PB95-964620
EPA/ROD/R10-95/130
February 1996
EPA Superfund
Record of Decision:
Fort Wainwright (O.U. 1),
Fairbanks, AK
8/9/1995
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RECORD OF DECISION
for
INTERIM REMEDIAL ACTION
CHEMICAL AGENT DUMP SITE
OPERABLE UNIT 1
FORT WAINWRIGHT
FAIRBANKS, ALASKA
JULY 1995
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DECLARATION STATEMENT
RECORD OF DECISION
INTERIM REMEDIAL ACTION
CHEMICAL AGENT DUMP SITE
OPERABLE UNIT 1
FORT WAINWRIGHT
FAIRBANKS, ALASKA
JULY 1995
SOURCE AREA NAME AND LOCATION
U.S. Army Alaska, Fort Wainwright
Fairbanks-North Star Borough
Fairbanks, Alaska
Source Area in Operable Unit 1
Chemical Agent Dump Site
STATEMENT OF BASIS AND PURPOSE
This decision document presents the selected interim remedial action for the Chemical Agent
Dump Site (previously known as the Chemical Warfare Disposal Area) on Fort Wainwright, a
National Priorities List site located near Fairbanks, Alaska. The interim remedy was chosen in
accordance with Section 117(a) of the Comprehensive Environmental Response, Compensation,
and Liability Act of 1980, as amended by the Superfund Amendments and Reauthorization Act of
1986, and, to the extent practicable, the National Oil and Hazardous Substances Pollution
Contingency Plan. The decision is based on the administrative record for this source area and is
summarized in the attached Decision Summary.
The United States Army is the lead agency for this decision. The United States Environmental
Protection Agency and the Alaska Department of Environmental Conservation participated in the
scoping of site investigations and evaluations of the interim remedial action alternatives and
concur with the remedy.
ASSESSMENT OF THE SITE
Actual or potential releases of hazardous substances from the Chemical Agent Dump Site, if not
addressed by implementing the interim remedial action selected in this Record of Decision, may
present an imminent and substantial endangerment to public health, public welfare, and the
environment.
I9-JT2901 ASCMOD OU1-O7W7/W-DI 11
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DESCRIPTION OF THE SELECTED REMEDY
The selected interim remedial action addresses contamination at one source area (the Chemical
Agent Dump Site) in Operable Unit 1, one of five operable units at Fort Wainwright. The
purpose of this interim remedial action is to reduce risks posed by the potential presence of soil
containing chemical agent breakdown products, debris, and chemical warfare materials. Chemical
warfare materials consist of glass vials or other containers that may still contain chemical agents.
Chemical warfare materials, if present, would pose a threat to human health and the environment
at this location.
This interim remedial action will also reduce the potential for contamination of groundwater, thus
eliminating a pathway of contaminant migration to humans, wildlife, and plants. The selected
interim remedial action is expected to be consistent with the final remedy that will be selected
following completion of the Remedial Investigation/Feasibility Study for Operable Unit 1.
The major components of the selected remedy include:
• Excavation of the Chemical Agent Dump Site to a maximum depth of
approximately 15 feet, or when bedrock is encountered;
• Field screening of excavated material for soil containing chemical agent breakdown
products, debris, and glass vials or other containers that may still contain chemical
warfare materials;
• Storage of all excavated chemical warfare materials in a secured interim holding
facility at Fort Wainwright until final disposition by treatment or disposal; and
• A chemical neutralization process and containerization of soil containing chemical
agent breakdown products and debris for off-site disposal at an out-of-state, licensed
disposal facility.
DECLARATION
The selected interim remedial action is protective of human health and the environment, complies
with federal and state requirements that are legally applicable or relevant and appropriate to the
remedial action, and is cost-effective. It is anticipated that this action will be the final action
required for removing potential contamination from this source area, unless groundwater
contamination is identified. If groundwater contamination is identified, the data will be
immediately evaluated and appropriate response actions will take place. This action will be
addressed in the Record of Decision for Operable Unit 1. This remedy utilizes permanent
solutions for potential soil contamination and alternate treatment technologies to the maximum
extent practicable, and satisfies the statutory preference for remedies that employ treatments that
reduce toxicity, mobility, or volume as a principal element. Because this remedy will not result
in hazardous substances remaining at this source above health-based levels, the five-year review
will not apply to this action.
AS8T*OD_OU1-OM»7/9S-DI 111
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SIGNATURES
Signature sheet for the foregoing Operable Unit 1, Chemical Agent Dump Site, Fort Wainwright
Interim Remedial Action, Record of Decision between the United States Army and the United
States Environmental Protection Agency, Region X, with concurrence by the Alaska Department
of Environmental Conservation.
.
A a •; u •; /" '• '. ""*•' S
Raymond J. Fatz Date
Acting Deputy Assistant Secretary of the Army
Environmental Safety and Occupational Health
United States Army
AS«7-*OOpUI-07/lJ/W-Ol IV
recycled paper ecology and environment
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Signature sheet for the foregoing Operable Unit 1, Chemical Agent Dump Site, Fort Waimvright
Interim Remedial Action, Record of Decision between the United States Army and the United
States Environmental Protection Agency, Region X, with concurrence by the Alaska Department
of Environmental Conservation.
Chuck Clarke Date
Regional Administrator, Region X
United States Environmental Protection Agency
l9:JT290!_A587-ROD_OUl-07/18/95-DI
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Signature sheet for the foregoing Operable Unit 1, Chemical Agent Dump Site, Fort Wainwright
Interim Remedial Action, Record of Decision between the United States Army and the United
States Environmental Protection Agency, Region X, with concurrence by the Alaska Department
of Environmental Conservation.
Kurt Fredriksson Date
Director, Spill Prevention and Response
Alaska Department of Environmental Conservation
l»JI7Wl_A*7.ROD_OUI-07/l(OTi-DI VI
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TABLE OF CONTENTS
Section Page
DECLARATION STATEMENT ii
DECISION SUMMARY 1
1.0 SITE NAME, LOCATION, AND DESCRIPTION 1
1.1 Site Demographic Characteristics 4
2.0 SOURCE AREA HISTORY AND ENFORCEMENT ACTIVITIES 4
2.1 History of Operations 4
2.2 History of Source Area Investigations 5
2.3 History of Enforcement Actions 7
3.0 HIGHLIGHTS OF COMMUNITY PARTICIPATION 7
4.0 SCOPE AND ROLE OF OPERABLE UNIT AND RESPONSE ACTION 8
5.0 SUMMARY OF SOURCE AREA CHARACTERISTICS 9
5.1 Geology and Hydrology 9
5.2 Sources and Types of Contaminants 9
6.0 SUMMARY OF SOURCE AREA RISKS 11
7.0 DESCRIPTION OF ALTERNATIVES 11
7.1 Alternative 1—No Action 12
7.2 Alternative 2—Long-Term Groundwater Monitoring and Institutional
Controls 12
7.3 Alternative 3—Soil Excavation with Removal of Chemical Warfare
Materials, if Found 13
8.0 SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES 14
I9JT2901 AS87-KOD OUl-CWWS-DI VH
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Table of Contents (Cont.)
Section Page
8.1 Criterion 1—Overall Protection of Human Health and the Environment 14
8.2 Criterion 2—Compliance with Applicable or Relevant and Appropriate
Requirements 17
8.3 Criterion 3—Long-Term Effectiveness and Permanence 17
8.4 Criterion 4—Reduction of Toxicity, Mobility, and Volume through Treatment 18
8.5 Criterion 5—Short-Term Effectiveness 18
8.6 Criterion 6—Implementability 18
8.7 Criterion 7—Cost 19
8.8 Criterion 8—State Acceptance 19
8.9 Criterion 9—Community Acceptance 19
9.0 SELECTED REMEDY 20
9.1 Rationale for Selection 20
9.2 The Interim Holding Facility 21
9.3 The Health and Safety Plan 21
10.0 STATUTORY DETERMINATIONS 22
10.1 Protection of Human Health and the Environment 22
10.2 Compliance with Applicable or Relevant and Appropriate Requirements and
To-Be-Considered Guidance 23
10.2.1 TBC Guidance 24
10.3 Cost Effectiveness 24
10.4 Utilization of Permanent Solutions and Alternative Treatment Technologies
or Resource Recovery Technologies to the Maximum Extent Practicable .... 24
10.5 Preference for Treatment as a Principal Element 24
11.0 DOCUMENTATION OF SIGNIFICANT CHANGES 24
Appendix
A RESPONSIVENESS SUMMARY A-l
19JT290I ACT-ROD OUI-IO/KV95-DI V1U
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LIST OF TABLES
Table Page
1 United States Environmental Protection Agency's Nine Evaluation Criteria 15
2 Comparison of Alternatives 16
19JT290I ASR7-KOD OUI-O7/13/95-DI IX
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LIST OF ILLUSTRATIONS
Figure Page
1 Fort Wainwright Main Post Area, Vicinity Map 2
2 Location Map, Chemical Agent Dump Site 3
3 Site Map, Chemical Agent Dump Site 6
19-JR90l_ASrMU>D_pUI-O7n3/«S-DI
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ACRONYMS
AAC Alaska Administrative Code
ADEC Alaska Department of Environmental Conservation
ARARs Applicable or Relevant and Appropriate Requirements
Army United States Army
BGS below ground surface
CAIS Chemical Agent Identification Sets
CERCLA Comprehensive Environmental Response, Compensation, and Liability Act of 1980
CWM Chemical warfare materials
CFR Code of Federal Regulations
°C Degrees Celsius
EPA United States Environmental Protection Agency
FFA Federal Facility Agreement
FS Feasibility Study
GPR ground-penetrating radar
IHF Interim holding facility
IRA Interim remedial action
MCL Maximum Contaminant Level
MCLG Maximum Contaminant Level Goal
NCP National Oil and Hazardous Substances Pollution Contingency Plan
OU-1 Operable Unit 1
OU Operable unit
PSE Preliminary Source Evaluation
RCRA Resource Conservation and Recovery Act
RI Remedial Investigation
ROD Record of Decision
TBC To-be-considered
I9-JT290I ACT-ROD OU1-07/I3/95-D1
XI
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DECISION SUMMARY
RECORD OF DECISION
INTERIM REMEDIAL ACTION
CHEMICAL AGENT DUMP SITE
OPERABLE UNIT 1
FORT WAINWRIGHT
FAIRBANKS, ALASKA
JULY 1995
This Record of Decision (ROD) provides an overview of the problems posed by the potential
contamination at the Chemical Agent Dump Site, a source area placed within Fort Wainwright's
Operable Unit 1 (OU-1). It describes the physical features of the source area, the history of
source area investigations, and the rationale for conducting an interim remedial action (IRA) at
the source area. In addition, the decision summary describes the remedial alternatives considered,
provides the rationale for the remedial action selected, and states how the remedial action will
satisfy the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA)
statutory requirements.
1.0 SITE NAME, LOCATION, AND DESCRIPTION
Fort Wainwright, also referred to as "the site," is located on the eastern edge of the City of
Fairbanks in the Fairbanks-North Star Borough in interior Alaska (Figure 1). Primary missions at
Fort Wainwright include the training of infantry soldiers in the arctic environment, testing of
equipment in arctic conditions, preparation of troops for defense of the Pacific Rim, and rapid
deployment of troops worldwide. On-site industrial activities include fixed-wing aircraft,
helicopter, and support vehicle maintenance. The 918,000-acre site includes the main post area, a
range complex, and two maneuver areas.
Fort Wainwright was originally established as a cold-weather testing station in 1938. Renamed
Ladd Army Airfield in 1939, the site next served as a resupply point for remote field stations and
a crew transfer point in the Lend-Lease Program through which military aircraft and other
supplies were ferried to the Soviet Union during World War II. In 1947, the site was
redesignated as Ladd Air Force Base and began serving as a resupply and maintenance base for
remote distance early warning sites and experimental stations in the Arctic Ocean. The site was
renamed Fort Wainwright on January 1, 1961, and all of its operations were transferred to the
United States Army (Army).
The Chemical Agent Dump Site, also referred to as the "source area," is a fenced area covering
approximately 3,200 square feet at the base of Birch Hill, north of the main post area and east of
the Fairbanks Fuel Terminal. The source area is bounded by a bedrock outcrop to the north and
Birch Hill Road and the Fairbanks-Eielson Pipeline to the south (Figure 2). Land uses
immediately adjacent to the Chemical Agent Dump Site include military training and recreational
uses.
19:JT2901_A5S7-ROD_Otll-07/06/95-Dl
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H:\JT\CAFIGURE.CDR
MUNICIPALITY
OF
FAIRBANKS
Continues to
I MAPCO Refinery
in North Pole
FORT
WAINWRIGHT
Figure 1 FORT WAINWRIGHT MAIN POST AREA, VICINITY MAP
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H:\JT\CAFIG2B.CDR
Fairbanks
Fuel Terminal
Chemical Agent
Dump Site
NOT TO SCALE
Figure 2 LOCATION MAP, CHEMICAL AGENT DUMP SITE
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1.1 Site Demographic Characteristics
The Fairbanks-North Star Borough has a population of 77,720. The City of Fairbanks is
relatively densely populated, but is surrounded by vast, uninhabited areas. The town of North
Pole, located to the southeast, has a population of 1,456. Of the 6,657 people working at Fort
Wainwright, 5,085 are soldiers, 701 are Army civilians, and 871 are other civilians.
Approximately 11,775 people live on the base itself.
The Fairbanks residential subdivision closest to the Chemical Agent Dump Site, Shannon Park, is
located approximately 0.75 mile southwest of the source area. The 801 Housing Subdivision, an
on-post housing area also known as Birchwood, is located 1 mile south of'the source area and
houses approximately 1,580 people. The North Post Housing Subdivision (another on-post
housing area) is located about 1.25 miles to the southeast and is home to a total of 698 people.
There are two main schools in the area. Ladd Elementary School is located approximately 0.85
mile south of the source area and serves approximately 675 students. Tanana Junior High School
is located approximately 0.9 mile south of the source area and serves 625 students. School is
usually in session from the end of August through the end of May.
2.0 SOURCE AREA HISTORY AND ENFORCEMENT ACTIVITIES
2.1 History of Operations
In 1946 or 1947, 20 to 30 cylinders of mustard agent were reportedly buried in a trench at this
source area. Long-time residents, former military personnel, and retired civilian workers
reported that the trench was posted as "Poison Gas" or "Gas."
Army records indicate that a removal action took place in 1966 at the Chemical Agent Dump Site.
A former soldier who operated the backhoe during the 1966 removal activity was interviewed in
1987. The former soldier stated that seven cylinders (approximately 2 to 3 feet long) and an
unknown number of wooden crates with glass vials were removed during the 1966 excavation.
The cylinders and wooden crates were buried to a depth of approximately 8 feet in the trench.
In a subsequent interview, the glass vials were identified as belonging to Chemical Agent
Identification Sets (CAIS). The Army used CAIS during World War II to train military personnel
in identification of chemical agents by odor and other immediate effects. The identification sets
consisted of small glass tubes of various chemical agents. The tubes were packed in cardboard or
other packing materials inside metal cans; the metal cans were overpacked into wooden crates.
I9JT2901 A587-ROD_OU1-07/06«5-D1
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2.2 History of Source Area Investigations
A Records Search to gather existing information to identify physical locations and potential
hazards at various potential source areas throughout Fort Wainwright was completed on
February 12, 1992. The Records Search scope of work included the collection and review of
records pertaining to the entire Fort Wainwright site (including aerial photographs, geological
surveys, and hydrological and topographical maps) and interviews with personnel associated with
current and past operations.
In order to determine the source area location, aerial photographs taken between 1948 and 1990
were subsequently reviewed. Other interviews conducted with local residents and former
employees confirmed what was known about historical activities at the source area. The physical
location of the source area was identified by the former soldier who operated the backhoe during
the 1966 removal activity.
A Preliminary Source Evaluation (PSE) was conducted at the source area in summer 1993.
During the evaluation, 12 soil borings were drilled and four of the borings were completed as
groundwater monitoring wells. Surface soils were field screened for evidence of mustard agent,
lewisite, phosgene, and chloropicrin—the compounds believed to most likely be present at the
source area. Subsurface soils and groundwater were also analyzed for chemical agents and their
breakdown products. The PSE results indicated that chemical agents and their breakdown
products were not present in the soil and groundwater sampled.
Based on the former soldier's account of the excavation, geophysical surveys (using nonintrusive
subsurface investigative techniques) were conducted from 1987 through 1993. In July 1992,
ground-penetrating radar (GPR) was used to delineate the source area and a magnetometer was
used to scan the area for ferrous metal objects. GPR, cross-borehole tomography, and electro-
magnetic resonance imaging surveys were conducted in 1993. The surveys were conducted by
government contractors and Cold Regions Research Engineering Laboratory personnel to confirm
the absence of metal containers.
The GPR and the cross-bore hole tomography surveys indicated two areas of disturbed ground at
a depth of 10 to 13 feet above a bedrock horizon. These areas of disturbed ground are the
suspected burial locations of chemical agents. Investigative efforts to date have been unable to
confirm whether soil containing chemical agent breakdown products, debris, or chemical warfare
materials (CWM) are still buried at the source area. (CWM consist of glass vials or other
containers that may still contain chemical agents.) Based on the results of the geophysical
investigations, there is a high level of confidence that no metallic cylinders remain at the source
area. The only way the presence or absence of CWM in nonmetallic containers can be
confirmed, however, is through excavation of the source area.
Figure 3 illustrates the Chemical Agent Dump Site, including the base of Birch Hill, the fence,
the location of the groundwater monitoring wells, the locations of subsurface soil disturbances
detected by the geophysical investigations, and the approximate location of the Fairbanks-Eielson
Pipeline.
lWn901_A587-ROD_OUI-07/06/95-Dl
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02:JT\SITEPLAN.CDR
APPROXIMATE
LOCATION OF
BIRCH HILL TOE
OF SLOPE
o\
KEY
X
Chainlink Fence
Monitoring Well Location
Approximate location of
anomaly identified by the U.S.
Army Corp of Engineer's Cold
Region Research and Engineering
Laboratory.
Approximate location of buried pipeline
Burial depth is estimated at 2 to 3 feet.
SOURCE: Harding Lawson Associates, 1994.
Figure 3 SITE MAP, CHEMICAL AGENT DUMP SITE
FORT WAINWRIGHT, ALASKA
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2.3 History of Enforcement Actions
Fort Wainwright was placed on the CERCLA National Priorities List in August 1990. The
United States Environmental Protection Agency (EPA), the United States Department of Defense,
and the State of Alaska signed a Federal Facility Agreement (FFA) in March 1992. The FFA
was designed to guide investigations and response actions for hazardous substance/waste releases
at the entire site, facilitate cooperation and information exchange among the three agencies, and
establish requirements for the performance of investigations and response actions. Source areas,
grouped into five operable units (Ous), were identified in the FFA for inclusion in the
environmental investigation and cleanup process for Fort Wainwright. (In the FFA, the Chemical
Agent Dump Site was referred to as the Chemical Warfare Disposal Area.) The Chemical Agent
Dump Site is one of five source areas currently being addressed in the OU-1 Remedial
Investigation (RI). There are no enforcement actions associated with this source area.
3.0 HIGHLIGHTS OF COMMUNITY PARTICIPATION
Community relations activities, aimed at increasing public awareness and involvement, have been
ongoing at Fort Wainwright for several years. In addition to a postwide Community Relations
Plan, OU-specific community relations plans have been developed to address OU and source area
concerns.
The public was encouraged to participate in the selection of the remedy for the Chemical Agent
Dump Site during a public comment period from April 19 to May 19, 1995. The Fort
Wainwright Proposed Plan for Interim Remedial Action at the Operable Unit 1 Chemical Agent
Dump Site presented alternatives being considered by the Army, EPA, and Alaska Department of
Environmental Conservation (ADEC) for the source area. The Proposed Plan was released to the
public on April 19, 1995, and copies were sent to all known interested parties including
approximately 150 elected officials and concerned citizens. An informational Fact Sheet dated
March 1995, providing information about the Army's entire cleanup program at Fort Wainwright,
was mailed to the individuals and organizations on the mailing list.
The Proposed Plan summarized available information about the source area. Additional materials
were placed in two information repositories located at the Noel Wien Library in Fairbanks and the
Fort Wainwright Post Library. An Administrative Record, comprising all items placed in the
information repositories and other documents used in the selection of the IRA, was established in
Building 3023 at Fort Wainwright. Members of the public were invited to inspect materials
available in the Administrative Record and the information repositories during business hours.
Interested citizens were invited to comment on the Proposed Plan and the remedy selection
process in writing by mailing comments to the Fort Wainwright Project Manager, calling a toll-
free telephone number to record a comment, or commenting in person at a public meeting on
April 25, 1995, in Fairbanks at the Fort Wainwright Library. One organization submitted
comments in writing, no comments were recorded on the toll-free line, and one person provided
oral comments at the public meeting. A total of 24 people attended the public meeting, which
also included presentations on the IRA and the Proposed Plan for OU 3 and an opportunity to ask
questions about both documents.
AVMtOO OU1-07/IMMM
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Display advertisements in the Fairbanks Daily News-Miner, published on April 12, 16, 19, 23,
24, and 25, 1995, also included information about the information repositories, the toll-free
telephone line, and the address for submitting written comments.
The Responsiveness Summary, found in Appendix A to this document, addresses the comments
received from the public on the Proposed Plan and the remedy selection process. This decision
document summarizes comments received from the public during the comment period and
provides official responses to those comments. The public was supportive of this IRA although
concerns were raised about potential risks during excavation and storage. The selection of the
IRA was based on the Administrative Record for this source area.
4.0 SCOPE AND ROLE OF OPERABLE UNIT AND RESPONSE ACTION
OU-1, which contains the Chemical Agent Dump Site, is one of five OUs comprising known and
suspected source areas at Fort Wainwright. Existing site characterization data indicate that this
source area may pose a threat to human health and the environment if glass vials or other
containers containing CWM remain at the source area. This ROD addresses the first IRA to be
conducted at Fort Wainwright.
RI fieldwork to determine the nature and extent of contamination at the remaining source areas in
OU-1 and to obtain information needed to identify cleanup alternatives is scheduled to begin in
1995. The Feasibility Study (FS), which will begin following completion of the RI, is scheduled
to conclude by August 1996. The FS will establish criteria for the cleanup and identify and
evaluate cleanup alternatives for the OU. Final cleanup for OU-1 is not scheduled to begin until
after completion of the entire RI/FS and publication of the ROD in 1997.
Because it is believed that every other available investigative technique has already been used at
the Chemical Agent Dump Site, excavation is the only method remaining to determine the
presence of soil containing chemical agent breakdown products, debris, and CWM. If CWM
remain at the source area, the Army, EPA, and ADEC are concerned that future releases of
CWM could occur if containers were to become damaged. The Army, EPA, and ADEC chose
the excavation IRA as a precautionary measure to prevent possible future releases. The selected
IRA will allow a response to occur in 1995, sooner than it could otherwise take place in the
RI/FS process.
The selected IRA will prevent possible exposures to CWM and associated risks to human health
and the environment. Excavation and secure storage will eliminate the chance for exposure and
off-site migration of contaminants. The potential for a release to occur during excavation
activities has been considered, and appropriate standards for protection will be in place. Although
CWM and their breakdown products were not detected during the field investigation, glass vials
or other containers of CWM may still remain buried at the source area.
If this IRA is not undertaken, and a CWM release occurs at this source area, contaminants may
migrate into soils, bedrock/schist (fractured bedrock), and groundwater. The selected IRA is
expected to be a final action for the Chemical Agent Dump Site unless groundwater contamination
is discovered. If groundwater contamination is identified, the data will be immediately evaluated
19:JT2901 A5S7-ROD OU1-07/06/95-D1
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and appropriate response actions will occur. These actions will be addressed in the ROD for
OU-1. It is expected that the selected IRA will be consistent with any planned future actions that
will take place as a result of the RI/FS process and the subsequent ROD for OU-1.
5.0 SUMMARY OF SOURCE AREA CHARACTERISTICS
5.1 Geology and Hydrology
Most of Fort Wainwright, including the main post area, lies within the lowlands of the Xanana
River Basin. The surficial layer (generally less than 5 feet thick) comprises fine-grained soil
overlying deeper alluvial floodplain deposits. The alluvial deposits beneath the surficial soil
consist of layers of silt, sand, and gravel. Subsurface materials at the base of Birch Hill consist
of variable thicknesses of Fairbanks loess and Chena alluvium that overlie the Birch Creek schist.
At the base of Birch Hill, from the source area west to the Fairbanks Fuel Terminal, subsurface
explorations have encountered Fairbanks loess overlying Chena alluvium at depths from 3 to
30 feet below ground surface (BGS). Weathered Birch Creek schist (fractured bedrock) is
encountered at depths from 8 to 10 feet BGS at this source area. The depth to the alluvium-
bedrock contact is believed to increase with distance from the base of Birch Hill, but this contact
may be undulating.
The main aquifer in the Fort Wainwright area is the Tanana basin alluvium. The aquifer ranges
from a few feet thick at the base of Birch Hill to at least 300 feet thick under the main post area.
The aquifer is considered to be unconfmed in areas free of permafrost. The water table is
generally encountered within 10 to 20 feet BGS and is generally believed to flow west-northwest,
similar to the flow direction of the Chena and Tanana rivers. Groundwater is encountered at
approximately 9 to 10 feet BGS at the base of Birch Hill and is generally reported to flow west-
southwest at the Chemical Agent Dump Site. The hydraulic gradient across the post on the south
side of the Chena River ranges from about 0.0015 to 0.0005 during periods of normal summer
flow. Hydraulic conductivity is commonly on the order of 1 x IQ-' centimeters per second or
more. No permafrost was encountered during investigations at the source area.
The Chena River flows from its headwaters through Fort Wainwright for approximately 2 miles
to confluence with the Tanana River. There are no surface water bodies or drainage ditches at
the Chemical Agent Dump Site. The nearest surface water bodies are shallow ponds located
approximately 40 feet south of the fence line. Many areas on and near Fort Wainwright are
covered by muskeg and wetlands. The source area is located within a white spruce quaking aspen
forest. However, a black spruce forested wetland is located less than 600 feet south of the source
area. The Chena River is approximately 1.1 mile south of the Chemical Agent Dump Site. The
source is not located within the 100-year floodplain.
5.2 Sources and Types of Contaminants
The CWM that are potentially still buried at the Chemical Agent Dump Site present both human
health and environmental concerns. CWM are compounds used in military operations to kill,
seriously injure, or incapacitate humans as a result of exposure. The four chemical agents most
19:JTWOI A587-ROD OUI-07/06.9S-D1
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likely buried at the source area and a summary of the physical and chemical properties of each are
listed below.
Mustard. Mustard is a blister agent used primarily for casualty effects. It acts as a cell irritant 4
to 6 hours after initial exposure and eventually progresses to a cell poison on all contaminated
tissue surfaces. It has a distinctive garlic-like odor and remains effective for a relatively long
period of time under normal weather conditions. Distilled mustard is a related agent that has been
purified through washing and vacuum distillation. Distilled mustard has a less-pronounced odor,
greater blistering power, and more stability in storage. Mustard has a liquid density of 1.2685 at
25°C (degrees Celsius), a vapor density of 5.4, and a freezing point of 14.45°C, well above the
source area's average groundwater temperature of 4°C . Mustard is expected to be a solid in soil
temperatures found at this source area. Mustard hydrolyzes slowly in water into thiodiglycol,
hydrochloric acid, sulfonium salts, and hydrogen chloride.
Lewisite. Lewisite is a blister agent similar to mustard, but uses arsenic as the central atom. It
has about the same blistering action on the skin as distilled mustard, but the lethal dosage for
lewisite is much higher. Exposure to this compound produces immediate physical discomfort and
a reddening of the skin within 30 minutes of the initial exposure. Blistering occurs approximately
13 hours after initial exposure. Permanent blindness occurs within 1 minute of initial exposure if
the eyes are not decontaminated with large amounts of water. Lewisite is a liquid with an odor
similar to geraniums. Lewisite has a liquid density of 1.89 at 20°C, a vapor density of 7.1, and a
freezing point of -18 to 0.1 °C (depending on purity and the presence of isomers). Lewisite is
expected to be a liquid because of the temperatures found on site. Lewisite hydrolyzes very
rapidly when in the presence of high humidity or water. The products of hydrolysis are
hydrochloric acid and chlorovinyl arsenous oxide.
Chloropicrin. Chloropicrin is a severe mucous membrane irritant and mild vomiting agent. It is
most effective when dispersed as a vapor. It causes immediate burning, pain, and tearing of the
eyes, even in very low concentrations. In high concentrations, this chemical agent causes severe
damage to lungs, resulting in pulmonary edema. As a liquid, Chloropicrin causes severe burns
that usually result in blisters and lesions. It has an intense stinging and pungent odor.
Chloropicrin has a liquid density of 1.6558 at 20°C, a vapor density of 5.7, and a freezing point
of -69.2°C. Chloropicrin is expected to be liquid because of the temperatures found on site.
This compound decomposes into chlorine gas and nitrogen oxide near open fires, producing toxic
fumes. Chloropicrin does not hydrolyze in water, but could move with groundwater in its pure
state. It does, however, decompose under the influence of light. It also readily breaks down in
the presence of organic solvents, lipids, organophosphorus compounds, mustards, phosgene,
diphosgene, and chlorides.
Phosgene. Phosgene is a very effective, delayed-casualty, choking agent. It produces
inflammatory effects on the eyes, nose, upper airways, and lungs with exposures to as little as 1
to 2 parts per million in air. Depending on exposure levels, symptoms can start as early as
10 minutes (in high concentrations, which usually result in death within 24 hours) to as long as
3 hours or more after initial exposure (low concentrations usually result in irritation of the eyes
and respiratory system). Early symptoms are usually mild but gradually develop into a severe
cough and shortness of breath, followed by the lungs filling with fluid, which results in "dryland
drownings." Phosgene is a volatile, colorless gas with an odor similar to newly mown hay,
!9JT2901_A587-ROD_OU1-07/06/9S-D1 10
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grass, or green corn. Phosgene has a vapor density of 3.4; it thus tends to linger in low places
and readily condenses to a colorless liquid below 7.8°C. It reacts rapidly with water, so rain,
fog, and dense vegetation reduce its concentration in air. Phosgene hydrolyzes into hydrochloric
acid and carbon dioxide. This material is misable in most organic solvents.
If a contaminant release occurs, contaminant migration via groundwater will depend on several
factors. Mustard, lewisite, and chloropicrin have low solubilities; have liquid densities greater
than 1.0; and, in pure product form, may behave as dense, nonaqueous phase liquids. A mustard
agent release would congeal as it approached groundwater, minimizing the potential for migration
through the silty, sandy gravel soil prevalent at the source area. A release of lewisite or
chloropicrin might migrate vertically and horizontally through saturated soil. Lewisite would
break down and migrate readily as it mixed with groundwater; chloropicrin would simply migrate
with the water. A release of phosgene would most likely not be detectable because of its rapid
decomposition in the environment. Mustard, lewisite, and chloropicrin by-products and/or
dissolved fractions caused by the mixing of solvents with the disposed CWM (a common practice
at the time of disposal) may migrate from the source area via the groundwater pathway.
Although numerical exposure values do not exist for CWM, they are highly toxic by design and
any ingestion of or exposure to contaminated groundwater would pose an unacceptable risk.
6.0 SUMMARY OF SOURCE AREA RISKS
A removal action took place in 1966 at this source area. Although records are incomplete, only a
portion of the reported CWM believed to be buried at this location was removed. A complete
assessment of potential human health and ecological risks was not performed for the Chemical
Agent Dump Site before the decision to conduct an IRA was made. Glass vials or other
containers containing CWM may still remain at the source area, however, and the potential exists
for future releases to soil and groundwater if CWM are still present.
A preliminary evaluation of potential contaminant migration to the air, groundwater, and surface
water at the source area has been conducted to determine possible migration routes should a
release occur. Because of the chemical and physical properties of the suspected CWM,
contamination would likely be found in subsurface soils at a depth of approximately 8 feet BGS or
more if a release were to occur. Migration to the surface through the soil column is considered to
be extremely unlikely. If subsurface soils were to become contaminated, CWM and their
breakdown products may migrate into groundwater, posing a risk to groundwater users. If this
were to occur, the groundwater would likely be the primary potential migration pathway.
Because of the ongoing threat of a future release and toxicity of the suspected contaminants, this
interim action is necessary to stabilize the source area and prevent degradation to groundwater.
7.0 DESCRIPTION OF ALTERNATIVES
The Army, EPA, and ADEC evaluated the following IRAs for the Chemical Agent Dump Site:
• Alternative 1—No Action;
I9-.JT2901_A587-ROD_OU 1-07/06/9S-D1
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• Alternative 2—Long-Term Groundwater Monitoring and Institutional Controls;
• Alternative 3—Soil Excavation with Removal of Chemical Warfare Materials, if
Found.
The no-action alternative was evaluated consistent with National Oil and Hazardous Substances
Pollution Contingency Plan (NCP) requirements and served mainly as a point of comparison with
the other two alternatives. The two other alternatives were selected for more detailed evaluation
because they could be readily implemented using commonly available technologies and equipment.
A 20-year duration for IRA activities was selected for cost comparison purposes. In the absence
of an excavation/removal action, there is no known or estimated date when monitoring would
cease at the source area. The costs presented are projected costs; actual costs will vary based on
the final design and detailed cost itemizations. Costs shown include capital costs and annual
operation and maintenance costs (including costs associated with monitoring, maintaining, and
repairing the installed system).
The main Applicable or Relevant and Appropriate Requirements (ARARs) and To-Be-Considered
(TBC) guidance that will be triggered by action at this source area include Army Toxic Chemical
Agent Safety Program. Alaska Water Quality Standards, and Resource Conservation and
Recovery Act (RCRA) to determine whether the materials are hazardous wastes for storage
requirements.
7.1 Alternative 1—No Action
The no-action alternative serves as a baseline for comparison with the other two alternatives.
Under this alternative, no IRA would be implemented at the Chemical Agent Dump Site. If
CWM or their breakdown products exist at the source area, they would remain in place. A final
decision about the source area would be made in the ROD for OU-1.
No known costs are associated with Alternative 1 for either capital construction or operation and
maintenance.
7.2 Alternative 2—Long-Term Groundwater Monitoring and Institutional Controls
Alternative 2 involves the installation of two new groundwater monitoring wells and semi-annual
sampling of existing and newly installed groundwater monitoring wells to conduct long-term (for
20 years) groundwater monitoring and develop groundwater flow direction data. Groundwater
samples would be analyzed for all potential CWM and their breakdown products to determine
whether groundwater contamination is present. The detection of groundwater contamination
would indicate whether CWM or their breakdown products have leaked into subsurface soils and
migrated into the groundwater. If groundwater contamination is detected, an immediate
evaluation of data would be conducted and an appropriate response action would take place.
Costs associated with any needed response action were not included in cost estimates for this
alternative.
19:JT2901 A587-ROD OU1-07AXWS-D1
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If CWM or their breakdown products exist at the source area, they would remain in place. Final
decisions about the source area would be made in the ROD for OU-1.
The costs associated with Alternative 2 would include installation of two additional groundwater
monitoring wells, semi-annual sampling of new and existing groundwater monitoring wells, and
laboratory analysis of samples. Capital costs are estimated to be $75,000, and annual operation
and maintenance costs are estimated to be $35,750 for a total of $715,000. Total costs for
Alternative 2 would therefore be approximately $790,000 over the 20-year time frame. The
inflation rate and the discount rate are assumed to counterbalance. The cost accuracy percentage
was calculated to be approximately -20% to +40%.
7.3 Alternative 3—Soil Excavation with Removal of Chemical Warfare Materials, if
Found
Alternative 3 involves excavation of the entire source area and removal of soil containing
chemical agent breakdown products, debris (e.g., small pieces of glass and wood), and glass vials
or other containers that may still contain CWM. Soils will be excavated to a point where no
CWM or by-products are detected. Field tests and quick-turnaround laboratory analysis will
provide data to ensure that all contaminated soils are excavated during this time period.
Excavated soils containing chemical agent breakdown products and debris will be neutralized (by
mixing a decontamination agent or solution, such as bleach, with the contaminated soil),
containerized, and disposed of in an out-of-state, licensed disposal facility, if required. All
excavated CWM will be identified and packaged in state-of-the-art storage and transportation
containers. The containers will then be transported, via truck, to a secured, interim holding
facility (IHF) at Fort Wainwright until a successful method for destroying or neutralizing
chemical agents is developed and final disposition by treatment or disposal is achieved.
The work plan for Alternative 3 will include measures necessary to ensure that no CWM are
released to the air during excavation, neutralization, and transportation. A comprehensive health
and safety plan has been developed and will be approved before the onset of any fieldwork at the
source area. The health and safety plan addresses potential releases and threats to workers and
nearby populations and emphasizes protection of human health and the environment. Excavation
at the source area will take approximately 2 weeks. The goal is to complete excavation before the
fall session starts at nearby elementary and junior high schools.
Unlike Alternatives 1 and 2, it is believed that the IRA under Alternative 3 will constitute a final
remedy for the Chemical Agent Dump Site. The source area will, however, be included in the
ROD for OU-1.
The costs for Alternative 3 include development of the work plan and a health and safety plan,
excavation of soils, neutralization of contaminated soil, and laboratory analysis of soil samples.
Because the technology to destroy or neutralize chemical agents is still being developed, costs
associated with the technology that may eventually be selected could not be estimated. Because
Alternative 3 will be a relatively short-term response action, the only costs will be capital costs.
The total cost for Alternative 3 is estimated to be $1 million.
lfcJT7901_A587-ROD_OUl-07/06/95-Dl 13
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8.0 SUMMARY OF COMPARATTST ANALYSIS OF ALTERNATIVES
The NCP identifies nine criteria to be used to evaluate remedial alternatives. These criteria are
described below as they apply to an interim action. The first two criteria, the "threshold
criteria," must be satisfied in order for an alternative to be eligible for selection. The next five
criteria, the "primary balancing criteria," are used to weigh major tradeoffs among alternatives
that meet the threshold criteria. The last two criteria, "state acceptance" and "community
acceptance," are referred to as "modifying criteria." State acceptance reflects the State of Alaska's
position on how acceptable each alternative is. Community acceptance is taken into account after
public comment is received on the Proposed Plan.
The three IRA alternatives were evaluated against the nine criteria to select the preferred remedy.
Table 1 provides definitions for each of the nine criteria. Table 2, presented following discussion
of the nine criteria, summarizes information about the evaluation of each alternative relative to the
nine criteria.
8.1 Criterion 1—Overall Protection of Human Health and the Environment
The first threshold criterion, Overall Protection of Human Health and the Environment, addresses
whether a remedy provides adequate protection and describes how risks posed through each
pathway are eliminated, reduced, or controlled.
Based on the PSE, no contamination has been detected in subsurface soil or groundwater at the
Chemical Agent Dump Site. Risks to possible future groundwater users may occur if CWM and
their breakdown products potentially still buried at the source area leak into subsurface soils and
migrate to groundwater.
Under Alternatives 1 and 2, soil containing chemical agent breakdown products, debris, and
containers that may still contain CWM would be left in place. If a release were to occur,
subsurface soils and groundwater could therefore become contaminated. Under Alternative 1,
contamination would remain undetected. Under Alternative 2, potential groundwater
contamination would be detected during the groundwater monitoring process. Alternative 2
provides no mechanism for determining the presence of subsurface soil contamination before
contaminant migration into the groundwater, however. As a result, soil contamination would
remain undetected until or unless contaminants have migrated through soils into the groundwater
under Alternative 2.
In contrast, Alternative 3 will protect human health and the environment. By removing soil
containing chemical agent breakdown products, debris, and any other containers that may still
contain CWM, potential leakage of contaminants into subsurface soils and groundwater will no
longer be possible. Short-term effects are expected to be minimal because of the safety
precautions implemented during excavation to prevent and control potential releases during field
activities.
1*JT2»1_AS87-RODOU1-07A)6/
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Table 1
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY'S
NINE EVALUATION CRITERIA
Overall Protection of Human Health and the Environment
Addresses whether a remedy provides adequate protection of human health and the environment and
describes how risks posed through each exposure pathway are eliminated, reduced, or controlled
through treatment, engineering controls, or institutional controls.
Compliance with Applicable or Relevant and Appropriate Requirements
Addresses whether a remedy will meet all the ARARs of other federal and state environmental laws,
or justifies a waiver.
Long-Term Effectiveness and Permanence
Refers to expected residual risk and the ability of a remedy to maintain reliable protection of human
health and the environment over time once cleanup goals are met.
Reduction of Toxicity, Mobility, and Volume through Treatment
Focuses on the anticipated performance of the treatment technologies that may be used as a cleanup
alternative.
Short-Term Effectiveness
Refers to the period of time needed to achieve protection and any adverse impacts on human health
and the environment that may be posed during die construction and implementation period until
cleanup goals are achieved.
Implementability
Addresses the technical and administrative feasibility of a remedy, including the availability of
materials and services needed to implement a specific solution.
Cost
Includes estimated capital and operations and maintenance costs.
State Acceptance
Considers whether the state, based on its review of the remedial investigation/feasibility study
(RI/FS) and Proposed Plan, concurs, opposes, or has no comment on the preferred alternative.
Community Acceptance
Considers all comments received from the public during the 30-day comment period on the RI/FS
and Proposed Plan.
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Table 2
COMPARISON OF ALTERNATIVES
CHEMICAL AGENT DUMP SITE
OPERABLE UNIT 1
FORT WAINWRIGHT, ALASKA
CRITERION
ALTERNATIVE 1
ALTERNATIVE 2
ALTERNATIVE 3
THRESHOLD CRITERIA
1 . Overall Protection of
Human Health and the
Environment
2. Compliance with
Applicable or Relevant
and Appropriate
Requirements
Would not offer protection as soil and
groundwater contamination would not be
detected
Would not comply if soil contains
chemical agent breakdown products,
debris, and/or chemical warfare materials
While allows for detection of groundwater
contamination during monitoring, would
offer no protection from groundwater or soil
contamination
Would not comply if soil contains chemical
agent breakdown products, debris, and/or
chemical warfare materials
Will protect because of removal of soil with
chemical agent breakdown products, debris,
and containers still containing chemical
warfare materials
Will comply
PRIMARY BALANCING CRITERIA
3. Long-Term Effectiveness
and Permanence
4. Reduction of Toxicity,
Mobility, and Volume
through Treatment
5. Shoit-Tcrm
Effectiveness
6. Implementability
7. Cost
Would not have long-term effectiveness
Would not include treatment and would
not reduce toxicity, mobility, or volume
No, but would cause no harm
Yes, immediately implementable
No cost
Would not have long-term effectiveness
Would not include treatment and would not
reduce (oxicity, mobility, or volume
No, but would cause no harm
Yes, immediately implementable
$790,000 over 20 years
Will be effective in the long term
No treatment, but will reduce mobility and
volume (no reduction in toxicily)
Could result in release of chemical agent to
environment or exposure to oil-site
personnel
Yes, will take one month to implement
contract
$1,000,000
MODIFYING CRITERIA
8. State Acceptance
9. Community Acceptance
No
No
No
No
Yes
Yes
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8.2 Criterion 2—Compliance with Applicable or Relevant and Appropriate Requirements
The second threshold criterion. Compliance with ARARs, addresses whether a remedy will meet
federal and state ARARs and/or justify a waiver. Compliance with ARARs requires evaluation of
the remedial alternatives for compliance with chemical, location, and action-specific ARARs, or
justification for a waiver.
The main ARARs that will be triggered by action at this source area include Army Toxic
Chemical Agent Safety Program. Alaska Water Quality Standards, and Resource Conservation
and Recovery Act (RCRA) to determine whether the materials are hazardous wastes for storage
requirements.
Under Alternative 1, possible CWM and breakdown products would be undetected and left in
place until completion of the ROD for OU-1. As a result, no compliance with ARARs would be
possible.
Under Alternative 2, no CWM or their breakdown products would be removed. If a release were
to occur, this alternative would not comply with soil or groundwater ARARs.
Under Alternative 3, soil containing chemical agent breakdown products, debris, and intact
containers that may still contain CWM will be removed and transported to appropriate facilities.
Soils will be excavated to a point where no CWM are detected. Intact glass vials and other
containers that may still contain chemical agents will be held in a secured IHF at Fort Wainwright
until final disposition by treatment or disposal. Soils with chemical agent breakdown products
and debris will be neutralized, containerized, and transported to an out-of-state, licensed disposal
facility.
Under Alternative 3, all ARARs will be met.
8.3 Criterion 3—Long-Term Effectiveness and Permanence
Long-Term Effectiveness and Permanence is the first of the primary balancing criteria. This
criterion refers to expected residual risk and a remedy's ability to maintain reliable protection of
human health and the environment over time, after cleanup goals have been met.
Under Alternative 1, no action would be taken. As a result, the alternative would have no long-
term effectiveness and permanence. Similarly, because Alternative 2 is only a method of
detecting contamination, it also would have no long-term effectiveness or permanence as a
remedial action.
Under Alternative 3, the excavation/removal option, has long-term effectiveness and permanence
because potential sources of contamination will be removed.
19:JT2901 A387-ROD OU1-07/OW95-D1
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8.4 Criterion 4—Reduction of Toxicity, Mobility, and Volume through Treatment
The second primary balancing criterion, Reduction of Toxicity, Mobility, or Volume through
Treatment, focuses on the anticipated performance of the treatment technologies that may be used
as a cleanup alternative.
Alternatives 1 and 2 would neither treat contaminants nor reduce toxicity. In addition, neither
Alternative 1 or 2 would have any impact on contaminant mobility or volume if CWM or their
breakdown products still exist at the source area.
Alternative 3 will reduce the volume of contaminants and thus contaminant mobility by removing
the contaminants from the source area. If soils with chemical agent breakdown products or debris
are detected, the soil and debris will be treated via neutralization, containerized, and shipped off
site for disposal in an out-of-state, licensed disposal facility. Treatment of the CWM still intact in
containers will not take place until suitable technologies are identified.
8.5 Criterion 5—Short-Term Effectiveness
Short-Term Effectiveness addresses the period of time needed to achieve protection from any
adverse impacts on human health and the environment that may be posed during the construction
and implementation periods, until cleanup goals are achieved.
Alternatives 1 and 2 would pose no short-term risks, unless a release were to occur from the
source area. The groundwater monitoring wells that would be installed under Alternative 2 would
be located in areas where no subsurface soil disturbances have been detected, so installation would
not be expected to cause any contaminant releases.
Alternative 3 is designed to excavate the entire source area and remove any contamination. The
potential exists for a release of CWM and their breakdown products to the environment and/or
exposure of on-site personnel under this alternative. Appropriate health and safety techniques
designed to minimize any potential contaminant release during excavation will be implemented
under Alternative 3.
8.6 Criterion 6—Implementability
Another of the primary balancing criteria, Implementability, addresses the technical and
administrative feasibility of a remedy, including the availability of materials and services needed
to implement a specific solution.
The Army is able to implement any one of the three alternatives. Alternatives 1 and 2 could be
implemented almost immediately. Alternative 3 is logistically and technically more difficult to
implement than Alternatives 1 or 2, however, and will take approximately 1 month to implement
the contract after the ROD is signed. Variations within the projected time frame for Alternative 3
could result based on the availability of personnel knowledgeable of CWM, the quantity and
condition of the containers that may still contain CWM, the potential for discovery of cultural
resources, and local weather conditions.
I9-JT2901 A587-ROD OU1-07/06/95-D1 18
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8.7 Criterion 7—Cost
The last primary balancing criterion, cost, considers estimated capital and operation and
maintenance costs, as well as present worth costs.
Costs for the three alternatives were calculated for a 20-year duration for comparison purposes.
Costs were projected, and actual costs may vary based on final design and detailed cost
itemizations.
No known costs are associated with Alternative 1.
Alternative 2 would cost $75,000 for capital construction and $715,000 for operation and
maintenance, for a total 20-year cost of approximately 5790,000. Although monitoring costs are
projected over 20 years, it is assumed that monitoring would continue indefinitely.
Alternative 3 will cost $1 million for capital construction, but no costs are expected for operation
and maintenance. The estimated total cost of Alternative 3 for the 20-year time frame is
$1 million.
8.8 Criterion 8—State Acceptance
The first of the modifying criteria, State Acceptance, considers whether the state will concur with,
oppose, or have no comment on the selected IRA.
ADEC was involved in the preparation of the Proposed Plan and supports the selection of
Alternative 3.
8.9 Criterion 9—Community Acceptance
The second of the modifying criteria, Community Acceptance, considers questions and comments
received from the public during the 30-day comment period on the Proposed Plan.
Appendix A, the Responsiveness Summary, provides responses to all comments received during
the comment period. Those who participated in the comment period did not voice the same
concerns. As a result, the determination of community acceptance is based on an estimation of
the overall acceptability of each alternative within the community.
Based on the comments received during the comment period, Alternative 1 is believed to be
unacceptable to the community, Alternative 2 is believed to be unacceptable, and Alternative 3 is
believed to be acceptable.
The community supports the Army, EPA and ADEC recommendation for Alternative 3 as the
best alternative that most fully addresses all community concerns.
The main concerns voiced by those who provided comments during the public comment period
addressed whether excavation is appropriate before an approved destruction method becomes
available for CWM, costs associated with the removal, and safety issues. The secured storage
19-.JT2901_A587-ROD_OU1^T7A)6«S-D1 19
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area is more protective of human health and the environment than leaving potential CWM and
their breakdown products buried at the current location. Excavation will take place under
requirements specified in the work plan designed to protect public health during excavation
activities. Costs associated with the removal of CWM are reasonable given the toxicity of the
CWM, if present.
9.0 SELECTED REMEDY
The selected remedy is Alternative 3 because it best meets the nine CERCLA criteria. It protects
human health and the environment and complies with ARARs. It is effective at reducing
contamination both in the short term and long term, and is implementable, cost-effective, and
acceptable to both the public and the State of Alaska. The other alternatives do not meet the
criteria as well as Alternative 3. Alternatives 1 and 2 would provide little additional
environmental benefit, especially relative to risk reduction. Alternative 3 is the most cost-
effective of the three alternatives because it addresses, with certainty, the possible presence of
CWM and prevents future releases.
The major components of the selected remedy include:
• Excavation of the Chemical Agent Dump Site to a maximum depth of
approximately 15 feet or when bedrock is encountered;
• Field screening of excavated material for soil containing chemical agent breakdown
products, debris, and glass vials or other containers that may still contain CWM;
• Storage of all excavated CWM in a secured IHF at Fort Wainwright until final
disposition by treatment or disposal; and
• A chemical neutralization process and containerization of soil containing chemical
agent breakdown products and debris for off-site disposal at an out-of-state, licensed
disposal facility.
9.1 Rationale for Selection
The ability to achieve risk reduction was a major factor in making the selection of this IRA.
Without excavation, there would be no means to determine whether CWM remain buried at the
source area. Without this information, there could be no certainty that a release will not occur at
this source area. Because there is no means to detect a release until it has occurred, and any
exposure via the air or groundwater pathways by chemical agents is considered unacceptable,
excavation of the source area is the most protective alternative. The selected remedy provides
confirmation of the presence or absence of CWM and their breakdown products at the source area
and provides a safe and secure holding facility for the CWM. There is a possibility that CWM
will not be found at this source area, given the results of geophysical and sampling data.
Adequate evidence exists to keep the source area in questionable status, however. As a result,
long-term monitoring will be needed until the presence of CWM and their breakdown products is
confirmed.
19dT2901_A587-ROD_pUl-07;06/9S-DI 20
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This alternative is also considered the most cost-effective in the long run. While the removal cost
is slightly higher than the costs of the long-term groundwater monitoring alternative over a
20-year period, it is very unlikely that monitoring would cease after 20 years. In all probability,
monitoring would continue indefinitely. Any CWM left in place could result in a release, and
costs of cleanup at a future date would far exceed the costs encountered in the selected alternative.
Excavation and storage eliminate the possibility for a release from this source area to the
groundwater at a future date. Any release could occur through container rupture or breakage
caused by ground movement or physical disturbance.
9.2 The Interim Holding Facility
The Chemical Agent Dump Site is located within 1.25 miles of on-post Fairbanks residential
areas, and the area is frequently used by nearby residents for recreational activities. In addition,
the current source area has a chain-link fence around it; access is otherwise unrestricted.
The IMF is located in a secured area of Fort Wainwright, with restricted access and a controlled
environment for storage of CWM. The facility was designed to prevent releases to the
environment. Periodic external air sampling will be conducted by explosive ordnance disposal
personnel to ensure that the containers are secure and that no release has occurred inside the
holding cell.
The IHF is capable of containing any excavated CWM indefinitely. The intention, however, is to
achieve ultimate disposal of the CWM as soon as possible. Final destruction of the CWM is not
part of this ROD. Shipment of CWM and their breakdown products to off-site locations, either
for holding or disposal, would comply with all applicable state and federal laws. The off-site rule
(40 CFR 300.440) is applicable to off-site disposal if the CWM is determined to be a hazardous
waste at time of disposal.
9.3 The Health and Safety Plan
The work plan for Alternative 3 includes measures necessary to ensure that no CWM are released
to the air during excavation, neutralization, and transportation. A comprehensive health and
safety plan has also been developed and will be approved by the Army Safety Office and other
appropriate federal, state, and local agencies before conducting fieldwork at the source area. The
health and safety plan addresses potential releases and threats to workers and nearby populations
and emphasizes protection of human health and the environment.
Excavation at the source area will take approximately 2 weeks. The goal is to complete
excavation before the fall session starts in the nearby elementary and junior high schools.
Additional measures that will be implemented to protect workers and residents include:
• A fence will be placed beyond the perimeter of the source area to restrict road
access during excavation;
• Air monitoring will be conducted continuously during excavation;
I9-JT290I AS87-ROD OUI-IO/W/93-DI 21
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Workers within the exclusion zone (area potentially affected by the removal action)
will be shielded by protective equipment;
Any soil with chemical agent breakdown products and debris will be immediately
neutralized (with a decontamination agent or solution) and containerized; and
If intact containers of CWM are found, they will be immediately placed in a
decontamination solution and overpacked in state-of-the-art storage/transportation
containers.
To reconfirm that no metal objects (such as canisters) are left at the source area,
metal detection equipment will be placed at a depth of approximately 4 feet during
excavation.
10.0 STATUTORY DETERMINATIONS
The primary responsibility of the Army, EPA, and ADEC under their legal CERCLA authority is
to select IRAs that are protective of human health and the environment. In addition, Section 121
of CERCLA, as amended by the Superfund Amendments and Reauthorization Act of 1986,
provides several statutory requirements and preferences. The selected remedy must be cost-
effective and utilize permanent treatment technologies or resource recovery technologies to the
extent practicable. The statute also contains a preference for remedies that permanently or
significantly reduce the volume, toxiciry, or mobility of hazardous substances through treatment.
CERCLA finally requires that the selected remedial action for the source area must comply with
ARARs established under federal and state environmental laws, unless a waiver is granted.
The selected alternative for this IRA is protective of human health and the environment and
satisfies the requirements of Section 121 of CERCLA. It is anticipated that this action will be the
final action required for removing CWM and their breakdown products from this source area
unless groundwater contamination is identified, in which case the data will be immediately
calculated and a response action taken. This remedy utilizes permanent solutions for potential soil
contamination and alternate treatment technologies to the maximum extent practicable and satisfies
the statutory preference for remedies that employ treatment that reduces toxicity, mobility, or
volume as a principal element. Storage of the CWM in a secured holding facility is the maximum
practicable treatment available at this time.
10.1 Protection of Human Health and the Environment
The selected IRA will protect human health and the environment by excavating the source area,
field screening of the excavated materials, neutralizing and containerizing of soil containing
chemical agent breakdown products and debris, and storing CWM in a Fort Wainwright IHF.
Removal of CWM and their breakdown products will reduce the potential for release of
contamination to the environment and subsequent migration of contaminants into groundwater.
The selected remedy thus reduces the threat to future potential drinking water supplies.
19:JT2901 A5S7-ROD OU1-07/06/95-D1
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102 Compliance with Applicable or Relevant and Appropriate Requirements and To-Be-
Considered Guidance
The selected remedy is expected to comply with all ARARs of federal and state environmental
and public health laws. These include compliance with all the chemical-, action-, and location-
specific ARARs listed below. No waiver of any ARAR is being sought or invoked for any
component of the selected remedy. In addition, the selected remedy will comply with additional
regulations that offer TBC guidance.
• Maximum Contaminant Levels (MCLs) and Maximum Contaminant Level Goals
(MCLGs) are established under the Safe Drinking Water Act (40 CFR 141). The
monitoring results will be compared to MCLs to determine whether the standards
have been exceeded. MCLs and MCLGs are relevant and appropriate.
• Alaska Water Quality Standards (18 AAC 70.020) protect groundwater from toxic
and other deleterious effects of organic and inorganic substances. The standards are
applicable if a release occurs to the groundwater.
• RCRA Subtitle C (40 CFR 261 [Code of Federal Regulations] Subpart D) is
applicable hi determining whether the CWM will be considered hazardous waste(s).
The RCRA Off-Site Disposal Policy (40 CFR 300) is applicable to off-site disposal
of RCRA-regulated waste.
• RCRA (40 CFR 264) Storage Requirements are applicable, but Army standards for
storage of CWM are expected to be more restrictive.
• The Cleanup section of the State Oil and Hazardous Substances Pollution Control
Regulations (18 Alaska Administrative Code [AAC] 75) requires that parties
responsible for the discharge of any hazardous substance to land or water
immediately contain, clean up, and dispose of the material collected. This state
regulation will apply should any discharge occur.
• Section 404 of the Clean Water Act, which is implemented through regulations in
the Federal Water Pollution Control Act (40 CFR 230), sets forth guidelines to
control discharges of dredged or fill material into wetlands. This action will be
designed to ensure that there is no discharge of materials into wetlands adjacent to
the source area.
• Army Regulation 50-6 Chemical Surety specifies handling and disposal
requirements for nonstockpiled CWM. This regulation is appropriate to
investigations and disposal of materials at this source area. This regulation also
specifies air release modeling requirements and standards for the protection of
public health.
• The source protection section of the State's Drinking Water Regulations (18 AAC
80.015) prohibits a person from creating or maintaining a condition that has a
I9-JT290I AOT4UX) OUI-07/13/W-DI 23
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significant potential to pollute or contaminate a public water system. This
regulation applies if a release occurs to the groundwater.
10.2.1 TBC Guidance
• Army Regulation 385-61, Army Toxic Chemical Agent Safety Program, outlines
the procedures for transportation and handling requirements for CWM.
• Army Pamphlet 385-61, Toxic Chemical Agent Safety Standards, provides details
and specific guidance for transporting and handling CWM.
103 Cost Effectiveness
The selected IRA is cost-effective because it protects human health and the environment, attains
ARARs, and meets the objectives established for the interim action in a way that is proportional
to its cost. The cost of the selected remedy is slightly higher than the cost of Alternative 2. The
Army, EPA, and ADEC do not believe that Alternative 2 is protective of human health and the
environment; however, Alternative 1 is the least expensive but is not protective of human health
and the environment.
10.4 Utilization of Permanent Solutions and Alternative Treatment Technologies or
Resource Recovery Technologies to the Maximum Extent Practicable
It is anticipated that this action will be the final action required for addressing this source area
unless groundwater contamination is identified. If groundwater contamination is identified, data
will be evaluated immediately and an appropriate response action will take place. This remedy
utilizes permanent solutions for potential soil contamination and alternate treatment technologies to
the maximum extent practicable, and satisfies the statutory preference for remedies that employ
treatments that reduce toxicity, mobility, or volume as a principal element. Storage of the CWM
hi a secured holding facility is the maximum practicable treatment available at this time.
10.5 Preference for Treatment as a Principal Element
This action removes source(s) of contamination, if any, and limits the spread of contaminants to
the groundwater in the aquifer beneath the Chemical Agent Dump Site. By removing intact
CWM to the IHF and by excavating and treating contaminated soils and debris, the selected
remedies address the principle threats posed by the source area through the use of treatment
technologies. Therefore, the statutory preference for remedies that employ treatment as a
principal element is satisfied.
11.0 DOCUMENTATION OF SIGNIFICANT CHANGES
The selected IRA is the same as the preferred alternative presented in the Proposed Plan and
during the public meeting. No changes in the components of the preferred alternative have been
made.
IfelTOOl A5T7-KOD OU1-O7/I3/95-OI 24
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APPENDIX A
RESPONSIVENESS SUMMARY
19JT2901.ASW.ROD.OUI-O7W7/W-D1 A - 1
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RESPONSIVENESS SUMMARY
FOR THE RECORD OF DECISION FOR INTERIM REMEDIAL ACTION AT THE
CHEMICAL AGENT DUMP SITE, FORT WAINWRIGHT, ALASKA
A. OVERVIEW
The U.S. Army (Army), United States Environmental Protection Agency (EPA), and the
Alaska Department of Environmental Conservation (ADEC), collectively referred to as the
Agencies, distributed a Proposed Plan for interim remedial action (IRA) at the Chemical
Agent Dump Site, a source area in Operable Unit 1 (OU-1), Fort Wainwright, Alaska. The
Proposed Plan identified a preferred alternative that includes soil excavation, field screening,
neutralization and containerization of soil containing chemical agent breakdown products and
debris, and storage of chemical agent materials. The term chemical agent materials used in
the Proposed Plan was substituted in the Record of Decision (ROD) and this Responsiveness
Summary with chemical warfare materials (CWM). CWM consists of intact glass vials or
other containers that may still contain chemical agents.
Specifically, the ROD describes the major components of the selected remedy as follows:
• Excavation of the Chemical Agent Dump Site to a maximum depth of
approximately 15 feet, or when bedrock is encountered;
• Field screening of excavated material for soil containing chemical
agent breakdown products, debris, and glass vials or other containers
that may still contain CWM;
• Storage of all excavated chemical warfare materials in a secured
interim holding facility at Fort Wainwright until final disposition by
treatment or disposal; and
• A chemical neutralization process and containerization of soil con-
taining chemical agent breakdown products and debris for off-site
disposal at an out-of-state, licensed disposal facility.
The purpose of the IRA is to reduce risks posed by the potential presence of soil containing
chemical agent breakdown products, debris, and CWM. The IRA will also reduce the
potential for contamination of ground water, thus eliminating a pathway of contaminant
migration to humans, wildlife, and plants.
No comments regarding the Proposed Plan for the Chemical Agent Dump Site were received
during the public comment period. However, questions asked at the public meeting on April
25, 1995, focused on rationale for excavation before final development and approved use of a
mobile system to destroy or neutralize chemical agents. These questions and Agency
responses are summarized in the following sections.
This Responsiveness Summary is organized into the following sections:
• Part B: Background of Community Involvement; and
• Part C: Summary of Questions Asked During the Public Meeting
and Agency Responses.
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B. BACKGROUND OF COMMUNITY INVOLVEMENT
Community relations activities, aimed at increasing public awareness and involvement, have
been ongoing at Fort Wainwright for several years. In addition to a postwide Community
Relations Plan, operable unit (OU)-specific community relations plans have been developed to
address OU and source area concerns.
The public was encouraged to participate in the selection of the remedy for the Chemical
Agent Dump Site during a public comment period from April 19 to May 19, 1995. The Fort
Wainwright Proposed Plan for Interim Remedial Action at the Operable Unit 1 Chemical
Agent Dump Site presented alternatives being considered by the Army, EPA, and ADEC for
the source area. The Proposed Plan was released to the public on April 19, 1995, and copies
were sent to all known and interested parties, including approximately 150 elected officials
and concerned citizens. An informational Fact Sheet dated March 1995, providing informa-
tion about the Army's entire cleanup program at Fort Wainwright, was mailed to the
individuals and organizations on the mailing list.
The Proposed Plan summarized available information about the source area. Additional
materials were placed in two information repositories located at the Noel Wien Library in
Fairbanks and die Fort Wainwright Post Library. An Administrative Record, comprising all
items placed in the information repositories and other documents used in the selection of the
interim remedial action, was established in Building 3023 on Fort Wainwright. Members of
the public were invited to inspect materials available in the Administrative Record and the
information repositories during business hours.
Interested citizens were invited to comment on the Proposed Plan and the remedy selection
process in writing by mailing comments to the Fort Wainwright project manager, calling a
toll-free telephone number to record a comment, or commenting in person at the public
meeting on April 25, 1995, in Fairbanks at the Noel Wien Library.
Postwide community relations activities conducted for Fort Wainwright, which includes the
Chemical Agent Dump Site as a source area in OU-1, have included:
• July 1992—Conducted community interviews with local officials and
interested parties;
• April 1993—Prepared Community Relations Plan;
• July 1993—Distributed an informational fact sheet covering all OUs
at Fort Wainwright;
• July 22, 1993—Conducted an informational public meeting covering
all OUs;
• February 23, 1994—Established information repositories at the Noel
Wien Library and the Fort Wainwright Post Library; and
• April 22, 1994—Established the Administrative Record at Building
3023 on Fort Wainwright.
Community relations activities specifically conducted for the Chemical Agent Dump Site
included:
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• April 12, 16, 19, 23, 24, and 25, 1995—Published display advertise-
ment announcing the public meeting in the Fairbanks Dotty News-
Miner,
• April 19, 1995—Distributed Proposed Plan for Interim Remedial
Action at the Operable Unit 1 Chemical Agent Dump Site;
• April 19 to May 19, 1995—30-day public comment period. No
extension was requested;
• April 19 to May 19, 1995—Offered a toll-free telephone number for
citizens to provide comment. The toll-free telephone number was
advertised in the Proposed Plan and the newspaper display advertise-
ment that announced the public meeting; and
• April 25, 1995—Conducted the public meeting at the Noel Wien
Library to provide information, a forum for questions and answers,
and an opportunity for public comment regarding the Chemical
Agent Dump Site.
C. SUMMARY OF QUESTIONS ASKED DURING THE PUBLIC MEETING AND
AGENCY RESPONSES
The public comment period on the Proposed Plan for Interim Remedial Action at the
Operable Unit 1 Chemical Agent Dump Site was held from April 19 to May 19, 1995. No
comments were received regarding the Chemical Agent Dump Site during the comment
period. A public meeting was conducted on April 25, 1995, at the Noel Wien Library. The
public meeting was divided into three parts: a presentation on the Chemical Agent Dump
Site1, an informal question-and-answer session, and a formal public comment session. The
public was informed of the meeting structure at the beginning of the meeting.
Questions regarding the Chemical Agent Dump Site were raised during the meeting. Many of
the questions were answered at the public meeting as reflected in the transcript filed in the
Administrative Record. Two comments were received during the formal public comment
period; however, they did not address the Chemical Agent Dump Site. Questions and Agency
responses from the informal question-and-answer session are organized by relevant topics and
summarized in the following section.
Presence of Contamination
1. Public Concern: A question was raised regarding why the Agencies plan to excavate
soils if uncertainty exists regarding the presence of chemical warfare material at the
site.
Agency Response: Every investigative technique has been used to determine the
presence of soil containing chemical agent breakdown products, debris, and CWM at
the site, except excavation. Based on the results of these investigations, it is not
1 The public meeting referred to in this Responsiveness Summary was a joint meeting for
IRA at the Chemical Agent Dump Site and Final Remedial Action at Operable Unit 3, Fort
Wainwright, Alaska.
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expected that metal containers are buried at the site. However, nonmetallic containers
of CWM may be present at the site. It is also possible that nothing is buried at the
site. The only way to determine whether CWM are buried at the site is to excavate
soil at the site. Without knowing whether chemical warfare materials are buried at
the site, the Agencies do not know whether or when potential soil or groundwater
contamination could occur. Soil excavation would provide definite answers to these
questions.
Destruction of Chemical Warfare Materials
1. Public Concern: A question was raised concerning the Army's plans to excavate the
site before a method to destroy CWM is developed.
Agency Response: The Army is currently designing a mobile system to destroy or
neutralize chemical warfare material. The system is scheduled to be field tested
during August 1995. If field tests are successful, the system will be shipped to
Alaska and used to neutralize any CWM excavated at the site.
2. Public Concern: A question was raised regarding the preferred alternative chosen by
the Agencies because a method to destroy chemical warfare materials has not been
approved for use. It was also questioned whether it would be safer to leave buried
materials in place until a destruction method is developed.
Agency Response: The Army conducted an investigation, at the Chemical Agent
Dump Site, which involved soil and groundwater sampling. Contamination was not
detected.. However, risk to possible future groundwater users may occur if CWM,
potentially still present, leak into subsurface soil and migrate to groundwater. By
excavating and removing soil containing chemical agent breakdown products, debris,
and CWM, potential leakage of contaminants into subsurface soil and groundwater
will no longer be possible.
3. Public Concern: Concern was expressed regarding the time frame between excava-
tion and the destruction of CWM.
Agency Response: Excavation of the site is scheduled to begin within one month
after the ROD is signed. Field tests for the mobile destruction system have not been
completed; however, the Army expects the system to be available within the next
year.
Cost Issue
1. Public Concern: The public questioned whether the $1 million estimated to imple-
ment the preferred alternative included only excavation or all costs to clean up the
site.
Agency Response: The $1 million estimate includes development of the work plan
and a health and safety plan, excavation of soils, neutralization of contaminated soil,
and laboratory analysis of soil samples. The cost also includes storage of excavated
CWM in a secured interim holding facility at Fort Wainwright.
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