991 the building was released to DOT&PF by the Ounalashka Corporation and was used for storage until 2001. A site assessment at that time found that the building material, groundwater, concrete floor, and sediment around the Torpedo Building were contaminated by various hazardous materials (ADEC, 2014). Some of the hazardous waste was removed in 2001 but the clean-up did not include the abatement of the building material. The building was also listed in “poor condition” in the 1991 site assessment report. A structural assessment in 2003 found that the building’s structural frame and foundation were sound yet the exterior, roof, and sheathing were safety hazards due to deterioration and flying debris. There is a documented history of debris flying off the building during incidents of severe weather. During a windstorm on February 7, 2014, large pieces of lumber and debris flew off the building into cars parked in an adjacent parking lot. The deterioration of the exterior walls over time has exposed the steel structure to the elements. In June 2014, DOT&PF contracted the services of a Structural Engineer to assess the current condition of the Torpedo Building. The survey found that nearly every structural member had

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some level of corrosion (PDC, 2014). The worst corrosion was occurring where the steel frame was cast against or into concrete. The steel has been compromised in several key locations. The metal siding and roofing help provide lateral stability and removing the siding or roofing could compromise the lateral stability. The report concluded that in its current condition the building would likely have a major structural failure in the near future. In August 2014, to address the immediate issues caused by flying debris, DOT&PF maintenance and operations staff removed loose siding and roofing from the building.

4.0 Alternatives Analysis

4.1 Section 4(f) Use According to 23 CFR 774.17, “use” of a Section 4(f) property occurs:

(4) When land is permanently incorporated into a transportation facility;

(5) When there is a temporary occupancy of land that is adverse in terms of the statute’s preservation purpose as determined by the criteria in Section 774.13(d); or

(6) When there is a constructive use of a Section 4(f) property as determined by the

criteria in Section 774.15. Pursuant to 36 CFR 800.5(d)(2), implementing regulations of Section 106 of the National Historic Preservation Act (NHPA), the FAA has found, and the SHPO has concurred, that the proposed project would adversely affect a contributing element of the Dutch Harbor NOB and Fort Meyers NHL. The adverse effect would be permanent in nature and therefore constitutes a permanent incorporation of a Section 4(f) property.

4.2 Avoidance Alternatives To proceed with the proposed project, it must be shown that there are no prudent and feasible avoidance alternatives. Under FAA Order 5050.4B, paragraph 1007.e(5)(a), a project can be eliminated if it might be feasible or technically possible, but not rational (prudent) when one considers its safety, policy, environmental, social, or economic consequences. After thorough consideration of various preservation alternatives, the DOT&PF and FAA determined that the only alternative that would meet the project purpose and need is the Proposed Action.

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The 2003 building condition assessment, and subsequent addendum, evaluated the following alternatives:

• Short-term stabilization: focus on removing hazardous material and alleviating flying debris with structural stabilization

• Building treatment and reuse: rehabilitation of building for contemporary use while maintaining historic integrity

• Long-term stabilization: this alternative would follow the short-term stabilization

alternative to further protect the integrity of the building’s remains

• Building relocation- reconstruction: demolition of the original site and reconstruction at another location

• Building relocation- ruin: this alternative would be the same as the relocation

alternative above except that it would relocate the building materials as a ruin to another location

• Building demolition: demolition of the building down to the concrete foundation slab

(current proposed action)

• Mid-term stabilization: this alternative would be done after the short-term stabilization if it appeared that long-term stabilization would not immediately follow and would take steps to protect the structural frame and foundation

A “no-action” alternative was not explicitly evaluated because it would not meet the purpose and need. Due to the rapid deterioration of the building no evaluation was necessary to show that complete avoidance of the section 4(f) property was neither feasible nor prudent. None of the alternatives evaluated in 2003 were substantially different enough in cost or level of impact to dismiss them from being prudent and feasible at the time. Although the remaining alternatives were determined feasible in 2003, the most recent structural survey shows that the building has likely deteriorated beyond the point of rehabilitation or even stabilization. The removal of debris from the building in August 2014 also removed some of the structural stability. Any alternative beyond immediate demolition is unfeasible due to the lack of structural stability and increased the potential for a failure of the structure in the near future. The safety issues that would result from prolonging the evaluation process, causing the project to not meet the stated need, also make any option besides immediate demolition not prudent.

5.0 Measures to Minimize Harm Per 23 CFR 774.3, if there are no feasible and prudent alternatives that avoid the Section 4(f) property, then the Administration may approve, from among the remaining alternatives that use the Section 4(f) property, only the alternative that causes the least overall harm to the Section

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4(f) property. The factors to be considered for an analysis of harm relative to a Section 4(f) property are defined in 23 CFR 774.3 (c)(1). Given that the Proposed Action is the only alternative that is feasible and prudent, a least overall harm analysis was not conducted for this Section 4(f) Evaluation. It was determined early in the project development process, through consultation as described in Section 6.0, that the most appropriate way to minimize harm to the NHL would be to prepare a Memorandum of Agreement (MOA) between DOT&PF, FAA, and the State Historic Preservation Office (SHPO). The National Park Service (NPS), as managers of the NHL, were invited to sign. The terms of the MOA include the following commitments:

• DOT&PF shall develop Design and Maintenance Guidelines for the remaining contributing properties of the Dutch Harbor NOB & Fort Mears NHL to aide DOT&PF in the stewardship of historic properties on DOT&PF property

• DOT&PF shall produce an interpretive display, through coordination with SHPO and NPS, that describes the historic function of the Torpedo Building and compliments other displays in the NHL

6.0 Coordination with Officials with Jurisdiction Coordination with the National Parks Service, Official with Jurisdiction, has been ongoing prior to and throughout the project development process. Prior to formal consultations as required by state and federal law, DOT&PF hosted numerous meetings with SHPO and NPS to discuss the current condition of the building and the best way to move forward with the proposed project. During these meetings it was acknowledged by both SHPO and NPS that regardless of the method selected to improve airport safety, any work or modification of the building would be an adverse effect and the best way to mitigate impacts would be through the development of an MOA. It was the recommendation of the NPS, and SHPO agreed, that the best mitigation measure within the MOA would be for DOT&PF to develop a Design and Maintenance Guide. In February 2014, DOT&PF formally consulted with the Alaska Office of History and Archeology (OHA) on the removal of the building as a state-funded project. At the time it was anticipated that FAA would not be involved in the undertaking. It was determined that the demolition of the Torpedo Building would have an adverse impact on the NHL. In cooperation with OHA and consulting parties, DOT&PF developed a MOA to mitigate adverse impacts on the NHL from the demolition of the torpedo building. Before the MOA could be signed it was determined that the proposed project is a Federal action as it requires FAA approval, constitutes and undertaking as defined in 36 CFR 8020.16(y), and further consultation under Section 106 of the NHPA was required. In August 2014, FAA, in cooperation with DOT&PF, submitted a finding of adverse effect per Section 106 to SHPO and other consulting parties. On September 19, 2014, SHPO concurred with the finding and all consulting parties moved forwards with developing the MOA. The MOA can be found in Appendix B of the Draft Environmental Assessment.

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7.0 References Alaska Department of Environmental Conservation (ADEC), 2014. Spill Prevention and Response Contaminated Sites Database: Cleanup Chronology Report for Dutch Hbr-Airport Torpedo Building (Hazard ID 1328). Accessed: August 19, 2014 Hyer, 2003. Building Condition Assessment/Materials Investigation: Torpedo Bombsite and Utility Shop, Unalaska Airport, Dutch Harbor, Alaska. Unpublished. Hyer, 2004. Historic Investigation and Preservation Alternatives Report: Torpedo Bombsite and Utility Shop, Unalaska Airport, Dutch Harbor, Alaska. Unpublished. National Parks Service, 2014. National Historic Landmarks Program: Dutch Harbor NOB and For Mears. http://tps.cr.nps.gov/nhl/detail.cfm?ResourceId=1913&ResourceType=District. Accessed: August 19, 2014 PDC, Inc, 2014. Unalaska Airport Torpedo & Bombsite Workshop: Structural Condition Assessment of Existing Torpedo Building. Unpublished.

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Figures

Figure 1 Location and Vicinity Map

Photo Sheet: Progression of Building’s Deterioration

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DATE:

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PRELIMINARY DESIGN ANDENVIRONMENTAL GROUP

STATE OF ALASKADEPARTMENT OF TRANSPORTATION

AND PUBLIC FACILITIES

NTS

8/21/2014

K. SHEALOCATION & VICINITY MAP

PROJECT NO. 55829

UNALASKA, ALASKA

FIGURE 1

LOCATION MAP

UNALASKA AIRPORT SAFETYIMPROVEMENT PROJECT

LOCATIONOF PROJECT

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Photo Sheet Progression of Building’s Deterioration

Unalaska Airport Safety Improvements: Torpedo Bombsight and Utility Shop\

Images 1 and 2: HABS AK, 1-UNAK, 2-C-(3 of 4) and (4 of 4), origional building design

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Image 3: HABS AK, 1-UNAK, 2-C—3; building condition in 1985


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Image 8: DOT&PF Maintenance and Opperations removing loose debris from the building in August 2014

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Image 9: Building after debris was removed in August 2014

UUNALASKA AIRPORT TORPEDO & BOMBSIGHT WORKSHOP

STRUCTURAL CONDITION ASSESSMENT OF

EXISTING TORPEDO BUILDING

July 2014

Prepared for: Alaska Department of

Transportation & Public Facilities 2200 East 42nd Avenue

Anchorage, Alaska 99508

Prepared by: PDC INC. ENGINEERS

1028 Aurora Drive Fairbanks, Alaska 99709

T: 907.452.1414 F: 907.456.2707

14067FB

Unalaska Torpedo Building June 2014Structural Condition Assessment Report

PDC Inc. Engineers Page 1

INTRODUCTION

This report summarizes the findings of structural condition assessment of an existing WWII era torpedo building located at the Unalaska Airport. A site visit was made June 26th, 2014 to observe and record the structural condition and corrosion of the structure.

The structural condition assessment was requested in response to a recent major wind storm that scattered loosely attached or unattached components of the building and caused significant damage to property around the building due to impact from the flying debris. The building has not been maintained in several decades and materials such as siding and roofing become loose during the frequent heavy wind events; the potential for building components to become airborne has been identified as a risk to persons and property. The purpose of this investigation is to determine if the structure would remain a safety hazard to people and property after removing all building materials except for the concrete foundation system and the primary structural steel framing system.

The intent of this report is to provide a general description of existing building condition, a thorough inspection and analysis would be required to determine actual stresses and failure modes. This report is provided to comment on the general safety of the building as a whole and it does not discuss safety concerns of individual components, nor does it discuss the feasibility of any repair or stabilization.

TORPEDO BUILDING CONFIGURATION

The current structure measures approximately 121’-0” x 71’-8”. The structure is framed with structural steel and is supported laterally by steel moment frames in the North/South direction; steel braced frames and concrete walls support the building laterally in the East/West direction. A 30’-0” wide high bay with an eave height of approximately 26’-6” runs lengthwise down the center of the building. Crane rails run down both sides of the high bay at an elevation of 19’-8”. Lower roofs with an eave height of approximately 14’-0”are positioned on either side of the high center bay; reference photos taken during our site visit, specifically Figure 1 and Figure 2. Excerpts from the original design drawings are included at the end of this report for reference.

SITE OBSERVATIONS

The structural assessment was limited to the concrete walls and exposed foundation elements, structural steel roof beams, purlins, columns, braces and associated connections. The assessment did not look at any architectural, mechanical, or electrical components.

Foundation

The majority of the foundation was unavailable for inspection because it exists below ground. However, the concrete that was visible appeared to be in relatively good condition with mostly minor cracking and weathering; no significant cracking or spalling of the concrete was observed. It seems a reasonable assumption to state that the existing foundation for this building remains in reasonably good condition. We could not verify whether significant differential settlement had taken place without the proper instruments available to check for a level condition of floor slab and foundation elements.



Structural Steel Gravity System

Nearly every structural member underwent some level of corrosion. Corrosion ranged from mild to severe. The most notable locations of severe corrosion occurred where the steel framing was cast against or into concrete.

Several column bases have undergone significant corrosion and delamination and consequently have a significantly reduced section estimated at 25% or less of original capacity, reference Figure 3 and Figure 4. Columns around the perimeter have been largely exposed to the weather since most of the siding and practically all of the windows have been compromised. A concrete wall extends 4’-6” above finished floor around the perimeter of the building and the exterior columns are partially embedded into the exterior concrete. It appears that the porous nature of concrete has helped to create a moist condition at the column bases that has accelerated corrosion. The flanges of several columns were noted to have disintegrated away until almost no steel remains in the flange; the thickness of the web is difficult to measure using conventional means, however evidence of significant delamination was observed. Interior column bases experienced similar corrosion although usually not as severe, reference Figure 5 and Figure 6. It appears that the interior slab floods with regular rain events and most of the corrosion can likely be attributed to the damp conditions inside the building. In general, the condition of interior and exterior columns improved above the bases where moisture was allowed to drain freely, even in places exposed to weather.

Roof beams and purlins experienced intermittent corrosion which is likely directly related to the condition of the roof system, reference Figure 7 and Figure 8. Roof purlins that had a moisture retaining wood nailer attached to the top flange appeared to experience more corrosion than those roof beams that had a gap between the steel and the roof decking. Roof beams that had a concrete wall cast below appeared to experience the highest corrosion with a corresponding significant reduction in carrying capacity. All roof beams acting along the numbered gridlines are assumed to be part of the lateral force resisting system, reference the original design drawings for grids. Significant delamination was noted on the flanges when roof beams were cast against concrete, reference Figure 9 and Figure 10.

Structural Steel Lateral System

The exact design methodology for the lateral force resisting system in the East/West direction for this structure is not well understood: bracing exists along Grid A and Grid B between Grids 6 and 7, there exists a concrete wall along grid C between Grids 5 and 6, but no bracing or shear walls exist along Grid D. When different bracing types are present, and the center of rigidity of the building is offset from the center mass of the building, a twisting motion is created and it imposes additional torsional loads on the lateral system further complicating the analysis. A conventional load path for lateral loads could not be determined in the East/West direction.

Moment frames were not identified in the original structural drawings available for our review, but based on the type of connections observed, it is assumed that the moment frames span all three bays in the North/South direction. The flanges of many of the roof beams that form part of the moment frames in the North/South direction have undergone significant delamination. Although the roof beams in the



high bay could not be inspected directly, they appeared to be in the range of mild to moderately corroded. It seems likely that the steel moment frames have some reasonable measure of remaining capacity for the cases of mild or moderate corrosion. Locations of severe corrosion are not likely to be able to continue contributing to the lateral force resisting system of this structure.

The braced frame along Grid A was constructed of steel angle shapes and has been cast into the concrete similar to the columns. One leg of the angle extends into the concrete and could not be inspected; the other leg of the angle was flush with the surface of the concrete but had completely corroded away, reference Figure 11. It is likely that the heavy gauge corrugated galvanized metal siding has been contributing to the lateral stability of the building along Grid A, and also along Grid D where no bracing exists. The remaining braced frame is interior to the building and has experienced moderate corrosion.

EXPECTED BUILDING PERFORMANCE

The structural condition assessment revealed many areas of the building’s structural framing system have undergone significant corrosion.

Current Condition

It seems unlikely that the building would pass a structural analysis of conventional methods under its current condition and before any prescribed modifications. Many areas of the structure have undergone significant corrosion and subsequently have a reduced capacity. It is expected that this building will continue to deteriorate at an accelerated rate as more of the protecting elements fail and the steel becomes more exposed. It seems very likely that this building will begin to experience failure of some of the major structural components under expected wind and/or snow loads in the near future.

Structural Framing without Components

Removing the siding, roofing, along with architectural components would reduce or eliminate a majority of the imposed gravity and lateral loads on the building; however, a comprehensive analysis would be required to determine the stresses in the highly irregular steel sections given the significantly reduced areas of some of the major structural components.

Locations where the columns are embedded in the perimeter concrete wall have experienced significant corrosion. Moment frames resist lateral loads by the stiffness of the connections; connection points are required to develop the bending strength of the attaching members or the connections become the limiting element. Since the columns were cast into the perimeter wall, they were likely designed with a very rigid connection at the base. The corrosion at the base of the column creates a very weak point which causes the column to rotate more than originally anticipated. The increased base rotation will require the top of column-to-roof beam connections to take a majority of the bending imposed from the lateral loads. The increased rotation at the base could cause the compromised column to yield at the base and undergo premature failure under combined lateral and gravity loads.



The lateral bracing interior of the building has fared reasonably well, however the lateral bracing at the perimeter along Grid A has deteriorated almost completely. There does not appear to be any roof bracing between Grid A and Grid B, nor Grid C and Grid D. It seems likely that the roofing and siding are involuntarily contributing to the lateral stability along Grid D and Grid A, and removing it may create an unstable condition. Without any form of bracing or shear walls, the exterior columns will be expected to resist lateral loads as cantilevered columns. Considering that several of the columns have severely compromised flange sections, it does not seem reasonable that they would have the strength required to resist bending in the minor axis. Removing the building components will also expose the major structural framing to the elements, accelerating corrosion. It does not seem sensible to consider this building safe and sound without a rigorous analysis.

SUMMARY

A comprehensive analysis would be required to determine actual stress and failure modes of highly compromised sections. Measurements of remaining steel thickness with all compromised steel removed would be required to build an analytical model to numerically analyze the structural performance.

The steel has been compromised in several key locations. Many of the moment frames have been compromised at column bases and at some roof beams. Key bracing is also missing that now requires the columns to resist loads in minor axis bending. It appears that the metal siding and roofing are acting as contributing members in the lateral stability of this structure; removing siding or roofing could compromise the lateral stability. Without a well-defined load path, and considering the significantly compromised sections at column bases of moment resisting frames, this building should not be considered safe.



Figure 1 – South East Building Exterior

Figure 2 – North West Building Exterior

Figure 3 – Column 2D, Common Exterior Column Base

Figure 4 – Column 2D Exterior Flange Corrosion

Figure 5 – Typical Interior Column, note severe corrosion at column base

Figure 6 – Typical Interior Column Corrosion



Figure 7 – Common Purlin Corrosion

Figure 8 – Common Purlin Corrosion

Figure 9 – Typical Roof Beam Against Concrete

Figure 10 – Typical Roof Beam Against Concrete

Figure 11 – Deteriorated Angle Bracing

Appendix B Memorandum of Agreement

Appendix CSection 106 Consultation

Finding of Adverse Effect Letter to SHPO (see consulting parties section of letter for distribution list, letter also sent to ACHP) C-1

SHPO Concurrence C-9

ACHP Response C-10

U.S. Department Alaskan Region Airports Division 222 W. 7th Avenue, Box #14of Transportation Anchorage, Alaska 99513-7587

Tel. (907) 271-5438Federal Aviation Fax (907) 271-2851Administration

In Reply Refer To:55829

Ms. Judith BittnerState Historic Preservation OfficerAlaska Office of History and Archaeology550 W. 7th Avenue, Suite 1310Anchorage, AK 99501-3565

RE: Finding of Adverse Effect and Agency Scoping Letter

Dear Ms. Bittner:

The Alaska Department of Transportation and Public Facilities (DOT&PF), in cooperation withthe Federal Aviation Administration (FAA), is proposing to mitigate safety risks by demolishingthe Torpedo Bombsight and Utility Shop (Torpedo Building) at the Unalaska Airport. TheUnalaska Airport is located on Amaknak Island in the Aleutians, about 800 miles fromAnchorage: Section 34, Township 72 S, Range 17 W, Seward Meridian, USGS Quad UnalaskaC-2 (Figure 1).

Pursuant to 36 CFR 800.4(d)(2) and 800.5(d)(2), implementing regulations of Section 106 of theNational Historic Preservation Act, the FAA finds an adverse effect on historic properties by theproposed project. This letter also serves as the agency scoping letter to identify other sensitiveenvironmental resources in the project area.

Building Context and ConditionThe Torpedo Building is a contributing element to the Dutch Harbor Naval Operating Base &Fort Mears National Historic Landmark (NHL)(UNL-00120). According to the 2004 HistoricInvestigation and Preservation Alternatives Report for the Torpedo Building, the building wasconstructed and operational during the campaign against the Japanese attacks on the AleutianIslands. It is one of two remaining structures in the state designed by internationally-renownedarchitect Albert Kahn.

A structural assessment in 2003 found that the building’s structural frame and foundation weresound yet the exterior, roof, and sheathing were a safety hazard due to deterioration and flyingdebris. There is a documented history of debris flying off the building during incidents of severeweather. During a windstorm on February 7, 2014, large pieces of lumber and debris flew off thebuilding into cars parked in an adjacent parking lot (Photo Sheet).

The soil and groundwater on site at the Torpedo Building (Hazard ID 1328) is contaminated bydiesel-range petroleum hydrocarbons and concrete floor contains leachable lead (source: Alaska

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Unalaska Airport Safety Improvement Project Finding of Adverse EffectProject No. 55829 August 26, 2014

Page 2 of 4

Department of Environmental Conservation [ADEC] Contaminated Sites Database website,August 18, 2014). In 2001 a large amount of contaminated sediment was removed from the site.The 2003 structural assessment also found that the exterior walls and siding are made fromasbestos-coated metal. At the time of the report, the siding material was in poor condition andwas worn down to the asbestos paper on the exterior of the walls. The 2001 clean-up did notabate hazardous building materials such as the asbestos and lead paint.

In June 2014, DOT&PF contracted the services of a Structural Engineer to assess the currentcondition of the Torpedo Building. The structural assessment indicated that the building’sstructural system was significantly corroded and will likely experience “failure of some of themajor structural components” in the near future. A copy of the survey is available upon request.

Project DescriptionWork associated with the removal of the Torpedo Building would consist of the following:

Abatement of hazardous materials including asbestos and lead based paintRemoval of all building contents except the concrete floor, foundation and undergroundutilities (This includes the roof, exterior sheathing, structural frame, pipes, electricalapparatuses, and other building components)Removal of concrete walls down to the finish floor gradeFill of any voids below finish floor grade to make the floor levelRemoval of all debris from the lot

Area of Potential EffectThe Direct Area of Potential Effect (APE) consists of the boundary of the lot the TorpedoBuilding is on (Figure 2). This includes the building and the area around the building wheredebris would be removed. The Indirect APE consists of the buildings within viewshed of theTorpedo Building.

Previous ConsultationsIn February 2014, DOT&PF consulted with the Alaska Office of History and Archeology (OHA)on a state-funded project to remove the building due to the safety risks. At the time it wasanticipated that FAA would not be involved in the undertaking. It was determined that thedemolition of the Torpedo Building would have an adverse effect on Torpedo Building and theNHL. In cooperation with OHA and consulting parties, DOT&PF developed a Memorandum ofAgreement (MOA) to mitigate adverse impacts on the NHL from the demolition of the torpedobuilding. Before the MOA could be signed it was determined that the proposed project is aFederal action, constitutes and undertaking as defined in 36 CFR 8020.16(y) and furtherconsultation under Section 106 was required.

Finding of EffectDue to the current condition of the building and the safety risk it causes, DOT&PF hasdetermined that the only prudent and feasible alternative is to demolish the Torpedo Building.Demolition of the Torpedo Building would result in an adverse effect to a contributing elementof the Dutch Harbor Naval Operating Base & Fort Mears NHL.

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cc w/o enclosures:Aaron Hughes, P.E., Project Manager, Aviation Design, DOT&PF CRBrian Elliott, Regional Environmental Manager, PD&E, DOT&PF CRTaraLyn Stone, Environmental Protection Specialist, FAAValerie Gomez, Cultural Resource Specialist, DOT&PF CR

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DATE:

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NTS

8/21/2014

K. SHEALOCATION & VICINITY MAP

PROJECT NO. 55829

UNALASKA, ALASKA

FIGURE 1

LOCATION MAP


LOCATIONOF PROJECT

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Photo SheetUnalaska Torpedo Building

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DATE:

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8/21/14

K. SHEAAREA OF POTENTIAL EFFECT

PROJECT NO. 55829

UNALASKA, ALASKA

FIGURE 2

TORPEDO BOMBSIGHTAND UTILITY SHOP


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September 23, 2014

Ms. Leslie Grey Lead Environmental Protection Specialist Federal Aviation Administration Alaskan Region Airports Division 222 W. 7th Avenue, Box #14 Anchorage, AK 99513-7587

Ref: Proposed Demolition of the Torpedo Bombsight and Utility Shop (Torpedo Building) at the Unalaska Airport located on Amaknak Island in the Aleutians, Alaska

Dear Ms. Grey:

The Advisory Council on Historic Preservation (ACHP) has received your notification and supporting documentation regarding the adverse effects of the referenced undertaking on a property or properties listed or eligible for listing in the National Register of Historic Places. Based upon the information provided, we have concluded that Appendix A, Criteria for Council Involvement in Reviewing Individual Section 106 Cases, of our regulations, “Protection of Historic Properties” (36 CFR Part 800), does not apply to this undertaking. Accordingly, we do not believe that our participation in the consultation to resolve adverse effects is needed. However, if we receive a request for participation from the State Historic Preservation Officer (SHPO), Tribal Historic Preservation Officer (THPO), affected Indian tribe, a consulting party, or other party, we may reconsider this decision. Additionally, should circumstances change, and it is determined that our participation is needed to conclude the consultation process, please notify us.

Pursuant to 36 CFR §800.6(b)(1)(iv), you will need to file the final Memorandum of Agreement (MOA), developed in consultation with the Alaska State Historic Preservation Office (SHPO), and any other consulting parties, and related documentation with the ACHP at the conclusion of the consultation process. The filing of the MOA, and supporting documentation with the ACHP is required in order to complete the requirements of Section 106 of the National Historic Preservation Act.

Thank you for providing us with the notification of adverse effect. If you have any questions or require further assistance, please contact Ms. Najah Duvall-Gabriel at 202-517- 0210 or via e-mail at ngabriel @achp.gov.

Sincerely,

LaShavio Johnson Historic Preservation Technician Office of Federal Agency Programs

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Appendix DAgency and Public Scoping

Agency Scoping

Agency Scoping Letter D-1

Public Scoping

Online Public Notice D-7

Affidavits of Publication D-8

Public Comments D-12

1

Stone, TaraLyn (FAA)

From: Stone, TaraLyn (FAA)Sent: Tuesday, August 26, 2014 2:13 PMTo: '[email protected]'; '[email protected]';

'[email protected]'; '[email protected]'; '[email protected]'; '[email protected]'; '[email protected]'; '[email protected]'; '[email protected]'; '[email protected]'; '[email protected]'; '[email protected]'; '[email protected]'; '[email protected]'; '[email protected]'; '[email protected]'; '[email protected]'; '[email protected]'; '[email protected]'; '[email protected]'; '[email protected]'; '[email protected]'; '[email protected]'; '[email protected]'; '[email protected]'; '[email protected]'; '[email protected]'; '[email protected]'; '[email protected]'

Cc: Grey, Leslie (FAA); '[email protected]'; brianelliott--alaskagov ([email protected]); Gomez, Valerie L (DOT)

Subject: DOT&PF project 55829: Unalaska Airport Safety Improvements 106 Findings and Scoping

Attachments: 55829_106 findings_agencies_8.26.14.pdf

Attached please find a combined Section 106 findings letter and agency scoping letter for a proposed Alaska Departmentof Transportation and Public Facilities project to mitigate safety risks by demolishingthe Torpedo Bombsight and Utility Shop (Torpedo Building) at the Unalaska Airport. Please direct any comments toLeslie Grey at [email protected] or by phone at 907 5453.

Thank you,Tara Stone

TaraLyn Stone Environmental Protection Specialist FAA, Airports Division Alaskan Region Phone: (907) 271-5454

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U.S. Department Alaskan Region Airports Division 222 W. 7th Avenue, Box #14of Transportation Anchorage, Alaska 99513-7587

Tel. (907) 271-5438Federal Aviation Fax (907) 271-2851Administration

In Reply Refer To:55829

RE: Finding of Adverse Effect and Agency Scoping Letter

Dear Agency Contact:

The Alaska Department of Transportation and Public Facilities (DOT&PF), in cooperation withthe Federal Aviation Administration (FAA), is proposing to mitigate safety risks by demolishingthe Torpedo Bombsight and Utility Shop (Torpedo Building) at the Unalaska Airport. TheUnalaska Airport is located on Amaknak Island in the Aleutians, about 800 miles fromAnchorage: Section 34, Township 72 S, Range 17 W, Seward Meridian, USGS Quad UnalaskaC-2 (Figure 1).

Pursuant to 36 CFR 800.4(d)(2) and 800.5(d)(2), implementing regulations of Section 106 of theNational Historic Preservation Act, the FAA finds an adverse effect on historic properties by theproposed project. This letter also serves as the agency scoping letter to identify other sensitiveenvironmental resources in the project area.

Building Context and ConditionThe Torpedo Building is a contributing element to the Dutch Harbor Naval Operating Base &Fort Mears National Historic Landmark (NHL)(UNL-00120). According to the 2004 HistoricInvestigation and Preservation Alternatives Report for the Torpedo Building, the building wasconstructed and operational during the campaign against the Japanese attacks on the AleutianIslands. It is one of two remaining structures in the state designed by internationally-renownedarchitect Albert Kahn.

A structural assessment in 2003 found that the building’s structural frame and foundation weresound yet the exterior, roof, and sheathing were a safety hazard due to deterioration and flyingdebris. There is a documented history of debris flying off the building during incidents of severeweather. During a windstorm on February 7, 2014, large pieces of lumber and debris flew off thebuilding into cars parked in an adjacent parking lot (Photo Sheet).

The soil and groundwater on site at the Torpedo Building (Hazard ID 1328) is contaminated bydiesel-range petroleum hydrocarbons and concrete floor contains leachable lead (source: AlaskaDepartment of Environmental Conservation [ADEC] Contaminated Sites Database website,August 18, 2014). In 2001 a large amount of contaminated sediment was removed from the site.The 2003 structural assessment also found that the exterior walls and siding are made fromasbestos-coated metal. At the time of the report, the siding material was in poor condition andwas worn down to the asbestos paper on the exterior of the walls. The 2001 clean-up did notabate hazardous building materials such as the asbestos and lead paint.

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In June 2014, DOT&PF contracted the services of a Structural Engineer to assess the currentcondition of the Torpedo Building. The structural assessment indicated that the building’sstructural system was significantly corroded and will likely experience “failure of some of themajor structural components” in the near future. A copy of the survey is available upon request.

Project DescriptionWork associated with the removal of the Torpedo Building would consist of the following:

Abatement of hazardous materials including asbestos and lead based paintRemoval of all building contents except the concrete floor, foundation and undergroundutilities (This includes the roof, exterior sheathing, structural frame, pipes, electricalapparatuses, and other building components)Removal of concrete walls down to the finish floor gradeFill of any voids below finish floor grade to make the floor levelRemoval of all debris from the lot

Area of Potential EffectThe Direct Area of Potential Effect (APE) consists of the boundary of the lot the TorpedoBuilding is on (Figure 2). This includes the building and the area around the building wheredebris would be removed. The Indirect APE consists of the buildings within viewshed of theTorpedo Building.

Previous ConsultationsIn February 2014, DOT&PF consulted with the Alaska Office of History and Archeology (OHA)on a state-funded project to remove the building due to the safety risks. At the time it wasanticipated that FAA would not be involved in the undertaking. It was determined that thedemolition of the Torpedo Building would have an adverse effect on Torpedo Building and theNHL. In cooperation with OHA and consulting parties, DOT&PF developed a Memorandum ofAgreement (MOA) to mitigate adverse impacts on the NHL from the demolition of the torpedobuilding. Before the MOA could be signed it was determined that the proposed project is aFederal action, constitutes and undertaking as defined in 36 CFR 8020.16(y) and furtherconsultation under Section 106 was required.

Finding of EffectDue to the current condition of the building and the safety risk it causes, DOT&PF hasdetermined that the only prudent and feasible alternative is to demolish the Torpedo Building.Demolition of the Torpedo Building would result in an adverse effect to a contributing elementof the Dutch Harbor Naval Operating Base & Fort Mears NHL.

Other Resource ImpactsSection 4(f)Under Section 4(f) of the Department of Transportation Act of 1966, currently codified as 49USC Section 303(c), the project would constitute a use because the proposed projectpermanently incorporates the Torpedo Building, a portion of an NHL. The DOT&PF, incooperation with the FAA, will conduct an Individual Section 4(f) Evaluation to show that no

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cc w/o enclosures:Aaron Hughes, P.E., Project Manager, Aviation Design, DOT&PF CRBrian Elliott, Regional Environmental Manager, PD&E, DOT&PF CRTaraLyn Stone, Environmental Protection Specialist, FAAValerie Gomez, Cultural Resource Specialist, DOT&PF CR

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See Appendix C, SHPO Findings Letter, for figures

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9/29/2014 Notice of Intent to Begin Engineering and Environmental Studies Unalaska Airport Safety Improvements Project No. 55829 - Alaska Online Publ…

http://aws.state.ak.us/OnlinePublicNotices/Notices/View.aspx?id=173877 1/2

Notice of Intent to Begin Engineering andEnvironmental Studies Unalaska Airport SafetyImprovements Project No. 55829

The Alaska Department of Transportation and Public Facilities (DOT&PF), in cooperation with the Federal AviationAdministration, is soliciting comments and information on a proposal to address health and safety concerns at the UnalaskaAirport on Amaknak Island, Alaska. The proposed project would demolish the Torpedo Bombshell and Utility Shop Buildingat the Unalaska Airport. The building exterior and roof are a safety hazard due to debris flying off the building during extremeweather events. A recent structural assessment of the building determined the structure’s overall stability is significantlycorroded and will likely fail in the near future.

The proposed project will comply with Executive Orders: 11990 (Wetlands Protection), 11988 (Floodplain Protection), 12898(Environmental Justice), 11593 (Historic Preservation), 13084 (Consultation and Coordination with Indian TribalGovernments), 13112 (Invasive Species); the Clean Air Act, Clean Water Act, Fish and Wildlife Coordination Act,Endangered Species Act, National Historic Preservation Act Section 106, Land and Water Conservation Fund Act Section6(f), and U.S. DOT Act Section 4(f).

To ensure that all possible factors are considered, please provide written comments to the following address by October 14,2014.

Brian Elliott, Regional Environmental Manager

DOT&PF Preliminary Design & Environmental

P.O. Box 196900

Anchorage, Alaska 99519-6900

907-269-0539

If you have any questions or require additional information, please contact Aaron Hughes, P.E., Project Manager, at 269-0523, or Brian Elliott through the contact information listed above.

It is the policy of the Alaska Department of Transportation & Public Facilities (DOT&PF) that no person shall be excludedfrom participation in, or be denied benefits of any and all programs or activities we provide based on race, religion, color,gender, age, marital status, ability, or national origin, regardless of the funding source including Federal TransitAdministration, Federal Aviation Administration, Federal Highway Administration and State of Alaska Funds.

The DOT&PF complies with Title II of the Americans with Disabilities Act of 1990. Individuals with a hearing impairment cancontact DOT&PF at our Telephone Device for the Deaf (TDD) at (907) 269-0473.

AttachmentsNone

Revision HistoryCreated 9/2/2014 4:04:27 PM by mlbyrdModified 9/8/2014 3:48:48 PM by mlbyrd

Details

Department: Transportation and PublicFacilities

Category: Public NoticesSub-Category:Location(s): Central RegionProject/Regulation #: 55829

Publish Date: 9/2/2014Archive Date: 10/31/2014

Events/Deadlines:

Attachments, History, Details

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Stone, TaraLyn (FAA)

From: Grey, Leslie (FAA)Sent: Monday, September 29, 2014 1:37 PMTo: Stone, TaraLyn (FAA)Subject: FW: Project No 55829 - Unalaska Airport Safety Improvement ProjectAttachments: HPC Resolution 2014-01 Torpedo Building Demolition.pdf; City Council Resolution

Torpedo Building.pdf

From: Erin Reinders [mailto:[email protected]]Sent: Monday, September 29, 2014 1:36 PM To: Grey, Leslie (FAA) Subject: Project No 55829 - Unalaska Airport Safety Improvement Project

Leslie –

Please see the attached resolution from Unalaska’s Historic Preservation Commission outlining its support of thedemolition of the Torpedo Building as well as two suggested mitigation measures. Additionally, I have also attached aresolution from our City Council supporting the demolition of the Torpedo Building from this past February. Thank youfor the opportunity to provide comment on these plans.

Erin Reinders, AICP, CPM | Planning DirectorCity of Unalaska | P.O. Box 610 | Unalaska, AK 99685Phone: 907 581 3100 or 907 581 1251 ext. 4103 | Email: [email protected]

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