NALEMP: The Makah Experience

Site visit, 2001

The Makah Tribe has been working with the U.S. Department of Defense under NALEMP to restore former military sites on the Makah Indian Reservation. 

• The Tribe met with Congress in 1993.
• DoD adopted its American Indian and Alaska Native Policy in October 1998.
• The Tribe teamed with RIDOLFI Inc. in 2000 to form the Makah Environmental Restoration Team.
• The first NALEMP cooperative agreement was prepared in 2000.
• Prepared a Strategic Project Implementation Plan (SPIP) in 2001.
• Conducted site investigations in 2002-2005.
• Initiated restoration activities, 2003-2005.

Twenty-four sites of concern have been identified to date.  In general, the types of environmental impacts identified at the former military sites include fuel and septic tanks, soils contaminated by petroleum products or hazardous substances, asbestos-containing materials, lead-based paint, and physical hazards.  In addition, surface water (i.e., streams) may be impacted by contaminants from former DoD dump sites.

Mitigation Project Objectives

The Makah Tribal Council's Mission Statement is:

• To protect, provide for, and enhance the health, safety, and well-being of the Makah people;
• To ensure that the Makah Tribe maintains its Sovereignty and self-sufficiency;
• To ensure that the development of the Makah Nation's human and natural resources is in harmony with the environment; and
• To preserve and enhance the Makah culture and both the inherent and documented rights of the Makah Nation and the Makah people.

The Makah Tribe's primary objectives for the cleanup and closure of the former military sites are:

• To protect and provide for the health and safety of the Makah people;
• To protect and enhance the environment and preserve the Makah culture; and
• To provide employment opportunities for the Makah people.

Accomplishments to Date

Sampling for asbestos, 2003

The Makah Environmental Restoration Team, under the leadership of the Makah Tribal Council and the Makah Environmental Program, accomplished the following with funding from NALEMP and other federal agencies.  These accomplishments were realized using funding provided by four Cooperative Agreements for fiscal years 2000, 2002, 2003, and 2004.

Program Development

• The Makah Environmental Division was developed.  The Tribe's program includes a Division Manager, a Program Manager, and an Administrative Coordinator.
• A Strategic Project Implementation Plan was developed to provide a comprehensive strategy and work plan to address sites with confirmed or potential environmental concerns and physical hazards.  The SPIP was first updated in May 2005, then again in August 2006 to account for field activities completed through July 2006.
• Organized two annual 40-Hour HAZWOPER Training Courses to train members of the Makah Environmental Restoration Team to safely conduct work on hazardous sites.
• Attended NALEMP annual meetings in Prescott, Arizona; Albuquerque, New Mexico; and Sitka, Alaska to present information on the Makah NALEMP Project.
• Completed an updated Health and Safety Plan for environmental mitigation activities on the Makah Indian Reservation.
• Met with Paul Lumley, DoD Senior Tribal Liaison, and representatives of the Seattle Post-Intelligencer in Neah Bay to visit former military sites on the Makah Reservation and to discuss the Makah Environmental Restoration Team's experience with NALEMP.
• Work plans, completion reports, and implementation activities were coordinated among several federal agencies, including the Bureau of Indian Affairs (BIA), Indian Health Service (IHS), U.S. Environmental Protection Agency (USEPA), U.S. Department of Defense (DoD), U.S. Army Corps of Engineers (USACE), Tribal Solid Waste Interagency Workgroup, and the U.S. Department of Agriculture - Rural Development (USDA-RD).
• Community outreach and education has been conducted to inform members of the Makah Tribe about goals and work in progress to address environmental concerns.
• Information related to the former DoD sites on the Makah Indian Reservation have been updated on the DoD Native American Environmental Tracking System (NAETS) web site.
• This website was created to make the Makah NALEMP information publicly available and to make the SPIP more accessible.
• New ortho-rectified aerial photographs of priority sites were created.

Site Restoration Activities

• Field reconnaissance was conducted throughout the Makah Indian Reservation and 24 sites of environmental concern were identified and listed.
• Historical documentation was obtained from federal repositories, including the National Archives at Sandpoint, Fort Lewis Museum, and the U.S. Army Corps of Engineers (USACE) office in Seattle, Washington.  The historical information was compiled and a map and photo board was produced.

Navy Life Boat Station (Site 2)

• Buildings were inspected and sampled for asbestos-containing materials and lead-based paint.
• Asbestos-containing materials were removed in July 2005.
• The barracks complex, storage building, and gymnasium were deconstructed and removed in August 2005.
• Four underground storage tanks and two aboveground storage tanks that formerly contained heating oil were removed in August 2005.  Approximately 5 cubic yards of associated contaminated soils were removed and transported off-site for proper disposal.

Warmhouse Beach Open Dump (Site 4)

Monitoring well at the Warmhouse Beach Open Dump

• A hydrogeologic investigation, including installing monitoring wells and sampling and analyzing ground water, was completed in 2001 with funding from IHS.
• To verify findings of the initial hydrogeologic investigation, follow-up investigation and monitoring was conducted in 2004 under NALEMP.
• An Integrated Solid Waste Management Plan was completed with funding from the USEPA to identify, evaluate, and select improved methods of solid waste management.
• A Preliminary Engineering Report and an Environmental Report were completed with funding from the USEPA to support the development of alternative solid waste handling facilities and systems needed to discontinue use of the Warmhouse Beach Open Dump.
• A Draft Dump Closure Plan was prepared to close the Warmhouse Beach Open Dump.
• Coordinated with USEPA and IHS representatives to secure funding for the transfer station project.
• Completed a topographic survey of the transfer station site, and developed the transfer station design using funding provided by USEPA and IHS.
• Semi-annual creek and ground water sampling activities were conducted in March 2006.

Cantonment Area (Site 11)

• Completed a limited remedial investigation that included collecting and analyzing ground water samples from monitoring wells near former fuel storage tanks.
• Conducted a test-pit investigation at the former burn pit and former pesticide rinse tank.
• Semi-annual creek and ground water sampling activities were conducted in March 2006.

Family Housing Area (Site 13)

AST removal at the Family Housing Area

• Buildings were inspected and sampled for the presence of asbestos-containing materials and lead-based paint.
• Removed fuel storage tanks and petroleum-contaminated soil.
• Conducted asbestos inspections at Houses 506, 509, and 512 in preparation for building deconstruction and removal services.

Tatoosh Island (Site 22)

• Completed a limited remedial investigation that included collecting and analyzing samples of soil, asbestos-containing material, and lead-based paint.
• Conducted a soil, asbestos, and lead-based paint inspection and soil removal in October 2005; approximately 100 cubic yards of petroleum-contaminated soils were removed.

Other Selected Sites

• Completed limited remedial investigations at Sites 1, 5, 6, 7, 8, 9, 10, 14, 16, 20, and 24.  The limited remedial investigation activities and findings were summarized in a Limited Remedial Investigation Report.
• Physical hazards were removed from concrete structures at Bahobohosh Point (Site 15), Portage Head Ruins (Site 18), and Anderson Point Ruins (Site 17) to eliminate safety hazards.
• No Further Action Reports and Fact Sheets for Bahobohosh Point (Site 15), Anderson Point Ruins (Site 17), and Portage Head Ruins (Site 18) were prepared and are awaiting Council approval.
• Collected material samples from the restroom building at the Family Camp and Trailer Court (Site 14) to identify asbestos-containing materials in preparation for site development by the Makah Tribal Council.  The site has been restored and is now used by the Makah Business Enterprises as a public recreational vehicle park.
• The Makah Environmental Restoration Team coordinated with the Makah Fisheries Department to plan the removal of Hobuck Creek Dam (Site 16).
• Semi-annual creek and ground water sampling activities were conducted at the 200-Line Dump and the Cape Flattery Dump (Sites 1 and 8) in March 2006.
• The Makah Environmental Restoration Team met with representatives of the U.S. Navy at Neah Bay on August 1, 2006 to discuss the Offshore Unexploded Ordnance and Wrecks (Site 23) and the possibility of working together to evaluate the feasibility of removing the ordnance and wrecks from the sea bottom.

Multi-Agency Partnerships

The DoD and other federal agencies are participants in a Memorandum of Agreement for the Tribal Solid Waste Interagency Workgroup, which solicits proposals for tribal open dump cleanup projects.  The workgroup was established in 1998 to assist tribes in bringing their waste disposal sites into compliance with landfill criteria, including open dump closure and planning for appropriate alternative disposal.  The Makah Tribe is receiving strong support and valuable assistance for such a project from federal agencies that include the BIA, DoD, USEPA, IHS, and USDA-RD. 

The USDA administers water and environmental programs in Indian Country under the Rural Development Service.  Funds are specifically earmarked for eligible federally recognized tribes.  USDA-RD has provided guidance to the Tribe related to planning for the financing and implementation of the Makah waste transfer station and is expected to provide funding for its construction.  To date, a preliminary engineering report, an environmental report, and a Phase I environmental site assessment have been prepared for the proposed waste transfer station and submitted to the USDA.

The USEPA regulates solid waste through RCRA and regulates hazardous wastes in accordance with CERCLA and in compliance with the NCP.  The USEPA has been working with the Makah Tribe for several years and has assisted the Tribe in developing plans and addressing technical issues.  The USEPA continues to offer its technical and administrative support to the Tribe.  Partial funding for design of the Makah waste transfer station has been secured through the USEPA.  The USEPA has also funded a seafood study in Neah Bay to determine the presence and concentration of contaminants of concern and to assess potential health effects from the contaminants present.

The BIA has assisted the Tribe directly for many years. A BIA Trust Officer located at Neah Bay is readily available to assist the Tribe with technical and administrative issues.

The IHS was involved in the hydrogeologic investigation of the Warmhouse Beach Open Dump and solicited bids from specialized contractors for the drilling and installation of ground water monitoring wells at the site.  Partial funding for design of the Makah waste transfer station was secured through the IHS Sanitary Deficiency System.