EPA Superfund
Record of Decision:
USARMY
Fort Richardson OU C
Fort Richardson, AK
9/30/1998
PB98-964607
EPA541-R98-182
March 1999
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RECORD OF DECISION
for
OPERABLE UNIT C
FORT RICHARDSON
ANCHORAGE, ALASKA
September 1998
ANC/TRM93 DOG980470002
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RECORD OF DECISION
for
OPERABLE UNIT C
FORT RICHARDSON
ANCHORAGE, ALASKA
September 1998
Contract No. DAC85-95-D-0015
Delivery Order 0012
Department of the Army
U.S. Army Engineer District, Alaska
Prepared by:
CH2MHILL
301 West Northern Lights Boulevard
Suite 601
Anchorage, Alaska 99503
ANC/TRM93.DOCV9804 70002
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DECLARATION STATEMENT
for
RECORD OF DECISION
FORT RICHARDSON
ANCHORAGE, ALASKA
OPERABLE UNIT C
1998
SOURCE AREA NAME AND LOCATION
Operable Unit C
Fort Richardson
Anchorage, Alaska
STATEMENT OF BASIS AND PURPOSE
This Record of Decision (ROD) presents the selected remedial actions for Operable Unit C
(OU-C). OU-C consists of two source areas: the Eagle River Flats (ERF) and the former Open
Burning/Open Detonation (OB/OD) Pad. This ROD was developed in accordance with the
Comprehensive Environmental Response, Compensation, and Liability Act of 1980
(CERCLA) as amended by the Superfund Amendments and Reauthorization Act of 1986;
42 United States Code 9601 et seq., and, to the extent practicable, the National Oil and
Hazardous Substances Pollution Contingency Plan (NCP), 40 Code of Federal Regulations 300
et seq. This decision is based on the Administrative Record for OU-C.
The United States Army (Army), the United States Environmental Protection Agency
(EPA), and the State of Alaska, through the Alaska Department of Environmental
Conservation (ADEC), have agreed to the selected remedies.
ASSESSMENT OF THE SITE
Actual or threatened releases of hazardous substances resulting from white phosphorus
contamination of the ERF source area of OU-C, if not addressed by implementing the
response actions selected in this ROD, may present an imminent or substantial threat to
public health, public welfare, or the environment. ERF is contaminated with white
phosphorus particles.
DESCRIPTION OF THE SELECTED REMEDY
OU-C is the third OU to reach the final-action ROD at the Fort Richardson National
Priorities List site. This ROD addresses sediment contamination at the ERF source area of
OU-C.
No further action is selected for the former OB/OD Pad for hazardous chemicals. Because
of concerns about potential human exposure to unexploded ordnance, the Army has
institutional controls that provide monitoring and control of access to the site. These
controls are required to remain in place. No analysis of remedial alternatives was conducted
for the OB/OD Pad source area. A discussion of the OB/OD Pad is provided in Section 9 of
this ROD.
ANC/TRM93.DOC/980470002
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The remedial action objectives (RAOs) for the ERF are designed to accomplish the
following:
• Within 5 years of the ROD being signed, reduce the dabbling duck mortality rate
attributable'to white phosphorus to 50 percent of the 1996 mortality rate attributable to
white phosphorus. Radio tracking and aerial surveys suggest that about 1,000 birds died
from white phosphorus at ERF in 1996. Therefore, the allowable number of duck deaths
from white phosphorus would be approximately 500.
• Within 20 years of the ROD being signed, reduce the mortality attributable to white
phosphorus to no more than 1 percent of the total annual fall population of dabbling
ERF ducks. Currently, that population is about 5,000. Therefore, the allowable number
of duck deaths from white phosphorus would be approximately 50. This long-term goal
could be adjusted based on future population studies conducted during the monitoring
program.
These objectives will be achieved by reducing the area of white phosphorus-contaminated
media and reducing the exposure to white phosphorus. Reducing the exposure will reduce
the availability of white phosphorus to ducks, which in turn will reduce duck deaths.
Monitoring at ERF will be conducted to verify that RAOs are achieved. The following are
goals of monitoring:
• To verify that an exposure pathway does not exist between waterfowl and white
phosphorus-contaminated sediment
• To determine the number of waterfowl using ERF
• To determine the number of waterfowl dying as a result of feeding in white
phosphorus-contaminated sediment
• To determine whether remedial action is effective or needs modification
The major components of the preferred remedy for OU-C are listed below. It is assumed
that implementation of the remedy will begin in 1999 and end in 2018 (duration of
20 years). Treatment will occur between 1999 and 2003, and will be followed by long-term
monitoring from 2004 to 2018. The sequence and schedule of operation and maintenance
activities are presented in Tables 1 and 2, respectively.
• Treat white phosphorus-contaminated sediment by draining ponds with pumps for five
summers beginning in 1999. Pumping would allow the sediments to dry and the white
phosphorus to sublimate and oxidize. The treatment season would begin in May and
end in September. A pond elevation survey would be conducted to determine the
optimal pump placement. To enhance drainage, explosives may be used to make small
sumps for the pumps and shallow drainage channels. These shallow drainage channels
would enhance hydraulic connectivity between ponds to encourage drainage.
• Implement the following protective procedures to minimize disturbances to wetlands
habitat:
- Restriction of activities that disturb wildlife in Area B and Area D, which are prime
waterfowl habitat areas
IV ANOTRM93.DOC/9804TO002
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- Selection of the narrowest and shortest walking corridors to minimize disturbances
to vegetation and habitat
- Proper maintenance of equipment and structures
- Minimization of the use of equipment and of staging-area footprints
- Minimal localized use of explosives
- Preparation of work plans and solicitation of agency reviews
- Monitoring for impacts to wetlands habitat
- Monitoring for waterfowl use of ERF
TABLE 1
Sequence of Activities for the Selected Alternative
Activity
Time Frame
Monitoring Activities
Waterfowl telemetry and mortality study
Aerial waterfowl surveys
White phosphorus monitoring of treated ponds
White phosphorus composite sampling 4n
untreated areas
GIS database management
Pond survey, ground truthing. limited aerial
survey
Aerial photography and interpretation
Mapping of physical habitat changes and
vegetation rebound
Treatment Activities
Pond pumping treatment
Cap and fill application
Cap and fill integrity inspection
Hazing (contingency)
Every year for first 8 years, Year 10, Year 15, and Year 20
(11 events)
Every year for first 8 years, Year 10, Year 15, and Year 20
(11 events)
Every year for first 5 years (5 events)
Every year for first 5 years (5 events)
Every year for first 8 years, Year 10, Year 15, and Year 20
(11 events)
Year 1 and every year from Year 9 to Year 20 (13 events)
Every other year for 10 years (5 events)
Once every 4 years for 20 years (6 events)
Even/ year for first 5 years (5 events)
Year 5 (1 event)
Every year for 4 years after material is placed (Year 5, 6, 7,
8), Year 10, Year 15, and Year 20 (7 events)
Every year for first 5 years (5 events, if needed)
ANC/THM93.DOC/980470002
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TABLE 2
Schedule of Activities for Selected Alternatives
1 2 3 4 6 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20
Y«ar: 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016 2017 2018
Tldt Predictions: W«t Wet Dry Dry Dry Wet Dry Dry Dry Wet Wet Dry Dry Wet Wet Wet
Activity:
Waterfowl telemetry and mortality study
Aerial waterfowl surveys
While phosphorus monitoring ol treated ponds
White phosphorus composite sampling in untreated areas
GIS database management
Ponds survey, ground truthing, limited aerial survey
Aerial photography and interpretation
Mapping ol physical habitat changes and vegetation rebound
T»«tin«nt .. .._.__. .
Pond pumping treatment
Cap and fill application
Cap and fill integrity inspection
Hazing (contingency)
Hcrtfllly md whttt pnotphana
conctntnttont Ofcnut caniltttnttr licit
tfftr.
Tnnd iitMtmid. Short Itm RAO mtl II
•ndolYurS.
Pumping ptrtonrtKL Men tctlvtty during
dry ynn; kit during wit yiin. Only
imitt. lioutid mount* of wtiltt
pnotehonn a*t*cttd.
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i-j-".;»:. s/V .Jfe. ' . .-• .''".
XX X
XXX
XXX
XXX
XXX
X
X X
X
Cip-md-mi
tppUfOtO
•mtttfufdo
not dry.
f:.\.i.vi.Vi.-i.'..:vfc
X X
X X
X X
X X
X X
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X
Continue mofttllty md
*rhlt* pftotphoru*
monitoring to tn» art
RAOl in nulnUlMd.
MorteMf? monitoring ptrformfd il Yiir 10. Ynr IS. ind Yur X lo miun Oat RAOl in
mtlntilntd. ^ ,
UmHid nrtil md Imd lumyi conducttd pfrtodlctlly
Nilunl proomm Ilki uaimmHtlon eonllnu*. | Long-
MOl
rmL
'• • - . . ' '.: • - 'it
X X X X X X
X X X X X X
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xxxxxxxxxxxx
X X
X X X X
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Assumptions:
t. Active remediation will be performed until Year 5. Treatment progress and monitoring technique will be evaluated during the 5-year review.
2. Waterfowl mortality will decline after each year ol treatment.
3. A trend will be established to justify that reaching the short-term mortality goal is the result of treatment (white phosphorus removal), and not just a limited data set.
4. Cap-and-lill material will be applied to 2.17 acres ol pond bottoms at Year 5. II is assumed that 5% of Pond 146, 5% ol Pond 155, and 10% of Northern A ponds will not dry.
5. Telemetry and mortality studies, aerial waterfowl surveys, reduced white phosphorus sampling, limited GIS database management, and studies ol habitat rebound will be performed lor an additional 3 years
alter active pumping is complete. This additional monitoring is to ensure that cleanup objectives are not only reached, but also maintained.
6. Telemetry and mortality studies, aerial waterfowl surveys, limited GIS database management, and limited studies of habitat rebound will be performed at Years 10,15, and 20 to ensure that cleanup objectives
are maintained.
7. Limited site visits to inspect for walerfowl mortality, physical habitat changes, and vegetation rebound will be performed during years that telemetry mortality studies are not performed. Assessment will be
performed visually on toot and by air.
ANC/T
IS/981140001
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Sample pond bottoms for white phosphorus at the beginning of the treatment season to
confirm or determine that the pond or area requires remediation. The sampling also
would establish a white phosphorus baseline and determine additional areas that may
require remediation. The baseline sampling would be performed at the beginning of
each field pumping season (every year for the first 5 years, starting in 1999).
Sample pond bottoms for white phosphorus after treatment to determine effectiveness
of the treatment system. This verification sampling would be performed at the end of
each field pumping season (every year for the first 5 years, starring in 1999).
Perform telemetry monitoring and aerial surveys every year for the first 5 years
concurrently with pumping activities to determine bird populations, usage, and
mortality. These activities would begin in 1999. Monitoring would be continued for
3 additional years to verify that short-term goals are maintained. Monitoring also would
be conducted at Year 10, Year 15, and Year 20 to ensure that remedial action objectives
continue to be maintained.
Perform limited aerial surveys and ground truthing during Year 9 to Year 20 to evaluate
waterfowl mortality, physical habitat changes, and vegetation rebound.
Perform aerial photography every other year for 10 years (beginning in 1999) to monitor
habitat changes resulting from remedial actions. Changes in drainage, topography, and
vegetation would be evaluated.
Perform habitat mapping once every 4 years for 20 years to evaluate impacts to habitat
as a result of remedial actions, as well as to observe physical habitat changes and
vegetation rebound after pumping is discontinued.
Perform limited hazing (only as a contingency) during first 5 years starting in 1999 if
incidental hazing from pumping operations and other fieldwork activities does not
deter bird usage.
After remedial action objectives are achieved and pumping is discontinued, apply cap-
and-fill material in ponded areas that did not drain and dry sufficiently to enable the
white phosphorus to sublimate and oxidize. Cap-and-fill material placement is expected
to occur in Year 5 (2003).
Monitor cap and fill material integrity every year for 4 years after the material is placed,
and also at Year 10, Year 15, and Year 20.
Incorporate white phosphorus sampling, telemetry, aerial survey, habitat, and physical
landform data into a geographical information system (GIS) database. Perform GIS
management every year for the first 8 years, starting in 1999, and then during Year 10,
Year 15, and Year 20.
Maintain institutional controls, including the restrictions governing site access,
construction, and road maintenance and the required training for personnel who work
at OU-C source areas, as long as hazardous substances, and unexploded ordnance
hazards, exist at OU-C.
ANC/TRM93.DOC/980470002
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STATUTORY DETERMINATION
The selected remedy 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. The remedy uses permanent solutions and alternative
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.
Because the remedy will result in hazardous substances that present a substantial ecological
risk remaining on site, a review will be conducted within 5 years after commencement of
the remedial action to ensure that the remedy continues to provide adequate protection of
human health and the environment. Review will continue for 5-year increments until the
RAOs are complete.
VIII ANOTRM93.DOC/980470002
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SIGNATURE
Signature sfieet for the foregoing Operable Unit C, Fort Richardson, Record of Decision
between the-United States Army and the United States Environmental Protection Agency,
Region X, yjith owtcurrenee by the Alaska Department of Environmental Conservation.
William M.Steele.
Lieutenant GeneraY USA
Commlmcttng'tjeneral
U.S. Army Pacific
ANC/TRM93.00C/98047000Z
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SIGNATURE
Signature sheet for the foregoing Operable Unit C, Fort Richardson, Record of Decision
between the Unked States Army and the United States Environmental Protection Agency,
Region X, with concurrence by the Alaska Department of Environmental Conservation.
uck Clarke, Regional Administrator, Region X
United States Environmental Protection Agency
ANOTRM93.DO&S8C47GOC2
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SIGNATURE
Signature sheet for the foregoing Operable Unit C, Fort Richardson, 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.
4 - It?-/
&/• /^/
\ Kurt Fredriksson, Director, Spill Prevention and Response
Alaska Department of Environmental Conservation
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Contents
Section
Decision Summary 1
Declaration Statement iii
Abbreviations xvii
1 Site Description 1-1
1.1 Operable Unit C Site Locations and Descriptions 1-2
1.1.1 Eagle River Flats 1-2
1.1.2 OB/ODPad 1-5
1.2 Land Use 1-5
2 Site History and Enforcement Activities 2-1
2.1 ERF Site History : 2-1
2.2 Enforcement Activities 2-8
2.3 Agency Cooperation 2-8
2.4 Highlights of Community Participation 2-9
2.5 Scope and Role of Operable Unit 2-9
3 Summary of Site Characteristics 3-1
3.1 Eagle River Flats 3-1
3.1.1 Physical Features, Hydrogeologic Conditions, and
Transport Pathways 3-1
3.1.2 Nature and Extent of Contamination 3-1
3.2 Treatability Studies 3-7
4 Summary of ERF Site Risks 4-1
4.1 Human Health Risk Assessment 4-1
4.1.1 Offsite Hunter Exposure Scenario 4-2
4.1.2 Onsite Recreation Scenario at ERF 4-3
4.1.3 Uncertainties 4-3
4.2 Ecological Risk Assessment 4-5
4.2.1 Ecological Problem Formulation 4-5
4.2.2 Ecological Risk Analysis 4-7
4.2.3 Ecological Risk Characterizarion 4-10
5 Description of Alternatives 5-1
5.1 Need for Remedial Action 5-1
5.2 Remedial Action Objectives 5-1
5.3 Significant Applicable or Relevant and Appropriate Requirements and To
Be Considered Criteria 5-2
5.4 Description of Alternatives 5-2
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Contents, Continued
6 Summary of Comparative Analysis of Alternatives 6-1
6.1 Threshold Criteria 6-1
6.1.1 Overall Protection of Human Health and the Environment 6-1
6.1.2 Compliance with Applicable or Relevant and Appropriate
Requirements 6-2
6.2 Balancing Criteria 6-2
6.2.1 Long-term Effectiveness and Permanence 6-2
6.2.2 Reduction of Toxicity, Mobility, and Volume Through Treatment.... 6-3
6.2.3 Short-term Effectiveness 6-3
6.2.4 Implementability 6-4
6.2.5 Costs : 6-4
6.3 Modifying Criteria 6-5
6.3.1 State Acceptance 6-5
6.3.2 Community Acceptance 6-5
7 Selected Remedy 7-1
7.1 Major Components of the Selected Remedy 7-1
7.2 Agency Review of the Selected Remedy 7-5
8 Statutory Determinations 8-1
8.1 Protection of Human Health and the Environment 8-1
8.2 Compliance With Applicable or Relevant and Appropriate Requirements
and To-Be-Considered Guidance 8-1
8.2.1 Applicable or Relevant and Appropriate Requirements 8-2
8.2.2 Chemical-Specific ARARs 8-2
8.2.3 Location-Specific ARARs , 8-2
8.2.4 Action-Specific Requirements 8-3
8.2.5 To-Be-Considered Criteria or Guidance 8-4
8.3 Cost Effectiveness 8-5
8.4 Utilization of Permanent Solutions and Alternative Treatment
Technologies or Resource Recovery Technologies to the Maximum Extent
Practicable 8-6
8.5 Preference for Treatment as a Main Element 8-6
9 OB/ODPad 9-1
9.1 Site History 9-1
9.2 Site Characteristics 9-1
9.2.1 Physical Features, Hydrogeologic Conditions, and
Transport Pathways 9-1
9.2.2 Nature and Extent of Contamination 9-2
XIV ANCTHM93.DOC.-98W70CO2
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Contents, Continued
9.3 Summary of Site Risks 9-9
9.3.1 Human Health Risk Assessment 9-9
9.3.2 Ecological Risk Assessment 9-13
9.4 OB/OD Pad Closure 9-13
9.4.1 Closure Process 9-15
10 Documentation of Significant Changes 20-1
Appendix
A Fort Richardson Administrative Record Index Update
B Responsiveness Summary
C Baseline Cost Estimates for Remedial Alternatives, Operable Unit C Source Area,
Fort Richardson
Table
1 Sequence of Activities for the Selected Alternative v
2 Schedule of Activities for the Selected Alternative vi
2-1 Summary of Previous Investigations at Eagle River Flats 2-5
3-1 Identification of ERF Areas, Pond Groups, and Ponds Requiring Cleanup 3-5
4-1 Noncancer Risks in Offsite Duck Hunter Scenario 4-3
6-1 Criteria for Evaluation of Alternatives 6-1
6-2 Cost Estimate for Cleanup Action Alternatives 6-5
7-1 Sequence of Activities for the Selected Alternative 7-2
7-2 Schedule of Activities for the Selected Alternative 7-3
9-1 Regulatory Levels for Detected Chemicals in Soil 9-5
9-2 Sediment/Soil Concentrations from OB/OD Pad and Reference Areas 9-6
9-3 Detected Chemicals in Groundwater 9-9
9-4 Toxicological Parameters 9-11
9-5 Summary of Risks in the Onsite Recreational Scenario 9-12
9-6 Critical Toxicity Values for Organic Soil Contamination at OB/OD Pad 9-14
ANC/TRM93.DOC/980470002
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Contents, Continued
Figure
1-1 Location Map 1-3
1-2 Site Map 1-4
2-1 Framework of Investigations 2-3
3-1 Pond Groups 3-6
4-1 Vicinity Map 4-4
4-2 Potential Exposure Routes and Pathways for Sediment 4-6
5-1 Floating Pump System 5-5
5-2 Blackhawk Helicopter Application of Cap-and-Fill Material 5-6
5-3 Winter Truck Application of Cap-and Fill Material 5-6
9-1 Metal Concentrations in Soil 9-3
9-2 Organic Concentrations in Soil .• 9-4
9-3 Metal Concentrations in Groundwater 9-7
9-4 Organic Concentrations in Groundwater 9-8
XVI ANC/TRM93 OOC98W 70002
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Abbreviations
AAC Alaska Administrative Code
ADEC Alaska Department of Environmental Conservation
ADFG Alaska Department of Fish and Game
AOPEC area of potential ecological concern
AR Army Regulation
ARAR applicable or relevant and appropriate requirement
Army U.S. Army
bw body weight
CERCLA Comprehensive Environmental Response, Compensation, and Liability
Act of 1980 (Superfund)
CFR Code of Federal Regulations
COE U.S. Army Corps of Engineers
COPC chemical of potential concern
COPEC chemical of potential ecological concern
CRREL U.S. Army Cold Regions Research and Engineering Laboratory
CSM conceptual site model
CTV critical toxiciry value
CWA Clean Water Act
EPA U.S. Environmental Protection Agency
ERF Eagle River Flats
FFA Federal Facility Agreement
FFCA Federal Facility Compliance Agreement
FS feasibility study
GIS geographical information system
HE high explosive
IRIS Integrated Risk Information System
LD50 lethal dose for 50 percent of a sample population
LOEL lowest observed effect level
ug/g micrograms per gram
ANC/TRM93.DOO980470002
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ABBREVIATIONS
ug/kg micrograms per kilogram
mg milligram
mg/kg milligrams per kilogram
msl mean sea level
NCP National Contingency Plan
NOEL no observed effect level
NPL National Priorities List
OB/OD Open Burning/Open Detonation
OU operable unit
RAO remedial action objective
RCRA Resource Conservation and Recovery Act of 1976
RI remedial investigation
RME reasonable maximum exposure
ROD Record of Decision
SARA Superfund Amendments and Reauthorization Act
SOP Standard Operating Procedure
TBC to be considered
UCI Upper Cook Inlet
USAEHA U.S. Army Environmental Hygiene Agency
USFWS U.S. Fish and Wildlife Service
UXO unexploded ordnance
XVIII
ANC/TRM93.DOC.-98M700C2
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DECISION SUMMARY
RECORD OF DECISION
for
OPERABLE UNIT C
FORT RICHARDSON
ANCHORAGE, ALASKA
SEPTEMBER 1998
This Decision Summary provides an overview of the problems posed by the contamination
at Fort Richardson Operable Unit C (OU-C) source area. This summary describes the
physical features of the site, the contaminants present, and the associated risks to human
health and the environment. The summary also describes the remedial alternatives
considered at OU-C; provides the rationale for the remedial actions selected; and states how
the remedial actions satisfy the Comprehensive Environmental Response, Compensation,
and Liability Act of 1980 statutory requirements.
The United States Army (Army) completed a Remedial Investigation (RI) at OU-C to
provide information regarding the nature and extent of contamination in the soils and
groundwater. A baseline Human Health Risk Assessment and Ecological Risk Assessment
were developed and used in conjunction with the RI to determine the need for remedial
action and to aid in the selection of remedies. A Feasibility Study was completed to evaluate
remedial options.
ANOTRM93.00C/980470002
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SECTION 1
Site Description
Fort Richardson is an active U.S. Army (Army) installation near Anchorage, Alaska. Fort
Richardson was established in 1940 as a military staging and supply center during World
War II and originally occupied 162,000 acres north of Anchorage. In 1950, the Fort was
divided between the Army and Elmendorf Air Force Base. Fort Richardson now occupies
approximately 56,000 acres and includes a central cantonment area surrounded by ranges
and by impact and maneuver areas to the north, east, and south. The Fort is bounded to the
west by Elmendorf Air Force Base, to the east by Chugach State Park, to the north by Knik
Arm, and to the south by the Municipality of Anchorage. The population of the
Municipality of Anchorage, which includes Elmendorf Airforce Base and Fort Richardson,
is approximately 255,000.
Fort Richardson's land use supports its current mission to provide the services, facilities,
and infrastructure necessary to support the rapid deployment of Army forces from Alaska
to the Pacific Theater. The area managed by Elmendorf Air Force Base adjacent to Fort
Richardson is dedicated to military uses; recreational uses are permitted where consistent
with the military mission.
Fort Richardson contains features that include flat to rolling wooded terrain. The upland
areas near the adjacent Chugach Mountain Range rise to approximately 5,000 feet above
mean sea level (msl). The post is located in a climatic transition zone between the maritime
climate of the coast and the continental interior climate of Alaska.
The predominant vegetation type at Fort Richardson comprises varying-aged stands of
mixed coniferous and deciduous forest. The diverse plant communities provide habitats for
a diverse wildlife population including moose, bear, Dall sheep, swans, and waterfowl.
There are no known threatened or endangered species residing on the post.
Fort Richardson straddles both the alluvial fan gravels of the Anchorage plain and the
moraine and glacial alluvium complex near the shore of Knik Arm. The gravel alluvium of
the Anchorage plain underlies the main cantonment. The confined gravel aquifer is from
197 to 394 feet below the surface in this area of the installation. Groundwater flow in this
confined aquifer is in a generally western to northwestern direction.
Just north of the main cantonment is the southern edge of the Elmendorf Moraine, a
hummocky, long series of ridges running east-west across Fort Richardson and Elmendorf
Air Force Base, roughly parallel to Knik Arm. The moraine is chiefly till, including poorly
sorted gravel.
Fort Richardson has generated and disposed of various hazardous substances since it began
operations. The Fort was added to the U.S. Environmental Protection Agency (EPA)
National Priorities List (NPL) in June 1994. The listing designated the post as a federal site
subject to the remedial response requirements of the Comprehensive Environmental
Response, Compensation, and Liability Act (CERCLA), as amended by the Superfund
Amendments and Reauthorization Act (SARA) of 1986.
ANC/TRM93.DOC/980470002
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SITE DESCRIPTION
On December 5,1994, the Army, Alaska Department of Environmental Conservation
(ADEC), and EPA signed a Federal Facility Agreement (FFA) that outlines the procedures
and schedules required for a thorough investigation of suspected historical hazardous
substance sources at Fort Richardson. Under the FFA, all remedial response activities will
be conducted to protect public health and welfare and the environment, in accordance with
CERCLA, the National Contingency Plan (NCP), the Resource Conservation and Recovery
Act (RCRA), and applicable state laws.
The FFA divided Fort Richardson into four operable units (OUs): OU-A, OU-B, OU-C, and
OU-D. The potential source areas at Fort Richardson were grouped into OUs based on the -
amount of existing information and the similarity of potential hazardous substance
contamination. Only OU-C is addressed in this Record of Decision (ROD). OU-A and OU-B
were addressed in a ROD signed in September 1997. OU-D will be addressed in a future
ROD.
Figure 1-1 shows the location of Fort Richardson and OU-C.
1.1 Operable Unit C Site Locations and Descriptions
OU-C comprises two source areas: the Eagle River Flats (ERF), an ordnance impact area,
and the former Open Burning/Open Detonation (OB/OD) Pad. The majority of this ROD
addresses ERF. Section 9 provides detail on the site history, results of the remedial
investigation (RI), and future activity at OB/OD Pad.
1.1.1 Eagle River Flats
ERF is a 2,160-acre, cornucopia-shaped, estuarine salt marsh at the mouth of the Eagle
River. It is surrounded by forested uplands on the west, south, and east sides, and bounded
by the Knik Arm on the north. The Eagle River flows through ERF from southeast to
northwest, ultimately discharging into Knik Arm. Two creeks, Clunie and Otter, also drain
into ERF (Figure 1-2).
ERF is the only impact area for heavy artillery and mortars on Fort Richardson.
Approximately 25 derelict cars and trucks have been placed individually or in groups as
targets around ERF. Army personnel practice firing at the targets from more than 25 points,
at distances of up to 6 miles. The ERF has been used for military training since 1949,
creating thousands of craters in the wetlands and associated mud flats and leaving an
estimated 10,000 unexploded mortar and artillery shells buried in the shallow subsurface.
Four types of munitions have been fired into ERF: high explosives (HEs), white phosphorus
smokes, illumination flares, and hexachloroethane-zinc mixture.
Although ERF is an active impact area, it remains a productive wetland, serving as an
important staging ground for migrating waterfowl during the spring and fall migrations.
ERF also supports local populations of fish, birds, mammals, and macroinvertebrates. A
series of ponds distributed throughout ERF provides excellent habitat for dabbling ducks
and other waterfowl.
1-2 ANC/THM93.00O'9eW700C2
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•SI
Scale: 1 in. - 20 miles
10 20 30
Figure 1-1
Location Map
OU-C Record of Decision
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Figure 1-2
Site Map
OU-C Record of Decision
Scale: r = 2000'
1000 2000 4000
SCALE IN FEET
;; Intermittent Pond
Permanent Pond
Road"
Area Boundary
OUC Site Boundary
1-4
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SITE DESCRIPTION
1.1.2 OB/ODPad
The former OB/OD Pad, also referred to as Demolition Area One or Demo 1, is an 8.5 acre
clearing with a 4-acre gravel pad constructed along the east side of ERF. Open burning and
open detonation of explosives on Fort Richardson historically have been performed on this
pad since at least 1956, according to aerial photography. No OB/OD activities have been
performed on OB/OD Pad since November 1988. The pad contains the remains of
destroyed surplus and outdated munitions, along with assorted objects such as junked
vehicles and rocket motor casings.
OB/OD Pad, which was designated a RCRA regulated unit, was scheduled for closure
under 40 Code of Federal Regulations (CFR) 265, Subparts G and P. This area was included in
OU-C under the FFA. The process for closing the OB/OD Pad in accordance with RCRA
regulations is detailed in Sections 9.4 and 9.4.1 of this ROD.
An RI at OB/OD Pad in 1996 that included sampling and analysis of soil and groundwater
indicated that concentrations of detected chemicals were considerably below regulatory
levels specified in the Operable Unit C Rl/FS Management Plan, Fort Richardson, Alaska,
prepared in 1996. In addition, the ecological and human health risk assessments completed
during the RI indicate that the risks are very low.
In addition, OB/OD Pad has restricted public access. Entry onto the pad is by road with a
locked gate. Access is controlled and monitored by the Range Control at Fort Richardson.
These restrictions are not expected to change. Because of the potential unexploded ordnance
(UXO) hazard in the area, OB/OD Pad is not available for future development.
1.2 Land Use
OU-C is situated on land that is withdrawn from the public domain for military purposes
by Executive Order. The U.S. Army Alaska holds no deed documents to the land. Current
land use is military training. In 1990, the Army banned the firing of smokes containing
white phosphorus into the ERF. Several additional restrictions currently apply to training
activities at ERF as follows:
• A minimum of 6 inches of ice must cover the ERF before it can be used for firing.
• Firing is allowed only between November 1 and March 31.
• Only point-contact detonators may be used.
Although there are no immediate plans to resume warm-weather firing onto the ERF, future
changes to the mission of Fort Richardson could necessitate the use of the training area
during the summer months.
ANC/TRM93.DOG98W70002
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SECTION 2
Site History and Enforcement Activities
2.1 ERF Site History
Biological, chemical, and physical investigations have been ongoing at ERF since the early
1980s. The focus of the investigations varied, depending on current site knowledge, and
questions that needed to be addressed.
A time-line presentation and a chronological listing of investigations and treatability
studies completed through 1996 are presented in Figure 2-1 and Table 2-1, respectively.
In 1980, Army biologists noticed an unusually high number of waterfowl carcasses,
including several dead swans, in the ERF marshes. Subsequent, random searches by the
Army, U.S. Fish and Wildlife Service (USFWS), and Alaska Department of Fish and Game
(ADFG) discovered abnormally high numbers of dead waterfowl, indicating a serious
problem. Ground searches conducted in September 1983 found 368 waterfowl carcasses,
including about 35 fresh carcasses. In August and September 1984, about 175 carcasses were
discovered. At that time, the Army estimated the number of waterfowl deaths to be
between 1300 and 2,000 per year. In a later study, a series of aerial and ground surveys in
1988 documented more than 900 waterfowl carcasses and feather piles in one area of ERF.
Several preliminary studies that focused on finding the cause of the mortality were
conducted between 1982 and 1987. Although the results of these studies eliminated a
number of possible causes from consideration, the actual cause of the mortality was not
identified. In late 1987, an interagency task force was formed to identify the cause of
waterfowl deaths. The ERF Task Force consisted of representatives from the U.S. Army
Alaska, EPA, USFWS, ADFG, and ADEC The primary objective of the ERF Task Force was
to identify the cause of the waterfowl deaths and recommend remedial alternatives.
In addition to the ERF Task Force member agencies, other agencies that have been involved
in the investigations in ERF include the following:
* U.S. Army Corps of Engineers (COE), Alaska District
• U.S. Army Cold Regions Research and Engineering Laboratory (CRREL)
• Army Center for Health Promotion and Preventive Medicine (formerly U.S. Army
Environmental Hygiene Agency [USAEHA])
• Army Environmental Center (formerly U.S. Army Toxic and Hazardous Materials
Agency)
• U.S. Department of Agriculture
ANOTRM93.DOC/980470002
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SITE HISTORY AND ENFORCEMENT ACTIVITIES
After the formation of the ERF Task Force, several studies and investigations were
conducted to identify contaminants of concern, characterize the nature and extent of
contamination,-and evaluate potential remedial alternatives. The approach to determining
the cause of waterfowl mortality included a review of physical and chemical data and an
evaluation of waterfowl behavior based on biological data. The studies initiated to assess
waterfowl behavior included bird utilization of habitat and bird mortality studies.
On the basis of results of the initial bird utilization and mortality studies, ERF was initially
divided into four Areas: A, B, C, and D. Over time, four other areas of potential concern
were identified: Area C/D (between Areas C and D), Bread Truck Pond, Pond Beyond, and
the mud flats. Additional research throughout ERF eventually led to the following
designated areas, which were the focus for RI and feasibility study (FS) activities: A, B, C,
C/D, D, Coastal East, Coastal West, Bread Truck, and Racine Island. Figure 1-2 shows the
locations and approximate boundaries for the ERF areas.
The results of a 1989 investigation indicated that chemicals from explosive ordnance were
the probable cause for the waterfowl mortality in ERF. In February 1990, on the basis of
conclusions reached in the 1989 study, the Army temporarily suspended the use of ERF for
live firing until the causative agent of waterfowl mortality was identified. Despite the
closure, large numbers of waterfowl continued to die at ERF during the spring and fall
migrations.
Census data for 1988 and 1989 indicated that dabbling ducks comprised the majority of the
affected waterfowl and the ducks were continuing to die. The focus of the following 1990
field season was to find the cause of mortality based on the assumptions that the
contaminant(s) resided in sediment, were distributed heterogeneously at ERF, and were
slow to degrade.
Field and laboratory studies conducted in 1990 provided evidence that white phosphorus
was the likely cause of the mortality. In addition, because white phosphorus persists (does
not sublimate and oxidize)°when wet or submerged, the water and sediment conditions at
ERF are conducive to the long-term retention of white phosphorus in the sediments. ERF
investigations performed in the following 3 years focused on defining the extent of the
white phosphorus contamination, determining site conditions and other factors that affect
the likelihood of exposure to white phosphorus, and understanding the physical dynamics
of ERF. In March 1991, the Army initiated a public review process that evaluated
alternatives for the resumption of live firing. ERF was reopened for training uses in January
1992, following a series of test firings. Several restrictions were established, including
elimination of firing during the summer months and permanent elimination of the use of
white phosphorus. The Army also banned the use of white phosphorus in wetland impact
areas nationwide on the basis of discoveries in ERF.
The results of the 1992 and 1993 ERF sampling program for pond sediments and waterfowl
carcasses generally confirmed that the highest concentrations of white phosphorus were
near Area C and Bread Truck Pond, in a densely cratered area east of Eagle River. The
existence of craters was considered to be another indicator of the extent of white
phosphorus.
During 1994 and 1995, several field investigations of the physical system of ERF and
laboratory studies of the potential of white phosphorus to bioaccumulate were completed.
2-2 ANC/TRM93.DOC'980470002
-------
IICM1IMCKKIOH » UUII
1 IWDCUnitHHOItnUTT
i • MM Hituio mo icturan
1 OCFMf [mm Of CONIunuTNM
I wKiiiuonmicustiifiionuincs
1 IMHTIFTHOI tPOIl
> DCvtiop «!«oi»i iicmoioGif!
S(0v»r(fl Oead dur»i and
n'Hjl'"1 r»rnnn»i«*nf»
ncMtance ol vilirtrwl
mortality nMirwd
Pertnrmen-grn.n.Kwett*
01 ""*****
Analv/f<1 rarratw lijr t
van"ryrilrhwn<|i
CGclaminanlS
Collected inrtul wflrmml inrt
*uri»ce wiier samples to-
Cnmmon rnntimmanlt
AnuVt toi mtUH.
pdCTjtVPCBi. eiptowei
and MUM m carcasses
were nggalive
Result! (Of pettodeVPCBs
amj txotosnres if ieftmem
and turtice wil»r writ
negative
MelUt wtie withm norm*)
background ItvtK
Birds weie *> flf-od
rtut'itionil ilile pimr In
rtMlh
Death tin sudden
Came of deal* i\ i/iimiwn
lewwwl rlila and
developed qu»stions that
d*iintd 'uiB'f ipijnifh in
m veil 4)it ID i
A intengency Talk Forte
Inrmed
Pertotmro in'1'11 mflrtjUy
rensm
Anatyreri ca'casw s to* s>gns
n> d'tpm
CondMttd OKJKUVS using
manatrl think*
Anityred wOrnenl and
surface water loi IOIT.
compiwnoi
«rt*«dAnasA.B C MD
WenWied prete*ted bird
tubrlavpnnds
DneO wifirlowl wttn E ltf(
Rnrerltitj water
0*ua<.t in) trauma do not
aoptat to caw* rncrtafcry
ftoanie cofflpowNh and
mttan, do noi ippeii to cause
monatty
WatKiovrt doted wtfi Eagle
Rrve< FOtl witer d-d not fl»
dutnti tJfjontixv f tudie*
Ptll|yn*|| in MI, jn(J ft vlu
b-oiiuif-.
Pertormed nec'Op^y
hematologv and Oarlrrnt
cuiures on inerted
wilertowi
Perionned mtegriied
tamnfrng and anil-rttt nl
ledimeni IM turtjre wiier
Can.l~,,»««,.,l««
«lit*fllffl(
Causative lutrsunci -i not
tramKl'M through food
crum
Dlbfcfcng dotkJ were dying
tntyillW" o' lOi'C
lubiianctv tnleclioui
disiatl ind concuiJioo
«tti ewnmaipd M causes of
ntnrtabfy
Secondary ertecu o>
UuMlivc MjtKUnr* *" nnl
delrrlrrt m pifrtjlof. inri
\uv*!ig»(-.
Anihr/dl wi"r mo on o> WP m ntsut
devetoped
• (jflU ftaii flat*
efeud tmpo>an)ir at
^ CJirlHrrt -gtnt
o^cwmt)
WP drtcovtred It prtmify
came oi monahTy
Water and ttdmint
condrtnni it [igte Flrvtr Ftiti
are cnnducm 10 tonp, -term
storage o< WP m stfl"-mn
t "t*rt«* tompnunch COuM
DC migiattng min f igle tivet
Fljli Irnm 08/00 P|d bi't ''o
nrt m>n< to bf CluS">ij
f-Kirtal'IV
•Jtrjlh^
Sf i f nnl WP HI w1im*nt&
atrc'u Irjnvri1.
Cpi^cleo gu;ardi ix-m f"0'*
man 3ooni* Procedures lor WP
ar^rjevewri
AIM Cmd Bread trudt Pond
account lor mosl 0< WP
j&vsninq
Are* A fud Ww contimiiulinn
nut hqn caiuit COIMIK
Human eiposure to WP
through o«Me migratilKi is
fhown lo be mtnimil
Mo 'omaminaton tnund wi
friFM ruih
Mudiedsfd^emitrf-oarfl
f'ns'°" '""
fcijty/Hi wtare a'wt
VutKiiMjc^ umpln lo> WP
tested uptake and
diuppea'ince oi WP m
witer'ow*
Pcrloimed sampkng |I
OftOD Pad tor expiosnTes
En'uated ahkry ot WP to
bKtaccumutite m witirtowi
L WflTEflFOV/L Ct
^ Army resumes lest Nrrng
dunngirf oer-Odl
^ Army rxovidet pf»i
rel-ist and conduclt
TV mlrrview
B-aacciirnuUhon ot WP m
lood thaui may be hmied
Setf-menlition and erosion
ralei apowf h»gh m mud tun
and ponds
Area C and Bread Truck Pond
i-icnntumeOairt>0/nrV
Cnntiminated witflowl
'eed>ng fuNiit
E ipiowei we>i diiecled Rrvtr 1 ttU md
n Uh vf ym*ar
f^jM^.rtMS^HtL,^
(.(Hi^rt^rtyot
^<1'rn(iiiil>nn ctrticn
wl'ment t'lmpol jnO
pnvsicai t-ai'^pdri nt w"
PerifMmed mapping »t
topology, rritgrv watn
txxtn, and teirim
Pertoimeo miegtated nst
asseiiment (r-ode*ng based
on toKOiogv « |ttdrm«ntalon.
ttawn wP iiarrtpnn Birough
OJhes)
Eviruaied methods ol
enhancing natural inenultinnit rjn occur al
f iff Ftivtr FlaK mrnugh
tutMimili'-in iru] W.VWY
SMimenlltion
inpinicft dwHnprt
Gutty nea< Brtad I'UCt Pnnd
•s tdvancmg it an rrtKn'rt
rate
f nhanced fttiu'll ittenualion
may not M cost eHecl-ve
Uoflrtty m control area n
very tow
[ndpotnt t B^CkQ'Ound
condition defined as dabbling
duck ind swan dcafM m
Susnn) Flits
FndnmrH? ferJiH-tWr
hot spnt*.
«*» Meaiiri and u'ety
leQuueffienK a>e
•atii^teiemet^and
census data are repmmutrve
because they ate nui
ifluenced by m/ng
CntK In op*nlf drtdO* I't
high
Dfiin«(t Bread True* Pnnd
'KluCtS Wllei'rwl riprKiK*
Gr'>ir4Mlft md tod
( (»w»titiit«*n it OB'OO pW
1<» MKW rlpjnuc :l»U't
Irvf';
Figure 2-1
Framework of Investigations
OU-C Record of Decision
-------
SITE MSTOBY AND ENFORCEMENT ACTIVITIES
TABLE 2-1
Summary of Previous Investigations at Eagle River Flats
Investigation/Report
Waterbird Utilization of Eagle River Flats and Upper Cook Inlet:
October 1996
Waterfowl Mortality on Eagle River Flats
Movement, Distribution, and Relative Risk of Mallards and Bald
April-
Eagles
Investigators
USFWS
DWRC
DWRC
Field Date(s)
1996
1996
1996
Using Eagle River Flats: 1996
Report of USDA-APHIS-Animal Damage Control for the U.S. Army at
Eagle River Flats, April-October 1996
Demonstration of Sample Compositing Methods To Detect White
Phosphorus Particles
Pond Draining Treatability Study: 1996 Studies-The Draining of Bread
Truck Pond
Monitoring of Contract Dredge Operations at Eagle River Flats, Alaska
Draft Physical System Analyses of Natural Attenuation and Intrinsic
Remediation of White Phosphorus Contamination, ERF, Fort Richardson,
Alaska
Waterbird Utilization of ERF and Upper Cook Inlet: April - October 1995
Movement, Distribution and Relative Risk of Waterfowl and Bald Eagles
Using ERF
Evaluation of AquaBlok™ on Contaminated Sediment to Reduce Mortality
of Foraging Waterfowl
Waterfowl Use and Mortality at ERF
Site Conditions, Ecological Inventory
Physical System Dynamics, White Phosphorus Fate and Transport,
Remediation and Restoration, Eagle River Rats, Fort Richardson, Alaska
Climate and Tides
White Phosphorus Evaluation and Characterization, White Phosphorus
Toxicity and Bioindicators of Exposure in Waterfowl and Raptors.
Toxicological Properties of White Phosphorus: Comparison of Particle
Sizes on Acute Toxicity and the Biotransfer of White Phosphorus from Hen
to Eggs
Analysis of the Eagle River Flats White Phosphorus Concentration
Database
Waterbird Utilization of Eagle River Flats: April-October 1994
Waterfowl Use and Mortality at Eagle River Flats
Movement, Distribution and Relative Risk of Waterfowl, Bald Eagles and
Dowitchers Using Eagle River Flats
Evaluation of White Phosphorus Effects on the Aquatic Ecosystem, Eagle
River Flats, Fort Richardson, Alaska
Integrated Risk Assessment Model (IRAM) for Determining White
Phosphorus Encounter Rate by Waterfowl
USDA 1996
CRREL 1996
CRREL 1996
CRREL 1996
CRREL 1995
USFWS 1995
DWRC 1995
DWRC 1995
NEILE 1995
CRREL 1994
CRREL 1994
CRREL 1994
PWRC 1994
Dartmouth 1994
CRREL 1994
USFWS 1994
NEILE 1994
DWRC 1994
USAEHA 1994
DWRC/CRREL/ 1994
NEILE
ANC/TRM93.DOO980470002
2-5
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SITE HISTORY AND ENFORCEMENT ACTIVITIES
TABLE 2-1
Summary of Previous Investigations at Eagle River Flats
Investigation/Report
Treatability Studies; Chemical Hazing of Free-Ranging Ducks in Eagle
River Flats: Field Evaluation of ReJex-iT™ WL-05
Hazing at Eagle River Flats
Evaluation of AquaBlok™ on Contaminated Sediments to Reduce Mortality
of Foraging Waterfowl
Screening Study of Barriers to Prevent Poisoning of Waterfowl in Eagle
River Flats, Alaska
Investigation of Natural Size Reduction of White Phosphorus Particles in
Eagle River Flats Sediments
Pond Draining Treatability Study
Dredging as a Remediation Strategy for White Phosphorus-Contaminated
Sediments at Eagle River Flats, Alaska
Appendix A. Eagle River Flats Map Atlas
Mapped Craters
Contaminant Inventory
Treatability Study-Hazing Waterfowl in ERF
Treatability Study-Laboratory Evaluation of a Methyl Anthranilate Bead
Formulation
Treatability Study-Field Behavioral Response and Bead Formulations for
Methyl Anthranilate
Treatability Study-Field Evaluation: Mortality of Mallards Feeding in Areas
Treated with Methyl Anthranilate
Waterfowl Mortality at ERF
Distribution and Concentrations of White Phosphorus in ERF
Waterfowl Distribution and Movements in ERF
White Phosphorus Poisoning of Water birds in ERF
Toxicological Studies of White Phosphorus in Waterfowl
Physical System Dynamics (Sedimentation and Erosion at ERF)
Food Chain Invertebrates and Fish: Sediment Bioassay
White Phosphorus in Invertebrates and Fish
Habitat and Vegetation in ERF
White Phosphorus in Plants at ERF
Water bird Utilization of ERF
Treatability Study-Pond Draining
Treatability Study-Air Drying Contaminated Sediments
Investigators
DWRC
ADC
DWRC
CRREL
CRREL
CRREL
CRREL
CRREL
CRREL
USAEHA
ADC
DWRC
DWRC
DWRC
NEILE
CRREL
DWRC
PWRC
PWRC
CRREL
USAEHA
PWRC
CRREL
CRREL
USFWS
CRREL
CRREL
Field Oate(s)
1994
1994
1994
1994
1994
1994
1994
1994
1993
12-23Jul 1993
May.
Sep-Oct 1993
1993
Jun, Aug 1993
Jun 1993
Apr-May,
Aug-Oct 1993
1991-1993
Apr-Jun,
Aug-Oct 1993
May-Sep 1993
1993
May 1992-
Sep 1993
July 12-23 1993
Jun 1993
1993
Jun 1993
Apr-Oct 1993
Jun-Aug 1993
Jun-Aug 1993
2-6
ANC/TRM93.DOC/980470002
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SrTE HISTOBV AND ENFORCEMENT ACTIvmES
TABLE 2-1
Summary of Previous Investigations at Eagle River Flats
Investigation/Report
Treatability Study-Geosynthetic Covering of Contaminated Sediment
Treatability Study-Evaluation of Concover and BentoBalls on
Contaminated Sediments to Reduce Mortality of Foraging Waterfowl
U.S. Army Eagle River Flats: Protecting Waterfowl from Ingesting White
Phosphorus
Investigators
CRREL
DWRC
DWRC
Rapid Uptake and Disappearance of White Phosphorus in American CRREL and
Kestrels Dartmouth
Medical School
Draft Report-Preliminary Assessment of Sedimentation and Erosion in the
Eagle River Tidal Flats, Fort Richardson, Alaska
Hazardous Waste Consultation No. 37-66-JR11-92, Soil Sampling
Results, Fort Richardson, Alaska, July 6-7, 1992
Draft Report-Water bird Utilization of Eagle River Flats, April - October
1992
Draft Report-White Phosphorus Contamination of Salt Marsh Sediments
at Eagle River Flats, Alaska, February 1993
Waterbird Utilization of Eagle River Flats, April-October 1991. December
1991
Waterfowl Mortality in Eagle River Flats, Alaska, The Role of Munitions
Residues. May 1992
Waterbird Utilization of Eagle River Flats, April - October 1 990. December
1990.
Eagle River Flats Expanded Site Investigation, Fort Richardson, Alaska.
Final Technical Report, June 1990
Eagle River Flats Waterfowl Mortality Progress Report, August 1989
Laboratory Investigations
Laboratory Investigations
Laboratory Investigations
Bird Utilization of ERF During Spring, Summer, and Fall, and Associated
Mortality
Investigations of Waterfowl Mortality, ERF
Laboratory Investigations
Field Investigations
CRREL
USAEHA
USFWS
CRREL
USFWS
CRREL
USFWS
ESE
As noted
ADEC
EPA
EPA
USFWS
USFWS
USAEHA
USFWS
Field Date(s)
Jul 1993
Jun 1993
1992
1992
May-Sep 1992
July 6-7 1992
Apr-Oct 1992
1991-1992
Apr-Oct 1991
1990
Apr-Oct 1990
Jul-Oct 1989
below
Sep15, 1988
Jul 11, 1988
Jul 22. 1988
Apr-Oct, 1988
1983-88
1985
1982-85
Notes:
ADC = Animal Damage Control
CRREL = U.S. Army Cold Regions Research and Engineering Laboratory
DWRC = Denver Wildlife Research Center
ER = Eagle River
ESE = Environmental Science and Engineering, Inc.
NEILE = New England Institute of Landscape Ecology
USAEHA = U.S. Army Environmental Hygiene Agency
USDA = U.S. Department of Agriculture
ANC/TRM93.DOC/980470002
2-7
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SITE HISTORY AND ENFORCEMENT ACTIVITIES
The bioaccumulation studies were performed to assess the impacts of white phosphorus on
wildlife at ERF. Additional studies were conducted on waterfowl utilization of ERF,
waterfowl mortality, waterfowl distribution and movements in ERF, and toxicological
studies of white phosphorus in waterfowl to determine acute lethal doses for ducks
(mallards).
From 1994 through 1997, the ERF investigations focused on finding a feasible remedy for
white phosphorus contamination in sediments. Areas of priority for cleanup were evaluated
by using white phosphorus sampling, waterfowl telemetry, carcass transects, physical
system dynamics, and mapping of landcovers (combinations of topographical features such
as ponds and vegetation). A comprehensive geographical information system (GIS)
database, established in 1994 and continuously updated, contains results of all ERF data.
This information has been used to determine the nature and extent of white phosphorus at
ERF and plan feasibility studies for possible remedial actions.
Results of a 1994 CRREL study showed that white phosphorus particles remained intact
and relatively unaffected in water-saturated sediments, but began to immediately degrade
and disappear when the sediments became unsaturated, especially at warmer temperatures.
Therefore, sublimation/oxidation was determined to be a viable remedial option for mud
flats and intermittent ponds that have the potential to drain and dry. This conclusion led to
additional feasibility studies in 1995,1996, and 1997 to determine potential technologies that
could be used in ERF to result in pond draining and drying of sediments so that
degradation would occur.
Results of historical investigations and the RI at OU-C are included in the Operable Unit C
Remedial Investigation Report and the Operable Unit C Feasibility Study Report, which were
prepared in 1997.
2.2 Enforcement Activities
Fort Richardson was placed on the CERCLA NPL in June 1994. Consequently, an FFA was
signed in December 1994 by EPA, ADEC, and the Army. The FFA details the
responsibilities and authority associated with each party pursuant to the CERCLA process
and the environmental investigation and remediation requirements associated with Fort
Richardson. The FFA divided Fort Richardson into four OUs, one of which is OU-C, and
outlines the general requirements for investigation and/or remediation of suspected
historical hazardous waste source areas associated with Fort Richardson.
An additional goal of the FFA was to integrate the CERCLA response obligations and
RCRA corrective action obligations of the Army. Remedial actions implemented will be
protective of human health and the environment. Consequently, the remediation of releases
will obviate the need for further corrective actions under RCRA (no further corrective action
will be required for source areas).
2.3 Agency Cooperation
The ERF investigation and cleanup activities have represented a unique cooperative effort
among the Army, EPA, and ADEC. These activities began before the listing of Fort
Richardson on the NPL and have focused on the observed waterfowl mortality. The
2-8 ANC/TRM93.DOO98W700C2
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SITE HiSTORY AND ENFOBCEMEMT ACTIVITIES
agencies understand that the historical and anticipated future use of ERF is firing heavy
artillery and mortars. Although the inclusion of an active impact area within an OU is
unusual, the decision to do so was made to address the waterfowl concerns without
adversely affecting the military use of ERF now or in the future.
2.4 Highlights of Community Participation
The public was encouraged to participate in the selection of the remedy for OU-C during a
public comment period from February 5 to March 6,1998. The Fort Richardson Proposed Plan
for Remedial Action, Operable Unit C presents combinations of options considered by the
Army, EPA, and ADEC to address contamination in soil and groundwater. The Proposed
Plan was released to the public on February 4,1998, and was sent to 180 known interested
parties, including elected officials and concerned citizens.
The Proposed Plan summarizes available information about OU-C. Additional materials
were placed in information repositories established at the Alaska Resources Library, Fort
Richardson Post Library, and the University of Alaska Anchorage Consortium Library. The
Administrative Record, including other documents used in the selection of the remedial
actions, was established in the Public Works Environmental Resource Office on Fort
Richardson. The public is welcome to inspect materials available in the Administrative
Record and the information repositories during business hours. The Administrative Record
Index is provided in Appendix A. The selected remedy presented in Section 7 is based on
the Administrative Record.
Interested citizens were invited to comment on the Proposed Plan and the remedy selection
process by mailing comments to the Fort Richardson project manager, by calling a toll-free
telephone number to record a comment, or by attending and commenting at a public
meeting on February 12,1998, at the Russian Jack Springs Chalet in Anchorage. Twenty-five
people attended the public meeting. Five sets of comments were received from the public
during the comment period.
The Responsiveness Summary in Appendix B provides more details about community
relations activities. It also summarizes and addresses public comments on the Proposed
Plan and the remedy selection process.
2.5 Scope and Role of Operable Unit
Four operable units (A, B, C, and D) have been identified at Fort Richardson. Three of these
OUs are driven primarily by human health risks. OU-C is the only site at Fort Richardson
with white phosphorus contamination and the only site at Fort Richardson driven by
ecological risk. OU-C is also unique in that it is still an active impact range. This ROD is the
second signed for Fort Richardson. A single ROD for OUs A and B was signed in 1997.
The OU-C RI/FS was performed in accordance with the Operable Unit C RI/FS Management
Plan (1996). The RI fieldwork at OU-C was conducted during 1996.
The principal threat at the ERF source area within OU-C is particulate white phosphorus in
sediment. According to results of the RI, potential risks to the environment are posed by
ANC/TRM93.00C/98MT0002 29
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SITE HISTORY AND ENFORCEMENT ACTIVITIES
onsite contamination. Accordingly, the agencies have elected to pursue remedial action
under CERCLA to address these potential risks.
The RI at the OB/OD Pad source area within OU-C concluded that the contaminants found
do not pose a risk^to human health and the environment and do not require cleanup action.
Therefore, except for continuing controls that are in place to control access and requiring
safety training for personnel who must work at the site, no cleanup action will be
conducted for OB/OD Pad.
2-10 ANC/TRM93.DOO98W70002
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SECTION 3
Summary of Site Characteristics
3.1 Eagle River Flats
3.1.1 Physical Features, Hydrogeologic Conditions, and Transport Pathways
ERF is characterized as a roughly triangular estuarine salt marsh surrounded by forested
uplands and the Knik Arm portion of Cook Inlet. It was formed as the Eagle River eroded
through the glacial and alluvial deposits of the Anchorage lowland to create a deep valley
that subsequently filled with sediment. The topography of ERF is relatively flat, with
landform and vegetation changes, and expected tidal flooding frequencies, occurring with
subtle changes in elevation. Measured elevations in ERF range from 3 feet above msl at the
river bottom of the Eagle River to 18 feet above msl on top of the highest levees along the
river.
The discharge from Eagle River bisects ERF. It can vary substantially from the impacts of
spring meltwater and rainstorms. With an average flow rate of 530 cubic feet per second,
Eagle River drains approximately 1,300 square miles of mountains and lowlands. Sediment
concentration of Eagle River does not depend on the discharge rate of the river, and results
of studies of ERF physical dynamics suggest that the tides have a greater suspended
sediment concentration than the river.
Distributary channels (or gullies) cut deeply through the mud flats and connect ponds with
Eagle River. Subtle changes in elevation of the channel floors dictate whether tidal flooding
occurs daily, occasionally, or rarely. Where elevations are 7 feet to 12 feet above msl, as in
the bottoms of gullies, flooding occurs daily during high tides. At between 12 and 14 feet
above msl, such as the heads of gullies and some mud flats, flooding occurs only with the
highest tide of each month. Only extreme high tides, in combination with high
river-discharge levels, flood areas between 14 and 15 feet above msl, such as the major pond
basins, higher mud flats, and some levees.
In summer, there may be long periods between flooding tides, and parts of ERF can become
relatively dry. During winter, Eagle River continues to flow, but ice thickens over ERF with
succeeding flood events during cold temperatures. Ice breakup typically occurs in April or
early May. It appears that the hydrology and sedimentology of the upper third of ERF is
dominated by the river, with the remainder dominated by the tides.
In addition to Eagle River, several small tributary streams enter ERF. Otter Creek, a small
perennial stream, drains Otter Lake and enters ERF near its southern end. Clunie Creek,
believed to be a ground water channel depression, drains several small lakes east and
northeast of ERF and enters ERF just north of OB/OD Pad.
3.1.2 Nature and Extent of Contamination
As discussed in Section 2, since the initial reports of elevated waterfowl mortality in the
early 1980s, a multidisciplinary investigation has been conducted to identify the cause of
ANC/TRM93DOG980470002 3-1
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SUMMARY OF SITE CHARACTERISTICS .
the mortality (shown in 1990 to be white phosphorus), the extent of the white phosphorus
contamination, and the potential effects of white phosphorus and other munitions on the
biota in ERF. White phosphorus was released into ERF by ordnance used to create smoke
for marking targets. White phosphorus that did not fully oxidize could remain as particles
in the sediment.'Ingestion of white phosphorus particles by feeding waterfowl has created
high levels of mortality. Birds have been observed to die within hours of ingesting white
phosphorus in a number of ponds in ERF.
Sampling results have focused primarily on a relatively small number of areas in ERF where
the greatest levels of mortality were observed. The results of this sampling have
demonstrated that elevated levels of white phosphorus exist in most ponds where the
highest mortality levels occur; however, sampling efforts in several ponds where high
mortality has been observed have not demonstrated that white phosphorus exists
extensively in the sediment. This finding suggests that some birds may fly away from the
point of exposure before succumbing. The potential for birds to move following exposure,
coupled with limitations on sampling efforts because of the hazard posed to site workers by
UXO, has complicated identification of the horizontal and vertical extent of white
phosphorus contamination.
Previous sampling results and detailed observations of wildlife populations within ERF
have identified swans and dabbling ducks as the primary receptors of white phosphorus
contamination. Although low levels of white phosphorus have been found in plants,
macroinvertebrates, and fish, existing data do not show that these populations have been
significantly affected by the presence of white phosphorus in ERF. Only a small percentage
of plants, macroinvertebrates, and fish contained detectable levels of white phosphorus.
There is some evidence indicating that scavengers that feed on waterfowl carcasses in ERF
have been exposed to white phosphorus. It is believed, however, that reducing the mortality
effect in dabbling waterfowl to acceptable levels also will reduce effects in the predators
and scavengers that have been identified as secondary receptors (that is, those that eat the
dabbling ducks) because of the reduction in their exposure concentrations.
Researchers used observations of carcass locations and crater densities in areas used by
waterfowl to identify areas most likely to contain white phosphorus. The sediments in these
areas were extensively sampled for white phosphorus with the use of radial transects and
close sampling in open ponds. The distribution of ponds and analytical results of white
phosphorus in sediment were compiled and used in conjunction with landcovers and bird
usage data to identify hot ponds that are the areas likely presenting the highest risk. The
UXO hazard in ERF makes extensive future sampling efforts infeasible.
The findings documented in the RI report are based primarily on data collected before
implementing the CERCLA process at OU-C. Compilation and review of all the data have
led to the following conclusions:
1. White phosphorus is the primary cause of waterfowl mortality. Symptoms exhibited
by ducks exposed to white phosphorus in ERF are similar to those observed in ducks
dosed with white phosphorus in the laboratory. White phosphorus also was detected in
tissue samples collected from duck carcasses found in ERF.
3-2 ANOTRM93.DOC/980470002
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SUMMARY OF SITE CHARACTERISTICS
2. White phosphorus was deposited in the sediment primarily during range firing
activities. White phosphorus marking rounds were used during training activities in
ERF for several decades. Rounds were fired into ERF and detonated, dispersing white
phosphorus particles over large areas. Further distribution of the particles likely
occurred-when HE rounds exploded in white phosphorus-contaminated soil and
sediment.
3. Craters in ERF potentially indicate the level of range firing activity. Detonation of HE
generally creates a crater at the point of impact. Although white phosphorus munitions
do not form craters upon detonation, they typically have been used in conjunction with
HE training activities. Therefore, it can be deduced that the more craters in an area, the
more munitions have likely been fired there, resulting in higher probability of white
phosphorus contamination.
4. The distribution of white phosphorus particles throughout ERF sediments is not
uniform. The dispersion of the white phosphorus particles was affected by the nature of
detonations in an area and whether munitions were detonated on land or over water.
Some areas were used more frequently as targets and, therefore, received higher
amounts of white phosphorus. In addition to differences in the distribution of white
phosphorus, particle sizes vary greatly, ranging from 0.01 inch to 0.113 inch. Particle
densities vary substantially even within small areas. The impacts of white phosphorus
shells typically resulted in "hot spots" of 3 to 6 feet in diameter. These hot spots contain
large numbers of white phosphorus particles and are generally surrounded by a 3-foot
ring containing fewer particles.
5. The detection frequencies and concentrations for white phosphorus in sediment are
highest in Area C, Bread Truck, and Racine Island. Sixty-three percent of the overall
ERF sampling locations had nondetectable concentrations, but at least 45 percent of the
locations in each of these three areas had detectable concentrations. The highest
concentration, 3,071 micrograms per gram (ug/g), was found on Racine Island.
6. White phosphorus particles can break down (sublimate and oxidize) when exposed to
air and warm temperatures, but are long lasting in water-saturated sediment. White
phosphorus particles that land on soil or dry sediment are readily oxidized and bum
under ambient air conditions. Because they are not water soluble, however, white
phosphorus particles have an indefinite life when submerged in the water and allowed
to settle into pond or marsh bottom sediments. White phosphorus monitoring has
shown thai particuiate white phosphorus persists in permanently flooded ponds, but
naturally sublimates and oxidizes in ponds that only flood intermittently. Therefore,
intermittently flooded ponds were eliminated from further remediation.
7. Waterfowl are exposed to white phosphorus from the sediment of ponds and sedge
marshes while they are feeding. Some white phosphorus particles may resemble seeds
and macroinvertebrates that dabbling ducks and swans feed on. As the waterfowl
forage for food in pond and marsh bottom sediments, they may intentionally or
inadvertently pick up the white phosphorus particles.
8. Dabbling ducks and swans are the primary receptors of white phosphorus. Dabbling
ducks and swans forage for food in pond and marsh bottom sediments. In addition,
mortality rates of dabbling ducks have been observed to be significantly higher than
ANC/TRM93.0CO980470002 3-3
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SUMMARY OF SITE CHARACTERISTICS
mortality rates of other waterfowl in ERF as well as in other Upper Cook Inlet (UCI)
marshes. Telemetry data in 1996 suggest that the mortality rate among radio-tagged
mallards was-about 35 percent. Mallards were selected as the indicator species because
they are the most frequently observed species of dabbling waterfowl at ERF.
9. Predation and human exposure to white phosphorus by consumption are not high-
level concerns at present. There has been no verified mortality resulting from predators
feeding on white phosphorus-contaminated waterfowl carcasses. Although a dead eagle
was found with white phosphorus contamination, current predator mortality appears
low. In addition, the results of analyses of tissue collected from dabbling ducks taken by
hunters near ERF do not indicate a threat to humans ingesting the meat.
10. Permanent ponds, with associated sedge marsh, having confirmed presence of white
phosphorus and/or moderate-to-high crater density and observed moderate-to-high
dabbling duck and/or swan use are the most significant exposure areas. According to
the conceptual site model (CSM), areas of greatest concern are where there is a source
(white phosphorus-contaminated sediment),'a receptor (dabbling duck or swan), and a
potential for exposure (foraging for food).
11. The movement of white phosphorus through Eagle River to Knik Arm appears to be
minimal. Low-level amounts of white phosphorus have been detected in the sediments
traveling through the gullies, but no sediment and water samples from the river had
any detectable white phosphorus. No sampling has been performed in the Knik Arm at
the mouth of the Eagle River.
During the initial phases of the white phosphorus sampling in ponds, crater density in mud
flats adjacent to ponds and mortality observations were the main criteria used in selecting
ponds to be sampled. Sampling priority was placed on ponds and adjacent mud flat areas
that had high density of crater coverage and high numbers of observations of water bird
mortality.
The most significant areas of concern for exposure to white phosphorus are the sediments of
ponds and some marshes, for which all of the following conditions apply:
1. White phosphorus presence has been confirmed and/or the number of craters (density)
is moderate to high.
2. Moderate to high use by ducks and/or swans has been observed.
3. High numbers of waterfowl deaths have been observed.
The ponds where these conditions exist (hot ponds) are the areas believed to present the
highest risk of white phosphorus exposure to waterfowl. Twenty-two hot ponds were
identified, covering 57 acres in Areas A, C, C/D, Racine Island and Bread Truck. To aid in
the evaluation of alternatives for the FS, the hot ponds identified in the RI were divided into
six pond groups based on physical site characteristics: (1) Northern A (7 ponds); (2)
Pond 290 (1 pond); (3) Ponds 183 and 146 (2 ponds); (4) Northern C and C/D ponds (8
ponds); (5) Racine Island (3 ponds); and (6) Bread Truck (1 pond). The characteristics of
these pond groups are discussed below. Figure 3-1 provides an illustration of the pond
group locations.
3-4 ANC/TRM93.00C/980470002
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SUMMARY OF SITE CHARACTERISTICS
• Northern A Pond Group. Seven ponds in Area A comprise this group. The 14.3-acre
area has uneven topography and a medium to high number of craters. The ponds are
believed to be interconnected by a small to medium-sized area of surrounding marsh.
Thirteen percent of samples collected in Area A contained white phosphorus at
detectable'concentrations. In 1996 birds being tracked spent more than 60 percent of
their time in Area A. In addition, 23 percent of the dead ducks found at ERF in 1996
were found in Area A.
• Pond 290. Pond 290 is in Area A and is 2.2 acres in size. This pond does not appear to be
connected to other ponds in the area and, therefore, is addressed separately. Low levels
of white phosphorus contamination have been detected in the north end of this pond. In
1997 numerous dead ducks were found in Pond 290.
• Ponds 183 and 146. Ponds 183 and 146 are in Area C. Pond 183 is 7.2 acres in size, and
Pond 146 is 13.6 acres in size. These ponds have a high number of craters. Pond 183 is
connected to Pond 146. In 1996, birds that were tracked by radio spent 10 percent of
their time in Area C. Thirty-five percent of the dead ducks found at ERF in 1996 were
found in Area C. More than 50 percent of the samples collected in Area C contained
white phosphorus.
• Northern C and C/D Ponds. Eight ponds totaling 8.9 acres comprise the Northern C and
C/D pond group. This pond group has a medium to high number of craters. The ponds
are believed to be interconnected to a large area of permanent ponds and marsh, which
provide constant sources of water flow or recharge. Ten percent of the samples collected
in Area C/D had detectable concentrations of white phosphorus. In 1996, birds being
tracked spent 8 percent of their time in Area C/D, and 16 percent of the dead ducks
among those being tracked were found in Area C/D.
Table 3-1 identifies the 18 ponds described above and provides information on duck use
and deaths in these areas.
TABLE 3-1
Identification of ERF Areas, Pond Groups, and Ponds Requiring Cleanup
Hot Pond Group
Northern A: Pond Numbers 138,
208, 226, 228, 246. 256, 258
Pond 290
Ponds 183 and 146
Northern C and C/D: Pond
Numbers 129, 145, 155, 40, 49,
85,93,112
Size
(acres)
14.3
2.2
20.8
8.9
ERF Area
A
C
C/D
1996 Duck Use
(%)
62
10
8
1996 Duck Death
(%)
23
35
16
Number of
Craters
medium to high
high
medium to high
Note: 1996 duck use and death percentages are based on birds that were radio collared in 1996.
Percentages do not add up to 100 percent because areas with low percentages of deaths were not selected (or
cleanup.
ANC/TRM93.00C/980470002
3-5
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SUMMARY OF SITE CHARACTERISTICS
C/D Ponds/ / C/D (lilt
/ Bread Truck
Pond
BT
r
Ponds 183
and 146
Figure 3-1
Pond Groups
OU-C Record of Decision
The remainder of the 22 hot ponds have undergone some treatment during the
investigation and treatability study phase at ERF:
• Racine Island Ponds. The Racine Island ponds include Ponds 285,293, and 297, which
together total about 2.5 acres in size. Pond 285 is 1 acre, and Ponds 293 and 297 together
are 1.5 acres. These ponds contain high numbers of craters. Elevated white phosphorus
concentrations, including some of the highest concentrations of all samples collected at
ERF, were detected in 73 percent of samples collected in these ponds. In 1996,16 percent
3-6
ANC/TRM93.00C/98M70002
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SUMMARY OF SFTE CHARACTERISTICS
of the dead ducks found in ERF were found in the Racine Island ponds. Capping and
tilling technology was tested at Pond 285 in 1995. This pond was tilled with a gravel-
clay mixture that prevented ducks from feeding in the contaminated sediment. The
mixture also supported the growth of vegetation. Ponds 293 and 297 in the Racine
Island Area were drained by breaching in 1997. (Draining of Pond 297 will continue in
1998 until completed.) Draining by breaching has discouraged waterfowl use. The
treatability study was conducted as a time-critical removal action because the breaching
needed to be completed before the ground melted in spring to protect the people
performing the work from explosive hazards.
Bread Truck Pond. Pond 109 is about 8.2 acres in size and contains a high number of
craters. White phosphorus contamination was detected in 45 percent of samples
collected in this pond. In 1996, 5 percent of the dead ducks found at ERF were at this
pond. Pond draining by breaching was tested at Pond 109 in 1996. The draining
technology removed the duck feeding habitat at Pond 109, which resulted in less duck
use.
3.2 Treatability Studies
Because of the heterogeneity of white phosphorus distribution, the UXO safety hazards, and
the physical setting, several treatability studies were performed to identify alternatives that
were not only effective in reducing exposure to white phosphorus contamination, but also
implementable and cost-effective. The technologies listed below were tested at ERF. The
first three were considered to be not implementable, not effective, or too'expensive. The
remaining four technologies were considered feasible, and were incorporated into the
alternatives presented in Section 5 of this ROD.
Unfeasible Methods
• Dredging-removal and drying of sediments that contain white phosphorus from
permanently flooded areas. This technology was not retained because it was only
moderately effective, altered duck habitat, and cost as much as 10 times more than other
technologies.
• Geosynthetics-use of textile material as liners for the bottoms of ponds. The material
acts as a physical barrier. This technology was not retained because a large-scale
implementation method has not been developed. In addition, the use of geosynthetics
altered duck habitat and installation of the material presented high risks to human
safety.
• Methyl anthranilate-application of this bird repellent. Methyl anthranilate settles to the
bottom of ponds and deters waterfowl from feeding. This technology was not retained
because its long-term effectiveness was marginal and it was very costly.
Feasible Methods
• Capping and filling-application of a material to act as a physical barrier to the white
phosphorus in the sediments of pond bottoms. The material used was called
AquaBlok™, a composite mixture of gravel and bentonite that expands in water to form
an impenetrable blanket over contaminated sediment. This technology was tested at
ANC/TRM93.DOG960470002 3-7
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SUMMARY OF SITE CHARACTERISTICS
Pond 285 at the Racine Island Area in 1995. The gravel-bentonite mixture filled the pond
and prevented ducks from feeding in the contaminated sediment. The material also
supported the-growth of vegetation.
Hazing-use of visible objects and sounds to deter waterfowl from use of an area,
thereby preventing exposure to white phosphorus. Hazing was conducted throughout
ERF with propane exploders, pyrotechnics, scarecrows, hovercrafts, flagging, balloons,
and other visual, acoustic, and behavioral devices designed to frighten birds. This
technology was retained as a contingency response action, in the event birds are not
deterred by the incidental hazing associated with remedy implementation. The hazing
contingency has been incorporated into Alternatives 2, 3, 4, and 5, which are discussed
in Section 5. (Hazing also occurs unintentionally when human activity and equipment
operations deter birds.)
Pond draining by breaching-iise of explosives to create a channel from a pond
containing white phosphorus, which allows the water to drain into a gully or Eagle
River. The draining activity permits the sediments of pond bottoms to dry and reduces
the feeding habitat of dabbling ducks in breached ponds. Draining by breaching was
retained and incorporated into Alternative 4. Pond draining by breaching was tested at
Pond 109 in the Bread Truck Area in 1996 and at Ponds 293 and 297 in the Racine Island
Area. Both areas were heavily contaminated with white phosphorus. The draining
technology removed or discouraged the duck feeding habitat at Pond 109, which
resulted in less duck use.
Pond draining by pumping-use of pumping systems to draw water from ponds
containing white phosphorus. The pumped water is discharged to gullies along the
Eagle River. The draining activity permits the sediments of pond bottoms to dry and,
therefore, allows white phosphorus to sublimate and oxidize. This technology was
tested at Pond 183 in Area C in 1997 and was found to be successful in removing white
phosphorus. Draining by pumping was retained and incorporated into Alternatives 3
and 4.
3-8 ANC/TRM93.00C/980470002
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SECTION 4
Summary of ERF Site Risks
Baseline risk assessments were conducted to determine the need for and extent of remediation
to be protective of human health and ecological values at ERF. These evaluations are
discussed in detail in Appendices A and B of the Final Operable Unit C, Remedial Investigation
Report, Fort Richardson, Alaska (1997), which is available at the information repositories. The
baseline risk assessments for OU-C include the ERF artillery impact range and OB/OD Pad.
The baseline risk assessments determined potential risks in the absence of remedial action.
The risk assessments were based on studies that identified the chemicals present and focused
on the chemicals of potential concern (COPCs). Results determined that risks within ERF were
limited to white phosphorus particles in sediment. The studies documented the history of
white phosphorus and ordnance use; the distribution, fate, and transport of white phosphorus
particles; and the toxicological effects of white phosphorus contamination within OU-C
White phosphorus is acutely toxic in minute quantities to humans and wildlife. In humans,
toxic effects of white phosphorus exposure include death at low doses, nausea, vomiting,
garlic-like odor on breath and in excrement, lethargy, convulsions, coma, fatty infiltration of
liver and other organs, enlargement of the liver with jaundice, kidney failure, and
electrocardiographic changes suggestive of an acute heart attack.
Eye exposure to white phosphorus fumes causes conjunctivitis, photophobia, and
lacrimation. Inhalation causes shortness of breath and hoarseness, but no permanent tissue
damage. Chronic occupational exposure causes phossy jaw (a disease of the jawbone
leading to tissue destruction and infection).
The most significant white phosphorus impacts at ERF are occurring to bird populations.
Dabbling ducks, such as northern pintails, mallards, and green-winged teal, and swans
(trumpeter and tundra) are the most affected species, as indicated by their high mortality.
Lethal oral doses for waterfowl have been established in toxicity studies. Sublethal effects
include reduced reproductive output in hens and teratogenic deformities in embryos,
including scoliosis, lordosis, submandibular edema, micropthalmia, and spina bifida.
Sublethal doses caused histopathological changes in the liver, spleen, heart, and duodenum.
Changes in blood chemistry (blood urea nitrogen, potassium, lactate dehydrogenase,
glucose, hematocrit, and hemoglobin) also were observed. Repeated subchronic exposures
resulted in mortality and histopathologic effects (liver and kidney damage) that were
consistent with acute exposures from single doses at similar concentrations.
4.1 Human Health Risk Assessment
The human health risk assessment determined that the limited human exposure at ERF
reduces potential risks and that risks of potential exposure to white phosphorus were very
low. The risk assessment also noted the existence of potential onsite risk to humans from
UXO. ERF is currently an active firing range and UXO risks are inherent. Any change in the
status of the range (if it became inactive) would be addressed under the Munitions Rule.
ANC/THM93 DOC/980470002
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SUMMARY OF ERF SITE RISKS
This subsection describes the background, approach, and conclusions of the human health
risk assessment.
A previous human health risk evaluation of hunters who may eat white phosphorus-
contaminated ducks from ERF, prepared in 1991 by the Army and the Alaska State
Epidemiologist, concluded that there is a very low human health risk. A baseline human
health risk assessment was designed and completed during the RI to determine the current
and potential human health risks based on the most up-to-date information available for
ERF. The baseline assessment assumed that no remedial action will be performed and
included more exposure scenarios than were reviewed in the 1991 risk evaluation.
Initially, several different current and potential exposure scenarios were considered,
including onsite and offsite activities. Although hunting in ERF is banned, the offsite hunter
scenario was addressed quantitatively because of the current level of hunting in nearby
areas and the potential for contaminated ducks to fly to those areas. In addition, because no
physical barriers prevent access to ERF from Knik Arm or Eagle River, an onsite recreation
scenario was considered.
Other human health risk scenarios were eliminated from consideration because of the low
potential for exposure or because exposure was mitigated by other site conditions.
4.1.1 Offsite Hunter Exposure Scenario
The exposure assessment for this scenario was based on an evaluation of the exposure
pathway and the estimated reasonable maximum exposure (RME). The RME is defined in
EPA guidance as "the highest exposure that is reasonably expected to occur at a site" and
represents a conservative exposure case that is still within the range of possibilities.
This offsite hunter scenario was developed from ADFG information to estimate that a very
active hunter might consume 23 ducks during a year. This estimate was adjusted,
considering the probability that a harvested duck would be contaminated with white
phosphorus from ERF. This probability was estimated as 0.005 based on (1) the proportion
of ducks in ERF compared to other areas of Cook Inlet and (2) data on the mortality rate
from white phosphorus exposure and the proportion of time ducks from ERF spend off site.
The portion sizes of duck meals (112 and 90 grams for an adult and child, respectively) were
estimated by using guidance from the EPA. An average concentration of 0.12 ug/g of white
phosphorus for the duck portion was estimated by using field and laboratory studies. The
chronic oral reference dose developed by EPA (2 x 10'5 milligrams per kilogram [mg/kg] of
body weight [bw] per day) and standard risk assessment equations also were used. The
calculated hazard quotients, which are estimates of the risk associated with a specified
exposure to a noncarcinongenic contaminant, were 0.005 and 0.003, respectively, for the
child and adult consumers in the scenario (Table 4-1). These quotients are considerably
below the reference value of one, indicating that the likelihood for significant chronic effects
from the consumption of contaminated ducks in the offsite hunter scenario is very low.
4-2 ANC/TRM93.00O980470002
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SUMMARY OF ERF SITE RISKS
TABLE 4-1
Noncancer Risks in Offsite Duck Hunter Scenario
Child
Adult
White Phosphorus
Concentration
(M9/9)
0.12
0.12
Meat Portion
(g/meal)
90
112
Meals per
year
23
23
Exposure
(mg/kg/day)
7.5 x10'8
6.0 x10'8
Hazard Quotient
0.005
0.003
Oral reference dose is 2 x 10'5 mg/kg-bw/day (from EPA's Integrated Risk Information System, 1996).
Additional assumptions:
Body weight: 36 kg (or child and 70 kg for adult (from EPA Risk Assessment Guidance for Superfund, Vols. I
and II, 1989).
0.5 percent of consumed ducks were those contaminated by white phosphorus at ERF.
On the basis of assumptions of the scenario, an adult would have to consume between
20 and 39 contaminated ducks each year, depending on the portion size consumed at each
meal, before the EPA oral reference dose for white phosphorus would be exceeded. Because
the ducks at the ERF represent a small fraction of the total ducks in Cook Inlet, this event
appears to have very low likelihood.
EPA has classified white phosphorus as a D carcinogen, meaning that it is not classified for
human carcinogenicity, on the basis of no available data for humans or animals. No cancer
slope factor is available, and no cancer risk was calculated.
4.1.2 Onsite Recreation Scenario at ERF
Although prohibited, access to ERF is not prevented by physical barriers. Means of access to
ERF are from Knik Arm or from upstream on the Eagle River. In addition, people on rafts or
other boats on the river can enter ERF by going past the Route Bravo Bridge beyond the
boat takeout, which is approximately 500 yards upstream from the bridge. Figure 4-1 shows
the locations of Route Bravo Bridge and the ERF vicinity. Few trespassers have been
observed in ERF in recent times.
For an upper-bound risk assessment for exposure to white phosphorus, it was assumed that
intruders, a child and an adult, enter ERF for a few hours on each of 10 days in the summer,
are exposed to an average white phosphorus concentration of 10 ug/g (which exceeds the
mean values for all areas except Racine Island), and ingests 200 and 100 milligrams (mg) of
sediment, respectively, at each visit. With these conservative assumptions, the calculated
hazard quotients are 0.08 and 0.02, respectively, which are much less than 1, the value of
concern. No cancer risk was calculated, as discussed in Section 4.1.1.
4.1.3 Uncertainties
The level of uncertainty in the risk results is a function of both site-specific characteristics
and the risk assessment process in general. Site-specific contributions include the following:
• White phosphorus concentrations in tissue were available from a variety of sampling
events over a period of several years, and little data were available for muscle, which
would be the major tissue expected to be ingested by humans.
ANC/TRM93.DOC/98W700Q2 •> 3
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Figure 4-1
Vicinity Map
OU-C Record of Decision
Scale: r = 4000"
2000 4000
SCALE IN FEET
8000
Area Designations:
Coastal West
Coastal East
A, B. C, C/D, and D
BT = Bread Truck Pond
Rl = Racine Island
4-4
-------
SUMMARY OF ERF SITE RISKS
• Measured concentrations were assumed to be representative of the future, which likely
overestimates the risk, given the likelihood of white phosphorus losses over time in areas
of ERF that occasionally become dry.
• Several judgments, which were designed to be conservative and therefore will lead to an
overestimate of the risk, had to be made for the exposure scenarios. Examples of these
judgments are the number of potentially contaminated ducks that a hunter would
consume and the time of exposure to white phosphorus at ERF in a year.
• The location and explosive potential of onsite UXO are not known.
• The parameter values may not accurately represent current or future conditions that may
lead to an over- or underestimate of the risk. In particular, this scenario has not
considered hunters who may subsist on duck during the hunting season. Their
consumption rate may be up to 10 times greater than that assumed in the offsite hunter
scenario. It should be noted, however, that the calculated hazard quotient was 0.001 for
the adult consumer in the offsite hunter scenario, and an additional exposure factor of
10 times would still result in a hazard quotient substantially below one.
4.2 Ecological Risk Assessment
An ecological risk assessment was prepared to address the current and future potential
impacts posed by white phosphorus contamination to the plants and animals of ERF in the
absence of cleanup action. The effects of white phosphorus exposure to ducks and swans
have been shown to be lethal. No other direct effects to wildlife or plants were identified.
This subsection describes the background, approach, and conclusions of the ecological risk
assessment.
The ecological risk assessment was conducted in three steps-problem formulation, analysis,
and risk characterizatiorv-to determine whether white phosphorus particles in surface water
and sediments at ERF may adversely affect local populations of ecological receptors. The
assessment was consistent with the EPA framework document for ecological risk assessment
and used previous reports and chemical data compiled during RI activities.
4.2.1 Ecological Problem Formulation
Studies at ERF conducted over several years provided detailed habitat surveys and
information on relevant receptors (mainly ducks and swans). The previous studies had
already established that particulate white phosphorus was the sole chemical of potential
ecological concern (COPEC) within ERF.
A CSM was developed for ERF based on information provided in previous reports. A CSM
provides a written or pictorial representation of an environmental system and the
biological, physical, and chemical processes that determine the transport of contaminants
from sources through environmental media to receptors within the system. The CSM for
exposure routes and pathways for sediment at ERF is shown in Figure 4-2.
Measurement and assessment endpoints were selected based on characteristics of the
COPECs, sensitive receptors or indicator species, and the expected or observed ecological
effects caused by the stressors. These biological and physical endpoints can be used to
ANC/TRM93.DOC/98M70002 1-5
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SOURCE
High Hazard Probability
Moderate Hazard Probability
| | Low Hazard Probability
Representative Species
Herbivores: Moose and Beavers
Fish: Sticklebacks, Sculpins
Terrestrial Predators: Bears,
Coyotes, Lynx, Raptors. Eagles
Terrestrial Scavengers: Gulls
Ravens, Raptors
Aquatic Predators: Beluga Whales.
Terns, Kingfishers
Shorebirds: Oowitchers
Dabbling Ducks: Mallards. Wigeon,
Green-winged Teal
Figure 4-2
Potential Exposure Routes and Pathways for Sediment
OU-C Record of Decision
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SUMMARY OF ERF SITE RISKS
evaluate remedial success and to guide remedial decisionmaking to protect animals, plants,
and their habitat in ERF and nearby Knik Arm.
Areas of potential ecological concern (AOPECs) were chosen based on physical characteristics
that corresponded with maximum exposure of waterfowl to white phosphorus or because of
their proximity to areas that were known to be contaminated and that waterfowl preferred for
feeding habitat. Ponded areas were determined to be AOPECs because they are preferred
feeding habitat for dabbling waterfowl. On the basis of earlier studies, these areas include
sedge marsh, permanent ponds, and intermittent ponds. The geographical areas of highest
potential ecological concern are Areas A, C, and C/D; Bread Truck; and Racine Island, as
well as nearby sedge marshes.
The CSM for ERF showed that the primary exposure pathway is by incidental ingestion of
white phosphorus particles contained within shallow pond sediments by dabbling ducks
when they feed. In deeper ponds, swans are exposed to white phosphorus in a similar
manner. Direct ingestion of the white phosphorus particles occurs because birds regularly
feed in habitats where white phosphorus is found. These birds either confuse the white
phosphorus particles with their natural food items (such as invertebrate larvae or plant
seeds) or accidentally ingest the particles along with pond sediments.
Of all bird species observed at ERF, three species of dabbling ducks (mallard, northern
pintail, and green-winged teal) have accounted for nearly 97 percent of all bird mortality.
These three duck species are considered to be primary ecological receptors that feed mainly
in shallow ponds. Swans feed in deeper water habitats than those used by the dabbling
ducks and also are considered to be primary ecological receptors. Because minimal
shorebird deaths have been discovered during the years of mortality studies in ERF, these
receptors have been ranked as having a moderate hazard probability. Shorebirds have less
exposure to white phosphorus because they feed in areas that periodically dry (which
allows the white phosphorus to sublimate) and they select organisms from the sediment
rather than sifting though the sediment or uprooting vegetation like dabbling ducks (and
therefore are less likely to ingest nonfood particles).
4.2.2 Ecological Risk Analysis
The analysis phase consists of two main components: (1) characterization of exposure and
(2) characterization of ecological effects. Conservative assumptions were used in estimating
potential exposure and effects to the selected indicator species.
Exposure Assessment Information used to evaluate potential ecological exposures at ERF
includes characterization of the ecosystem, evaluation of tissue concentrations of white
phosphorus in biota collected at ERF, and in situ and laboratory analysis of potential
exposure to white phosphorus in environmental media from the different areas at ERF. The
potential receptors that were considered for ERF included aquatic vegetation, aquatic
invertebrates, fish, and birds, as well as their consumers.
Investigations at ERF determined that aquatic plants growing within contaminated
sediments contained low levels of white phosphorus in plant roots, but no white
phosphorus in plant tissue. Therefore, the risks to grazing animals from plant consumption
are very low when compared to incidental ingestion of the sediment containing white
ANC/TRM93DOG980470002 4-7
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SUMMARY OF ERF SITE RISKS
phosphorus particles. No observed mortality of geese and wigeons, waterfowl that feed
mainly on vegetation, supports this conclusion.
White phosphorus impacts to aquatic invertebrates and fish were investigated in separate
studies. In general, the population diversity of benthic macroinvertebrates was not affected
by white phosphorus contamination under field conditions, even though representative
aquatic species were shown to be sensitive to white phosphorus in laboratory tests.
Sampling and analysis of ERF macroinvertebrates and fish did not reveal significant
accumulations of white phosphorus that would constitute a significant risk for birds or
mammals who eat them.
Secondary receptors include predators and scavengers such as the bald eagle, herring gull,
raven, wolf, coyote, and fox. Studies of activities and potential risk related to scavengers
and predators indicated a potential for indirect impacts from white phosphorus exposure
through consumption of dead and moribund white phosphorus-contaminated waterfowl.
Evidence of direct impacts on scavengers and predators (through direct ingestion of white
phosphorus-contaminated sediments) was not confirmed by field studies.
Although the uptake of white phosphorus by predators is rapid, the potential for
bioaccumulation in the food chain may be limited because of rapid loss of white
phosphorus upon reduction of dose, as seen in laboratory tests. No white phosphorus was
detected in the leg muscle of a coyote collected from behind the Canoe point tower in the
woods closer to ERF. White phosphorus was detected in one dead eagle collected in ERF;
however, the cause of death could not be determined.
The above studies of various ERF biological components have shown that the most
significant white phosphorus impacts are occurring to bird populations. Dabbling ducks,
such as northern pintails, mallards, and green-winged teal, and swans (trumpeter and
tundra) are the most affected species, as indicated by their high mortality at ERF. Mortality
of dabbling ducks has been concentrated in areas of ERF where suitable pond habitat is
located. White phosphorus measured in tissue samples from field-collected ducks (such as
mallards, pintails, and teal) and swans that had been exposed to in situ white phosphorus
showed similar or higher white phosphorus concentrations than corresponding tissues of
mallards in toxicological feeding studies.
Effects Assessment. The ecological effects assessment evaluated the cause-and-effect
relationships between white phosphorus and waterfowl through an evaluation of field
studies and laboratory toxicity studies as well as literature on the ecological effects of white
phosphorus.
Waterfowl mortality studies were completed by counting duck carcasses along permanent
transects in ERF and in the surrounding woods. The studies found that eagle predation and
scavenging of white phosphorus-affected ducks and carcasses are much more prevalent in
spring than in fall. Some ducks are consumed where they are captured, and some are
carried to other locations. The spring duck mortality rate dropped from 1992 to 1995. The
declining mortality rates in fall were attributed to the implementation of hazing (use of
visible objects and mechanized sounds to intentionally deter waterfowl from entering an
area) in the most contaminated areas, lack of suitable foraging habitat, and reduction of
available white phosphorus. Because mortality transects were not evaluated during the 1996
field season, the effect of the lack of hazing on duck mortality was not evaluated by using
4-8 ANOTRM93.00G980470002
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SUMMARY OF ERF SITE RISKS
transects. Although field studies did not establish a reliable estimate of bird mortality in the
reference areas of UCI, the mortality rate in ERF is likely much higher than the background
mortality rate in reference areas.
Daily movements, habitat preference, turnover rates, site-specific exposure, and mortality of
birds in ERF were studied with radio telemetry studies conducted from 1993 to 1996. Radio-
transmitted ducks and eagles were used in the telemetry studies. ERF duck habitat
preference during nonhazing periods indicated that the two most commonly used habitats
were sedge marshes and the permanent ponds (at 28.7 and 11.4 percent, respectively). Other
habitat types such as Ramenski's sedge, halophytic herb, interior sedge, and intermittent
ponds had progressively lower duck use percentages. Turnover rate among the ERF ducks
was high; the average length of stay was 12.5 days. Mortality of radio-equipped ducks on
ERF was 35 percent in 1996. Mallard mortality exceeded proportional area use in ERF
Areas C and C/D, Racine Island, and Bread Truck Pond. Duck deaths were recorded for
each year. None of the 31 radio-equipped bald eagles died from white phosphorus
exposure.
The USFWS conducted aerial bird population surveys of ERF during spring, summer, and
fall (April through October) from 1989 through 1997 as part of ongoing water bird studies.
The objective of these surveys was to monitor bird abundance and distribution in ERF
during spring, summer, and fall. Waterfowl were counted or estimated and recorded by
species or species group.
Laboratory and field toxicity tests of birds (primarily mallards) and aquatic
macroinvertebrates were conducted to determine acute and chronic toxicity as well as
potential effects to secondary receptors. A target white phosphorus concentration in
sediment at ERF was not established for the following reasons. Because white phosphorus
occurs in particulate form in ERF, its uneven distribution, caused by deposition by munition
rounds, creates considerable uncertainty for sampling and quantification. Actual dosage to
waterfowl from sediment is affected by the suitability of the feeding habitat (such as water
depth) and the relative efficiency of each species in locating and ingesting white
phosphorus particles of different sizes during feeding.
Birds. Various types of toxicity tests were conducted to determine the lowest dose of white
phosphorus resulting in mortality (5.2 mg/kg bw) and the lethal dose for 50 percent of a
sample population (LD^) (4.05 to 6.4 mg/kg bw) for mallards. A lowest observed effect
level (LOEL) based on mortality was estimated for particles of white phosphorus to be
between 3 and 4 mg/kg-bw/day, and a LOEL based on sublethal effects (liver, kidney, and
heart tissue damage) would be less than 2 mg/kg-bw/day. Preliminary reproductive
studies indicated that hens exposed to sublethal levels of white phosphorus have reduced
reproductive output and embryos with teratogenic deformities, including scoliosis, lordosis,
submandibular edema, microphthalmia, and spina bifida. Toxicological effects in birds
tested under laboratory conditions were similar to those observed in field toxicity tests.
Histopathological changes were observed in the liver, spleen, heart, and duodenum (small
intestine) in some birds treated with white phosphorus. The combination of changes in
some blood chemistry indicators (such as blood urea nitrogen, potassium, lactate
dehydrogenase, glucose, hematocrit, and hemoglobin) could be used as an indicator of
possible white phosphorus exposure. Test results for repeated subchronic exposures
ANOTRM93.DOC/9SW70002 ' 4-9
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SUMMARY OF ERF SITE RISKS
indicated that mortality and histopathologic effects (liver and kidney damage) were
consistent with acute exposures from single doses at similar concentrations.
The results of studies of white phosphorus toxicity for secondary receptors indicated that
the greatest risk-was through ingesrion of portions of the digestive tract that contained
pellerized white phosphorus. For example, a duck gizzard could have more than 100 times
the white phosphorus dose compared to other tissues. Although the uptake of white
phosphorus by predators is rapid, the potential for bioaccumulation in the food chain may
be limited because of the rapid elimination of white phosphorus seen upon reduction of
dose in laboratory tests. Bioaccumulation and toxicity could be significant if the ingested
dosage exceeds the degradation rate of the receptor. These studies indicate that predators
could be exposed to harmful doses of white phosphorus, which could result in sublethal
effects such as decreased reproductivity or survival. However, the absorption, distribution,
and metabolism of white phosphorus within an individual species results in a low
likelihood that white phosphorus is being transferred within the food web.
Macroinvertebrates. Laboratory toxicity tests and field studies of aquatic biota were
conducted to determine acute toxicity (lethal concentration for 50 percent of sample
population) and chronic toxicity (no observed effect level [NOEL]) of white phosphorus in
sediment, as well as impacts on the community structure of benthic macroinvertebrates.
Toxiciry tests indicated that sediments from Racine Island were not toxic to organisms
living in them in the field, but were toxic to laboratory organisms at diluted concentrations.
Chironomus riparius was more sensitive to white phosphorus than Hyallela azteca, and the
lowest NOELs were 26 micrograms per kilogram (ug/kg) and 1,500 ng/kg, respectively.
The community structure of benthic macroinvertebrates within ERF did not appear to be
affected by white phosphorus concentrations in sediment or surface water.
4.2.3 Ecological Risk Characterization
In this part of the risk assessment, the likelihood of adverse ecological effects occurring as a
result of exposure to white phosphorus in ERF is evaluated. Risk characterization consists of
two steps: (1) risk estimation and (2) risk description. For the ecological risk assessment,
waterfowl mortality was considered to be the only significant effect of white phosphorus on
ecological resources at ERF.
Area characteristics such as habitat (vegetation, landform, pond), white phosphorus
concentrations, and duck use were combined in the CIS database to identify areas where all
these factors exist together (overlap) that could be considered as a hot area. Other areas
were included because of their proximity to known white phosphorus-contaminated area and
because they contain preferred feeding habitat for dabbling waterfowl. The geographical
areas of highest potential ecological concern are Areas A , C, and C/D; Bread Truck; and
Racine Island, as well as nearby sedge marshes. Dying waterfowl or carcasses have been
collected from all these areas. Comparison of white phosphorus levels in various tissues of
these ducks showed higher than the corresponding maximum tissue concentrations for
mallard white phosphorus toxiciry studies, indicating that the ducks ingested enough white
phosphorus in ERF to result in mortality.
Duck mortality studies show that the largest proportions of dead or dying ducks in ERF
were observed in Area C (37 percent), Racine Island (22 percent), Area A (22 percent), Bread
Truck (12 percent), and Area C/D (6 percent). Of these areas, only Area A did not contain
ANCTRM93.tX>O980470002
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SUMMARY OF ERF SITE RISKS
confirmed or identified hot areas for white phosphorus exposure. Dead swans also were
observed in Area C (44 percent), Areas A and D (25 percent), and Area C/D (6 percent). No
observations of dead or dying birds in the coastal areas (east or west) were recorded in the
GIS database. Plant, fish, and invertebrate sampling and white phosphorus analysis from
these hot areas did not show significant uptake of white phosphorus.
Duck use of the various areas used in the telemetry studies was estimated by using the
telemetry observations during periods when hazing was not occurring. The results
indicated relative use by ducks as follows: Area C, 22 percent; Coastal East, 16 percent; Area
C/D, 14 percent; Area B, 10 percent; Bread Truck, 7 percent; Area A, 7 percent; Coastal
West, 5 percent; Area D, 4 percent; and Racine Island, 3 percent. Comparison of duck
mortality to duck use indicates that highest mortality occurs in Area C, Bread Truck, and
Racine Island.
Of the three habitat types considered to be preferred by ERF waterfowl, the following
percentages of total habitat areas were found in the white phosphorus-contaminated ERF
areas (C and C/D, Bread Truck, and Racine Island): permanent ponds, 29 percent;
intermittent ponds, 19 percent; and sedge marsh, 51 percent.
The actual percentage of utilization by waterfowl in these white phosphorus-contaminated
ERF areas (as indicated by telemetry observations during non-hazing periods) was higher
than would be indicated by the relative proportion of those habitats based on area:
permanent ponds, 47 percent; intermittent ponds, 31 percent; and sedge marsh, 54 percent.
(These percentages are calculated independently by area; they are not expected to add up to
100 percent.)
When the waterfowl utilization of the hot spots was compared to waterfowl utilization for
all of ERF (rather than limiting the comparison to the three preferred habitat types only),
the percentage of waterfowl utilization was much lower: permanent ponds, 5.4 percent;
intermittent ponds, 2.3 percent; and sedge marsh, 16 percent.
Comparison of bird use of ERF with overall bird use in UCI marshes was based on aerial
surveys conducted during the 1995 field season. In general, about 3 to 5 percent of
waterfowl (swans, geese, ducks) in UCI were found in ERF wetlands. Between 9 and
52 percent of UCI eagles were found to use ERF. The relative proportion of birds would be
expected to vary from year to year.
Studies of duck mortality between 1993 and 1995 with telemetry indicated an average
annual mortality rate of about 16 percent for ducks in ERF. However, mortality results from
the 1996 study based on a larger sample of birds and without hazing indicated a mortality
rate of 35 percent, a value that is probably more indicative of current risk at ERF without
remediation.
Ecological Risk Summary. The weight of evidence indicates that ingestion of white
phosphorus particles by ducks and swans is the cause of most of the elevated waterfowl
mortality in ERF. White phosphorus has been identified at elevated levels in the sediment
of three areas of ERF: Area C, Bread Truck, and Racine Island. Area C/D is adjacent to these
areas and also could have high levels of white phosphorus that were not detected because
of the limited sediment sampling. Area A also may be of ecological concern because of its
heavy use by waterfowl and documented duck mortality.
ANGTRM93. DOC/960470002
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SUMMARY OF ERF SITE RISKS
The significance of waterfowl mortality at ERF is given perspective by providing an
estimate of the proportion of UCI waterfowl that are using ERF. Only a small percentage of
UCI waterfowl (3_to 5 percent) may be using ERF (based on 1 year of surveys). If the
estimated 35 percent in-ERF mortality rate from telemetry studies is accepted as indicative
of current risk af ERF and it is assumed that approximately 5 percent of UCI waterfowl use
ERF, the estimated percentage of UCI waterfowl affected by white phosphorus in ERF
would be about 2 percent. Field studies have not established a reliable estimate of bird
mortality in reference UCI marshes; however, mortality in ERF is much higher than
background mortality in the reference areas.
Uncertainties associated with this assessment stem from the nature of the studies used to
(1) characterize the ecosystem, (2) estimate white phosphorus concentrations in ERF biota
tissues, and (3) characterize exposure of ERF biota to white phosphorus contamination.
Limitations of aerial and ground bird census methods contribute to the uncertainty
associated with the ecosystem characterization. The actual cause of telemetry bird death
was not always determined. Uncertainty in studies to estimate white phosphorus tissue
concentrations was affected by live-versus-dead bird samples, uneven distribution of
sample locations, lack of predator tissue samples, lack of tissue sample information, and
variations in the tissues analyzed and the white phosphorus detection limits and analytical
instrumentation. Uncertainty in the exposure analysis resulted from difficulties in sampling
and quantification of white phosphorus because of a lack of sampling for white phosphorus
in some areas and the irregular distribution of white phosphorus at ERF.
Estimates of uncertainty (or confidence intervals) were not provided in most previous
studies. Uncertainties associated with the laboratory tests include intra- and inter-study
variations, limitations of study design, and the ability to match laboratory conditions to
those observed in the field. Additional uncertainties include the limitations of the bird
mortality studies, such as the assumption that birds do not travel a significant distance after
exposure before dying, the uneven distribution of mortality transects, and the accuracy of
the ground survey counts used in calculating the mortality ratio. In addition, levels of white
phosphorus in fish and invertebrates may have been below detection limits. The single
largest source of error associated with comparison of ERF bird use to that of the UCI
marshes was that the comparison was based on a single field season. Considerable variation
from year to year already has been demonstrated in the ERF population studies.
4-12 ANC/TRM93.00O980470002
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SECTION 5
Description of Alternatives
5.1 Need for Remedial Action
If not addressed by implementing the response action selected in this ROD, the actual or
threatened releases of hazardous substances resulting from white phosphorus
contamination of the ERF source area of OU-C from exploded ordnances may present an
imminent and substantial threat to public health, public welfare, or the environment.
The specific reasons for conducting remedial actions at OU-C are as follows:
• White phosphorus in the shallow ponded sediment of ERF has contributed to elevated
waterfowl mortality.
• ERF is an important staging ground for migrating waterfowl during spring and fall
migration.
5.2 Remedial Action Objectives
As part of the RI/FS process, remedial action objectives (RAOs) were developed in
accordance with the NCP and EPA guidance for conducting RI/FS investigations. The
primary objective of the remedial action is to reduce the number of waterfowl deaths
attributable to white phosphorus.
Short and long-term RAOs for the remedial action at OU-C are as follows:
• Within 5 years of the ROD being signed, reduce the dabbling duck mortality rate
attributable to white phosphorus to 50 percent of the 1996 mortality rate attributable to
white phosphorus. Radio tracking and aerial surveys suggest that about 1,000 birds died
from white phosphorus at ERF in 1996. Therefore, the allowable number of duck deaths
from white phosphorus would be approximately 500.
• Within 20 years of the ROD being signed, reduce the mortality attributable to white
phosphorus to no more than 1 percent of the total annual fall population of dabbling
ERF ducks. Currently, that population is about 5,000. Therefore, the allowable number
of duck deaths from white phosphorus would be approximately 50. This long-term goal
could be adjusted based on future population studies conducted during the monitoring
program.
These objectives will be achieved by reducing the area of white phosphorus-contaminated
media and reducing the exposure to white phosphorus. Reducing the exposure to white
phosphorus will reduce the availability of white phosphorus to ducks, which in turn will
reduce duck deaths.
ANC/TRM93.DOC*80470002
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DESCRIPTION OF ALTERNATIVES
Monitoring through aerial surveys and radio telemetry at ERF will be conducted to ensure
that RAOs are achieved. The goals of monitoring will be as follows:
• To ensure that an exposure pathway does not exist between white phosphorus-
contaminated'sediment and waterfowl
• To determine the number of waterfowl using ERF
• To determine the number of waterfowl dying as a result of feeding on white
phosphorus-contaminated sediment
• To determine whether remedial action is effective or needs modification
5.3 Significant Applicable or Relevant and Appropriate
Requirements and To Be Considered Criteria
A full list of applicable or relevant and appropriate requirements (ARARs) and
to-be-considered (TBC) criteria is provided in Section 8. The following ARAR and TBC
criterion, respectively, are the most significant regulations that applied to the remedy
selections for ERF:
• Section 404 of the Clean Water Act (CWA), which coincides with Alaska water quality
standards, for protection of wetlands
• Provisions in the Migratory Bird Treaty Act of 1918 that prohibit unregulated "taking"
of birds, including poisoning at waste sites
5.4 Description of Alternatives
Many technologies were considered to clean up the white phosphorus-contaminated
sediment at OU-C. Appropriate technologies were identified and screened for applicability
to site conditions. The potential technologies were then assembled into alternatives.
Potential remedial alternatives for OU-C were identified, screened, and evaluated in the FS-
With the exception of Alternative 1, the following ERF-wide monitoring activities would be
conducted throughout all of ERF: a telemetry study of mallard movement and mortality,
aerial bird population surveys, and aerial photography of physical changes in habitat. The
changes in physical characteristics that are of interest include drainage, topography, and
vegetation. Some vegetation differences can be detected with the use of photography that
uses varying wavelengths, but some ground truthing and revisiting of study plots also
would be required.
In addition to the monitoring activities, hazing would be used as necessary in ERF to deter
waterfowl during critical migration periods. Hazing involves the use of visible objects and
sounds to deter waterfowl from using an area, thereby preventing exposure to white
phosphorus. Visual, acoustic, and behavioral devices have been used throughout ERF to
deter birds from contaminated areas.
The activities described above are referred to as ERF-wide activities.
5-2 ANC/TRM93.00C/98W70002
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DESCRIPTION OF ALTERNATIVES
The alternatives evaluated in the FS and the Proposed Plan are described in the following
paragraphs. All alternatives include the use of institutional controls to control access. The
Army restricts entry by maintaining a locked gate at the entrance to OU-C, posting signs
next to Eagle-River for boaters, and regulating admission to OU-C through the Range
Control.
Alternative 1: No Action
CERCLA requires evaluation of a no-action alternative as a baseline reflecting current
conditions without any cleanup effort. This alternative is used for comparison to each of the
other alternatives and does not include monitoring.
Published studies suggest that several natural processes occurring at ERF may lead to some
natural restoration over time. These processes include white phosphorus sublimation and
oxidation, gully advancement that leads to natural pond draining and the sublimation and
oxidation of white phosphorus, and the covering of white phosphorus with sediment
(called sedimentation). Because no monitoring would occur under Alternative 1, the effects
of the natural processes on the white phosphorus in pond sediments and its toxic effects on
waterfowl that use ERF would not be known. No costs would be associated with this
alternative.
Alternative 2: Detailed Monitoring
No treatment technologies would be implemented in Alternative 2. Only natural processes
such as gully recession, sedimentation, and white phosphorus sublimation and oxidation
would continue at ERF. However, under this alternative extensive, active monitoring for
these natural processes would be performed to understand whether natural processes are
occurring and to determine the level of protection for the environment that is achieved.
Alternative 2 expands on the ERF-wide activities currently planned for the entire ERF. It
adds the activity of monitoring ERF to determine whether natural restoration is occurring
and at what rate. Monitoring would include additional aerial photography, measurement of
net sedimentation, and an elevation survey. Aerial photography would measure pond
changes and gully recession. Net sedimentation measurements would determine whether
exposure pathways between contaminated sediment and waterfowl are being broken. The
elevation survey of ground surface and pond bottoms would determine pond
interconnectiveness and flooding potential.
In addition, baseline monitoring of white phosphorus in sediment would be performed by
using a composite sampling method to determine current white phosphorus levels. This
monitoring would help identify areas with white phosphorus contamination and provide
baseline information. Limited monitoring of sublimation and oxidation conditions would
be performed to detect whether conditions have been suitable for white phosphorus
sublimation and oxidation. Verification sampling of white phosphorus also would be
performed to confirm the success of this alternative if the pond conditions have been
sufficient to expect substantial white phosphorus sublimation/oxidation and loss.
The estimated time frame for cleanup goals to be achieved is between 10 years and more
than 50 years, depending on the portion of ERF.
ANC/TRM93.00O980470002 S-3
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DESCRIPTION OF ALTERNATIVES
Detailed monitoring would be conducted for 20 years or until it is consistently
demonstrated that remedial goals are achieved. The estimated 20-year present-worth cost of
this alternative is-$5,850,000, which includes $150,000 for capital costs and $286,000 per year
for annual monitoring.
Alternative 3: Pumping with Capping and Filling
The objective of this alternative is to temporarily drain ponds to allow the pond sediments
to dry and allow white phosphorus to sublimate and oxidize. This alternative consists of
draining ponds by pumping after flooding cycles and/or rain. After several drying periods
and verification sampling (approximately 5 years), capping and filling would be performed
in areas where white phosphorus remains.
This pumping technology was tested during the summer 1997 pond pumping rreatability
study. Baseline and verification sampling was performed before and after pumping. During
the summer of 1997, baseline and verification samplings showed an 80 percent decline in
white phosphorus concentrations in the top 3.5 inches of sediments.
In each pond system, a dedicated pump system would be installed annually after spring
breakup and would be removed before the winter freeze. The typical useful drying season
is mid-May to mid-September. Pumped water would be discharged to an adjacent
unconnected pond, river, gully, or open area. Mounted on floats, each pump system would
be completely automated to start and stop at established elevations of pond surface.
Scheduled maintenance service and refueling would be required. Figure 5-1 provides an
illustration of a floating pump system.
To create holes for placement of the pumps and short ditches for drainage from the pumps,
minor use of explosives may be included in this alternative. The affected areas would be
very small, and impacts would be minimal and temporary.
The pump systems are expected to operate for 5 consecutive years, based largely on tide
predictions. Tidal fluctuations affect the ability of the ponds to dry. This alternative
includes baseline (before the pumping season) sampling of white phosphorus to confirm
the ponds requiring cleanup and verification (after the pumping season) sampling to
confirm that white phosphorus has sublimated and oxidized or to determine areas that
require further cleanup.
Although Alternative 3 includes the ERF monitoring and hazing activities, it does not
include the extensive natural process monitoring described for Alternative 2. Baseline and
verification sampling of white phosphorus is expected to continue annually for 5 years.
After 5 years of pumping and monitoring, those pond systems where white phosphorus
exposure remains a concern would be capped and filled. A composite material would be
applied to areas of the pond systems that do not dry and still contain white phosphorus.
These areas generally will be isolated and will contain deep depressions that are not
connected hydraulically to other portions of the pond system being drained. The cap-and-
fill material is a manufactured gravel and bentonite mixture called AquaBlok™. This
material expands in water, sealing spaces in gravel and creating a barrier to permeability. It
will be applied only to small, deep portions of the pond bottoms. Therefore, despite its
swelling characteristics, it is not expected to significantly change feeding habitat or overall
5-4 ANOTRM93.DOC/980470002
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DESCRIPTION OF ALTERNATIVES
Figure 5-1
Floating Pump System
OU-C Record of Decision
pond depths, This material also supports vegetation growth. It provides a barrier between
the dabbling waterfowl and the sediment contaminated with white phosphorus.
During treatability studies at ERF, the cap-and-fill material was applied from a helicopter.
The application was similar to spreading fertilizer. Areas where capping and filling would
be performed would be inspected regularly for integrity and thickness. Following
application, restoration of the pond systems would occur naturally through precipitation
and tidal flooding. Figures 5-2 and 5-3 show helicopter and truck applications of cap-and-
fill material.
Temporary pumping is expected to be conducted for 5 years or until it is consistently
demonstrated that remedial goals are achieved. Minor capping and filling then would be
performed in small unremediated ponded areas, where necessary. ERF-wide activities
(monitoring) would be performed for the first 8 years of the remedy and then during
Year 10, Year 15, and Year 20 to ensure that remedial goals are consistently maintained. On
the basis of these assumptions, the estimated 20-year present-worth cost of this alternative
is $5,685,000, which includes $251,000 for capital costs (additional pumps) and $272,000 per
year for operation and maintenance, which cover monitoring.
Alternative 4: Breaching and Pumping with Capping and Filling
The objective of this alternative is to breach ponds, allowing water to flow out and the
sediments to dry. Breaching would be done by using explosive charges. Breaching results in
the permanent removal of duck habitat.
ANC/TRM93 DOO380470002
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Figure 5-2
Blackhawk Helicopter
Application of Cap-and-Fill Material
OU-C Record of Decision
Figure 5-3
Winter Truck Application of
Cap-and-Fill Material
OU-C Record of Decision
5-6
-------
DESCRIPTION OF ALTERNATIVES
Alternative 4 includes the use of explosives to create a ditch from a hot pond (or pond
system) to Eagle River or a nearby gully or creek that ultimately would permit the water to
drain into Cook Inlet. Areas that do not drain through the breached gully then would be
drained with-the pump system that is described for Alternative 3. For example, the
elevations of some pond bottoms may be lower than the breached gully elevation, and a
pump would be needed to fully drain water from the ponds and dry the sediments. Finally,
areas that do not dry sufficiently would be capped and filled as described above. Although
breaching allows large volumes of water to be drained quickly, it also lowers the threshold
elevation and allows a breached pond system to be reflooded often with lower tides.
Use of explosives would occur in March, when ERF is frozen and access is easier. It is
expected that explosives would be strategically placed to create a 20-foot-wide, 6-foot-deep
ditch. Pumping operations would be similar to those for Alternative 3, but would require
smaller pumps because most of the water is expected to be drained through the breached
gully system. The drying season also would be the same as described under Alternative 3.
Breaching considerations would include preference of gullies that naturally progress
toward pond systems, the shortest possible drainage route, and the shallowest possible
ditch. These criteria would minimize negative effects on existing habitat.
Pond breaching would be conducted within the first year of the ROD being signed and
would be followed by 8 years of pumping ponds that do not drain. Remedial goals are
expected to be achieved in a longer time than under Alternative 3 because the lower
breached threshold elevations would result in increased tidal flooding sequences.
Additional years for pumping would be needed because breached ponds would be flooded
more often, resulting in a lower rate of sublimation and oxidation.
Baseline (before pumping season) and verification (after pumping season) sampling will be
performed every year for 8 years. Minor capping and filling then would be performed in
small unremediated ponded areas, where necessary. Application of the cap-and-fill material
would be similar to that for Alternative 3 and would require the same follow-up inspection.
ERF-wide activities (monitoring) would continue to be performed after pumping is
complete for the duration of the remedy to ensure that remedial goals are consistently
maintained. Alternative 4 does not include the extensive natural process monitoring
performed under Alternative 2. On the basis of these assumptions, the estimated 20-year
present worth costs of this alternative is $9,132,000, which includes $2,064,000 for capital
cost (mostly explosives and additional pumps) and $353,000 per year for operation and
maintenance, which cover monitoring.
Alternative 5: Capping and Filling
The objective of this alternative is to cap and fill portions of hot ponds where the presence
of white phosphorus has been identified. As mentioned under the discussion of
Alternative 3, capping and filling prevents white phosphorus ingestion by ducks.
Alternative 5 is particularly well suited for areas that cannot be drained or dried. Unlike the
limited applications proposed under Alternatives 3 and 4, capping and filling under
Alternative 5 would cover the entire pond systems. Because of the swelling characteristics
of the cap-and-fill material, pond bottom elevations likely would be raised, and in some
cases, shallow ponds would be filled.
ANC/TRM93.DOC/980470002 5-7
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DESCRIPTION OF ALTERNATIVES
Implementation is expected to take 1 year. The cost of applying cap-and-fill material by
helicopter is high. Truck application is about twice as fast as application by helicopter,
and the equipment cost for trucks would be as much as one-tenth the cost for helicopter
application. Therefore, where capping and filling is required over larger areas, the
applications likely would be by vehicles on wheels or tracks during winter. The use of
vehicles would require driving heavy equipment on the frozen ground to transport the
material. Transport to and spreading at the ponds would be done when ice thickness is
sufficient to support the weight without damage to the ground surface. At some ponds, the
cap-and-fill material could be spread in a slurry in the spring.
Cap and fill material would be placed within the first 3 years after the ROD being signed,
followed by up to 20 years of monitoring to demonstrate that remedial goals are achieved.
Alternative 5 includes the ERF-wide activities, as well as baseline sampling for white
phosphorus and inspection of the integrity of areas where capping and filling is performed.
However, Alternative 5 does not include the extensive natural process monitoring under
Alternative 2. The estimated 20-year present worth cost of this alternative is $6,165,000,
which includes $2,694,000 for capital costs (cap-and-fill material and application) and
$174,000 per year for operation and maintenance, which cover monitoring.
5-8
-------
SECTION 6
Summary of Comparative Analysis of
Alternatives
The selection of alternatives was based on an evaluation using the nine CERCLA criteria
specified in Table 6-1. The first two criteria are known as threshold criteria that must be met
by all selected remedial actions. The following five criteria are known as balancing criteria,
and the final two criteria are referred to as modifying criteria.
TABLE 6-1
Criteria for Evaluation of Alternatives
THRESHOLD CRITERIA: Must be met by all alternatives.
1. Overall protection of human health and the environment. How well does the alternative protect human
health and the environment, both during and after construction?
2. Compliance with requirements. Does the alternative meet all applicable or relevant and appropriate state
and federal laws?
BALANCING CRITERIA: Used to compare alternatives.
3. Long-term effectiveness and permanence. How well does the alternative protect human health and the
environment after completion of cleanup? What, if any, risks will remain at the site?
4. Reduction of toxlcity, mobility, and volume through treatment. Does the alternative effectively treat the
contamination to significantly reduce the toxicity, mobility, and volume of the hazardous substances?
5. Short-term effectiveness. Are there potential adverse effects to either human health or the environment
during construction or implementation of the alternative?
6. Implementability. Is the alternative both technically and administratively feasible? Has the technology
been used successfully at similar areas?
7. Cost. What are the relative costs of the alternative?
MODIFYING CRITERIA: Evaluated as a result of public comments.
8. State acceptance. What are the state's comments or concerns about the alternatives considered and
about the preferred alternative? Does the state support or oppose the preferred alternative?
9. Community acceptance. What are the community's comments or concerns about the alternatives
considered and the preferred alternative? Does the community generally support or oppose the preferred
alternative?
6.1 Threshold Criteria
6.1.1 Overall Protection of Human Health and the Environment
Alternatives 1 and 2 are not protective of the environment and, therefore, will not be further
evaluated in this ROD. Risk reduction by natural processes may take from 10 to more than
20 years.
ANC/TRM9300O980470002 6-1
98047000
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SUMMARY Of COMPARATIVE ANALYSIS OF ALTERNATIVES
The levels of protection to the environment provided by Alternatives 3 and 4 would be
significantly higher. White phosphorus-contaminated sediment would be actively treated
through draining, and the exposure pathway between untreated sediment and waterfowl
would be blocked with cap-and-fill material. Cap-and-fill material would be applied only to
small depressions". Therefore, despite the swelling potential of the material, overall pond
bottom depths and feeding habitat are not expected to change significantly from impacts of
the cap-and-fill material under Alternatives 3 and 4. No adverse impacts from the cap-and-
fill material were observed during previous treatability studies. In addition, the limited
application of this material under Alternatives 3 and 4 is expected to preclude significant
habitat changes.
Although Alternative 4 would treat and remove white phosphorus, it also would cause
permanent large-scale changes to pond habitats. Ponds that were originally waterfowl
feeding habitats would be permanently removed. In addition, after long periods of drying,
vegetation would die and rebound would be unlikely.
Alternative 5 would provide protection by blocking the exposure pathway with a barrier
material; however, it does not treat or remove the white phosphorus. Alternative 5 also
would result in changes to habitat because the cap-and-fill material would cover the entire
pond system and the elevations of pond bottoms would be raised. In some cases, shallow
ponds would be filled entirely.
6.1.2 Compliance with Applicable or Relevant and Appropriate Requirements
A significant ARAR that applies to the OU-C site is Section 404 of the CWA, for protection
of wetlands. The Migratory Bird Treaty Act of 1918 is a TBC that prohibits unregulated
"taking" of birds.
All state ARARs would be met by Alternatives 3,4, and 5. These alternatives include active
treatment and/or covering of white phosphorus-contaminated sediment to prevent
waterfowl exposure.
All federal ARARs would be met by Alternatives 3 and 5. However, Alternative 4 would
not meet Section 404 of the CWA, in that this alternative would permanently destroy
wetland habitat.
6.2 Balancing Criteria
6.2.1 Long-term Effectiveness and Permanence
Alternatives 3 and 4 would involve treatment and removal of the white phosphorus
contamination through sublimation and oxidation and, therefore, would provide long-term
effectiveness and permanence. Residual risk of future exposure to white phosphorus would
remain in some small areas because capping and filling would not treat and remove white
phosphorus. Under Alternatives 3 and 4, cap-and-fill material would be applied to areas of
pond bottoms that do not dry.
It is expected that draining ponds by pumping and breaching (Alternatives 3 and 4) would
alter, and in some cases temporarily or permanently destroy, some wetlands at ERF.
Alternative 4 would have the most destructive impact on wetlands, because it would
6-2 ANC/TRM9aDOC/980470002
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SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES
permanently eliminate habitat. Under Alternative 3, impacts to the ERF wetlands habitat
would be temporary. Under both Alternatives 3 and 4, the protective procedures for
conducting activities that may disturb wetlands would be established and followed during
the cleanup to minimize impacts. These protective procedures include: (1) pumping
restrictions in Area B and Area D, which are prime waterfowl habitat; (2) selection of the
narrowest and shortest walking corridors to minimize disturbances to vegetation and
habitat; (3) proper maintenance of equipment and structures; (4) minimization of
equipment and staging area footprints; (5) minimal localized use of explosives;
(6) preparation of work plans and solicitation of agency review; (7) monitoring for impacts
to wetlands habitat; and (8) monitoring for waterfowl use of ERF.
Alternative 5 would not provide permanent removal of the white phosphorus, but it would
block the exposure pathway. Residual risk, which is risk resulting from contaminants that
remain after treatment is complete, would remain in the entire area of the pond that is
covered under Alternative 5. Residual risk remains because capping and filling does not
actively treat and remove the white phosphorus in sediments; instead, capping and filling
only prevents exposure of ducks to white phosphorus-contaminated sediment. The white
phosphorus would remain below the cap-and-fill material. The remaining residual white
phosphorus would still be present, just not accessible.
6.2.2 Reduction of Toxicity, Mobility, and Volume Through Treatment
Alternatives 3 and 4 would treat the largest area of white phosphorus-contaminated
sediment by reducing water level, drying pond sediment, and causing white phosphorus
removal by sublimation and oxidation. Residual risk is expected to be low under
Alternatives 3 and 4, as demonstrated in treatability studies. Alternative 5 does not involve
treatment to reduce toxicity and volume of white phosphorus-contaminated sediment,
although it would prevent exposure by reducing the mobility of white phosphorus.
Residual risk would be highest under Alternative 5, because contaminated sediment would
be only covered and not treated.
6.2.3 Short-term Effectiveness
It is estimated that the cleanup objective of reducing duck deaths by 50 percent in 5 years
would be met by Alternatives 3 and 4. RAOs would be achieved faster under Alternative 3,
but exposure would be reduced more slowly. The slower removal of exposure would occur
under Alternative 3 because bird habitat would still be available until all pond water is
removed by pumps. Once the water is removed (1 week), the pond would remain dry and
would only become wet again during heavy rains or high tides. Although the threshold
elevation of breached ponds would be lowered under Alternative 4 to allow a large volume
of water to initially drain to Eagle River, the ponds then would flood more frequently
during lower tides. The frequent refilling of the pond system under Alternative 4 would not
allow pond sediment to dry quickly. Therefore, 5 years of pumping would be needed for
cleanup under Alternative 3, as opposed to 8 years of pumping under Alternative 4.
The criterion of short-term effectiveness also would be met under Alternative 5, when
capping and tilling were completed. Application of cap-and-fill material throughout ERF is
estimated to take a total of 2 to 3 weeks and would occur within the first 3 years of remedy
implementation.
ANOTHM93.DOO980470002 5-3
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SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES
Alternatives 4 and 5 may result in permanent changes, and Alternative 3 would result in
temporary changes to pond bottoms, habitat, and bird use. The limited application of cap-
and-fill material in Alternative 3 is not expected to result in large-scale permanent habitat
changes. Short distances of vegetation or uneven topography may restrict water movement
within and between ponds. To enhance draining of the ponds, Alternative 3 also may
include limited use of explosives to clear small drainage channels that radiate from the
pump location. The effects from use of explosives to create the small drainage channels is
expected to be very short term.
All alternatives would pose some short-term potential risk to onsite workers during
monitoring activities and during setup, operation and maintenance, and removal of
monitoring and cleanup equipment. These potential risks could be minimized by
engineering and institutional controls. The most significant risk to workers is from the
existence of UXO at ERF. To reduce this risk, all areas where workers would be exposed
would be cleared of unexploded ordnance either visually or electronically.
The community would not experience any significant effects from the alternatives. The
explosions produced for pond breaching in Alternative 4 may affect the community
through impacts such as noise and vibration. Use of explosives on clear weather days
would reduce these impacts (cloud cover reflects and emphasizes sounds from explosions),
and a community relations program would be used to alert the public in advance of these
activities.
6.2.4 Implementability
Alternatives 3 and 4 would use readily available technologies and. would be feasible to
construct and operate. Treatability studies of pond breaching and pond pumping were
successfully conducted in the summers of 1996 and 1997. Alternative 5, which includes a
containment technology only, also would use readily available materials. Minor technical
difficulties are anticipated during application of cap-and-fill material because of the
presence of craters throughout ERF. Visual inspections of caps to assess their integrity
would be performed under Alternatives 3 through 5.
Alternatives 3 through 5 involve UXO ordnance hazards to onsite field personnel. Steps
previously described, including having work areas and pathways cleared by unexploded
ordnance specialists, would be taken to minimize risk.
6.2.5 Costs
The estimated costs for each alternative evaluated are provided in Table 6-2. The estimates
are based on the information available at the time the alternatives were developed. The
costs projected over 20 years are estimated for purposes of comparison and are considered
to be accurate to within -30 percent to +50 percent. Costs are described by using the present-
worth methodology with a discount rate equal to 5 percent. Capital cost includes the
purchase price of the pumps, monitoring equipment, cap-and-fill material, and explosives.
It also covers the labor and transportation associated with initial setup of equipment.
Annual operation and maintenance cost includes startup and dismantling activities, routine
maintenance, refueling, pump system setup and removal, and annual monitoring. Also
included are the activities conducted in the entire ERF and sampling of sediments for white
phosphorus. In addition, annual operation and maintenance cost covers labor,
ANC/TRM93.DOC/980470002
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SUMMARY OF COMPARATIVE ANALYSIS Of ALTERNATIVES
TABLE 6-2
Cost Estimate for Cleanup Action Alternatives
Location
Average Annual 20YearO&M Total Cost-
Capital Cost O&M Present Present Worth 20 Year O&M
($000) Worth ($000) ($000) ($000)
Alternative 1-No Action
Alternative 2-Detailed Monitoring
Alternative 3-Pumping with Capping and
Filling
Alternative 4-Breaching and Pumping with
Capping and Filling
Alternative 5-Capping and Filling
0
150
251
2,064
2,694
0
286
272
353
174
0
5,700
5.434
7.068
3,471
0
5.850
5.685
9,132
6.165
Notes:
O&M = Operation and maintenance
Average = The 20-year present-worth O&M cost divided by 20.
Present worth means costs are expressed as U.S. dollars in 1998. The amount indicates moneys needed in
1998 dollars to complete the project over 20 years. The majority of these costs will be used to achieve the
5-year cleanup goal. A discount rate of 5 percent is used.
Costs include ERF-wide long-term monitoring and contingency hazing.
transportation, and clearance of work areas by UXO specialists associated with these
activities.
Under Alternative 4, costs do not include restoring breached ponds to reestablish habitat.
6.3 Modifying Criteria
6.3.1 State Acceptance
The State of Alaska has been involved with the development of remedial alternatives for
OU-C and concurs with the Army and EPA in the selection of Alternative 3.
6.3.2 Community Acceptance
Community response to the preferred alternative was generally positive. Community
response to the remedial alternatives is presented in the Responsiveness Summary in
Appendix B, which addresses comments received during the public comment period.
ANC/TRM93.00C/98M70002
6-5
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SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES
ANC/TRM93 DOC/980470002
-------
SECTION 7
Selected Remedy
Alternative 3 is the selected alternative for treating white phosphorus-contaminated
sediment at OU-C. It is the least expensive of the treatment-oriented alternatives. A
thorough assessment of alternatives considered current risks, residual risks, impacts to
habitat, and costs. Alternatives 1 and 2 were eliminated because they did not satisfy
threshold criteria. Although Alternative 4 would actively treat a large portion of the ERF, it
does not meet overall protection of the environment or ARARs because it permanently
removes wetlands. Alternative 5, capping and filling does not provide reduction in
contamination through treatment, and would leave a large amount of residual risk.
Protection of human health and the environment and compliance with ARARs will best be
attained through pond draining with pumping, ERF-wide monitoring activities, and
institutional controls.
7.1 Major Components of the Selected Remedy
The major components of the preferred remedy for OU-C are listed below. It is assumed
that implementation of the remedy will begin in 1999 and end in 2018 (duration of
20 years). The sequence and schedule of operation and maintenance activities are presented
in Tables 7-1 and 7-2, respectively.
• Treat white phosphorus-contaminated sediment by draining ponds with pumps for five
summers beginning in 1999. Pumping would allow the sediments to dry and the white
phosphorus to sublimate and oxidize. The treatment season would begin in May and
end in September. A pond elevation survey would be conducted to determine the
optimal pump placement. To enhance drainage, explosives may be used to make small
sumps for the pumps and shallow drainage channels. These shallow drainage channels
would enhance hydraulic connectivity between ponds to encourage drainage.
• Implement the following protective procedures to minimize disturbances to wetlands
habitat:
- Restriction of activities that disturb wildlife in Area B and Area D, which are prime
waterfowl habitat areas
- Selection of the narrowest and shortest walking corridors to minimize disturbances
to vegetation and habitat
- Proper maintenance of equipment and structures
- Minimization of the use of equipment and of staging-area footprints
- Minimal localized use of explosives
- Preparation of work plans and solicitation of agency reviews
ANOTRM93DOC880470002 M
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SELECTED REMEDY
TABLE 7-1
Sequence of Activities for the Selected Alternative
- Activity Time Frame
Monitoring Activities
Waterfowl telemetry and mortality study Every year for first 8 years, Year 10, Year 15, and Year
20 (11 events)
Aerial waterfowl surveys Every year for first 8 years, Year 10, Year 15. and Year
20(11 events)
White phosphorus monitoring of treated ponds Every year for first 5 years (5 events)
White phosphorus composite sampling in Every year for first 5 years (5 events)
untreated areas
GIS database management Every year for first 8 years, Year 10, Year 15, and Year
20(11 events)
Pond survey, ground truthing, limited aerial survey Year 1 and every year from Year 9 to Year 20 (13 events)
Aerial photography and interpretation Every other year for 10 years (5 events)
Mapping of physical habitat changes and vegetation Once every 4 years for 20 years (6 events)
rebound
Treatment Activities
Pond pumping treatment Every year for first 5 years (5 events)
Cap and fill application Year 5 (1 event)
Cap and fill integrity inspection Every year for 4 years after material is placed (Year 5, 6,
7, 8), Year 10. Year 15, and Year 20 (7 events)
Hazing (contingency) Every year for first 5 years (5 events, if needed)
- Monitoring for impacts to wetlands habitat
- Monitoring for waterfowl use of ERF
Sample pond bottoms for white phosphorus at the beginning of the treatment season to
confirm or determine that the pond or area requires remediation. The sampling also
would establish a white phosphorus baseline and determine additional areas that may
require remediation. The baseline sampling would be performed at the beginning of
each field pumping season (every year for the first 5 years, starting in 1999).
Sample pond bottoms for white phosphorus after treatment to determine effectiveness
of the treatment system. This verification sampling would be performed at the end of
each field pumping season (every year for the first 5 years, starring in 1999).
Perform telemetry monitoring and aerial surveys every year for the first 5 years
concurrently with pumping activities to determine bird populations, usage, and
mortality. These activities would begin in 1999. Monitoring would be continued for
3 additional years to verify that short-term goals are maintained. Monitoring also would
7-2 ANC/TRM93.DOG98W70002
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TABLE 7-2
Schedule of Activities for Selected Alternatives
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20
Year: 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016 2017 2018
Tide Predictions: Wet Wet Dry Dry Dry Wet Dry Dry Dry Wet Wet Dry Dry Wet Wet Wet
ftetlvltw "or*1"* *"* "M* P"01?*0"" Conttnu* mortality *na
Mcuvny. fg^ontnUon* d»cn**t contltttntty ttcn whit* photphorut
r*V- monitoring to tnturt
Tram* tttihUthta. Short ttm MOmtttt HAD* *r* mtlnttinni
Horttttty monitoring p*rtorm*d *t Y*tr 10, Y»*r IS, tnd Yttr 20 to mur* ttutHAOttrt
mmlnttlnm.
Urnltta ttrttl tnd Itna turny* conducttd ptrlodtetllf.
i. '
Pumping ptrformtd. lion activity during N*tual aroc*****llt* **ajm*nt*tton conUnu*. |
tmttt. Itdttfd tmount* at omit*
photphorut Otttcttd.
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tnttthtiao
*X*y.
llWr^'^->ir>>^tisrtf:' ' '-' - ^^.--^'^^ •^•-••-^ l:. • v: ,••.:-•'.•'
Waterfowl telemetry and mortality study XXXXXXXX X X
Aerial waterfowl surveys XXXXXXXX X X
White phosphorus monitoring ol treated ponds X X X X X
White phosphorus composite sampling in untreated areas X X X X X
GIS database management XXXXXXXX X X
Ponds survey, ground trulhing, limited aerial survey X XXXXXXXXXXX
Aerial photography and interpretation XX X X X
Mapping ol physical habitat changes and vegetation rebound XX X X X
Pond pumping treatment X X X X X
Cap and fill application X
Cap and fill integrity inspection X X X X
Hazing (contingency) X X X X X
X X
Long-
ttm
MO*
mil
X
X
X
X
X
X
Assumptions:
1 . Active remediation will be performed until Year 5. Treatment progress and monitoring technique will be evaluated during the 5-year review.
2. Waterfowl mortality will decline after each year of treatment.
3. A trend will be established to justify that reaching the short-term mortality goal is the result of treatment (white phosphorus removal), and not just a limited data set.
4. Cap-and-fill material will be applied to 2.17 acres of pond bottoms at Year 5. It is assumed that 5% of Pond 146, 5% of Pond 155. and 10% of Northern A ponds will not dry.
5. Telemetry and mortality studies, aerial waterfowl surveys, reduced white phosphorus sampling, limited GIS database management, and studies of habitat rebound will be performed for an additional 3 years
after active pumping is complete. This additional monitoring is to ensure that cleanup objectives are not only reached, but also maintained.
6. Telemetry and mortality studies, aerial waterfowl surveys, limited GIS database management, and limited studies of habitat rebound will be performed at Years 10. 15. and 20 to ensure that cleanup objectives
are maintained.
7. Limited site visits to inspect for waterfowl mortality, physical, habitat changes, and vegetation rebound will be performed during years that telemetry mortality studies are not performed. Assessment will be
performed visually on foot and by air.
ANC/Trm178.xls/981140001
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SELECTED REMEDY
be conducted at Year 10, Year 15, and Year 20 to ensure that remedial action objectives
continue to be maintained.
• Perform limited aerial surveys and ground truthing during Year 9 to Year 20 to evaluate
waterfowl mortality, physical habitat changes, and vegetation rebound.
• Perform aerial photography every other year for 10 years (beginning in 1999) to monitor
habitat changes resulting from remedial actions. Changes in drainage, topography, and
vegetation would be evaluated.
• Perform habitat mapping once every 4 years for 20 years to evaluate impacts to habitat
as a result of remedial actions, as well as to observe habitat rebound after pumping is
discontinued.
• Perform limited hazing (only as a contingency) during first 5 years starting in 1999 if
incidental hazing from pumping operations and other fieldwork activities does not
deter bird usage.
• After remedial action objectives are achieved and pumping is discontinued, apply cap-
and-fill material in ponded areas that did not drain and dry sufficiently to enable the
white phosphorus to sublimate and oxidize. Cap-and-fill material placement is expected
to occur in Year 5 (2003).
• Monitor cap and fill material integrity every year for 4 years after the material is placed,
and also at Year 10, Year 15, and Year 20.
• Incorporate white phosphorus sampling, telemetry, aerial survey, habitat, and physical
landform data into a GIS database. Perform GIS management every year for the first
8 years, starring in 1999, and then during Year 10, Year 15, and Year 20.
• Maintain institutional controls, including the restrictions governing site access,
construction, and road maintenance and the required training for personnel who work
at OU-C source areas.
The concept of appropriate institutional controls and expectations about their use, as
specified in the NCP at 40 CFR 300.430(a)(l)(iii)(D), is incorporated by reference into this
ROD.
Institutional control SOPs applicable to selected remedies at CERCLA OUs on Fort
Richardson are currently being developed by the Army in close consultation with the EPA
and ADEC. They will be completed and incorporated into the final OU-D ROD for Fort
Richardson. These institutional control SOPs will be implemented sitewide for all of Fort
Richardson when the OU-D ROD is signed. The SOPs will include institutional controls that
specify particular restrictions, controls, and mechanisms that will be used to protect public
health, safety, and the environment. The objective of these institutional controls is
protection of human health, safety, and the environment by limiting or preventing access to
contaminated areas or otherwise denying exposure pathways.
7-4 ANC/TRM93 DOC/980470002
-------
SELECTED REMEDY
7.2 Agency Review of the Selected Remedy
The goal of this remedial action is to reduce waterfowl deaths attributed to white
phosphorus. Section 5 outlines the RAOs for OU-C. On the basis of information obtained
during the Rl-and careful analysis of all remedial alternatives, the Army, EPA, and ADEC
believe that the selected remedy will achieve this goal. Monitoring data will be reviewed by
the EPA, ADEC, and the Army every year pumping occurs to determine whether the
selected remedy is meeting or will meet the short-term and long-term RAOs. This telemetry
monitoring will continue until short-term RAOs are met. It will continue for 3 years after
achieving the short-term RAO to ensure that the short-term RAO is consistently
maintained. After that time, monitoring will be conducted at Year 10, Year 15, and Year 20
to determine whether the long-term RAOs are being met by the selected remedy.
If at any time, monitoring data reveal that either the short-term or long-term RAOs (or both)
are not being met, then the EPA, ADEC, and Army will meet within 3 months of the
discovery of these failures of the selected remedy in order to determine what, if any,
changes are needed to the selected remedy in order to provide adequate protection of
human health and the environment.
Because the remedy will result in hazardous substances remaining on site above levels
specified in the long-term RAOs, a review will be conducted within 5 years after
commencement of the selected remedial action to ensure that the remedy continues to
provide adequate protection of human health and the environment. This 5-year review
process will continue on 5-year increments until the selected remedy has been certified by
the EPA, ADEC, and Army to be complete. After the first 5 years of implementation, if the
monitoring and performance data indicate that the selected remedy and any enhancements
to the selected remedy are not protective of human health and the environment, the selected
remedy will be reevaluated by the EPA, ADEC, and Army to determine what, if any,
changes or additional remedial actions are necessary to protect human health and the
environment. At this time, the telemetry results, interpretation methods, and remedial
action objectives will also be reevaluated.
ANOTRM93.DOC/98M70002 7-5
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SELECTED REMEDY
7-6 ANOTRM93.DOO98M70002
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SECTION 8
Statutory Determinations
The main responsibility of the Army, EPA, and ADEC under their legal CERCLA authority
is to select remedial actions that are protective of human health and the environment. In
addition, Section 121 of CERCLA, as amended by SARA, provides several statutory
requirements and preferences. The selected remedy must be cost-effective and use
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, toxicity, or mobility of hazardous substances through
treatment. Finally, CERCLA requires that the selected remedial action must comply with
ARARs established under federal and state environmental laws, unless a waiver is granted.
8.1 Protection of Human Health and the Environment
The selected remedy for OU-C will provide long-term protection of human health and the
environment and satisfy the requirements of Section 121 of CERCLA.
The selected remedy will provide long-term protection of human health and the
environment by draining ponds and removing the white phosphorus contamination from
sediments through drying of the sediments and subsequent sublimation and oxidation of
the white phosphorus particles. The small, deep, isolated areas of pond bottoms that do not
dry sufficiently will be covered with a cap-and-fill technology. Draining ponds and drying
sediments to allow the white phosphorus to sublimate will eliminate the potential exposure
route for waterfowl. Monitoring will be completed to ensure the effectiveness of the
remedy.
Hazing will be conducted at ERF as a contingency measure during critical migration
periods to reduce the threat of exposure to contaminated sediments until remediation goals
are met.
Institutional controls will be in place to limit access to OU-C and minimize the threat of
exposure to Army training activities and onsite UXO.
No unacceptable short-term risks will be caused by implementation of the remedy.
8.2 Compliance With Applicable or Relevant and Appropriate
Requirements and To-Be-Considered Guidance
The selected remedy for OU-C will comply with all ARARs of federal and state
environmental and public health laws. These requirements include compliance with all the
location-, chemical-, and action-specific ARARs listed below. No waiver of any ARAR is
being sought or invoked for any component of the selected remedy.
ANOTRM93DOO980470002 3-1
-------
STATUTORY DETERMINATIONS
8.2.1 Applicable or Relevant and Appropriate Requirements
An ARAR may be either applicable or relevant and appropriate. Applicable requirements
are those cleanup"standards, criteria, or limitations promulgated under federal or state law
that specifically address the situation at a CERCLA site. A requirement is applicable if the
jurisdictional prerequisites of the environmental standard show a direct correspondence
when objectively compared with the conditions at the site. An ARAR is relevant and
appropriate if, although it may not meet the definition of "applicable," it is promulgated
under federal or state law and still addresses problems or situations sufficiently similar to
those encountered at the CERCLA site so that the use of the ARAR is well-suited to the
particular area.
Pursuant to EPA guidance, ARARs generally are classified into three categories: chemical-
specific, location-specific, and action-specific requirements. This classification was
developed to help identify ARARs, some of which do not fall precisely into one group or
another. These categories of ARARs are defined below:
• Chemical-specific ARARs are usually health- or risk-based numerical values or
methodologies that establish an acceptable amount or concentration of a chemical in an
ambient environment.
• Location-specific ARARs are restrictions placed on the concentration of hazardous
substances or the conduct of activity solely because the ARARs occur in special
locations.
• Action-specific ARARs are usually technology- or activity-based requirements for
remedial actions.
TBC requirements are generally nonpromulgated federal or state standards or guidance
documents that are to be used on an as-appropriate basis in developing cleanup standards.
They usually fall into three categories:
• Health effect information with a high degree of certainty
• Technical information about how to perform or evaluate site investigations or response
actions
• State or federal policy documents
8.2.2 Chemical-Specific ARARs
On the basis of available information collected to date about the chemicals of concern
associated with past activities at OU-C, white phosphorus at ERF has been identified as the
chemical of concern. Currently, there are no promulgated numerical cleanup or discharge
limitation values for white phosphorus; therefore, there are no chemical-specific ARARs for
potential remedial actions at OU-C.
8.2.3 Location-Specific ARARs
• CWA, Section 404: Section 404 of the CWA, which is implemented by the EPA and the
Army through regulations found in 40 CFR 230 and 33 CFR 320 to 330, prohibits the
discharge of dredged or fill materials into waters of the United States without a permit.
8-2 ANC/TRM93 DOO980470002
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STATUTORY DETERMINATIONS
This statute is applicable to the protection of wetlands at ERF. Section 404 of the CWA
authorizes the COE to regulate the discharge of dredged or fill material into all "waters
of the United States (including wetlands)." The definition of "discharge of dredged
material" was revised by the EPA and COE (Federal Register, 58:45008) on August 25,
1993. Under the newly defined "discharge of dredged material," the COE regulates
discharges associated with mechanized land clearing, ditching, channelization, and
other excavation activities that destroy or degrade wetlands or other waters of the
United States under Section 404 of the CWA.
The substantive requirements of the CWA Section 404 (b)(l) guidelines (hereinafter referred
to as the Guidelines) are applicable to cleanup activities that involve water discharges from
the pumping operations and channel clearing conducted in wetlands at ERF. The
Guidelines were promulgated as regulations in 40 CFR 230.10 and include the following:
• 40 CFR 230.10(a) states that no discharge of dredged or fill material will be permitted if
a practicable alternative exists to the proposed discharge that would have less impact on
the aquatic ecosystem, as long as the alternative does not have other significant adverse
environmental consequences.
• 40 CFR 230.10(b) states that no discharge of dredged or fill material will be permitted if
it causes or contributes to violations of any applicable state water quality standard or
violates any applicable toxic effluent standard or discharge prohibition under CWA
Section 307.
« 40 CFR 230.10(c) prohibits discharges (or activities) that will cause or contribute to
significant degradation of the waters of the United States.
• 40 CFR 230.10(d) states that when a discharge (or activity) would degrade the waters of
the United States, and there are no practicable alternatives to the discharge, compliance
with the Guidelines can be achieved generally through the use of appropriate and
practicable mitigation measures to minimize or compensate for potential adverse
jmpacts of the discharge (or activity) on the aquatic ecosystem.
8.2.4 Action-Specific Requirements
• Alaska Oil Pollution Regulations (Title 18, Alaska Administrative Code, Chapter 75
[18 AAC 75]) set requirements for discharge reporting, cleanup, and disposal of
hazardous substances for spills of hazardous substances to Alaska's land or water
within specified time frames. The broad ADEC definition of "hazardous substance"
includes constituents such as oil and other petroleum products. The selected remedy
will involve the use of onsite diesel generators to power the pump systems. These
regulations are applicable for the discovery and cleanup of spills of diesel fuel or other
hazardous substances at OU-C that are regulated by the State of Alaska.
• Alaska Water Quality Standards (18 AAC 70) in general, apply to groundwater and
surface water and establish criteria for protected classes of water use. Where water is
used for more than one purpose, the most stringent water-quality criteria ARARs will be
used. Eagle River is protected for all water use classes. Specific criteria applicable to
Eagle River will depend on the parameter being evaluated and the potential impact or
discharge that may occur as a result of implementation of the remedy. The "Criteria for
ANOTRM90.DOC/980470002 B-3
-------
STATUTORY DETERMINATIONS
Growth, Propagation of Fish, Shellfish, other Aquatic Life and Wildlife" are the most
stringent and, therefore, applicable to OU-C. Because pumping and installation of cap-
and-fill material may affect surface water, these ARARs are applicable.
• Regulations contained in 40 CFR 266, Subpart M, specify when military munitions
become solid, and possibly hazardous, wastes and include requirements for storage and
transportation of military munitions wastes that are designated as hazardous waste.
8.2.5 To-Be-Considered Criteria or Guidance
• Migratory Bird Treaty Act of 1918 and the treaties cited therein: This statute implements
the 1916 Convention between the United States and Great Britain (for Canada) for the
protection of migratory birds. It establishes a federal prohibition, to be enforced by the
Secretary of the Interior, against the illegal taking of migratory birds. This prohibition
applies to birds included in the respective international conventions between the United
States and Great Britain, Mexico, Japan, and the Soviet Union. Fort Richardson is
implementing remedial action at ERF primarily to protect migratory birds, to satisfy the
intent of this treaty.
• Executive Order 11990, Protection of Wetlands: 40 CFR 6, Subpart A sets forth EPA
policy for carrying out the provisions of Executive Order 11990, Protection of Wetlands.
These regulations are applicable to cleanup and monitoring activities conducted in ERF
wetlands. Activities will be conducted during implementation of the selected remedy to
minimize adverse impacts to the wetlands.
• ADEC, Draft Water Quality Standards (18 AAC 70) and Draft Revision to Oil and
Hazardous Substances Cleanup Standards, May 4,1998 (18 AAC 75): These proposed
regulations include numerical cleanup standards and procedures for developing risk-
based cleanup standards for hazardous substance releases to ensure protection of
human health and the environment. These draft regulations are TBCs for the cleanup of
releases of hazardous substances, such as diesel fuel from pump generators, during
remediation.
• Army Regulation (AR) 200-2 (Environmental Quality), Environmental Effects of Army
Actions, states Department of Army policy, assigns responsibilities, and establishes
procedures for the integration of environmental considerations into Army planning and
decisionmaking in accordance with 42 United States Code 4321 et seq., National
Environmental Policy Act of 1969; the Council on Environmental Quality regulations of
November 29,1978; and Executive Order 12114, Environmental Effects Abroad of Major
Federal Actions, January 4,1979.
• AR 210-20 (Master Planning for Army Installations) explains the concept of
comprehensive planning and establishes policies, procedures, and responsibilities for
implementing the Army Installation Master Planning Program. It also establishes the
requirements and procedures for developing, submitting for approval, updating, and
implementing the Installation Master Plan.
• AR 190-13 (Enforcement of Hunting, Trapping and Fishing on Army Lands in Alaska):
Appendix B in this Army regulation describes enforcement of hunting, trapping, and
fishing laws on Fort Richardson, Alaska. The appendix lists the Eagle River Flats Impact
8-4 ANOTRM9300C'98W70002
-------
STATUTORY DETERMINATIONS
Area, including a 300-meter buffer zone, as closed to all hunting and fishing; and also
specifies that no fishing or watercraft are allowed in the Eagle River Flats Impact Area.
• AR 385-63 (Access Restrictions to Army Impact Areas and Ranges): Range safety,
trespassing precautions, and education programs for range impact areas are included in
Chapter 2"of this Army regulation. The regulation requires that SOPS be published for
the safe operation and use of ranges and that ranges, maneuver areas, and training
facilities be maintained and managed. In addition, range boundaries must be surveyed
and posted as off-limits to prevent trespass by unauthorized personnel. This regulation
also includes precautions that must be taken to prevent all unauthorized persons from
entering the surface danger zones of a range before firing, trespassing on target ranges
during firing, and entry into an impact area by unauthorized personnel until it has been
searched and any duds are destroyed. Access for training maneuvers may be permitted
upon completion of a visual surface clearance operation. Education requirements
included in the regulation specify that all personnel must be properly cautioned on the
dangers of UXO; military family members must be instructed that ranges are off-limits
and cautioned about the hazards; and the local news media will be used periodically to
warn nearby communities of the hazards in trespassing on range areas and handling
UXO.
AR 350-2: Chapter 5 of this AR addresses impact areas, which include a high hazard impact
area such as ERF. In the regulation, a high hazard impact area is defined as an impact area
that is permanently designated within the training complex and used to contain sensitive
HE ammunition and explosives and the resulting fragments, debris, and components. The
regulation also requires that all impact areas are marked with warning signs, barriers,
and/or guards. Passing any of these hazard warnings without Range Control permission is
forbidden. Entry into an impact area must be approved by Range Control. In addition, the
regulation requires that anyone observing personnel or vehicles in an impact area inform
Range Operations immediately. Range Control will investigate, and request military police
assistance, at the site.
8.3 Cost Effectiveness
The combination of remedial actions identified as the selected remedy for OU-C will reduce
or eliminate the risks to human health and the environment at an expected cost of $5.7
million. The remedy is cost-effective. It provides an overall protecttveness proportional to
its cost.
By tailoring the remedy so that pumping treatment is applied to ponds that are preferred by
waterfowl and where white phosphorus has been detected and/or craters observed, the
selected remedy cost-effectively provides an appropriate level of protection. Allowing
natural processes to recover intermittent ponds avoids costly and unnecessary remedial
action.
ANC/TRM93 000960470002 9-5
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STATUTORY DETERMINATIONS
8.4 Utilization of Permanent Solutions and Alternative
Treatment Technologies or Resource Recovery Technologies to
the Maximum Extent Practicable
The Army, State of Alaska, and EPA have determined that the selected remedy represents
the maximum extent to which permanent solutions and treatment technologies can be used
in a cost-effective manner at OU-C. Of those alternatives that protect human health and the
environment and comply with ARARs, the Army, State of Alaska, and EPA have
determined that the selected remedy provides the best balance of trade-offs in terms of
long-term effectiveness and permanence; reduction of toxicity, mobility, or volume through
treatment; short-term effectiveness; implementability; cost; and the statutory preference for
treatment as a principal element in considering state and community acceptance.
The selected remedy would use readily available technologies and would be feasible to
construct. The placement and use of pumping systems and later use of cap-and-fill material
would be focused on the areas of highest white phosphorus contamination in ERF
sediments. Pumping and potential cap-and-fill technologies provide a permanent solution
by eliminating the source of white phosphorus contamination or eliminating the exposure
pathway.
8.5 Preference for Treatment as a Main Element
The selected remedy for OU-C satisfies the statutory preference for treatment of sediment
by using pond pumping as the main method to permanently reduce the toxicity, mobility,
and volume of contaminated sediment. Pond pumping will dry the pond bottoms to
encourage sublimation and oxidation of white phosphorus particles from the sediment.
8-6 ANGTRM93.DOC/980470002
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SECTION 9
OB/OD Pad
9.1 Site History
OB/OD Pad was used for open burning and open detonation of explosives on Fort
Richardson from at least 1956, according to historical aerial photographs. Records and
literature that specifically address OB/OD Pad are limited, especially information about the
types and quantities of wastes burned and disposed. Most of the historical records were
destroyed; however, some documentation is available for 1983 and 1985. Much of the
recorded history of pad operations, acquired from file records and interviews with
Explosive Ordnance Disposal personnel, is summarized in the Operable Unit C RI/FS
Management Plan (1996) and the Operable Unit C OB/OD Pad Site Investigation Work Plan
(1996).
The quantity of material disposed of at the site since its initial use in the 1950s is not known.
From available Fort Richardson file information, the pad was used approximately five times
per year during the summer months. Charges were limited to 100 pounds or less, and were
frequently set off in sets of three to eight charges. Open detonation activities were typically
conducted 1 day per month, from late spring to early fall. OB/OD activities conducted in
the 1980s were limited to a 2-acre area in the western portion of the pad. Occasionally,
explosive materials from non-military sources were detonated on the pad. Many of the
materials destroyed at the pad were originally reactive, ignitable, and toxic. According to
Explosive Ordnance Disposal personnel, no liquids, such as paint thinner or antifreeze,
were disposed of at OB/OD Pad. Small quantities of diesel fuel, approximately 5 gallons or
less, were used to ignite smaller pieces of ordnance in the 1960s. No OB/OD activities have
been conducted at the pad since November 1988.
The only sampling program conducted at OB/OD Pad before the 1996 RI was the collection
of surface soil samples by USAEHA in 1992. The sampling was intended to screen for
potential surface soil contamination from OB/OD operations. Sampling was limited to
surface soils primarily because of the danger of encountering UXO in subsurface soils.
9.2 Site Characteristics
9.2.1 Physical Features, Hydrogeologic Conditions, and Transport Pathways
OB/OD Pad was engineered in glacial till composed of sandy gravel and gravelly sand. The
pad slopes toward the southwest, from the surrounding upland forest to the edge of ERF.
The surface soils consist of poorly sorted sandy gravels, with a mix of pebbles, cobbles, and
clayey soils. The gravel pad has been periodically graded in the past by the Army to
facilitate use and access. Most of the grading occurred in the southwest comer, where most
of the OB/OD activities were conducted in the past. The pad was graded as recently as 1994
during construction of a dredge spoils-retention basin. The pad supports a sparse vegetative
cover in the form of woody shrubs, with some grasses and broad-leaved herbaceous plants.
ANC/TRM93.00O98W70002 9-1
-------
A berm separates the pad from the forest on the northern border. The berm appears to
consist of local material bulldozed from the pad surface and is more heavily vegetated than
the pad. Beyond the berm lies a mixed forest of white spruce, alder, paper birch, and poplar.
A road, controlled by a gate one-quarter mile from the pad, enters at the southeast comer of
the pad and provides the primary vehicular access to the site.
On its southern side, OB/OD Pad contacts the wetlands of ERF. The contact appears to
consist of surface material pushed from the pad a short distance onto the wetlands. This
edge now forms a bluff rising approximately 10 feet from the marsh.
Disposal through burning was performed either on the ground surface or in an excavated
pit. Materials that were destroyed during OB/OD activities included fuses, HE projectiles,
smoke pots, mortar rounds, star clusters, flares, mines, rocket motors, shape charges,
detonation cord, dynamite, and some flammable solids. Existing records indicate that no
liquids were disposed of there. During the 1960s, smaller pieces of ordnance were ignited
on the ground surface by using diesel fuel. Occasionally pits were excavated and small-
arms ammunition was disposed of by covering with other material soaked in a small
volume of diesel fuel and igniting. The ordnance disposal by detonation would tend to
spread shrapnel and explosives over adjacent areas on the pad surface.
During well drilling for the 1996 RI, a layer of gravel, generally 6 to 13 feet thick, was
observed overlying poorly graded sand throughout the depth the wells were drilled. The
coarse-grained material suggests that precipitation infiltrates freely through the pad surface
to the groundwater table. Groundwater elevations range from 19 to 36 feet below the
ground surface. On the basis of groundwater measurements taken during the RI, the water
table appears to be generally flat with a slight gradient to the southwest. It is believed that
the groundwater movement patterns are strongly influenced by both the tides and Eagle
River.
9.2.2 Nature and Extent of Contamination
Surface soil sampling conducted by USAEHA in 1992 for a list of five explosive-related
analytes showed that contaminants were spread throughout the pad, with most
contamination found at depths less than 18 inches and predominantly on the western half
of the pad. An additional study conducted at the ERF in 1991 analyzed 128 sediment
samples collected along transects extending from the edge of OB/OD Pad into ERF.
Elevated concentrations (greater than 1 part per million) of 2,4-dinitrotoluene (2,4-DNT)
were recorded in over half the samples, indicating that some migration of OB/OD Pad
contaminants into ERF had occurred in the past. The concentrations of 2,4-DNT were not
considered acutely toxic.
The RI of the soil and groundwater at OB/OD Pad was completed in 1996. Nine monitoring
wells were installed and developed, and groundwater samples were collected. Surface and
subsurface soil and groundwater samples were analyzed for an extensive list of volatile and
semivolarile organic chemicals, including those included in the 1992 investigation, and
metals. During the 1996 RI, very few chemicals were detected in either the soil or the
groundwater All detected chemicals had concentrations considerably below their action
levels specified in the Operable Unit C RI/FS Management Plan (1996). Figures 9-1 and 9-2
show sampling locations and the metal and organic concentrations detected in soil samples
collected during the RI. Table 9-1 summarizes the regulatory levels for soil compared to the
9-2 ANC/TRM93.DOC/980470002
-------
Notm»:
1. No action levels were exceeded.
2. Acbon levels based on OperaUe Unit CRVFS Management
Wan. 1996:
Arsenic (As)
Barium (Ba) 4.000
Chromium (Cr) 400
Lead (Pb) 1.000
Mercury (Hg) 20
Zinc (Zn) 24.000
3. Samples collected in October 1996.
4. Concentrations are in micrograms per gram, a metric unit
commonly used for soil concentrations that is equivalent to
parts per m*on.
5. Depth indicates meters below ground surface (m bgs) that
soil sample was cotected. 1 meter (m) equals 3.28 teet
6. NO indicates not detected.
\* J^PS. I
fc»4 ^X Mm
*• jr ^ H
S - '
to
APPROXIMATE SCALE IN UETERS
Figure 9-1
Metal Concentrations in Soil
OU-C Record of Decision
-------
MotM:
1. No action levels were exceeded. With the exception of the
surface sample results presented, no organics were detected
in soil.
2. Action levels for detected compounds are based on Opetatte
Unit CRI/FS Management Plan, 1996. •—'indicates an action
level has not been established.
3. Samples cotected in October 1996.
4. Concentrations are in micrograms per gram (ng/g), a metric
unit commonry used lor soil concentrations that is equivalent
to parts per million.
5. Depth indicates meters below ground surface (m bgs) that
sample was collected. 1 meter (m) equals 3.28 feet
6. NO indicates not detected.
30
60
APPROXIMATE SCALE IN METERS
Figure 9-2
Organic Concentrations in Soil
OU-C Record of Decision
-------
OB/00 PAD
TABLE 9-1
Regulatory Levels for Detected Chemicals in Soil
Action Level* Maximum Concentration in Number of Boreholes with
Parameter (119/9) OB/OD Pad Samples (ng/g) Detected Constituents
2,4,6-TNT
2,4-DNT
2,6-DNT
2-Amino-4,6-DNT
4-Amino-2,6-DNT
Arsenic
Barium
Chromium
Lead
Mercury
Zinc
Di-n-butylphthalate
N-nitrosodiphenytamine
40
100
100
none
none
80
4,000
400
1,000
20
24,000b
8,000
100
0.36
40
1.20
0.47
0.45
10.2
127
58.4
10.8
0.28
86.4
14
3.7
1
2
1
2
2
7
7
7
7
2
7
1
1
a Source: Operable Unit C RI/FS Management Plan. 1996.
b For zinc chloride (as total zinc).
maximum concentrations for the detected chemicals in soil. Table 9-2 summarizes
maximum metals concentrations from OB/OD Pad soil samples and representative values
from reference areas in Alaska. The concentrations at OB/OD Pad are in the range of the
reference values.
Figures 9-3 and 9-4, respectively, summarize the detected inorganic and organic
concentrations for groundwater samples collected from the monitoring wells at OB/OD
Pad. Table 9-3 summarizes the maximum detected organic and inorganic concentrations
and compares them with reference values and cleanup action levels in the 1996
Management Plan. All groundwater concentrations were considerably below closure action
levels, with the possible exceptions of chromium and zinc, which were determined to be
naturally occurring compounds.
No organic compounds were detected in subsurface samples collected during the RI.
Surface contamination was very low, indicating contaminants have not sorbed to soil
particles. Very limited low-plasticity material was observed in the subsurface. It is likely
that the limited presence and low concentrations of contaminants on the surface are the
result of regular grading of OB/OD Pad.
ANC/TRM93.DOG980470002
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TABLE 9-2
Sediment/Soil Concentrations from OB/00 Pad and Reference Areas (pg/g)
Chemical
Arsenic
Barium
Chromium
Lead
Mercury
"Zinc
Maximum in
OB/OD
Investigation
10.2
127
58.4
10.8
0.28
86.4
Fort
Richardson and
Elmendorf
Mean
Background*
5.46-7.2
52.5-113.8
19.6-32
5.3-10
•-
36.7-52.1
Goose Bay
Sediments'1
15, 13
140, 110
42,21
12. 7.9
<0.1,<0.1
100, 86
Alaska Soils and
Surficlal Materials0
(geometric mean,
arithmetic mean)
6.7, 9.6
595, 678
50, 64
12, 14
»
70,79
Alaska Stream
and Lake
Sediments0
(arithmetic mean)
17.3
811
115
12
--
157
Chugach
Mountains0
(geometric
mean)
--
672
111
25
-
-
Average of Alaska
Means0
(geometric mean,
arithmetic mean)
6.7. 13
633, 744
80,89
18, 13
70, 118
Arithmetic Mean
of Eagle River
Bridge and
Cottonwood
Slough
Sediments0
7
190
56
15
0.097
133
aFrom Background Data Analysis Report. Fort Richardson, Alaska, Ecology and Environment, Inc., 1996.
bFrom Interagency Expanded Site Investigation: Evaluation of White Phosphorus Contamination and Potential Treatability at Eagle River Flats, Alaska,
C. Bouwkamp, CRREL, 1994.
cFrom Eagle River Flats Expanded Site Investigation, Environmental Science and Engineering, Inc., 1990.
ANC/TRM93.00C/98M70002
-------
i
|
i
Approximate Penmeter
ofOB/ODPad
No action levels were exceeded.
Action levels based on Operate Unit C FU/FS Management
Plan, 1996:
Arsenic (As) 50
Barium (Ba) 2.000
Chromium (Cr) 100
Lead (Pb) 15
Mercury (Hg) 20
Zinc (Zn) 10.500
Samples collected in November 1996.
Concentrations am in micrograms per liter, a metric unit
commonly used tor groundwater concentrations that is
equivalent to parts per million.
Metals samples were not cotected in MW-6O during this
sampling event They will be collected during February 1997.
NO indicates not detected.
One meter equals 3.28 (eel
\
•"- * »•
>•-* -
30
60
APPROXIMATE SCALE IN METERS
Figure 9-3
Metal Concentrations in Groundwater
OU-C Record of Decision
9-7
-------
Approximate Perimeter
: ofOBKJDPad
Groundwater
Monitoring Wen
Notes:
hexahydro-1.3-5-trinitro-1,3,5-trtazine
HMX = octahydro•1.3.5,7-tetranitro-1,3.5,7^etrazocine
2. No action levels were exceeded.
3. Action levels based on Operable Unit C RI/FS Management
Plan, 1996:
RDX = 100
HMX = 2.000
4. Semivolatile organic compounds; benzene, toluene,
ethytoenzene, and xytenes; and other explosive compounds
were not detected.
5. Samples collected in November 1996.
6. Concentrations are in micrograms per liter, a metric unit
commonly used for groundwater concentrations that is
equivalent to parts per million.
7. ND indicates not detected.
8. One meter equals 3.28 feet
Figure 9-4
Organic Concentrations in Groundwater
OU-C Record of Decision
9-8
-------
OBODPAD
TABLE W
Detected Chemicals in Groundwater
Concentration (ng/L)
Parameter
RDX
HMX
Arsenic
Barium
Chromium
Lead
Mercury
Zinc
Action
Level*
100
2,000
50
2,000
100
15
2
10,500'
Background6
-
-
1-9.9
0.50-510
1-46
0.23-11,200
0.10-0.64
1-1.300
Reference
Areac
none
none
5
42
5
1
2
6
MCLd
NA
NA
50
2,000
100
15e
2
5,0009
Maximum in
OB/OD Pad
Investigation
6.3
1.1
5.4
49.5
9.2
1
0.2
16.3
Number of
Wells with
Detects
4
1
3
6
6
1
1
6
NA = Not available
aSouree: Operable Unit C RI/FS Management Plan. Fort Richardson. Alaska 1996.
bFiltered metals, Fort Richardson background concentrations, from Background Data Analysis Report, Fort
Richardson, Alaska, 1996.
cEagle River Valley groundwater from Eagle River Flats Expanded Site Investigation, Fort Richardson,
Alaska. 1990.
dMCL = Maximum contaminant level (EPA).
"Action level
'For zinc chloride (as total zinc).
^Secondary MCL.
9.3 Summary of Site Risks
9.3.1 Human Health Risk Assessment
The human health risk assessment for OB/OD Pad used an onsite recreation scenario to
evaluate site risk. Although currently prohibited, people on rafts or other boats might gain
access to OB/OD Pad by going under the Route Bravo Bridge on Eagle River or coming
upstream from Kru'k Arm and hiking across ERF (Figure 4-1), Pad access is also possible by
a road, but there is a locked gate with warning signs. No trespassers have been observed at
OB/OD Pad, however.
For the recreational scenario in OB/OD Pad, an upper-bound risk assessment for exposure
to the surface soil was performed. As with this scenario at ERF, it was assumed that child
and adult intruders are on OB/OD Pad for a few hours on each of 10 days in the summer. A
child was assumed to weigh 36 kg, ingest 200 mg of soil per visit, and visit the pad 10 times
per year for 10 years. An adult was assumed to weigh 70 kg, ingest 100 mg of soil per visit,
and visit the pad 10 times per year for 20 years. These were considered to be conservative
values given that no trespassers had been observed at the pad.
ANC/TRM93.DOO98CX70002
-------
OB0DPAO
Exposure to soil was calculated according to the following equation:
E = C*IR*EF*ED/(1,000,000»BW*AT)
where:
E = exposure (mg/kg-bw/day)
C = soil concentration (ug/g)
IR = soil ingestion rate (mg/day)
EF = exposure frequency (days/year)
ED = exposure duration (years)
BW = body weight (kg)
AT = days averaging time (365*ED for noncancer effects and 25,550 for cancer
effects)
Hazard indexes and cancer risks were calculated for the detected chemicals at each
sampling location. The noncancer risks were evaluated as a hazard quotient, which is
calculated as follows:
HQ = E/RfD
where:
HQ = hazard quotient
E = exposure (mg/kg-bw/day)
RfD = reference dose (mg/kg-bw/day)
The cancer risk was calculated from:
R = E*SF
where:
R = cancer risk (excess lifetime cancer risk)
E = exposure (mg/kg-bw/day)
SF = oral slope factor (kg-day/mg)
By using the recreational scenario assumptions described above, the calculated cancer risks
were about 10'7 for the child and adult, and the largest calculated hazard indexes were 0.01
and 0.003 for the child and adult, respectively.
The concentrations of arsenic and chromium are similar to those at nearby reference areas.
If these chemicals are excluded from the risk calculations, the cancer risks and hazard
indexes decrease because these metals are significant contributors. The EPA has used a
cancer risk level of 1 x lO'6 and a hazard index of 1 as levels of concern. Calculated risks for
the recreational scenario are substantially less than these levels of concern.
Table 9-4 summarizes the toxicological characteristics from the EPA 1996 Integrated Risk
Information System (IRIS) database for the detected chemicals. Because IRIS does not have
information on two of the detected chemicals, 2-amino-4,6-DNT and 4-amino-2,6-DNT, they
are not included in the table.
Excess lifetime cancer risk is the incremental increase in the risk of getting cancer over and
above the rate one would have if not exposed to the conditions of the defined recreational
9-10 ANC/TRM93.DOC98W70002
-------
TABLE 9-4
lexicological Parameters
Chemical
Arsenic
Barium
Chromium III
Chromium VI
Lead
Mercury
Zinc
2,4,6-TNT
2.4-DNT
2.6-DNT
Di-n-buytlphthalate
N-nitrosodiphenylamine
Oral
Reference Dose
(mg/kg/dny)
0.0003
0.07
1
0.005
0.3
0.0005
0.002
0.001
0.1
Uncertainty
Factor
3
3
100
500
3
1.000
100
3.000
1.000
Noncancer
Modifying
Factor
1
1
10
1
1
1
1
1
Effects
Confidence
in Study
medium
medium
low
low
medium
medium
high
low
Confidence
In Database
medium
medium
low
low
medium
medium
high
low
Confidence
In Value
medium
medium
low
low
medium
medium
high
low
Cancer
Weight of
Evidence
A
A
82
0
D
C
B2
Effects
Oral Slppe
Factor
(kg-day/mg)
1.5
0.03
0.0049
Modifying factor—An uncertainty factor which is greater than zero and less than or equal to 10; the magnitude ol the MF depends upon the professional
assessment of scientific uncertainties of the study and database not explicitly treated with the standard uncertainty factors (e.g., the completeness of the
overall data base and the number of species tested); the default value for the MF is 1.
Uncertainty factor—One of several, generally 10-fold factors, used in operationally deriving the reference dose (RfD) from experimental data. UFs are
intended to account for (1) the variation in sensitivity among the members of the human population; (2) the uncertainty in extrapolating animal data to the
case of humans; (3) the uncertainty in extrapolating from data obtained in a study that is of less-than-lifetime exposure; and (4) the uncertainty in using
lowest-observed adverse effect data rather than no-observed adverse effect data.
Weight-of-evidence for carcinogenicity—The extent to which the available biomedical data support the hypothesis that a substance causes cancer in
humans. A: Human carcinogen. B1: Probable human carcinogen, indicating that limited human data are available. B2: Probable human carcinogen,
sufficient evidence in animals, and inadequate or no evidence in humans. C: Possible human carcinogen. D: Not classifiable as to human carcinogenicity.
E: Evidence of noncarcinogenicity for humans.
ANC/TRM93.DOO980470002
-------
O&OOPAD
exposure scenarios. The individual chemical cancer risks were summed across chemicals to
estimate the risk associated with a simultaneous exposure to multiple chemicals.
Table 9-5 summarizes the calculated risks. The calculated cancer risks are about 10"7 for the
child and adult at all sampling locations, with the major contribution from the arsenic
concentrations. However, concentrations of arsenic in OB/OD Pad are similar to other
surrounding non-contaminated areas. If arsenic is excluded from the cancer risk estimate,
the calculated cancer risks decrease by about an order of magnitude.
TABLE 9-5
Summary of Risks in the Onsite Recreational Scenario
Hazard Index Cancer Risk
Location Adult Child Adult Child
MW-1
MW-2
MW-3
MW-4
MW-5
MW-6
MW-7
0.0030
0.0008
0.003
0.0002
0.0003
0.0002
0.0004
0.001
0.003
0.01
0.008
0.001
0.0008
0.001
1 X 10'7
1 x 10'7
1 x 10-7
1 x 10'7
8 x 10'8
9x10-8
1 x 10'7
2 x 10'7
2 x 10'7
2 x 10'7
2 x 10'7
2 x 10'7
2 x 10'7
2 x 10'7
The onsite recreational scenario is a potential future scenario, because there is no
evidence that it is occurring today. It involves assumptions of representative
concentrations, soil ingestion rates, and frequency and duration of visits.
The hazard indexes range from 0.0008 to 0.01 for the child and 0.0002 to 0.003 for the adult,
with the major contribution from chromium concentrations (with the assumption of
chromium VI) at all locations. At Well MW-2, 2,4-DNT is also a significant contributor. At
Well MW-3, 2,4,6-TNT is a significant contributor. The chromium concentrations measured
at OB/OD Pad are similar to reference values in surrounding non-contaminated areas. If
chromium is excluded from the assessment, all hazard indexes decrease by different
amounts, depending on the relative contribution of chromium to the hazard index.
In considering the value of the cancer risk, the EPA has used a cancer risk level of 1 x 10'6 or
less as acceptable for hazardous waste sites. Under the recreational scenario at all sampling
locations, the cancer risks in Table 9-5 are about 10'7, which is less than the cancer risk
criterion, and the noncancer hazard indexes also are considerably under their criterion of
one.
Uncertainties are present in this assessment, including future human activities in the area,
probability and magnitude of UXO detonation, environmental concentrations, appropriate
exposure factors for the scenarios, and toxiciry factors. Because the calculated hazard
quotients are so small, it is unlikely that other reasonable combinations of exposure factors
could result in a hazard quotient greater than 1 for the scenarios. It is likely that the greatest
risk in the recreational scenarios come from potential explosions from UXO.
9-12 ANC/TRM93.DCO980470002
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OB0DPAD
9.3.2 Ecological Risk Assessment
A number of inorganic and organic contaminants were detected in surface soils and
groundwater at OB/OD Pad during the 1996 RI. The surface soil and groundwater
contaminants were observed at relatively low levels in samples collected from the soil
borings and installed monitoring wells on OB/OD Pad. All detected inorganic and organic
contaminants were considerably below regulatory levels included in the 1996 Management
Plan. Groundwater contaminants would be diluted even further as groundwater discharged
into and mixed with surface waters of ERF. Therefore, none of the detected contaminants in
groundwater was retained as a COPEC for OB/OD Pad.
Inorganic and organic surface soil contaminants were screened to determine whether any of
these chemicals should be considered as a COPEC for OB/OD Pad. The maximum detected
inorganic concentrations from recent soil samples were similar to or below corresponding
background levels. Therefore, none of the inorganic chemicals was retained as a COPEC.
Additional risk to ecological receptors at OB/OD Pad was assessed by comparing
maximum concentrations of detected organic chemicals to available data or derived critical
toxicity values (CTVs). Organic chemicals were compared to soil CTVs derived for a small
mammal, the deer mouse, considered to be representative of small rodents at OB/OD Pad
(Table 9-6). None of the organic soil contaminants detected at the pad was retained as a
COPEC.
Larger mammals were not expected to derive a significant proportion of their diet on the
limited pad area. Risk to plants was estimated, but toxiciry to plants and significant uptake
and bioaccumulation of the detected explosive residues or semivolatile organic compounds
was not expected to occur. Overall use of OB/OD Pad by ducks, as indicated by telemetry
and lack of preferred feeding habitat, was very low (about 1 percent of all observations).
Therefore, waterfowl were not evaluated as potential ecological receptors. Risk to terrestrial
invertebrates was not evaluated because of the lack of applicable CTVs. None of the
detected contaminants in the OB/OD Pad surface soil and groundwater samples were
retained as a COPEC. Therefore, OB/OD Pad was not considered to be an area of potential
ecological concern.
On the basis of results of the 1996 site investigation at OB/OD Pad and an evaluation of
data collected during previous studies at this site, no further action is selected for OB/OD
Pad for hazardous chemicals. Because of concerns regarding potential human exposure to
UXO, existing institutional controls to monitor and control access to OU-C apply to OB/OD
Pad.
9.4 OB/OD Pad Closure
This ROD selects the final remedial action for OU-C, as well as the EPA decision under
RCRA regarding hazardous waste closure of the OB/OD Pad at this time. (The OB/OD Pad
is being treated administratively as part of OU-C as agreed by the EPA, ADEC, and Army
in the 1994 FFA.)
The EPA, ADEC, and Army are issuing this ROD as part of their public participation
responsibilities under Section 117(a) of CERCLA. The EPA also is issuing this ROD
pursuant to public notice and other requirements for closure of the OB/OD Pad, which is a
ANC/TRM93.DOO98W700Q2 9-13
-------
08/00 PAD
TABLE 9-6
Critical Toxicity Values for Organic Soil Contamination at OB/OD Pad3
Organic
2,4,6-TNT
2.4-DNT
2.6-DNT
2-amino-4,6-DNT
4-amino-2,6-DNT
Oi-n-butylpthalated
N-nitrosodiphenylamine
Maximum Reported
OB/OD Pad Value
(M9/9)
0.36
39
3.9U
0.47
0.45
14
4.2
Deer Mouse6
Soil CTV
2
10
199
103
103
3.718
251
COPECC
No
Noe
No
No
No
No
No
Notes:
^g = micrograms per gram. This metric unit of measurement is commonly used for soil
concentrations. It is equivalent to parts per million.
TNT = Trinitrotoluene
U = Flagged by laboratory as estimated value.
a CTV derived as described in Toxicological Benchmarks for Wildlife, Electronic Database VI.5, U.S.
Department of Energy, 1996, and Wildlife Exposure Factors Handbook. EPA, 1993.
b Deer mouse considered to represent small mammal receptors at site.
c Chemical of potential ecological concern
d Toxicological Benchmarks for Screening Potential Contaminants of Concern for Effects on Terrestrial
Plants (Suter et al., Oak Ridge National Laboratory. 1993) estimates a no observed effect
concentration for plants at 200 ng/g that represents a soil CTV for plants.
6 CTV is a conservative extrapolation that assumes plant concentration in mouse diet is equal to soil
concentration. The deer mouse soil CTV is derived from data from dog toxicity studies that increases
uncertainty in the value.
hazardous waste regulated unit under the authority of Sections 3004(a) and 3005(e) of
RCRA, as amended, and its implementing regulations codified in 40 CFR 264 and 265.
The EPA, ADEC, and Army recognize the similarities between RCRA corrective action and
CERCLA remedial action processes and their common objective of protecting human health
and the environment from potential releases of hazardous substances, wastes, or
constituents. Actions taken to remediate OU-C will comply with the provisions of both
CERCLA and RCRA.
The EPA, ADEC, and Army are electing to combine response actions under RCRA and
CERCLA remedial action primarily because the OB/OD Pad is administratively subject to
RCRA closure authority; however, the OB/OD Pad also is in the same physical location as
the rest of OU-C, which is subject to CERCLA authority. Thus, regardless of regulatory
authority, it is only natural that the investigation and, if necessary, any remedial physical
response be applied to these adjacent OU-C areas. In addition, there were similar, but not
identical, historical actions that took place at the OB/OD Pad (destruction of explosives) in
comparison to the rest of OU-C (use as a firing range with residuals of explosives
remaining). By applying CERCLA authority concurrently with RCRA closure and corrective
9-14 ANC/TRM93.DOC/980470002
-------
oe/QOPAo
action requirements through this integrated plan, the EPA, ADEC, and Army intend to
minimize response costs as much as possible while remaining fully protective.
This ROD forOU-C fulfills the RCRA corrective action and the CERCLA remedial action
processes for describing and analyzing closure and remedial alternatives. (The 1996 RI was
functionally equivalent to a RCRA facility investigation.) To fulfill the requirements for the
RCRA closure process, the Army will submit a closure plan in accordance with procedures
described in Section 9.4.1
9.4.1 Closure Process
The OB/OD Pad was identified in the 1991 Federal Facility Compliance Agreement (FFCA),
signed by the Army and EPA, as a RCRA-regulated, land-based unit. As such, the OB/OD
Pad is subject to the interim status standards codified in 40 CFR 265. Under the 1991 FFCA,
the Army was required to submit a closure plan for this unit that had to comply with the
requirements for closure codified in 40 CFR 265, Subparts G and P. In addition, pursuant to
the terms of the 1994 CERCLA FFA, the Army, ADEC, and EPA agreed that where feasible,
any RCRA corrective actions required at solid waste management units at Fort Richardson
would be integrated with any ongoing CERCLA response actions so that duplication of
effort would not occur and the Army could realize cost savings as a result. However, the
1994 FFA also specified that such integration efforts would not obviate the need for the
Army to meet its RCRA closure obligations under the 1991 FFCA.
Although the OB/OD Pad is not currently active, EPA believes that it is prudent to allow
final RCRA closure of the OB/OD Pad concurrently with final clearance of the operating
range. Because the OB/OD Pad is physically part of the operating range, RCRA closure at
this time would be technically complex, with little, if any, demonstrable environmental
benefit. In addition, as part of the RCRA/CERCLA integration effort under the 1994 FFA,
the Army has completed some investigatory work and sampling efforts at and near the
OB/OD Pad. The result of these activities indicate levels of organic and metal contaminants
below any health-based action levels and RCRA "clean closure" requirements. For these
reasons, the EPA is approving a delay of closure of the OB/OD Pad in accordance with 40
CFR 265.113(b)(l)(i). Delay of closure under this provision is subject the requirements of 40
CFR 265.113(b), which states, among other things, that final closure, by necessity, will take
longer than 180 days to complete.
Additionally, the facility must take, and continue to take, all steps to prevent threats to
human health and the environment from the unclosed, but not operating, hazardous waste
management unit or facility, including compliance with applicable interim status
requirements, 40 CFR 265.113(b)(2). The Army has indicated, and the EPA agrees through
the signing of this ROD, that the OB/OD Pad meets the requirement for extension of time
for closure specified in 40 CFR 265.113(b)(l)(i), provided that an interim closure plan
acceptable to EPA is completed by the Army as specified below.
According to the requirement specified in the 1991 FFCA and in 40 CFR 265.112(a) for
compliance with RCRA interim status standards, the Army will submit, within 150 days
from the date the ROD for OU-C becomes final, a draft interim closure plan for the OB/OD
Pad that meets the requirements specified in 40 CFR 265, Subparts G and P. The draft
interim closure plan will be developed and completed in accordance with the procedures
for submittal and review of primary documents specified in Paragraphs 20.12 through 21.13
ANOTHM93 DOC/980470002 9-1S
-------
OB/00 PAD
of the 1994 FFA. Final closure will occur under the authority of the 1991 FFCA, RCRA, and
its implementing regulations.
No less often than during the CERCLA 5-year reviews, the Army will evaluate whether
acceptable delay 6f closure by the EPA becomes no longer viable for one of the following
reasons:
• The ERF is no longer operating.
• The post is being closed.
• Any other reason.
The findings of this evaluation will be submitted to EPA for review and approval. If either
the EPA or the Army believe that delay of closure is no longer viable, the OB/OD Pad will
be closed under the substantive and procedural RCRA closure requirements in effect at that
time, and at that time, the Army will revise and resubmit the interim closure plan for the
OB/OD Pad to the EPA for review and approval. Upon approval of the final closure plan,
the Army will close the OB/OD Pad in accordance with the terms and conditions of that
final closure plan.
In addition, the Army may elect to close the site under 40 CFR 265, Subparts G and P, at any
earlier time. This closure will also require compliance with all substantive and
administrative closure requirements, including EPA approval.
9-16 ANC/TRM93 DOC^SW 70002
-------
SECTION 10
Documentation of Significant Changes
The selected remedy for the ERF portion of OU-C is the same as the preferred alternative
described in the Proposed Plan.
In the Proposed Plan, the OB/OD Pad was not identified as a RCRA unit subject to closure.
Subsequent review of the Administrative Record indicated that it is necessary to close the
OB/OD Pad in accordance with the administrative and substantive requirements in 40 CFR
265, Subparts G and P, and the 1991 FFCA. Section 9.4 of this ROD outlines the procedures
that the Army will follow to close the OB/OD Pad.
ANC/TRM93.DOC/980470002 '0-1
-------
Appendix A
Fort Richardson Administrative
Record Index Update
ANC/TRM93,D00980470002
-------
Administrative Record Index
Fort Richardson, Alaska
September 1998
-------
Fort Richardson, Alaska Administrative Record Index Update for 1998
Page Numbers OU Cat No Date Title Abstract Author
06888 06897 C
OU-C Book 2
1.1 2/15/88 Memorandum of Understanding
Coniained within (he EA for the resumption of tiring in None Given
(he Eagle River Flats Impact Area; provides for
formalization of the Eagle River Flats Task Force
among the key agencies.
Recipient
None Given
06163 06163 C 1.1 3/10/92 Eagle River Flats Task Force
OU-C Book I Administrator Heads
Eagle River Flats Task Force administrative heads. None Given
None Given
06162 06162 C
OU-C Book I
3/10/92 Eagle River Flats Task Force
Agencies
Eagle River Flats Task Force agencies.
None Given
None Given
06164 06167 C
OU-C Book I
1.1 3/10/92 Eagle River Flats Task Force
Participants
Eagle River Flats Task Force participants.
None Given
None Given
06168 06175 C
OU-C Book I
06176 06179 C
OU-C Book I
1.1 7/31/92 Memorandum of Agreement Establishes the respective responsibilities of the parlies None Given
Between the Army Toxic and f°r delivering technical assistance, procurement,
Hazardous Materials Agency and the conlracl management, and related services.
6th Infantry Division (Light) and
Army Garrison, Alaska
4/26/93 Draft Memorandum of Establishes roles of CKREL in environmental studies
Understanding Between CRREL and conducted at Eagle River Flats.
Fort Richardson, Alaska
None Given
None Given
None Given
/ tif 67
-------
Fort Richardson, Alaska Administrative Record Index Update for 1998
Abstract
Author
Page Numbers OU Cat No Date Title
0618006191 C 1.1 8/15/93 Distribution of White phosphorus Determination ol'the spatial distribution and persistence CRREL
Recipient
USAED Alaska
OU-C Book I
Residues from the Detonation of 81 - of white phosphorus residues following detonation of
mm Mortar WP Smoke Rounds at an 8' mm mortar rounds
Upland Site
06192 06192 C 1.1 6/30/94 Eagle River Flats: An Army Describes the evems leading 10 the decision to evaluate William Gosswciler None Given
OU-C Book I Environmental Rescue Operation human health and ecological risks from exposure to DPW
white phosphorus at Eagle River Flats.
06193 06273 C
OU-C Book I
1.2.2 8/15/89 Eagle River Flats Waterfowl
Mortality Investigation, Progress
Report
Progress report lor the 1989 Eagle River Flats Randy Twclen
waterfowl mortality investigation. ESE
None Given
06274 06300 C
OU-C Book I
1.2.3 3/15/88 Eagle River Flats General Study Plan Development ol ihe study approach to be followed by None Given
the Eagle River Flats Task Force.
None Given
06301 06406 C
OU-C Book I
1.2.3 7/14/89 Eagle River Flats Expanded Site Presents the sampling and analysis plan, schedule, and
Investigation, Fort Richardson, heallh and safc|X P'an lor the 1989 Eagle River Flats
Alaska. Final Sampling Design Plan waterfowl mortality study.
ATHAMA
06407 06426 C
OU-C Book I
1.2.4 2/7/86 Water Quality Biological Study No. Surface water inve.siigaiion ol potential contaminants AEHA
32-24-1371 -86, Waterfowl Die-Off responsible lor waterfowl die-oils
Investigation, Eagle River Flats, Fort
Richardson, Alaska
USAED Alaska
2,./ 67
-------
Fort Richardson, Alaska Administrative Record Index Update for 1998
Page Numbers OU Cat No Date Title Abstract Author
06427 06441 C 1.2.4 7/15/86 Cooperative Agreement for Agreement lor ADFG, USFWS. and the Army to work None Given
OU-C Book I Management of Fish and Wildlife together to manage the Army lands.
Resources on Army Lands in Alaska
Recipient
None Given
06442 06450 C 1.2.4 2/13/87 Eagle River Flats Waterfowl Die-Off Summary of work done lo date on the Eagle River Flats USFWS
OU-C Book I bird kill problem.
None Given
06451 06458 C
OU-C Book I
1.2.4 2/4/88 Investigation of Waterfowl Mortality, Review of 1983 through 1985 study results and
Eagle River Flats, Alaska, Draft proposed field and laboratory research.
USFWS
None Given
06459 06886 C
OU-C Book 2
1.2.4 6/15/90 Eagle River Flats, Expanded Site
Investigation, Fon Richardson,
Alaska, Final Technical Report
Presenis the results of the 1989 investigation of the ESE
causes of waterfowl mortality at Eagle River Flats.
ATHAMA
06899 06900 C
OU-C Book 2
1.2.4 11/12/91 Finding of No Significant Impact for Contained within the EA for the resumption of tiring in William Bolt
Resumption of Firing into the Eagle tne Ea8'e River Flats Impact Area; describes the FONSI Army
River Flats for the resumption of firing into Eagle River Flats.
None Given
06887 07068 C
OU-C Books 2 & 3
1.2.4 12/15/91 Environmental Documents: Public A report containing the following documents: A NoneGiven
Notice, Finding of No Significant memorandum of understanding; a notice of availability
Impaci, and Environmental ^ Pub''c comment period; the FONSI for resumption
Assessment for Resumption of Firing ol firin8in EaSle River Flats; and lhe EA fbr the
in the Eagle River Flats Impact Area rcsumP''™ ol'lrine in
-------
Fort Richardson, Alaska Administrative Record Index Update for 1998
Page Numbers OU Cat No Date Title
Abstract
06901 07068 C 1.2.4 12/31/91 Environmental Assessment for EA to address ihe resumption ol live-fire artillery
OU-C Book 3 Resumption of Firing into the Eagle training in Eagle River Flats.
River Flats Impact Area, Fort
Richardson, Alaska
Author
William Quirk
DPW
Recipient
None Given
07069 07073 C 1.2.5 6/2/89 Comments, Eagle River Flats Comments on the 1989 Eagle River Flats waterfowl Edwin Ruff
OU-C Book 3 Expanded Site Investigation-Draft mortality study draft sampling plan. DEH
Sampling Plan
Douglas Reagan
ESE
0707407076 C 1.2.5 6/6/89 Comments, Eagle River Flats Comments on the 1989 Eagle River Flats waterfowl
OU-C Book 3 Expanded Site Investigation-Draft mortality study draft sampling plan.
Sampling Plan
USFWS
ESE
07077 07079 C
OU-C Book 3
1.2.5 6/7/89 Comments, liagle River Flats
Expanded Site Investigation-Draft
Sampling Plan
Comments on ihe 1989 Eagle River Flats waicrt'owl Dan Rosenberg
mortality study draft sampling plan. ADFG
Douglas Reagan
BSE
07080 07082 C
OU-C Book 3
1.2.5 6/9/89 Comments, Eagle River Flats
Expanded Site Investigation-Draft
Sampling Plan
Comments on the 1989 Eagle River Flats waterfowl Rob Lipkin
mortality study draft sampling plan. EPA
Wayne Rush
Anny
07083 07095 C 1.3.3
OU-C Book 3
4/15/93 EPA Closure Plan Comments,
Demolition Area #1 (OB/OD Area)
at Fort Richardson, Alaska
EPA review comments on (he second draft of
Closure/Post--Closure Plan for Demolition Area tt\
(OB/OD Area).
EPA
None Given
67
-------
Fort Richardson, Alaska Administrative Record Index Update for 1998
Page Numbers OU Cat No Date Title
Abstract
Author
07096 07115 C 1.3.3 4/15/93 Secondary Hazards ol White
OU-c Book 3 phosphorus to Bald Eagles, Draft
Study Protocol
A study plan to determine the secondary hazards posed John Cummings
by white phosphorus-exposed ducks that are scavenged UWKC
by bald eagles.
Recipient
USAED Alaska
07116 07122
OU-C Book 3
1.3.3 4/29/93
Comments. DERP OEW Ft.
Richardson OB/OD Closure Plan
Draft #4-145
Comments from several USAED Alaska reviewers on Wilson Walters
the second draft of Closure/Post-Closure Plan for USAED Alaska
Demolition Area #1 (OB/OD Area).
None Given
07123 07201 C 1.3.3 12/15/93 Demolition Area Number One
OU-c Book 3 Closure Guidelines, Fort Richardson,
Alaska
Report discussing guidelines for closure of Demolition
Area #1 ai Eagle River Flats in compliance with (he
Federal Facility Agreement and RCRA regulations.
EMCON
Army
07202 07217 C
OU-C Book 3
1.3.3 12/20/93 Response to EPA and COE
Comments, Demolition Area Number
One Closure Guidelines, Fort
Richardson, Alaska
Provides responses to EPA and USAED Alaska
comments on the second draft of Closure/Post-Closure
Plan for Demolition Area #1 (OB/OD Area).
EMCON
Army
07218 07230 C
OU-C Book 3
1.3.4 1/22/93 Hazardous Waste Management
Consultation No. 37-66-JR11-92,
Soil Sampling Results, Fort
Richardson, Alaska
Discusses results from soil samples collected from the
explosive ordnance disposal burning grounds adjacent
to Eagle River Flats in order to identify any potential
soil surface contamination from explosives and
propellants destruction operations.
USAEHA
USAED Alaska
07056 07056 C
OU-C Book 3
1.3.5 12/20/91 Review Comments on the
Environmental Assessment for Eagle
River Flats
Contained as an appendix to the EA for the resumption
of firing in the Eagle River Flats Impact Area;
comments on the EA for Eagle River Flats.
Marilyn Twitched
Sierra Club Legal Defense
Fund
Chuck Canterbury
FAO
5 »/ 67
-------
Fort Richardson, Alaska Administrative Record Index Update for 1998
Page Numbers OU Cat No Date Title Abstract
07057 07060 C
OU-C Book 3
07055 07055 C
OU-C Book 3
23922 23929 C
OU-C Book 16
'97 Update
23930 23932 C
OU-C Book 16
'97 Update
29057 29160 C
OU-C Book 20
•98 Update
23933 24323 C
OU CBook 16
'97 Update
1 .3.5 1 2/20/9 1 Review Comments on the
Environmental Assessment for Eagle
River Flats
1.3.5 12/20/91 Review Comments on the
Environmental Assessment for Eagle
River Flats
1 .4. 1 3/7/96 Proposed Approach to the Site
Investigation at the OB/OD Pad
1 .4. 1 6/27/96 OU-C, Eagle River Flats, EPA
Comments on OB/OD Pad Site
Investigation Work Plan
1 .4. 1 7/1 5/97 Interagency Expanded Site
Investigation, Evaluation of White
phosphorus Contamination and
Potential Treatability at Eagle River
Flats, Alaska
1.4.2 2/6/96 Inleragency Expanded Site
Investigation, FY 95 Final Report
Contained as an appendix to the EA for the resumption
of firing in the Eagle River Flats Impact Area;
comments on the EA lor Eagle River Flats.
Contained as an appendix to the EA for the resumption
of firing in the Eagle River Flats Impact Area;
comments on the EA for Eagle River Flats.
This memorandum outlines the estimated minimal level
of effort required to delineate the site characteristics
identified in the draft-final management plan.
Review comments
•
A summary of work conducted at Eagle River Flats
during 1996. Includes three R A reports, four
treatability studies, and a discussion of the Eagle River
Flats spatial database.
The sixth annual report describing results of white
phosphorus contamination studies at Eagle River Flats.
Author Recipient
Dave Cline Chuck Canterbury
National Audubon Society PAO
Ruth Wood Chuck Canterbury
Alaska Center I'orihe PAO
Environment
Jacques Gusmano Bill Gossweiler
CH2M Hill OPW
Howard Orlcan Bill Gossweiler
tPA
CRREL William Gossweiler
USAED Alaska
CRREL DPW
r>7
-------
Fort Richardson, Alaska Administrative Record Index Update for 1998
Page Numbers OU Cat No Date Title Abstract __
24324 24328 C
ou-C Book 17
•97 Update
6/27/96 OU-C, Eagle River Flais EPA Review comments.
comments on Interagency Expanded
Site Investigation
Author
Howard Orlcan
EPA
Recipient
Bill Gossweiler
DPW
07231 07238 C 1.7 6/28/49 phosphorus Poisoning in Waterfowl Results of an investigation on the effects of poisoning Don Coburn ct.al. APA
OU-C Book 3 from white phosphorus. USFWS
07239 07264 C .
OU-C Book 3
1.7 3/3/93 Laboratory Evaluation of a Methyl
Anthranilate Bead Formulation on
• Mallard Feeding Behavior, Draft
Study Protocol
Assesses the effectiveness of a methyl amhranilate bead John Cummings
formulation lor reducing feeding by mallards. DWRC
None Given
07265 07268 C
OU-C Book 3
1.7 12/8/93 White phosphorus Contamination of
Wetlands: Effects and Options for
Restoration
Presents the biogcothemical cycling of, waterfowl Susan Richardson
exposure to. and possible remediation options for white
phosphorus contamination in wetlands.
None Given
07269 07274 C
OU-C Book 3
1.7 3/11/94 Predalion of Ducks Poisoned by
White phosphorus: Exposure and
Risk to Predators
Evaluation ol P4 uptake at Eagle River Plats by species Bill Roebuck None Given
that prey on poisoned ducks. Dartmouth Medical School
07399 07400 C
OU-C Book 3
2.1.2 6/17/93 On-Going and Planned 1993 Summary results lor identification of biomarkers and Donald Sparling
Activities for Investigations on White histopathological effects in birds, white phosphorus in UWRC
phosphorus at Eagle River Flats lood chains-and Physiological effects in waterfowl.
None Given
67
-------
Fort Richardson, Alaska Administrative Record Index Update for 1998
Page Numbers OU Cat No Date Title
Abstract
Author
Recipient
29161 29166 C 2.3 3/18/97 Decision Document for a Removal
OU-C Book 20 Action at Eagle River Flats Racine
•98 Update Island Pond
Describes a time-criiical removal aciion to be conducted William Gosswciler Kenneth Simpson
at Racine Pond within Eagle River Flats. The proposed DPW CO
aciion is to drain Racine Island pond to remove white
phosphorus contamination. ' ,
29167 29167 C 2.5 3/12/97 Comments, Eagle River Flats Draft Comments on the dral't decision document for Eagle Gene Kubccka
OU-C Book 20 Decision Document River Flats. DCSENG
'98 Update
Cristal Fosbrook
DPW
07275 07277 C
OU-C Book 3
3.1.1 4/12/90 Preliminary Brief of Proposed FY90 Summary of objectives and initial strategies for FY Edwin Ruff
Eagle River Flats Study '"0 Eag'e River Flats study as developed by DEH
ATHAMA and the Eagle River Flats Task Force during
the April 10, 1990, meeting.
Army
07278 07285 C
OU-C Book 3
3.1.1 3/3/93 Baseline Risk Assessment and FS for SOW to conduct a baseline RA and FS lor the 2,500-
Eagle River Flats, Fort Richardson, acre Eagle River Flats Impact Area.
Anchorage, Alaska
None Given
None Given
07286 07302 C 3.1.1
OU-C Book 3
3/3/93 Mission Statement for the 6lh Goals tor the Eagle River Flats investigation, None Given
Infantry Division/Eagle River Flats responsibilities ot each task force member, and plans to
Task Force achieve desired goals.
None Given
07303 07335 C
OU-C Book 3
3.1.1 4/15/93 Eagle River Flats Task Force Briefing Goals and responsibilities lor the I-agle River Flats
Task Force.
EPA
None Given
tinl 07
-------
Fort Richardson, Alaska Administrative Record Index Update for 1998
Page Numbers OU Cat No Date Title
Abstract
07336 07370 C
OU-C Book 4
07371 07388 C
OU-C Book 4
07389 07398 C
OU-C Book 4
3.1.1 4/14/94 Continued Evaluation of White
phosphorus Effects on the Aquatic
Ecosystem, Eagle River Flats, Forl
Richardson, Alaska, Revised Scope
of Work
Revised SOW fur continued evaluation of white
phosphorus effects on (he aquatic ecosystem, Eagle
River Flats.
Author
David Smart
AEHA
Recipient
Charles Rucinc
CRREL
William Gossweiler
DPW
3.1.1 3/16/95 Scope of Work for Pilot Study of Plans to confirm the feasibility ol operating a small Michael Walsh
Dredging to Remove White dredge in an area of Eagle River Flats wiih unexploded CRREL
phosphorus Contaminated Sediments ordnance:
from a Limited Area in Eagle River
Flats, Alaska
3.1.2 11/20/90 Summary of 1990 Eagle River Flats . Overview of 1990 work completed for the Eagle River William Gossweiler None Given
Waterfowl Mortality Work Flats waterfowl mortality study. DPW
07405 07422 C 3.1.2 10/N/93 Progress Report lor Fourth Quarter, Review of progress 10 dale on CRREL studies at Eagle Charles Racine Army
OU-C Book 4 1993 River Flats CRREL
07401 07404 C
OU-C Book 4
3.1.2 10/14/93 Protecting Waterfowl from Ingesting Presents progress regarding waterfowl management John Cummings
White phosphorus, Progress Report techniques, responses of waterfowl to Concover and DWRC
Bara-kade (brand names), and waterfowl distribution
and movements in Eagle River Flats.
William Gossweiler
DPW
07423 07467 C
OU-C Book 4
3.1.2 12/6/93 Eagle River Flats, Project Review
Meeting, December 6-9, 1993
Summary report ol previous invesiigations conducted al None Given
Eagle River Flats.
None Given
V,,/ 67
-------
Fort Richardson, Alaska Administrative Record Index Update for 1998
Page Numbers OU Cat No Date Title Abstract Author Recipient
07468 07471 C 3.1.2 6/15/94 Waterfowl Mortality at Eagle River Includes a comparison oil 994 mortality rates of ducks NEILE NoneGiven
OU-C Book 4 Flats, Progress Report lo lhose OI previous years at Eagle River Flats.
07472 07474 C 3.1.2 6/15/95 Eagle River Flats Drilling/Coring Progress report regarding the explosive ordnance Michael Walsh NoneGiven
OU-C Book 4 Project, Progress Report disposal pad drilling and coring project and test bed CRREL
machine.
07475 07475 C 3.1.2 7/12/95 DWRC Progress Report Summary of activities conducted during spring 1995. DWRC NoneGiven
OU-C Book 4
07476 07478 C 3.1.2 7/15/95 Eagle River Flats Dredge Project, Progress repon on dredging operations at Eagle River Michael Walsh NoneGiven
OU-C Book 4 Progress Report Flats. CRREL
0747907490 C 3.1.3 2/2/90 Eagle River Flats Study Proposal, Draft plan for the 1990 Held seasonal Eagle River Flats. Waller Slieglil/. Kenneth Norlhamcr
OU-C Book 4 Fiscal Year 1990 USFWS USAED Alaska
07491 07500 C 3.1.3 5/8/91 Proposed FY91 Eagle River Flats Summary ot proposed projects lor investigating Eagle Charles Racine ATHAMA
OU-C Book 4 Remedial Investigations, Draft River Flats. CRREL
Id a) 67
-------
Fort Richardson, Alaska Administrative Record Index Update for 1998
Page Numbers OU Cat No Date Title Abstract
07501 07514 C 3.1.3 6/11/91 Elemental phosphorus as the Cause
OU-C Book 4 of Waterfowl Mortality in an Alaskan
Salt Marsh, Draft
Results of investigation linking white phosphorus to
waterfowl mortality at Eagle River Flats.
Author
Charles Racine
CRREL
Recipient
None Given
07515 07518 C 3.1.3
OU-C Book 4
9/27/91 Action Plan for the Eagle River Flats Action plan for assessment of the avian repellent methyl None Given
Environmental Restoration Program anthranilate and geotextile capping at Eagle River Flats.
None Given
07519 07519
OU-C Book 4
3.1.3 10/31/91 Eagle River Flats Management Plan
Suggestion to Fort Richardson that (he Eagle River Kurt Eilo
Flats management plan may be facilitated best if the EPA
project is completed locally.
Robert Wrcnimore
DEH
07520 07529
OU-C Book 4
3.1.3 12/10/91 Acute Toxicity Tests of Methyl
Anlhranilale for Aquatic Vertebrates
Plans for investigation of the effects of methyl Larry Clark
anlhranilate on waterfowl. OWKC
None Given
07530 07545 C 3.1.3 12/15/91 Eagle River Flats Management Plan
OU-C Book 4 Outline
Discusses the technical and managerial approach to be
used to accomplish the Eagle River Flats Installation
Restoration Program.
ATHAMA
None Given
07546 07582 C 3.1.3 1/2/92 Twenty-Ninth Report ol the
ou-c Book 4 Intcragency Testing Committee to
the Administrator, Environmental
Protection Agency, November 1991
Toxic Substances Control Act Interagency Testing Waller Slieglil/
Committee proposes that white phosphorus be tested USFWS
because of the problems at Eagle River Flats.
Robert Wrcnimore
DEH
11 <•/ 67
-------
Fort Richardson, Alaska Administrative Record Index Update for 1998
Page Numbers OU Cat No Date Title Abstract
Date
07583 07607 C 3.1.3 2/10/92 Effects of Methyl Anthranilate Bead
OU-C Book 4 Formulation on Mallard Feeding
Behavior in an Aqueous
Environment, Study Protocol
Author
Plans for investigation of methyl anihramlate effects on John Cummings
feeding behavior. DWRC
Recipient
None Given
07608 07610 C 3.1.3 2/15/92 1992/1993 Comprehensive Work
ou-c Book 4 Plan for Eagle River Flats
Outlines plans for investigation of Eagle River Flats.
Steven Bird
IKU
Robert Wrentmorc
DPW
07611 07647
OU-C Book 4
3.1.3 2/15/92
Management Plan for the Eagle
River Flats Remediation and
Restoration Program, Fort
Richardson, Alaska
Reviews (he history of studies of Eagle River Flats and Army
outlines the objectives and structure for long-term
management of the remediation and restoration of Eagle
River Flats.
Army
07648 07673
OU-C Book 4
3.1.3 3/10/92
Field Test of Formulated Methyl
Anihramlate: Risk Reduction for
White phosphorus Toxicity, Study
Protocol
Deicrmines the effectiveness of methyl anthranilatc for Larry Clark
reducing mortality of ducks exposed to white UWKC
phosphorus in marsh sediment.
None Given
07674 07690 C
OU-C Book 4
3.1.3 4/15/92 Study Protocols for FY92, Eagle
River Flats Remediation Study
List and brief descriptions of planned investigations for Charles Racine
Eagle River Flats. CRREL
None Given
07691 07724 C 3.1.3
OU-C Book 4
3/3/93 Evaluation of a Formulated Methyl Determines effectiveness of a beaded formulation of
Anthranilate Bird Repellent at Eagle niethyl anthranilate at reducing foraging activity and
River Flats, Alaska, Draft Study area us<: by waterfowl at Eagle River Flats.
Protocol
Larry Clark
DWRC
None Given
67
-------
Fort Richardson, Alaska
Page Numbers OH Cat No Date
07725 07732 C 3.1.3 3/3/93
OU-C Book 4
Administrative Record
Title
Management Plan Elements and
Criteria for Eagle River Flats
Management Plan
Index Update for 1998
Abstract
Management Plan Elements and Criteria
River Flats Management Plan as desired
for Eagle
by ADEC.
Author
Louis Howard
ADEC
Recipient
Wendy Fuller
Army
07733 07741
OU-C Book S
07742 07761
OU-C Book 5
3.1.3 3/3/93 Proposal to Monitor Environmental
Conditions of Eagle River Flats,
Alaska, Prior to Remediation of
White phosphorus Contamination
and Determine the Toxicological
Hazards of White phosphorus
3.1.3 3/3/93 Secondary Hazards of White
phosphorus to Bald Eagles, Draft
Study Protocol
Plan to measure preremediation environmental USFWS Army
conditions in sites targeted tor remediation within Eagle
River Flats and to produce toxicily data necessary to
determine cleanup criteria.
Determines the secondary hazards of white phosphorus- John Cummings None Given
exposed ducks scavanged by bald eagles on Eagle River DWRC
Flats.
07762 07766 C
OU-C Book 5
07767 07801 C
OU-C Book 5
3.1.3 3/3/93 Sedimentation, Erosion, and
Sediment Transport in the
Remediation and Treatment of White
phosphorus Contamination in Eagle
River Flats
3.1.3 3/15/93 Draft Work Plan. Eagle River Flats,
Fort Richardson, Alaska,
Toxicological and Ecological
Evaluation
Plan to conduct an analysis of rates of erosion, Daniel Lawson None Given
deposition, sediment transport, and while phosphorus CRREL
particle transport within Eagle River Flats.
Eagle River Flats work plan describing the history, AEHA None Given
cause, and plan to determine cleanup goals for major
contaminant source areas and risks posed by white
phosphorus.
07802 07804 C
OU-C Book 5
3.1.3 4/2/93 Continuing Investigation of
Waterfowl Mortality on Eagle River
Flats, Fort Richardson, Alaska
Plan to continue and expand the index of waterfowl
mortality on Eagle River Flats.
USAED Alaska
None Given
/.I „/ 67
-------
Fort Richardson, Alaska Administrative Record Index Update for 1998
Page Numbers OH Cat No Date Title
Abstract
07805 07847 C
OU-C Book 5
07848 07849 C
OU-C Book 5
Provides an overview of contractor plans for an
investigation of contamination in Eagle River Flats.
3.1.3 7/23/93 Receiving Waler Biological Study
No. 32-24-HIZV-93, Water,
Sediment, Macroinvcrtebralc and
Fish Sampling, Eagle River Flats,
Protocol
3.1.3 11/18/93 Draft Proposal for USDA-APHIS- Requests permission for a waterfowl hazing program.
ADC Activities on Eagle River Flats
in 1994
Author
AEHA
Paul ONeil
USDA ADC
Recipient
Army
Daniel Lawson
CRREL
07850 07851 C
OU-C Book 5
3.1.3 12/15/93 Field Study for Placement and Use of Determines whether placement of geocomposite Karen Henry
Geocomposite to Reduce Waterfowl products over a contaminated area will reduce CRREL
Mortality in Eagle River Flats waterfowl mortality.
None Given
07852 07859 C
OU-C Book 5
3.1.3 12/15/93 Report of USDA/APHlS/Animal
Damage Control Activities for the
Army at Eagle River Flats
Damage control activities for migratory waterfowl at Paul O"Neil
Eagle River Flats. USDA ADC
None Given
07860 07860 C
OU-C Book 5
07861 07862 C
OU-C Book 5
3.1.3 12/15/93 While phosphorus Absorption in Determines the location of white phosphorus absorption Bill Roebuck None Given
Ducks: Rate, Extent, and ar>d factors controlling dissolution of white phosphorus Dartmouth Medical School
Completeness of Absorption of from panicles.
Particles in Relation to Development
of Toxicily
3.1.3 12/15/93 White phosphorus in Herring Gull Evaluation ol distribution and hioaccumulation ot white Bill Roebuck None Given
(Larus argcntatus) Eggs: Strategy for phosphorus in herring gull eggs. Dumnouih Medical School
Monitoring the Effectiveness of
Remediation at Eagle River Flats
nl t>7
-------
Fort Richardson, Alaska Admiinistrative Record Index Update for 1998
Page Numbers OU Cat No Date Title
Abstract
07863 07877 C 3.1.3 3/31/94 Development and Analysis of ihe
.OU-c Book 5 Eagle River Flats Spatial Database,
Scope of Work
Presenis ihe (asks, sampling and analysis plan, health
and safely plan. QA/QC plan, and schedule for
reviewing, refining, and updating the geographic
information system database for Eagle River Flats.
Author
Charles Racine
CRREL
Recipient
William Gossweilcr
DPW
07878 07912 C
OU-C Book 5
3.1.3 3/31/94 Evaluation of White phosphorus
Effects on the Aquatic Ecosystem,
Eagle River Flats, Fort Richardson,
Alaska, Scope of Work
Presents the tasks, study plan, health and safety plan, Carl Bouwkamp
QA/QC plan, and schedule for an investigation of the AEHA
aquatic effects of white phosphorus at Eagle River Flats.
William Gossweilcr
DPW
07913 07929 C
OU-C Book 5
3.1.3 3/31/94 Index of Waterfowl, Eagle, and
Shorebird Use and Mortality on
Eagle River Flats, Fort Richardson,
Anchorage. Alaska, Scope of Work
Presents the tasks, sampling and analysis plan, health
and safety plan, QA/QC plan, and schedule for
investigation of waterfowl, eagle, and shorebird use and
mortality on Eagle River Flats.
Lenard Rcitsmu
NEILE
None Given
07930 07959 C
OU-C Book 5
3.1.3 3/31/94
Investigation ol Natural Size
Reduction of White phosphorus
Particles in Eagle River Flats
Sediments, Scope of Work
Presenis the lasks, sampling and analysis plan, health
and safely plan, QA/QC plan, and schedule for
investigation of (he natural size reduction process for
white phosphorus at Eagle River Flats.
Marianne Walsh
CRREL
William Gosswciler
DPW
07960 07980 C
OU-C Book 5
3.1.3 3/31/94 Physical System Dynamics, WP Fate
and Transport, Remediation and
Restoration, Scope of Work
Presents (he tasks, sampling and analysis plan, health
and safety plan, QA/QC plan, and schedule for
investigation of the transport and fate of white
phosphorus in Eagle River Flats sediments.
Daniel Lawson
CRREL
William Gossweiler
DPW
07981 08000 C
OU-C Book 5
3.1.3 3/31/94 Pilot Study ol Dredging to Remove
White phosphorus Contaminated
Sediments from a Limited Area in
Eagle River Flats, AK, Scope of
Work
Presents the tasks, sampling and analysis plan, health
and safety plan, QA/QC plan, and schedule for a pilot
study to assess Ihe functionality of dredging sediments
in Eagle River Flats lo remove while phosphorus.
Michael Walsh
CRREL
William Gossweilcr
DPW
15 ,•) 67
-------
Fort Richardson, Alaska Administrative Record Index Update for 1998
Page Numbers OU Cat No Date Title
08001 08022
OU-C Book 5
3.1.3
3/31/94 Pond Draining Treaiabilily Sludy,
Scope of Work
Abstract Author
Presents the tasks, sampling and analysis plan, health Charles Collins
and safety plan. QA/QC plan, and schedule to assess CRKEL
pond drainage as a viable remedial alternative of white
phosphorus-contaminated areas at Eagle River Flats.
Recipient
William Gossweiler
DHW
08023 08045 C
OU-C Book 5
08046 08058 C
OU-C Book 5
3.1.3 3/31/94 Screening Study of Barriers to
Immobilize While phosphorus and
Prevent Poisoning of Walerfowl in
Eagle River Flats, Alaska, Scope of
Work
3.1.3 3/31/94 White phosphorus Toxicity and Risk
Assessment, Scope of Work
Presents the tasks, sampling and analysis plan, health Karen Henry William Gossweilcr
and safety plan, QA/QC plan, and schedule to evaluate CRREL DPW
the ability of physical barriers to limit the transport of
white phosphorus particles in Eagle River Flats
sediment.
Presents the tasks, sampling and analysis plan, health Bill Roebuck William Gossweilcr
and safety plan, and QA/QC plan to determine the Dartmouth Medical School DPW
extent of white phosphorus in waterfowl gastrointestinal
tracts and test treatments for white phosphorus
waterfowl toxicity.
08059 08066 C
OU-C Book 5
3.1.3 4/1/94 Protecting Waterfowl from Ingesting
White phosphorus, Scope of Work
Presents the tasks, sampling and analysis plan, health John Cuinmings
and safely plan. QA/QC plan, and schedule to frighten DWRC
waterfowl from hazardous areas of Eagle River Flats.
None Given
08067 08106 C
OU-C Book 5
3.1.3 4/1/94
Toxicological Studies on White
phosphorus and Identification of
Bioindicators, Scope of Work
Presents the tasks, sampling and analysis plan, health
and safely plan, and QA/QC plan for toxicological
studies on the effects of while phosphorus at Eagle
River Flats.
Donald Sparling
DWRC
None Given
08107 08138
OU-C Book 5
3.1.3 4/7/94
Scope ol Work, Denver Wildlife
Research Center
Presents the schedule, objectives, description of tasks,
sampling and analysis plan, health and safety plan, and
QA/QC plan lor development of potential remediation
measures to reduce the ingestion of white phosphorus
by waterfowl.
John Cummings
UWRC
William Gossweiler
DPW
10 nl ti7
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Fort Richardson, Alaska Administrative Record Index Update for 1998
Page Numbers OU Cat No Date Title
Abstract
08139 08152
OU-C Book 5
08153 08175
OU-C Book $
08176 08200 C
OU-C Book 6
3.1.3 10/4/94 Safety Plan for Pilot Study of
Dredging to Remove White
phosphorus Contaminated Sediments
from a Limited Area in Eagle River
Flats, Alaska
3.1.3 2/27/95 Draft Technology Assessment of a
Remotely Controlled Drill for
Drilling Cased Water Sample Wells
and a Remotely Controlled Sampler
for Obtaining I m x 5 cm-Diameter
Cores in Contaminated Areas at
Eagle River Flats, Alaska, Sampling
and Analysis Plan
3.1.3 2/27/95 Dredging Treatability Study in Eagle
River Flats, Sampling and Analysis
Plan. Draft
Includes the sampling and analysis plan and minimal
health, safely, and emergency response activities
involved with the Eagle River Flats site investigation.
Includes methods and procedures to drill monitoring
wells safely and effectively on the explosive ordnance
disposal pad in Eagle River Flats.
Author
Michael Walsh
CRREL
Recipient
William Gossweilcr
DPW
CRREL
None Given
Includes methods and procedures for removal of
sediments from large, permanently Hooded areas of
Eagle River Flats that potentially contain lethal amounts
of white phosphorus.
CRREL
None Given
08201 08210 C
OU-C Book 6
08211 08285 C
OU-C Book 6
3.1.3 3/10/95 Eagle River Flats Spatial Database,
Draft Workplan
3.1.3 3/15/95 Remedial and Treatability
Investigations of Physical System
Dynamics and White phosphorus
Fate and Transport, FY95 Workplan
Includes methods and procedures to develop a spatial Charles Racine None Given
database containing while phosphorus data, and CRREL
information regarding Tale and transport, monitoring
sites, remediation sites, and ecological conditions in
relation to physical, biological, and hydraulic site
features at Eagle River Flats.
The FY95 work plan includes remedial investigation None Given Laurie Angell
and Ireaiabilily study objectives for Eagle River Flats, a DPW
description of tasks, a detailed analysis plan, a health
and safely plan, a QA plan, and a schedule.
08286 08319 C
OU-C Boofc 6
3.1.3 3/16/95 Attenuation of While phosphorus
Particles in Eagle River Flals
Sediments, Sampling and Analysis
Plan, Revised Draft
Includes methods and procedures to monitor aiienuulion CRREL
of while phosphorus panicles in sediments ai Eagle
River Flals under natural and altered conditions.
None Given
17,,) 67
-------
Fort Richardson, Alaska Administrative Record Index Update for 1998
Page Numbers OU Cat No Date Title Abstract
08320 08335
OU-C Book 6
08336 08510 C
OU-C Book 6
08511 08679
OU-C Book 7
08680 08691 C
OU-C Book 7
3.1.3 3/16/95 Scope of Work for Pilot Study of
Dredging to Remove White
phosphorus Contaminated Sediments
from a Limited Area in Eagle River
Flats, Alaska
3.1.3 3/20/95 Evaluation of AquaBlok on
Contaminated Sediments to Reduce
Mortality of Foraging Waterfowl,
Proposed Remedial Investigation/FS
Workplan
3.1.3 3/20/95
3.1.3 4/7/95
Movements, Distribution and
Relative Risk of Waterfowl and Bald
Eagles Using Eagle River Flats, Fort
Richardson, Alaska, Proposed
Remedial Investigation/FS Workplan
Proposal for 1995 ERF Field Season,
Workplan, Draft
Includes (he sampling and analysis plan and minimal
health, safety, and emergency response activities
involved with the Eagle River Flats site investigation.
Author
Michael Walsh
CRREL
Recipient
William Gossweilcr
DHW
Includes a plan to continue to evaluate the effectiveness Patricia Pochop el ul.
of AquaBlok (trademark) application on contaminated DWRC
sediments (o provide a physical barrier to feeding
waterfowl at Eagle River Flats.
Army
Includes a plan to determine daily and seasonal
movements of waterfowl at Eagle River Flats and to
determine hazards that waterfowl poisoned by white
phosphorus pose to bald eagles.
Includes methods and procedures for monitoring and
measuring waterfowl mortality at Eagle River Flats.
John Cummings
DWRC
None Given
Lenurd Reitsma
NEILE
William Gossweiler
DHW
08692 08734 C
OU-C Book 7
3.1.3 4/10/95 Sampling and Analysis Plan, Pond
Draining Trealability Study in Eagle
River Flats
Sampling and analysis plan tor samples to be collected CRREL
during the pond draining trcatabilily study in Eagle
River Flats.
None Given
08735 08736 C 3.1.3 5/23/95 Program Plan, Drill and Core
ou-c Book 7 Project, Eagle River Flats, Alaska
Includes a revision in (he original plan for deploying the Michael Walsh
drill rig and drilling wells on the explosive ordnance CRREL
disposal pud.
William Gossweiler
DPW
I Kit) 67
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Fort Richardson, Alaska Administrative Record Index Update for 1998
Page Numbers OU Cat No Date Title
Abstract
08737 09285 C
OU-C Books 7 & 8
3.1.3 6/15/95 Eagle River Flats Final 1995 Work
Plan, Fort Richardson, Alaska
Includes the sampling and analysis plan, QA/QC plan,
and site health and safety plan to identify daia gaps to
support key CERCLA decisions.
Author
CH2M Hill
Recipient
William Gossweiler
DPW
09296 09363 C
OU-C Book 8
3.1.3 6/15/95 Final QA Program Plan for 1995
Ficldwork, Eagle River Flats, Fort
Richardson, Alaska
Describes ihe planned objectives of the 1995 field
investigations, Ihe data required to meet these
objectives, and the procedures that will be followed to
obtain the data.
CH2M Hill
William Gossweiler
DPW
09364 09411 C
OU-C Book 9
09412 09417 C
OU C Book 9
3.1.3 6/15/95 Sampling and Analysis Plan,
Remedial and Treatabilily
Investigations of Physical System
Dynamics and While phosphorus
Fate and Transport
3.1.3 7/14/95 Eagle River Flats Decision Document
Includes a plan to conduct RIs on the Eagle River Flats USAED Alaska None Given
physical system, examining ihe hydrology,
sedimeniology and hydraulic processes controlling the
erosion, transport, deposition, and burial of white
phosphorus-bearing sediments.
Describes the selected interim remedial action lor ihe None Given None Given
Eagle River Flats site in accordance with CERCLA.
24329 24494
OU-C Book 17
'97 Update
3.1.3 9/1/96 OU-C OB/OD Pad, Fort Richardson,
Alaska, Site Investigation Work Plan
Sampling and QA procedures are presented for
investigating potentially contaminated soil and
groundwater at Ihe OB/OD Pad.
CH2M Hill
USAED Alaska
09418 09422 C 3.1.4 8/3/90 Ingeslion of Munitions Compounds,
ou-C Book 9 Hypothesis for Waterfowl Mortality
in Eagle River Flats, Alaska, Draft
Interim Report
Hypothesis for waterfowl mortality in Eagle River Flats. CRREL
None Given
/V.;/ 67
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Fort Richardson, Alaska Administrative Record Index Update for 1998
Page Numbers OU Cat No Date Title Abstract
09423 09425 C
OU-C Book 9
09426 09543 C
OU-C Book 9
06993 06994 C
OU-C Book 3
09544 09551 C
OU-C Book 9
09552 09565 C
OU-C Book 9
09566 09571 C
OU-C Book 9
3. 1 .4 9/10/90 Waterfowl Mortality in Eagle River
Flats Impact Area, Anchorage, Alaska
3.1.4 1/15/91 Waterfowl Mortality in Eagle River
Flats, Alaska: The Role of Munition
Compounds
3. 1 .4 6/28/9 1 Waterfowl Deaths at Eagle River
Flats (ERF): Possible Human Health
Hazard, Preliminary Evaluation
3. 1 .4 9/15/9 1 tagle River Hals Waterfowl
Mortality Studies, 1991
3.1.4 11/13/91 Waterfowl Mortality in Eagle River
Flats, Alaska: The Role of Munition
Compounds
3.1.4 3/10/92 Preliminary Report, Ecological
Assessment of Methyl Anthranilate
Includes a summary of field investigations ai Eagle
River Flats fur (he 1990 field season and
recommendations lor future studies.
Presents investigation results regarding the presence of
while phosphorus in Eagle River Flats sediments, and
(he effects on local waterfowl.
Contained as an appendix (o the EA for the resumption
of firing in the Eagle River Flats Impact Area; summary
of the potential for human health effects and
recommendations lor further study.
Radio telemetry sludy of the fall use of Eagle River
Flats by mallards and pintails.
Presents investigation results regarding the presence of
while phosphorus in sediments, and the effects of white
phosphorus on waterfowl at Eagle River Flats,
including human health RA information.
Preliminary report regarding ecological assessment of
methyl amhranilate
Author Recipient
Charles Racine None Given
CRREL
1 '
Charles Racine ATHAMA
CRKEL
Maurice Weeks None Given
Army Toxicology Division
Laurel Bennett William Gossweiler
UPW UHW
Charles Racine None Given
CRREL
l.arry Clark None Given
DWRC
67
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Fort Richardson, Alaska Administrative Record Index Update for 1998
Page Numbers OU Cat No Date Title
Abstract
09572 09777
OU-C Book 9
3.1.4 3/15/92 Remedial Investigation Report:
White phosphorus Contamination of
v Salt Marsh Sediments at Eagle River
Flats, Alaska, Final
Presents the results of the 1991 Eagle River Flats
studies and investigation into the presence of white
phosphorus in Eagle River Flats sediments and
verification ol while phosphorus'effects on waterfowl.
Author
Charles Racine
CRREL
Recipient
ATHAMA
09778 09821 C 3.1.4 5/15/92 Waterfowl Mortality in Eagle River
OU-C Book 9 Flats, Alaska: The Role of Munition
Residues
Presents results of investigation of white phosphorus in Charles Racine
Eagle River Flats sediment and effects of phosphorus CRREL
on waterfowl.
None Given
09822 09923 C 3.1.4 1/15/93 Army Eagle River Flats: Protecting
OU-C Book to Waterfowl from Ingesting White
phosphorus, Technical Report 93-1
Contains three reports from 1992 studies regarding the John Cummings
effectiveness and (oxicity of methyl anthranilate. DVYRC
ATHAMA
09924 09948 C 3.1.4 3/3/93 Responses ol Waterfowl to Concover
OU-c Book 10 and Bara-kade, Draft Study Protocol
Evaluates feasibility of applying Concover and Bara- Patricia Pochop
kade on contaminated sediments to provide a physical DWRC
barrier to feeding waterfowl.
None Given
09949 10181 C 3.1.4 6/15/93 Phase II Remedial Investigation
OU-C Book to Report: White phosphorus
Contamination of Salt Marsh
Sediments at Eagle River Flats,
Alaska, Fiscal Year 1992, Final
10182 10211 C 3.1.4 12/15/93 Preliminary Assessment of
OU-C Book 10 Sedimentation and Erosion in Eagle
River Flats, South-Central Alaska,
Report 93-23
Final 1992 report regarding the investigation into the
cause and extent of annual waterfowl die-offs.
Evaluation of the physical processes of sedimentation
and erosion within tidal mud flats and salt marshes at
Eagle River Flats.
Charles Racine
CRREL
Army
Daniel Lawson
CRREL
None Given
21 ,>/ 67
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Fort Richardson, Alaska Administrative Record Inidex Update for 1998
Page Numbers OU Cat No Date Title
10212 10246 C 3.1.4 12/21/93 Nature and Extent of While
OU c Book 10 phosphorus Contamination in Eagle
River Flats Sediments, Draft
Abstract
Presents the results of three years of sampling and
analysis 10 determine the nature and extent of while
phosphorus contamination at Eagle River Flats.
Author
Charles Racine
CRREL
Recipient
None Given
10247 10293 C
OU-C Book 10
3.1.4 1/10/94 lexicological Studies ol White
phosphorus in Waterfowl and Its
Presence in Food Chain Organisms,
Draft
Presents a summary of waterfowl research conducted
during 1993 at Eagle River Flats.
Donald Sparling
DWRC
None Given
10294 10373 C
OU-C Book 11
10706 10713 C
OU-C Book 11
10734 10742 C
OU-C Book 11
3.1.4 4/15/94
3.1.4 5/15/94
3.1.4 5/15/94
Receiving Water Biological Study
No. 32-24-H1ZV-93, Water,
Sediment, Macroinveriebrate and
Fish Sampling, Eagle River Flats,
Fort Richardson, Alaska, Final Report
A Preliminary Literature List and
Review for Salt Marsh Restoration as
Applied to Eagle River Flats, Alaska
Analytical Method lor While
phosphorus in Water
Presents the results ol the 1993 field study to determine AEHA
the effects of Eagle River Flats contaminants on aquatic
species.
Army
Contained in the Intcragcncy Expanded Site
Investigation FY93 Final Report; a review of a
literature base on sail marshes to determine whether
methods and techniques for restoration exist and how
other salt marshes have responded to major alterations
such as draining or dredging.
Contained in the Intcrugcncy Expanded Site
Investigation FY93 Final Report; a description of (he
analytical method for detecting white phosphorus in
water.
Charles Racine
CKREL
None Given
Marianne Walsh
CRREL
None Given
10471 10496 C
OU-C Book 11
3.1.4 5/15/94 Contaminant Inventory
Contained in the Interagency F.xpanded Site Carl Buuwkamp
Investigation FY93 Final Report; provides the results of AEHA
the analysis ot sediment and water samples collected
from IK sites in Eagle River Flats and analy/.ed lor
multiple parameters.
None Given
2!../ 67
-------
Fort Richardson, Alaska Administrative Record Index Update for 1998
Page Numbers OU Cat No Date Title
Abstract
10680 10687 C 3.1.4 5/15/94 Evaluation of Concover and
OU-c Book 11 Bentoballs on Contaminated
Sediments to Reduce Mortality of
Foraging Waterfowl
Contained in the Interagency Expanded Site
Investigation FY93 Final Report, the results of
Laboratory and field trials to evaluate the feasibility and
performance of materials to provide a physical barrier
between feeding waterfowl and contaminated sediments.
Author
Patricia Pochop et al.
USDA ADC
Recipient
None Given
10656 10669 C 3.1.4 5/15/94 Field Behavioral Response and Bead
OU-C Book 11 Formulations for Methyl Anlhranilate
Encapsulated Bird Repellents
Contained in the Interagency Expanded Site
Investigation FY93 Final Report; a report on field tests
using a bird repellent on waterfowl from study areas.
Larry Clark et al.
USDA ADC
None Given
10670 10673 C
OU-C Book 11
3.1.4 5/15/94 Field Evaluation: Mortality of
Mallards Feeding in Areas Treated
with Methyl Anthranilate
Contained in the Interagency Expanded Site
Investigation FY93 Final Report; results of a lest study
to determine the mortality of mallards feeding in pens
treated with a modified methyl anihranilate formulation.
John Cummings et al.
USDA ADC
None Given
10688 10696 C
OU-C Book 11
3.1.4 5/15/94 Field Study of Air-Drying
Contaminated Sediment
Contained in (he Interagency Expanded Site
Investigation FY93 Final Report; results of tests to air-
dry contaminated sediments under field conditions to
reduce the concentrations of white phosphorus.
Michael Walsh
CRREL
None Given
10620 10636 C
OU-C Book 11
3.1.4 5/15/94 Food Chain Invertebrates and Fish:
Sediment Bioassay
Contained in the Interagency Expanded Site
Investigation FY93 Final Report; discusses the results
of sediment samples and Laboratory studies to
determine the effect of while phosphorus on bcnlhic
invertebrates and fish.
Carl Bouwkamp
AEHA
None Given
10674 10679 C
OU-C Book 11
3.1.4 5/15/94 Geosynthetic Covering of
Contaminated Sediment
Contained in the Inleragcncy Expanded Site
Investigation FY93 Final Report; conclusions from
pilot field testing of four geosynthelic products to limit
exposure ol dabbling ducks to while phosphorus in
Eagle River Flats.
Karen Henry
CKKEL
None Given
2) i>l 67
-------
Fort Richardson, Alaska Administrative Record Index Update for 1998
l'age Numbers OU Cat No Date Title
10393 10411
OU-C Book 11
3.1.4 5/15/94 Habitat and Vegetation
Abstract
Author
Coniained in ihe Intcragcncy Expanded Sile Charles Racine
Investigation FY93 Final Report; summarizes the zones CRREL
of habitat and vegetation types occurring within Eagle
River Flats.
Recipient
None Given
10644 10650 C
OU-C Book 11
3.1.4 5/15/94
Hazing Waterfowl in Eagle River
Flats
Coniained in the Interagency Expanded Sile Paul 0"Neil
Investigation FY93 Final Report; discusses the methods USDA ADC
and results of hazing waterfowl at Eagle River Flats to
prevent white phosphorus poisoning.
None Given
10374 10768 C
OU-C Book 11
10637 10640 C
OU-C Book 11
3.1.4 5/15/94 Interagency Expanded Sile "
Investigation: Evaluation of White
phosphorus Contamination and
Potential Treatability at Eagle River
Flats, Alaska. Fiscal Year 1993.
Final Report
3.1.4 5/15/94 Invertebrates and Fish
A compilation of reports detailing 1993 field and CRREL
laboratory work, performed by several groups, on white
phosphorus at Eagle River Flats.
Contained in the Interagency Expanded Site Donald Sparling
Investigation FY93 Final Report; sampling analysis DWRC
results ol white phosphorus in macromvertcbraies
collected from ponded areas of Eagle River Flats.
William Gossweiler
DPW
None Given
10651 10655 C 3.1.4 5/15/94 Laboratory Evaluation of a Methyl
OU-C Book 11 Anthranilate Bead Formulation for
Reducing Mallard Mortality and
Feeding Behavior
Contained in Ihe Interagency Expanded Site
Investigation FY93 Final Report; results of a test to
apply a bird repelleni to bottom sediment in a simulated
pond to determine effectiveness.
John Gumming* el ul.
DWRC
None Given
10714 10720 C
OU C Book 11
3.1.4 5/15/94
Method Documentation in
US ATH AM A (1990) Formal:
Analytical Method lor White
phosphorus in Soil or Sediment
Contained in the Inleragency lixpanded Sile
Investigation FY1J3 Final Report; details the analytical
method suitable for determining while phosphorus in
wet soil or sediment.
Michael Walsh
CRREL
None Given
.'-/.-/ 67
-------
Fort Richardson, Alaska Administrative Record Index Update for 1998
Page Numbers OH Cat No Date Title
Abstract
10412 10470
OU-C Book 11
3.1.4 5/15/94 Physical System Dynamics
Contained in the Inieragency Expanded Site
Investigation FY93 Final Report; discusses the
progressive, physical environment changes at Eagle
River Flats from the interaction and response of various
physical processes.
Author
Daniel Lawson ct al.
CRREL
Recipient
None Given
10697 10705 C
OU-C Book 11
3.1.4 5/15/94 Pond Draining Treaiability Study
Contained in the Inieragency Expanded Site
Investigation FY93 Final Report; results of a Held test
to determine the insitu conditions of pond bottom
sediments under drying conditions as a remediation
option.
Charles Collins
CRREL
None Given
10721 10733 C 3.1.4 5/15/94 Preliminary Evaluation of the
OU-c Book 11 Analytical Holding Time for White
phosphorus in Surface Water
Contained in the Inieragency Expanded Site Michael Walsh el al.
Investigation FY93 Final Report; information regarding CRREL
determination of a suitable holding time under the
analysis of white phosphorus dissolved in water.
None Given
10497 10517
OU-C Book 11
3.1.4 5/15/94
Review ol Chemical and Physical
Properties of While phosphorus
Contained in the Interagency Expanded Site
Investigation FY93 Final Report; a review of literature
regarding the properties of white phosphorus to
determine the factors that influence the persistence of
white phosphorus in the environment.
Michael Walsh
CRREL
None Given
10743 10768 C 3.1.4 5/15/94 Sediment Samples Collected and
OU-C Book 11 Analyzed from Eight Areas on Eagle
River Flats, 1991 to 1993
Contained in the Interagency Expanded Site
Investigation FY93 Final Report; a summary of sample
results from Eagle River Flats from 1991 to 1993.
None Given
None Given
10518 10536
OU-C Hook 11
3.1.4 5/15/94
Toxicological Studies of While
phosphorus in Waicrfowl
Contained in (he Inieragency Expanded Site Donald Sparling
Investigation FY93 Final Report; discusses the findings UWRC
of studies lo determine lethal dose and lowest observed
effect level concentrations for waterfowl and related
elfecls.
None Given
25 »/ 67
-------
Fort Richardson, Alaska Administrative Record Index Update for 1998
Page Numbers OU Cat No Date Title
10568 10572
OU-C Book 11
3.1.4 5/15/94 Water Sampling
Abstract
Contained in the Inlcragency Expanded Site
Investigation FY93 Final Report; discusses the results
of water samples collected from Eagle River Flats in
relation to the presence or absence of white phosphorus
in sediment.
Author
Michael Walsh
CRREL
Recipient
None Given
10573 10585 C 3.1.4 5/15/94 Waierbird Utilization of Eagle River
OU-C Book 11 Flats: April to October 1993
Contained in the Interagency Expanded Site W.D. Eldridge
Investigation FY93 Final Report: provides the results of USFWS
a bird census taken at Eagle River Flats.
None Given
10607 10613 C
OU-C Book 11
10586 10606 C
OU-C Book 11
10641 10643 C
OU-C Book 11
3.1.4 5/15/94
3.1.4
3.1.4
Waterfowl Distribution and
Movements in Eagle River Flats
5/15/94 Waterfowl Mortality at Eagle River
Mats
5/15/94 White phosphorus in Plants at Eagle
River Flats
John Cummings c( al.
DWRC
Lcnard Rcitsina
NEILI-
Contained in the Interagency Expanded Site
Investigation FY93 Final Report; discusses the
movement, distribution, turnover rate, and site-specific
exposure of waterfowl species most susceptible to white
phosphorus poisoning ul Eagle River Flats during fall
migration.
Contained in the Interagency Expanded Site
Investigation FY9.1 Final Report; results of a study
conducted to assess the relative amount of waterfowl
mortality in order to detect year-to-year changes as
white phosphorus exposure decreases because of
remediation efforts.
Contained in the Interagency Expanded Site Michael Walsh
Investigation FY93 Final Report; provides the results of CRREL
analyzing for white phosphorus in plants collected from
sites where while phosphorus was delected previously
in the sediment.
None Given
None Given
None Given
10537 10567 C
OU-C Book 11
3.1.4 5/15/94 White phosphorus in Sediments
Contained in die Interagency Expanded Site
Investigation FY93 Final Report; summari/.es the
results of sampling efforts to determine the distribution
and concentrations of white phosphorus in Eagle River
Flats.
Charles Racine
CRREL
None Given
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Fort Richardson, Alaska Administrative Record Index Update for 1998
Page Numbers OU Cat No Date Title
Abstract
Author
Recipient
10614 10619
OU-C Book 11
10769 10797
OU-C Book 12
3.1.4 5/15/94
White phosphorus Poisoning of
Waterfowl in Eagle River Flats
3.1.4 7/14/94 Eagle River Flats Potential ARARs
Evaluation
Contained in the Interagency Expanded Site
Investigation FY93 Final Report; the results of
necropsies performed on waterfowl found dead at Eagle
River Flats and a comparison of conditions between
birds found dead in the flats and those that died from
laboratory experiments with while phosphorus.
Review of ARARs for Eagle River Flats in preparation CH2M Hill
of future CERCLA remedial activities.
Donald Sparling ct al. None Given
DWRC
None Given
10798 11028 C 3.1.4 7/15/94 Eagle River Flats Comprehensive
OU-c Book 12 Evaluation Report, Fort Richardson,
Alaska
Summarizes information obtained from Eagle River
Flats investigations and is designed to determine
practical, implementable, and effective remedial actions.
CH2M Hill
Army
11029 11032 C
OU-C Book 12
3.1.4 2/17/95 Report of USDA/APHlS/Animal
Damage Control for the Army at
Eagle River Flats, May to October,
1994
Includes damage control activities for migratory
waterfowl at Eagle River Flats from May through
October 1994.
USDA ADC
None Given
11033 11078 C
OU-C Book 12
3.1.4 3/15/95 Initial Analysis of Eagle River Flats
Hydrology and Sedimentology, Fort
Richardson, Alaska, Report 95-5
Presents the initial analysis of the physical system of Daniel Lawson
Eagle River Flats, focusing on the inter-relationships of CRREL
the hydrological and sedimentological processes.
None Given
11079 11091 C 3.1.4 4/25/95 Fort Richardson Multi-Agency Site
OU-C Book 12 Investigation
Includes background information and a summary of
past investigations for Eagle River Flats.
William Gossweiler
DHW
None Given
27,ij 67
-------
Fort Richardson, Alaska Administrative Record Index Update for 1998
Page Numbers OU Cat No Date Title
11347 11368
OU-CBook 13
3.1.4 5/15/95
Analysis of the Eagle River Flats
White phosphorus Concentration
Database
Abstract
Contained in Volume I of the Inieragency Expanded
Site Investigation FY94 Final Report; presents results
of the while phosphorus concentration database for
sediment and water at Eagle River Flats.
Author
Charles Racine
CRREL
Kecipient
None Given
11728 11793 C 3.1.4 5/15/95 Appendix A, Eagle River Flats Map
OU-C Book 14 Atlas
Contained in Volume 2 of the Inieragency Expanded
Site Investigation FY94 Final Report: a compilation of
maps documenting all sampling, monitoring, and
remediation test sites during studies from 1991 to 1994.
Charles Racine et al.
CRREL
None Given
11506 11517 C 3.1.4 5/15/95 Chemical Hazing of Free-Ranging
OU-C Book 13 Ducks in Eagle River Flats: Field
Evaluation of Rejex-H WI -05
Contained in Volume 2 of the Inieragency Expanded
Site Investigation FY94 Final Report; discusses the
results of field testing of a chemical waterfowl repellent
at Eagle River Flats.
Larry Clark cl al.
DWRC
None Given
11280 11293
OU-C Book 13
3.1.4 5/15/95 Climate and Tides
Contained in Volume I ol the Inieragency Expanded Richard Haugcn
Site Investigation FY94 Final Report; describes the CRREL
results of meteorological studies and tide predictions for
Eagle River Flats.
None Given
11658 11727
OU-CBook 14
3.1.4 5/15/95
Dredging as a Remediation Strategy
for White phosphorus-Contaminated
Sediments at Eagle River Flats,
Alaska
Contained in Volume 2 of the Interagency Expanded
Site Investigation FY94 Final Report; a discussion of
the preparation and initiation of the dredging operations
as part of ihc study of remediation strategies.
Michael Walsh cial.
CRREL
None Given
11121 11148 C 3.1.4 5/15/95 Ecological Inventory of Eagle River
ou-c Book 13 Flats, Alaska
Contained in Volume I ol the Interagency Expanded
Site Investigation FY94 Final Report; provides the
results of an ecological evaluation of Eagle River Flats
to charactcri/.e the ecosystem; to help evaluate white
phosphorus distribution, persistence and ecological risk;
and to provide u Baseline tor evaluating and predicting
the luiuic effects of remediation.
Charles Racine et al.
CRREL
None Given
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Fort Richardson, Alaska Administrative Record Index Update for 1998
Page Numbers OU Cat NO Date Title
Abstract
11524 11539 C 3.1.4 5/15/95 Evaluation of AquaBlok on
Oli-C Book 13 Contaminated Sediments to Reduce
Mortality of Foraging Waterfowl
Contained in Volume 2 of the'Interagency Expanded
Site Investigation FY94 Final Report; results of a study
of the AquaBlok barrier system in preventing waterfowl
exposure to white phosphorus.
Author
Patricia Pochop et al.
DWRC
Recipient
None Given
11426 11493
OU-CBook 13
11518 11523
OU-CBook 13
3.1.4 5/15/95 Evaluation of White phosphorus
Effects on the Aquatic Ecosystem,
Eagle River Flats, Fort Richardson,
Alaska
3.1.4 5/15/95 Hazing at Eagle River Flats
Contained in Volume I of the Interagency Expanded
Site Investigation FY94 Final Report; discusses the
results of studies to determine whether white
phosphorus has an adverse impact on the aquatic biota
or is bioatcumulating in the food chain, and to
determine a no observed effect level concentration for
white phosphorus in sediment.
Contained in Volume 2 of the Interagency Expanded
Site Investigation FY94 Final Report; discusses Ihe
results of various hazing methods applied at Eagle
River Flats to keep migratory waterfowl from being
poisoned by white phosphorus.
Carl Bouwkamp
AEHA
None Given
Corey Rossi
USDA ADC
None Given
11494 11501 C 3.1.4 5/15/95 Integrated Risk Assessment Model
ou-c Book 13 (1RAM) for Determining White
phosphorus Encounter Rate by
Waterfowl
Contained in Volume I of the Interagency Expanded Larry Clark
Site Investigation FY94 Final Report; includes a model DWRC
that provides a method for RA for ihe white phosphorus
encounter rate by waterfowl feeding at Eagle River
Flats.
William Gossweiler
UPW
11092 11793 C
OU-C Books 13 & 14
11566 11623
OUCBook 13
3.1.4 5/15/95 Interagency Expanded Site
Investigation, Evaluation of White
phosphorus Contamination and
Potential Treatability at Eagle River
Flats, Alaska, Fiscal Year 1994,
Final Report, Volumes 1 and 2
3.1.4 5/15/95 Investigation of Natural Size
Reduction of While phosphorus
Particles in Euglc River Flats
Sediments
Two-volume compilation of reports detailing FY94
CRREL studies of Eagle River Flats.
CRREL
Contained in Volume 2 of the Imcragency Expanded
Site Investigation FY94 Final Report; includes an
investigation of natural decontamination of Eagle River
Flats sediments.
William Gossweiler
DPW
Marianne Walsh el al.
CRREL
None Given
67
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Fort Richardson, Alaska Administrative Record Index Update for 1998
Page Numbers OU Cat No Date Title
11412 11425
OU-C Book 13
3.1.4 5/15/95
Abstract
Movements, Distribution and
Relative Risk of Waterfowl, Bald
Eagles and Dowiichers Using Eagle
River Flats
Contained in Volume I of the Inleragency Expanded
Site Investigation FY94 Final Report; provides results
of daily and seasonal movements of waterfowl at Eagle
River Flats.
Author
John Cummings el al.
DWRC
Recipient
None Given
11149 11279
OU-C Book 13
11624 11657
OU-C Book 13
3.1.4 5/15/95 Physical System Dynamics, WP Fate
and Transport, Remediation and
Restoration, Eagle River Flats, Alaska
3.1.4 5/15/95 Pond Draining Treatability Study
Contained in Volume I of ihe Inleragency Expanded Daniel Lawson None Given
Site Investigation FY94 Final Report; presents the CKREL
results of an analysis of the physical processes of
erosion, sedimentation and sediment transport, and fate
and transport of white phosphorus within Eagle River
Flats.
Contained in Volume 2 of the Inleragency Expanded Charles Collins None Given
Site Investigation FY94 Final Report; presents results CRREL
of the pond draining study conducted at Eagle River
Flats.
11540 11565 C 3.14 5/15/95 Screening Study ol Barriers to
ou-C Book 13 Prevent Poisoning ol Waterfowl in
Eugle River Flats, Alaska
Coniaincd in Volume 2 of the Inleragency Expanded
Site Investigation FY94 Final Report; describes
procedures and results of the use of barriers to prevent
waterfowl from eating while phosphorus al Eagle River
Flats.
Karen Henry
CRREL
None Given
1)327 11346
OU-C Book 13
11369 11380 C
OU-C Book 13
3.1.4 5/15/95 Toxicological Properties of White
phosphorus: Comparison of Particle
Sizes on Acute Toxicity and the
Biotransfer of White phosphorus
from Hen to Eggs
3.1.4 5/15/95 Watcrbird Utili/alion of Eagle River
Flats: April-October 1994
Contained in Volume I of the Intcragency Expanded
Sile Investigation FY94 Final Report; provides results
of the comparison of particle si/es of white phosphorus
on acute loxicity in birds and transfer from hen to egg.
Contained in Volume I of the Inleragency Expanded
Sile Investigation FY94 Final Report; provides (he
results ot a water bird survey for the reported period.
Bill Roebuck
Dartmouth Medical School
William Gos.sweiler
DPW
William Eldridge
USKWS
None Given
-------
Fort Richardson, Alaska Administrative Record Index Update for 1998
Page Numbers OH Cat No Date
II 381 114 II C 3.1.4 5/15/95
OU-CBook 13
11294 11326 C 3.1.4 5/15/95
OU-CBook 13
11794 11803 C 3.1.4 5/16/95
OU-CBook 14
Title
Walcrfowl Use and Mortality at
Ragle River Flats
White phosphorus Toxicily and
Bioindicators or Exposure in
Wateirfowl and Raptors
1995 Eagle River Flats Spatial
Database Project
Abstract
Contained in Volume 1 ol the Intcragcncy Expanded
Silc Investigations FY94 Final Report. Presents results
ol waterfowl mortality studies at Eagle River Flats.
Contained in Volume 1 of the Interagency Expanded
Site Investigation FY94 Final Report; presents results
of efforts to identify indicators of white phosphorus
exposure in waterfowl at Eagle River Flats.
Includes types and locations ot data to be input into the
Eagle River Flats database.
Author
Lcnard Rcilsma cl al.
NEILE
Donald Sparling
DWRC
Charles Racine
CRREL
Recipient
None Given
None Given
None Given
11804 11945 C
OU-C Book 14
11946 11976 C
OU-C Book 14
3.1.4 6/5/95 Receiving Water Biological Study
No. 32-24-H37Y-94, Evaluation of
White: phosphorus Effects on the
Aquatic Ecosystem, Eagle River
Flats, Fort Richardson, Alaska, Final
Report
3.1.4 6/28/95 Potential Assessment and
Measurement Endpoints for Eagle
River Flats, Draft
Provides results of white phosphorus movement in the AEH A
aquatic food chain at Eagle River Flats and the
derivation of a no observed effect level concentration of
white phosphorus in sediment.
Presents the selection of assessment and measurement
endpoints for the ERA of Eagle River Flats.
CH2M Hill
None Given
Richard Jackson
USAED Alaska
11977 11977 C
OU-C Book 14
3.1.4 7/12/95 Eagle River Flats Waterfowl Hazing,
Spring 1995 Summary
Summarizes waterfowl hazing operations at Eagle River Corey Rossi
Flats for spring 1995. USDA ADC
William Gossweilcr
DPW
31 <>t 67
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Fort Richardson, Alaska Administrative Record Index Update for 1998
Page Numbers OU Cat No Date Title Abstract
Author
11978 12086
OU-C Book 14
3.1.4
12115/95 Army Eagle River Flats: Protecting
Waterfowl from Ingesting White
phosphorus. Final, Technical Report
95-1
Final report on Eagle River Flats 1995 studies: contains John Cummings
two reports. DWRC
Recipient
William Gosswcilcr
DPW
12037 12086 C
OU-C Book 14
3.1.4 12/15/95 Evaluation of AquaBlok on
Contaminated Sediment to Reduce
Mortality of Foraging Waterfowl
Contained in Army Eagle River Flats: Protecting
Waterfowl from Ingesting White phosphorus. Final,
Technical Report 95-1; describes tests on the
performance of a physical barrier material to prevent
waterfowl from accessing contaminated sediment.
Patricia Pochop et al.
DWRC
None Given
11980 12036 C
OU-C Book 14
12087 12110 C
OU-C Book 14
3.1.4 12/15/95 Movement. Distribution and Relative
Risk of Waterfowl and Bald Eagles
Using Eagle River Flats
3.1.4 12/16/95 Waterfowl Use and Mortality at
Eagle River Flats, FY 1995
Contained in Army Eagle River Flats: Protecting John Cummings et al. None Given
Waterfowl from Ingesting White phosphorus, Final, DWRC
Technical Report 95-1: summarizes the dynamics of the
waterfowl population in Eagle River Flats and the
estimated risk of exposure to white phosphorus and
mortality.
Summary of FY9S activities and findings.
Benjamin Steele
NEILE
None Given
24495 24656
OU-C Book 17
'97 Update
3.1.4 7/1/96 Draft Risk Assessment Report, OU-
C, Fort Richardson, Alaska
An analysis of current and potential future adverse
environmental and human health effects caused by
release of and exposure to OU-C-relaled chemicals.
CH2M Hill
USAED Alaska
24657 24880
OU-C Book IS
•97 Update
3.1.4 7/11/96 Draft Remedial Investigation Report,
Fort Richardson, Alaska
Presents the results of the OU-C Rl.
CH2M Hill
Army
12 »} 67
-------
Abstract
Fort Richardson, Alaska Administrative Record Index Update for 1998
Page Numbers Oil Cat No Date Title
24881 24908 C 3.1.4 7/15/96 Draft Natural Resources Appraisal of
ou-c Book 18 Damage on Eagle River Flats, OU-C,
•97 Update Fort Richardson, Alaska
Ovuluiiiion of level of ihc natural resource damage lor
determining natural resource compensation.
Author
CH2MHill
Recipient
USAED Alaska
29168 29242 C
OU-C Book 20
•98 Update
29243 29278 C
OU-C Book 20
'98 Update
29279 29829 C
OU-C Book 20 & 21
'98 Update
3.1.4 12/15/96 Physical Processes and Natural
Attenuation Alternatives for
Remediation of White phosphorus
Contamination, Eagle River Flats,
Fort Richardson, Alaska
3.1.4 I/15/97 Movement, Distribution and Relative
Risk of Waterfowl and Bald Eagles
Using Eagle River Flats
3.1.4 5/15/97 Final Remedial Investigation Report,
OU-C, Fort Richardson. Alaska
Describes the results of a study on the role ol tidal Hal
physical systems in the natural attenuation of white
phosphorus.
CRREL
DPW
Results of a study to determine daily and seasonal John Cummings ct al. William Go^sweilcr
movement, distribution, turnover, and mortality rates of DWRC DPW
mallards. Determines the hazard that a mallard
poisoned by white phosphorus poses to bald eagles.
Establishes baseline mallard and bald eagle data with
respect to proposed remediation.
Presents the results of (he Rl of OU-C, including the CH2M Hill
primary ordnance impact area at Eagle River Flats and
the adjacent gravel pad used for open burning and open
detonation (OB/OD Pad).
Joann Walls
USAED Alaska
121II 12115 C 3.1.5 6/5/89 Eagle River Flats Expanded Site
OU-C Book 14 Investigation-Draft Sampling Plan,
Comments
Comments on the Hunter/ESE sampling design plan for Edwin Ruff
Eagle River Flats. DEH
Douglas Reagan
ESE
12116 12117
OU-C Book 14
3.1.5 4/9/90
Eagle River Flats Expanded Site
Investigation, Comments
Review comments on the Eagle River Flats expanded
site investigation draft technical report.
Douglas Johnson
EPA
Edwin RulT
DEH
3} of 67
-------
Fort Richardson, Alaska
Page Numbers Oil Cat No Date
121 18 12122 C 3.1.5 4/27/90
OU-CBook 14
12123 12128 C 3.1.5 4/30/90
OU-C Book 14
12129 12131 C 3.1.5 5/1/90
OU-C Book 14
12132 12134 C 3.1.5 5/2/90
OU-C Book 14
12135 12141 C 3.1.5 5/17/90
OU-CBook 15
i '
12142 12143 C ' 3.1.5 12/27/90
OU-C Book 15
Administrative Record Index Update for 1998
Title
Eagle River Flals Expanded Site
Investigation Fort Richardson,
Alaska Draft Technical Report,
Comments
Eagle River Flats Expanded Site
Investigation, Draft Technical
Report, Fort Richardson, Alaska,
Comments
Eagle River Flats Expanded Site
Investigation, Comments
Eagle River Flats Expanded Site
Investigation and Scope of Work,
Comments
Eagle River Flats Expanded Site
Investigation, Fort Richardson,
Alaska Draft Technical Report,
Comments
Waterfowl Mortality in Eagle River
Flats, Alaska: The Role of Munitions
Compounds, Comments .
Abstract Author Recipient
Review comments on the Eagle River Flais expanded Bill Lamorcaux Edwin Ruff
site investigation drat'i technical report, data item AOI 1. ADEC DEH
Review comments on the Eagle River Flats expanded Waller Stieglitz Edwin Ruff
site investigation draft technical report. USFWS DEH
Review comments on the Eagle River Flals expanded Douglas Johnson Edwin Ruff
site investigation draft technical report. EPA DEH
Review comments on the Eagle River Flats expanded Bruce Duncan Douglas Johnson
site investigation draft technical report and SOW. EPA EPA
Review comments on the Eagle River Flats expanded Dan Rosenberg Edwin Ruff
site investigation draft technical report, data item AOI 1 . ADFC DEH
Review comments on Waterfowl Mortality in Eagle Dan Rosenberg Edwin Ruff
River Flats, Alaska: The Role of Munitions Compounds. ADFG DEH
.»•/ c/ 67
-------
Fort Richardson, Alaska Administrative Record Index Update for 1998
PaRc Numbers OU Cat No Date Title
12144 12145 C 3.1.5 12/28/90 Waterfowl Mortalily in Eagle River
OU-CBook 15
Flats, Alaska: The Role of Munitions
Compounds, Draft Report, Comments
Abstract Author Recipient
Includes recommendations for the 1991 proposed SOW. Jennifer Roberts Edwin Ruff
ADEC OEM
12146 12148 C 3.1.5
OU-CBook IS
1/4/91 Waterfowl Mortality in Eagle River Review comments on the draft Waterfowl Mortality in Walter Stciglil/ Edwin Ruff
Flats, Alaska: The Role of Munitions Eagle River Flats, Alaska: The Role of Munitions USFWS DEH
Compounds, Comments Compounds.
12149 12150 C
OU-CBook 15
3.1.5 3/19/91 Waterfowl Mortality Study,
Comments
USFWS comments on the proposed 1991 llcldwork for Walter Steiglit/. Edwin Ruff
the Eagle River Flats waterfowl mortality study. USFWS DEH
12151 12153 C
OU-CBook 15
12154 12155 C
OU-CBook 15
12156 12163 C
OU-CBook 15
3.1.5 1/31/92 Review Comments on the Remedial
Investigation Report: White
phosphorus Contamination of Salt
Marsh Sediments at Eagle River
Flats, Alaska, January 14, 1992,
Draft Report
3.1.5 2/4/92 Review Comments on the Remedial
Investigation Report: White
phosphorus Contamination of Salt
Marsh Sediments at Eagle River
Flats, Alaska, January 14, 1992,
Draft Report
3.1.5 3/9/92 Re view Comments on the 1992/1993
Comprehensive Workplan for Eagle
River Flats
Review comments on Remedial Investigation Report:
White phosphorus Contamination of Salt Marsh
Sediments at Eagle River Flats, Alaska, January 14,
!992,Drafl Report.
Review comments on Remedial Investigation Report:
White phosphorus Contamination of Salt Marsh
Sediments at Eagle River Flats, Alaska, January 14,
1992, Draft Report.
Review comments on 1992/1993 Comprehensive
Workplan for Eagle River Flats.
Jennifer Roberts
ADEC
Daryl Calkins
USFWS
Kurt Eilo
EPA
Robert Wrcntmorc
DPW
Robert Wrentmorc
DPW
Robert Wrcntmorc
DPW
35 <>l 67
-------
Fort Richardson, Alaska Administrative Record Index Update for 1998
Page Numbers OU
12164 12165 C
OU-CBook IS
12166 12170 C
OU-CBook IS
12171 12175 C
OU-CBook IS
12176 12178 C
OU-CBook IS
12179 12180 C
OU-CBook IS
i •'
12181 12182 C
OU-CBook IS
Cat No Date Title
3.1.5 3/9/92 Review Comments on the Remedial
Investigation Report: White
phosphorus Contamination of Salt
Marsh Sediments at Eagle River
Flats, Alaska, January 14, 1992,
Draft Report
3.1.5 3/10/92 Eagle River Flats 1992/1993
Comprehensive Workplan
3. 1 .5 4/2/92 Comprehensive Work Plan for Eagle
River Flats, Response to Comments
3.1.5 4/19/92 Comprehensive Work Plan for Eagle
River Flats, Comments
3. 1 .5 2/22/93 Response lo Comments on the Draft
Scope of Work for Baseline Risk
Assessment and FS
3.1.5 2/22/93 Responses to Eagle River Flats Task
Force Comments and Concerns in
Regard to CERCLA
Abstract Author Recipient
Review comtncnls on Remedial Investigation Report: Kurt liilo Robert Wrentmore
White phosphorus Contamination of Salt Marsh EPA DPW
Sediments at Eagle River Flats, Alaska, January 14,
1992, Draft Report.
Review comments on Eagle River Flats 1992/1993 ADEC Robert Wrcntmorc
Comprehensive Workplan. DPW
Responses to EPA, Region X, comments on the Robert York Douglas Johnson
comprehensive work plan for Eagle River Flats. ATHAMA EPA
USFWS comments on the comprehensive work plan for Daniel Allen None Given
Eagle River Flats. USFWS
Responses to comments on the draft baseline RA and Robert York Douglas Johnson
FS for Eagle River Flats. AEC EPA
Responses to Eagle River Flats Task Force comments None Given None Given
and concerns in regard to CERCLA.
.16 nl 67
-------
Fort Richardson, Alaska Administrative Record Index Update for 1998
Page Numbers Oil Cat No Dale Title Abstract Author
12183 12187 C 3.1.5 2/22/93 Responses lo Eagle River Flats Task Responses to Eagle River Flais Task Force conference Rohcrl York
OU-C Book 15 Force Conference Call ca"
Recipient
Douglas Johnson
EPA
12188 12191 C 3.1.5 4/14/93 Comments and Recommendations, Review comments and recommendations on draft Robert York
OU-C Book is Draft Remedial Investigations for RcP«r' '• Rls 'or Eagle River Flats. AEC
Eagle River Flats. Report I
Larry Gatto
CRREL
12192 12192 C
OU-C Book I *
3.1.5 4/14/93 Comments and Recommendations,
Draft Remedial Investigations for
Eagle River Flats. Report II
Review comments on the report II, ircaiahility studies Robert York
for Eagle River Flats. AEC
Larry Gatto
CRREL
12193 12197 C
OU-C Book 15
3.1.5 4/14/93 Comments on the Draft Phase II
Remedial Investigation Report for
Eagle River Flats
Review comments on the draft phase II RI report for Robert York Larry Gat lo
Eagle River Flats. AEC . CRREL
12198 12199 C
OU-C Book 15
3.1.5 5/15/94 USCOE Review of the draft-final
Comprehensive Evaluation Report
for Eagle River Flats, Fort
Richardson, Alaska
Review comments on the comprehensive evaluation USAED Alaska
report for Eagle River Flats.
William Gossweiler
DPW
12200 12203 C 3.1.5 5/31/94 Comprehensive Evaluation Report Review comments on the draft-final comprehensive Jennifer Roberts
OU-C Book 15 and Potential ARARs Evaluation for evaluation report and potential ARARs evaluation for ADEC
Eagle River Flats, draft-final Ea8le River Flats
William Gossweiler
DPW
37 <•/ 67
-------
Fort Richardson, Alaska Administrative Record Index Update for 1998
Page Numbers OU Cat No Dale Title Abstract Author
12204 12208 C 3.1.5 6/6/94 Description of Items Nol Addressed Includes a description of items not addressed in the CH2M Hill
OU-C Book 15 in ERF Ficldwork QAPP Ea£le River Flals fieldwork QA project plan.
Recipient
USAED Alaska
12209 12210 C
OU-C Book 15
3.1.5 6/21/94 Comments on ERF Comprehensive
Evaluation Report and ARARs
Evaluation
Review comments on Ihe Eagle River Flats draft-final Ann Rappaport
comprehensive evaluation report and ARARs USFWS
evaluation.
William Gosswcilcr
DPW
12211 12217 C
OU-C Book 15
3.1.5 6/21/94 Review of the draft-final
Comprehensive Evaluation Report
for Eagle River Flats, Fort
Richardson, Alaska
Review comments on the draft-final comprehensive Arthur Lee
evaluation report for Eagle River Flats. AEHA
William Gosswcilcr
DPW
12218 12224 C
OU-C Book 15
3.1.5 2/8/95 Draft 1994 Project Meeting
Summary for Eagle River Flats
Recommended changes for Donald Sparling's portion of Donald Sparling Richard Jackson
the draft 1994 project meeting summary for Eagle River DWRC USAED Alaska
Flats.
12225 12235 C 3.1.5 3/28/95 Eagle River Flats 1995 Field Work Recommendations from the Biological Technical Sonce de Vries
OU-C Book 15 Proposals Assistance Group for Eagle River Flats regarding 1995 USFWS
ficldwork proposals.
William Gosswcilcr
DPW
12236 12237 C 3.1.5 5/24/95 Review Comments on the Draft 1995 Review comments on the draft 1995 QA program plan. Michael Walsh Richard Jackson
OU-C Book 15 QAPP CRREL USAED Alaska
3K,if 67
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Fort Richardson, Alaska Administrative Record Index Update for 1998
Page Numbers OU Cat No Dale Title Abstract
12238 12240 C 3.1.5
OU-C Book 15
Date
7/23/95 Comments on "Potential Assessment
and Measurement Endpoints for
Eagle River Flats"
ADFG comments on the technical memorandum
Potential Assessment and Measurement Endpoints lor
Eagle River Flats.
Author
Daniel Rosenberg
ADFG
Recipient
Soncc dc Vrics
USFWS
12244 12246 C 3.1.5
OU-C Book 15
7/26/95 Comments on "Potential Assessment
and Measurement Endpoints for
Eagle River Flats"
CRREL comments on the technical memorandum Charles Racine
Potential Assessment and Measurement Endpoints for CRREL
Eagle River Flats.
William Gossweilcr
DPW
12241 12243 C
OU-C Book 15
3.1.5 7/26/95 Comments on "Potential Assessment
and Measurement Endpoints for
Eagle River Flats"
Biological Technical Assistance Group comments on Soncc dc Vrics
the technical memorandum, Potential Assessment and USFWS
Measurement Endpoints for Eagle River Flats.
William Gossweilcr
DPW
24909 24922 C
OU-C Book 18
'97 Update
3.1.5 1/1/96 Response to November 1995
Comments on Draft Rl/FS
Documents, OU-C, Eagle River Flats
CH2M Hill's response to comments made by EPA, the
New England Institute for Landscape Ecology,
USFWS, CRREL. the USDA Animal and Plant Health
Inspection Service, USAED Alaska, and Dartmouth-
Hitchcock Medical Center.
None Given
None Given
24923 24941 C 3.1.5 1/30/96 Response to January 1996 Comments
OU-C Book 18 on Draft RI/FS Documents, OU-C,
•97 UpcUu Eagle River Flats
CH2M Hill's response to comments made by USAED None Given
Alaska. CRREL, EPA and CHPPM.
None Given
24942 24949 C
OU-C Book 18
•97 Update
3.1.5 3/18/96 Review of CH2M Hill Documents
Response to January 1996 comments on the draft-final Michael Walsh Laurie Angell
RI/FS management plan. CRREL DPW
39,,/ 67
-------
Fort Richardson, Alaska Administrative Record Index Update for 1998
Page Numbers OU Cat No Date Title Abstract
24950 24953 C 3.1.5 8/19/96 Eagle River Flats Draft Rl
OU-C Book 18
'97 Update
Review comments.
Author
Matthew Wilkening
EPA
Recipient
Bill Gossweilcr
DPW
24954 24955 C
OU-C Book IB
'97 Update
3.1.5 8/23/96 ADEC comments on ARAR's and RI Review comments.
Jennifer Roberts
ADEC
Richard Jackson
USAED Alaska
24956 24960 C
OU-C Book 18
•97 Update
3.1.5 8/23/96 CHPPM Comments on Draft RI and Review comments.
RA, OU-C, July 1996
Arthur Lee
CHPPM
Richard Jackson
USAED Alaska
29830 29834 C
OU-C Book 21
•98 Update
3.1.5 8/23/96 Comments on Draft RI and RA, OU- Comments by the Army CHPPM.
C
Arthur Lee
CHPPM
Richard Jackson
USAED Alaska
24961 24974 C
OU-C Book 18
'97 Update
3.1.5 8/29/96 EPA Comments on Draft RI and
Baseline RA
Review comments.
Howard Orlean
EPA
Bill Gossweilcr
DPW
29835 29868 C
OU-C Book 21 &22
'98 Update
3.1.5 3/25/97 Comments, draft-final Remedial
Investigation Report, OU-C
Review comments.
Army
CH2M Hill
40 <>j 67
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Fort Richardson, Alaska Administrative Record Index Update for 1998
Page Numbers OU Cat No Dale Title
12247 12247 C l"2 3/3/9?
OU-CBook II
Guidelines lor Remediation
Experiments on Eagle River Flats.
1993
Abstract
USI-'WS encourages the most expeditious means (o
resolve the water bird mortality problem at Eagle River
Flats without compromising the long-term health of the
wetlands.
Author
USFWS
Recipient
None Given
12248 12248
OU-CBook IS
3.2 3/11/93
Eagle River Flats Remediation
Alternatives
ADEC supports implementation of the trcatability
analysis ol the remediation measures lor Eagle River
Flats discussed at Hanover, New Hampshire, December
1992.
Jennifer Roberts
ADEC
Robert Wrentmore
DPW
24975 27979
OU-CBook 18
•97 Update
3.2 2/23/96 Revised SOW, Hydraulic Dredging.
Eagle River Flats
An SOW to perform remote-controlled hydraulic Steven Russell
dredging of Eagle River Flats for removal of white Army
phosphorus-contaminated sediments.
Bill Gosswciler
UPW
29869 29919 C
OU-C Book 22
'98 Update
3.2 9/15/96
Dredging in an Active Artillery
Impact Area, Eagle River Flats,
Alaska
A study to investigate the feasibility of using a small.
remote-controlled dredge to remove while phosphorus-
contaminated sediments from ponded areas and to (real
the spoils in an open retention basin.
CRREL
USAED Alaska
29920 29962 C
OU-C Book 22
•98 Update
3.2 1/15/97
Eagle River Flats Technology
Screening
An evaluation of all potential treatment technologies on CH2M Hill
the basis of implcmcntability, effectiveness, and cost.
Also identifies which retained technologies may be
applicable to ponds presenting the greatest threat of
white phosphorus acute loxicity to water birds.
USAED Alaska
12249 12251
OU-CBook 15
3.3 12/4/89 Eagle River Flats Task Force Study
Request, on behalf of the Eagle River Flats Task Force,
for ATHAMA's action, comments, and assistance on
issues from the FY89 study and direction for the FY90
study.
Kenneth Norlhamcr
USAED Alaska
ATHAMA
•II of 67
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Fort Richardson, Alaska Administrative Record Index Update for 1998
Page Numbers OH Cat No Date Title Abstract
Author
12252 12256 C 3.3 1/29/90 Eagle River Flats Task Force Study Includes information addressing concerns expressed by Louis Jackson
OU-C Book I5 Fon Richardson on behalf of the Eagle River Flats Task ATHAM A
Force.
Recipient
Kenneth Northamcr
USAEU Alaska
12257 12268 C 3.3 2/8/90 Eagle River Flats Task Force
OU-C Book 15 Meeting Minutes
Eagle River Flats Task Force meeting minutes,
Februarys, 1990.
None Given None Given
12269 12295 C 3.3 4/9/90 Eagle River Flats Task Force
OU-C Book 15 Meeting Minutes
Eagle River Flats Task Force meeting minutes, April 9. None Given
1990.
None Given
12296 12296 C
OU-C Book 15
3.3 8/24/90 Reply to Senator Frank Murkowski's Reply to Senator Frank Murkowski's letter concerning William Kakel
Letter Concerning Eagle River Flats Eagle River Flats. USAED Alaska
Dated August 14, 1990
Frank Murkowski
U.S. Senate
12297 12312 C
OU-C Book 15
3.3 12/10/90 Minutes of the 10 December 1990 Eagle River Flats Task Force meeting minutes.
Eagle River Flats Task Force Meeting December 10, 1990.
William Gosswciler None Given
DPW
12313 12313 C ' 3.3 12/18/90 Eagle River Flats Waterfowl
OU-C Book IS Mortality Study at Fort Richardson,
Alaska
Summary of findings in the draft report, waterfowl Charles Nichols Edwin Ruff
Mortality on the Eagle River Flats Impact Area: The CRREL DEH
Role of Munitions Compounds.
•12 »f 67
-------
Fort Richardson, Alaska Administrative Record Index Update for 1998
Page Numbers OU Cat No Date Title Abstract
12314 12315 C 3.3 3/21/91 Eagle River Flats Remedial
OU-CBook 15
Investigation
Concerns lhal need to be considered in the proposed
FY9I Eagle River Flats Rl.
Author
Kurt Eilo
EPA
Recipient
Edwin Ruff
DEH
12316 12316 C 3.3
OU-CBook 15
10/8/91 Concurrence on Environmental
Assessment for the Resumption of
Firing into the Eagle River Flats,
Memorandum for Record
Office of the Assistant Secretary of the Army concurs Bill Quirk
with the EA for Eagle River Flats and offers no Army
comments.
None Given
12317 12317 C
OU-CBook 15
3.3 11/12/91 Comprehensive Management Plan Endorses the strategy of developing a comprehensive Walter Stieglit/
for Remediation of Eagle River Flats management plan lor remediation of Eagle River Flats. USFWS
Robert Wrcntmorc
DPW
12318 12318 C 3.3 12/15/91 Eagle River Flals Waterfowl Die-Off Memorandum describing 1991 fieldwork regarding William Gossweiler None Given
OU-CBook 15 Abstract, Memorandum for Record waterfowl dic-offs and white phosphorus. DPW
12319 12321 C
OU-CBook 15
3.3 I/I 3/92 Eagle River Flals Update
Update on past, current, and future Held investigations William Gossweiler None Given
at Eagle River Flats. DPW
12322 12322 C
OU-CBook 15
3.3 3/19/92 Fiscal Year 1992 Eagle River Flals
Study of Bird Hazing Activilies
Reaffirms the position of the Eagle River Flats Task Robert Wrcntmore
Force and the 6th Infantry Division regarding the DPW
integration of bird hazing and repellent operations in
the FY92 study.
ATM AM A
4} of 67
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Fort Richardson, Alaska Administrative Record Index Update for 1998
Page Numbers OU Cat No
12323 72324* C3.3
OU-C Book 15
Date Title
2/10/93 ERF
Abstract
Author
Request that the project to investigate and remediate Roherl Wrcnlmore
white phosphorus contamination ut Eagle River Flats be DPW
transferred from AEC to the Army Garrison, Alaska.
Recipient
Gerald Brown
AEC
12325 12325 C 3.3
OU-C Book 15
2/11/93 Performance of AEC at Eagle River
Flats
Concern that the AEC has not performed satisfactorily Walter Sticglit/
in executing studies needed for remediation at Eagle USFWS
River Flats.
Robert Wrentmore
DPW
12326 12328 C 3.3 3/8/93
OU-C Book 15
Remediation Measures at Eagle
River Flats in Regards to Interlidal
Wetlands
ADFG supports proceeding with remediation measures Daniel Rosenberg
at Eagle River Flats as long as intertidal wetlands are ADFG
unaffected.
Robert Wrcnlmore
DPW
12329 12330 C
OU-C Book 15
3.3 3/17/93 Eagle River Flats Alternatives
USFWS supports implementation of treatability studies Walter Stieglitz Gerald Brown
of potential remediation measures for Eagle River Flats USFWS AEC
in FY93.
12331 12332
OU-C Book 15
3.3 3/19/93
Eagle River Flats Project
Management
Response to a request by Fort Richardson that Gerald Brown
management of Eagle River Flats be transferred from AEC
AEC to USAED Alaska.
Robert Wrentmore
DPW
12333 12335 C ' 3.3 3/25/93 Eagle River Flats Environmental
ou-c Book 15 Cleanup
Concern about AEC's interpretation of the State of Charles Cole Gerald Brown
Alaska's legal requirements relating to (he investigation ADOL AEC
and cleanup of contamination at Eagle River Flats.
4-1 «l 67
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Fort Richardson, Alaska Administrative Record Index Update for 1998
Page Numbers OU Cat No Date Title Abstract
Author
12336 12339 C 3.3 4/21/93 Comments, Eagle River Flats Draft Review comments on the Eagle River Flats draft work David Charters
OU-CBook 15 Workplan. Fort Richardson, Alaska P'an. EPA
Recipient
Roy Melkar
AEHA
12340 12342 C 3.3 4/28/93 White phosphorus Lowest Observed Review of waterfowl loxicity data lor while phosphorus. Jack Dacre
OU-CBook 15 Effect Level Geo-Cemcrs. Inc.
William Burrows
12343 12346 C 3.3
OU-CBook IS
8/18/93 Eagle River Flats Task Force
Meeting Minutes
Eagle River Flats Task Force meeting minutes. None Given
None Given
12347 12347 C
OU-CBook 15
3.3 3/29/94 Telephone Conversation with Slate Contact report regarding the need lor Stale Historic William Gossweiler Ted Rockwell
Historic Preservation Office Preservation Office review of work to be conducted at DPW USAED Alaska
Eagle River Flats.
12348 12350 C 3.3
OU-C Book 15
8/1/94 Eagle River Flats FY94, Describes how FY94 fieldwork for Eagle River Flais William Gossweiler Charles Canterbury
Memorandum for Public AFederal relates to remedial treatability studies and the DPW PAO
Facilities Agreementirs Office development of an RA.
12351 12352 C 3.3
OU-CBook 15
3/7/95 Eagle River Flats, Roles of Remedial Letter explaining the roles of remedial project managers Daniel Rosenberg
Project Managers and Ihe Biological and lne Biological Technical Assistance Group for ADFG
Technical Assistance Group at Eagle EaBlc Rivcr Flals
River Flals
Albert Kraus
DPW
67
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Fort Richardson, Alaska Administrative Record Index Update for 1998
Page Numbers OU Cat No
Abstract
1 2353 12353
ou-c Book is
13
3/29/95 Eagle River Flats, Role of the
Biological Technical Assistance
Group at Eagle River Flals
Letter explaining the role of the Biological Technical
Assistance Group ui Eagle River Flats.
Author
Albert Kruus
DPW
Recipient
Daniel Rosenberg
ADFC
12354 12355 C
OU-C Book 15
3.3 4/4/95 Eagle River Flats, Roles of Remedial Letter explaining the roles of remedial project managers Sonce de Vrics
Project Managers and the Biological ancl Ine Biological Technical Assistance Group for USFWS .
Technical Assistance Group at Eagle EaS|e R'v«r Flats.
River Flats
Albert Kraus
UPW
12356 12357 C 3.3
OU-C Book 15
4/15/95 Eagle River Flats, Role of the
Biological Technical Assistance
Group at Eagle River Rats
Letter explaining the role of the Biological Technical Albert Kraus Sonce de Vries
Assistance Group at Eagle River Flats. Army USFWS
12358 12471 C 3.3 12/15/95 Eagle River Flals, Final 1994 Project Eagle River Flats meeting minutes-December 12
OU-C Book 15 Meeting Summary through N, 1994
CH2M Hill
William Gossweilcr
DPW
24980 25007
OU-C Book 18
'97 Updmc
29963 29965
OU-C Book 22
•98 Update
3.3 3/1/96 Eagle River Flals CIS Database
Review and Evaluation of
Assessment End Points Approach
3.3 2/20/97 Endpoint lor Eagle River Flats
This technical memorandum summari7.es CH2M Hill's CH2M Hill
efforts to obtain, quality check, and test the Army
CRREL Eagle River Flals geographic information
system. A summary of the QC review status on the
geographic information system and a trial application
for (he identification of hot spots arc included.
Discusses activities of (he Biological Technical Sonce dc Vrics
Assistance Group with regard to endpoints, and USFWS
preparation of the technical screening of remedial
alternalivcs for Eagle River Flals.
Army
William Gossweilcr
DPW
•JO <
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Fort Richardson, Alaska Administrative Record Index Update for 1998
Page Numbers OU Cat No Date Title Abstract Author
12472 12472 C 4.2 7/31/95 Pilol Sludy of Dredging to Remove
ou-c Book is White phosphorus Contaminants
from Sediments in a Limited Area of
Eagle River Flats, Alaska
Discussion of preliminary test results from Ihe use of an CRREL
experimental remote-controlled dredging system in
Eagle River Flats.
Recipient
None Given
25008 25364
OU-C Book 19
•97 Update
4.2 4/1/96 Final Remedial Investigation/PS
Management Plan
The management plan documents the approach and
methodologies used to conduct the Rl for OU-C.
CH2M Hill
DPW
29966 30302 C
OU-C Book 22 & 23
•98 Update
4.2 9/15/97
Final FS Report, OU-C. Fort
Richardson, Alaska
Presents the results of the FS tor OU-C. The FS is
intended to provide remedial project managers and the
public with an assessment of remedial alternatives.
CH2M Hill
USAED Alaska
12473 12480 C
OU-C Book IS
4.3 8/31/95 Eagle River Flats (OU-C) Decision
Document
Describes the treatment alternatives being evaluated by
the Army to select a removal action for Eagle River
Flats in accordance with CERCLA.
None Given
None Given
25365 25392
OU-C Book 19
•97 Update
30303 30320 C
OU-C Book 23
•98 Update
4.3 4/1/96
Evaluation of Field Studies to
Support Assessment Endpoints
Approach
4.3 12/24/97 Final Proposed Plan, OU-C
This technical memorandum summarizes the results of CH2M Hill
an evaluation of ongoing avian studies conducted at
Eagle River Flats to determine whether endpoints have
been reached. The objective of the evaluation was to
assess the adequacy of studies performed to document
attainment of sitcwide remediation goals.
Presents cleanup ultcrnutives considered by the Army, Army
EPA, and ADEC to the public.
Army
Public
47,,1 67
-------
Fort Richardson, Alaska
Page Numbers OH Cat No Date
25393 25402 C 4.4 2/23/96
OU-CBook 19
'97 Update
25403 25403 C 4.5 3/15/96
OU-CBook 19
'97 Update
25404 25407 C 4.5 10/30/96
OU-CBook 19
'97 Update
25408 25412 C 4.5 10/30/96
OU-C Book 19
'97 Update
30321 30328 C 4.5 1/15/97
OU-C Book 23
'98 Update
30329 30334 C 4.5 1/30/97
OU-C Book 23
'98 Update
Administrative Record Index Update for 1998
Title
SOW Modification (o the OU-C
RI/FS Management Plan
Comments on OU-C RI/FS
Management Plan
OU-C FS Schedule
OU-C Technical Memo, Draft FS
Data Needs
Hot Pond Screening, Draft Method
Meeting Minutes: Eagle River Flats
Technology Screening
Abstract
A modification to perform an Rl, HHRA, ERA, and
Natural Resources Damage Assessment Plan.
Review comments.
Presents an outline of dales for documents to be
prepared by CH2M Hill. Presents data gaps in the FS.
Summary of current information available and
remaining data needed for researchers and principal
investigators.
Discussion of a melhod for identifying the hot areas and
ponds at Eagle River Flats.
A memorandum presenting the minutes from a January
22, 1997, meeting to discuss the results of the Eagle
River Flats technology screening for the upcoming draft
Author
None Given
Marianne Walsh
CRREL
Colleen Burgh
CH2M Hill
Colleen Burgh
CH2M Hill
David Lincoln
CH2M Hill
Colleen Burgh
CH2M Hill
Recipient
None Given
i i
Richard Jackson
USAED Alaska
Richard Jackson
USAED Alaska
Richard Jackson
USAED Alaska
Bill Gossweiler
DPW
Joann Walls
USAED Alaska
OU-C PS.
-------
Fort Richardson, Alaska Administrative Record Index Update for 1998
Page Numbers OU Cat No Date Title Abstract
30335 30337 C 4.5 5/27/97 Comments, ERF Draft FS, April 1997 EPA comments on the draft FS lor Eagle River Flats.
OU-C Book 23
'98 Update
Author
Howard Orlean
EPA
Recipient
Bill Gossweiler
DPW
30338 30347 C 4.5 5/30/97 Comments, OU-C Draft FS
OU-C Book 23
•98 Update
Review comments.
Howard Orlean
EPA
William Gossweiler
DPW
30348 30395 C 4.5 10/15/97 Response to Comments on Draft A response to comments presented by EPA, CRREL. CH2M Hill
OU-C Book 23 Proposed Plan, OU-C CHPPM, USFWS. ADFG, and USAED Alaska. The
'98 Update original comments are attached.
USAED Alaska
30396 30396 C
OU-C Book 23
'98 Update
5.5 3/11/97 Review of Decision Document, Eagle Comments on the decision document lor Eagle River Dennis Druck
River Plats Flats'Racine Island Pond. CHPPM has no comments CHPPM
and concurs with the remedial action.
William Gossweiler
DPW
30397 30397 C
OU-C Book 23
'98 Update
5.5 3/28/97 Review and Comments to Draft
Decision Document
Review comments on the Draft Decision Document for Michael Harada Kevin Gardner
Eagle River Flats' Racine Island Pond. Army DPW
25413 25414 C
OU-C Book 19
•97 Update
6.1 3/15/96 Memorandum of Agreement USAED Alaska entered an MOA to acquire waterfowl None Given
Between the USDA Animal Damage mortality reduction services.
Control, Animal and Plant Health
Inspection Service and the USAED
Alaska
None Given
67
-------
Fort Richardson, Alaska Administrative Record Index Update for 1998
Page Numbers OU Cat No Date Title Abstract
25415 25415 C
OU-C Book 19
•97 Update
9.0 12/16/96 Review of Draft Natural Resources Review comments
Appraisal of Damage on ERF, July
1996
Author Recipient
Dennis Druck Joann Walls
CHPPM USAED Alaska
12482 12485
OU-C Book 15
10.6 10/5/88 Current Status of Eagle River Flats
Description of current, past, and planned activities for
the Eagle River Flats investigation.
William Gossweiler
DPW
None Given
12486 12488 C
OU-C Book 15
10.6 1/30/89 Current Status of Eagle River Flats
Waterfowl Investigation
Summary of progress, action taken, and action required
for Eagle River Flats investigations.
William Gossweiler
DPW
None Given
12489 12492 C
OU-C Book 15
106 7/31/89 Current Status of Eagle River Flats
Investigation
Presents the status of the 1989 Eagle River Flats Alan Bennett
waterfowl mortality investigation and lists actions taken Army
and required.
None Given
12493 12496 C
OU-C Book 15
10.6 2/6/90 Update on Eagle River Flats/Poleline
Road Contaminated Site Studies
Summary of progress, action taken, and action required
for Eagle River Flats FY89 investigations.
William Gossweiler
UPW
None Given
12497 12498
OU-C Book 15
10.6 6/29/90
Eagle River Flats Waterfowl
Investigation Update
Review and update of the waterfowl investigation at
Eagle River Flats.
William Gossweiler
DPW
None Given
-------
Fort Richardson, Alaska Administrative Record Index Update for 1998
Page Numbers OU Cat No Date Title Abstract
12499 12500 C 10.6 11/5/90 Eagle River Flats Waterfowl
ou-c Book 15 Investigation, Fact Sheet
Fact sheet about the Eagle River Flats waterfowl
investigation.
Author
Edwin Ruff
DEH
Recipient
William Gossweiler
DPW
12501 12503 C 10.6 1/9/91 Eagle River Flats Waterfowl
ou-CBook 15 Investigation
Review of historical waierfowl investigations at Eagle William Gossweiler None Given
Rivet Flats. DPW
12504 12506 C
OU-CBook IS
10.6 2/7/91 Eagle River Flats Waierfowl
Investigation
Review of historical waterfowl investigations at Eagle William Gossweiler None Given
River Flats. DPW
06933 06935 C
OU-C Bodk 3
10.6 2/21/91 Press Release: Eagle River Flats
Report Released
Contained as an appendix to the EA for resumption of PAO
firing in the Eagle River Flats Impact Area. Release of
(he results of the report. Waterfowl Mortality in Eagle
River Flats, Alaska: The Role of Munitions Compounds.
None Given
12481 12481 C
OU-CBook 15
10.6 3/15/91 Fact Sheet: Eagle River Flats
Waterfowl Mortality
Information about waterfowl mortality at Eagle River None Given
Flats and investigations to date.
None Given
12507 12508 C
OU-CBook 15
1.0.6 3/21/91 Eagle River Flats Study-Progress
Report
Assessment of 1990 study and discussion about
resumption of firing at Eagle River Flats.
William Gossweiler None Given
DPW
-------
Fort Richardson, Alaska Administrative Record Index Update for 1998
Page Numbers OU Cat No Date Title
Abstract
Author
06940 06944 C 10.6 9/25/91 Press Release: Eagle River Flats
ou-c Book 3 Studies Continue
Contained as an appendix to the EA for resumption of PAO
firing in the Eagle River Flats Impact Area; describes
earlier and ongoing investigation results at Eagle River
Flats.
Recipient
None Given
0689806898 C 10.6 11/12/91 Notice of Availability and Public A notice ol the availability of the EA and FONSI for the William Boll
OU-C Book 2 Comment Period resumption of live-lire artillery and mortar training in Army
Eagle River Flats.
None Given
12509 12510 C 10.6 12/19/91 Eagle River Flats Update
OU-C Book 15
Summarizes 1991 ficldwork, projections for 1992 William Gosswcilcr None Given
fieldwork. and preparation of an EA to evaluate the DPW
resumption of firing into Eagle River Flats.
12511 12512 C 10.6 1/3/92 Press Release; FONSI Signed, Firing General information concerning ihe signing ol the Army
OU-C Book 15 Resumes on Eagle River Flats FONSI for the resumption of firing into Eagle River
Flats,
None Given
12513 12514 C 10.6 1/9/92 Press Release; Eagle River Flats Test Provides preliminary results of lesi firing munitions in Army
OU-C Book 15 Results Eagle River Flats
None Given
12515 12515 C
OU-C Book 15
10.6 5/13/92 Eagle River Flats Update
Brief summary of Army actions and plans to date.
Robert Wrcntmore
UHW
None Given
-------
Fort Richardson, Alaska Administrative Record Index Update for 1998
Page Numbers OU Cat No Date Title Abstract Author
12516 12516 C
OU-CBook 15
10.6 3/23/94 Eagle River Flats Waterfowl
Mortality
Brief explanation of past, current, and future research at William Gosswcilcr
Eagle River Flats. DPW
Recipient
None Given
12517 12517 C
OU-CBook 15
10.6 5/18/95 Fact Sheet: White phosphorus
Contamination of Eagle River Flats,
Fort Richardson, Alaska
Brief summary of historical Findings at Eagle River Charles Collins Laurie Angell
Flats. CRREL DPW
25416 25419 C
OU-C Book 19
'97 Update
10.6 2/27/96 Fact Sheet: Eagle River Flats
Remediation Project
A fact sheet presenting a brief history of waterfowl
deaths at Eagle River Flats.
William Gossweiler None Given
DPW
12518 12518 C
OU-CBook 15
10.9 8/14/90 Letter from Senator Frank Letter from Senator Frank Murkowski expressing
Murkowski Concerning Eagle River concern about contamination at Eagle River Flats.
Flats
Frank Murkowski
U.S. Senate
William Kakcl
USAED Alaska
18216 18239 FTR
FTR Book I
I.I 10/28/83 Evaluation of Solid Waste Disposal
Practices, Fort Richardson and
Wainwrighl, Alaska
Evaluation of solid waste disposal practices and
facilities with regard to protection of environmenlul
quality and compliance with current regulations as they
relate to sanitary landfill permitting and groundwater
monitoring.
AEHA
None Given
18240 18241 FTR
FTR Book I
1.1 7/6/90 DERP Program Review, Army
Installation Restoration Program,
FTW-D-001. Ft. Richardson Landfill
Plume Investigation
Description, history, list of contaminants, mode of
cleanup, status, issues and concerns, milestones, and
fund status of an unlined landfill at Fort Richardson.
None Given
None Given
i>f 67
-------
Fort Richardson, Alaska
Page Numbers OU Cat No Date
18242 18243 FTR 1.1 7/6/90
FTR Book 1
18244 18257 FTR I.I 1/15/92
FTR Book 1
20281 20281 FTR I.I 7/14/92
FTR Book 1
18258 18328 FTR I.I 4/8/94
FTR Book 1
26984 27086 FTR I.I 11/6/96
FTR Book 5
'97 Update
18329 18336 FTR 1.2 7/8/93
FIR Book 1
Administrative Record
Title
DERP Program Review, Army
Installation Restoration Program,
WN-D-008, All Fort Assessment,
GW Monitoring, and All Well
Installation
Installation Action Plan lor Fort
Richardson
Index Update for 1998
Abstract Author Recipient
Description, history, list of contaminants, mode of None Given None Given
cleanup, status, issues and concerns, milestones, and
fund status of the existing monitoring wells at Fort
Richardson. ', >
Review of each OU's condition and funding. USAED Alaska None Given
Closure of Solid Waste Landfill at Ft. Discussion of current situation at the landfill. Karen Klocke None Given
Richardson
Sampling and Analysis Plan,
Groundwuter Monitoring, Fort
Richardson, Alaska
Final Landfill Closure Baseline
Study. June-July 1996
Fort Richardson Landfill, June 17
1993 Inspection
DPW
Outlines the procedures for chemical contamination USAED Alaska Army
monitoring in the groundwater of Fort Richardson.
Analytical results of groundwater sampling performed USAED Alaska DPW
in June and July 1996
Summary of sue conditions reported by ADIiC alter its Kevin Klcweno Robert Wrenlmore
inspection of the landfill. AUtC DPW
-------
Fort Richardson, Alaska Administrative Record Index Update for 1998
Page Numbers OU Cat No Date Title
Abstract
18337 18400
FTR Book I
FTR 1.2.3 2/15/90
Sampling, Analysis, & QA/QC Plan
for Groundwaler Monitoring al Fort
Richardson, Alaska
Sampling and data quality procedures 10 be used in the
assessment of groundwater from existing supply wells,
monitor wells, and piezometers at Fort Richardson.
Author
USAED Alaska
Recipient
None Given
18401 18571 FTR 1.2.3 4/3/90
FTR Book I
Fort Richardson Landfill Work Plan,
Part I & II
Methods to be employed for completion of the For)
Richardson landfill hydrogeological investigation;
includes the sampling and analysis plan, site safety and
health plan, and subsurface exploration plan.
E&E
USAED Alaska
18572 18580 FTR 1.2.4 12/1/89
FTR Book I
Results of Chemical Analyses, Fon
Richardson Landfill, Groundwater
Monitoring
QA report and groundwater results, a report from
USAED Alaska, cooler receipts and chain-of-custody
forms, and diskettes with all reported data for the
landfill wells u( Fort Richardson.
James Paxton
USAED Alaska
USAED Alaska
18581 18712 FTR 1.2.4
FTR Book I
8/15/90 Draft of the Fort Richardson Landfill
Geophysical Surveys Report
The principal goal of the geophysical surveys is to help E&E
select the locution and number of monitoring wells
needed to efficiently characterize the groundwater in the
landfill area.
David Williams
USAED Alaska
18713 18784 FTR 1.2.4
FTR Book 2
6/28/91 Geouxhnical Report lor
Groundwater Monitoring Network,
Fort Richardson, Alaska
1990 chemical and hydrogeological data from two
sampling events during spring and fall 1990.
USAED Alaska
USAED Alaska
18785 18792 FTR 1.2.4 8/13/91
FTR Book 2
Bascwide Groundwaler Monitoring
Study and Landfill, Chemical QA
Data Report
Chemical QA report for the Kort Richardson bascwidc Tim Secman Lynn Fischer
groundwaler study and landfill data. USAED Alaska E&E
55 ,ij 67
-------
Fort Richardson, Alaska Administrative Record Index Update for 1998
Page Numbers OU Cat No Date Title
18793 18947
FTR Book 2
FTR 1.2.4 2/20/92 Forl Richardson Landfill Report
Abstract
Author
An investigation and report on ihe hydrogeology of, and E & E
leaching from, Ihe landfill at Fort Richardson.
Recipient
Alaska
18948 19118 FTR 1.2.4 7/16/92 Geotechnical Report for
FTR Book 2 Groundwaier Monitoring Network,
Fort Richardson, Alaska
1991 chemical and hydrogeological data from two
sampling events in May and November 1991.
USAED Alaska
Army
19119 19128 FTR 1.2.4 1/27/93 Fort Richardson and Forl Greely
FTR Book 2 Groundwaier Monitoring Well
Network Sampling Results
Results of groundwater sampling conducted at Fort Bob Wilson
Richardson in Oclober and November 1992. ENSK
Jane Smith
UEH
19129 19197 FFR 1.2.4 4/15/94 Geoiechnical Report for
FTR Buok 2 Groundwater Monitoring Network,
Fort Richardson, Alaska
Number and slate ol groundwater wells present at Fort
Richardson in 1994 and recommendations for new
wells; boring logs are provided.
USAED Alaska
Army
19198 19330 FTR 1.2.4 7/19/94 Chemical Data Report, Groundwater
FTR Book .1 Study (Spring 1994)
Results ol a groundwater quality investigation lor Forl USAED Alaska None Given
Richardson.
19331 19484
FTR Book .1
FTR 1.2.4 5/15/95
Final Addendum to the Forl
Richardson Landfill Report,
Anchorage, Alaska
As a result ol Ihe recommendation;, presented in the
1992 Forl Richardson landfill report, USAED Alaska
directs ti & E to sample, log, and monitor the
installation of ihrec additional monitoring wells at (he
Fort Richardson landfill and to complete a report
documenting the activities.
C&E
USAED Alaska
1)7
-------
Fort Richardson, Alaska Administrative Record Index Update for 1998
Page Numbers OU Cat No Date Title
19485 1950S FTR 1.4.2 10/9/90
Abstract
FTR Book 3
Final Phase, Results ot'lhe Analysis
of Solid Waste Samples, Hazardous
Waste Study No. 37-26-0474-91
Summary of ihe sampling and analysis of mure than
200 containers of potentially hazardous waste located ai
four sites on Fort Richardson.
Author
AEHA
Recipient
None Given
19509 19564
FTR Book 3
FTR 1.4.2 10/9/90
Phase 1, Results of the Analysis of
Solid Waste Samples, Hazardous
Waste Study No. 37-26-0474-91
Summary of the sampling and analysis of more than
200 containers of potentially hazardous waste located at
four sites on Fort Richardson.
AEHA
None Given
19565 19595
FTR Book 3
FTR 1.4.2 10/9/90
Phase II, Results of the Analysis of
Solid Waste Samples, Hazardous
Waste Study No. 37-26-0474-91
Summary of the sampling and analysis of more than
200 containers of potentially hazardous waste located at
four sites on Fort Richardson.
AEHA
None Given
19596 19635
FTR Book 3
FTR 2.1.4 1/15/94
Sampling Report for Groundwater
Monitoring Network at Fort
Richardson, Alaska
Summarizes new groundwater data collected from the
monitoring well network on the main containment as
well as water supply wells located on various training
ranges.
ENSR
Army
19636 19717
FTR Book 3
FTR 3.1.3 4/15/95
Areawide Community Relations
Plan, Fort Richardson, Anchorage,
Alaska
Identifies current issues of community concern
regarding known and potential contamination at Fort
Richardson and includes proposals for community
involvement activities to address these concerns.
E&E
USAED Alaska
27087 27341
FTR Book 5
'97 Update
FTR 3.1.3 4/18/96 Final Environmental Staging Facility
Work Plan, Fort Richardson, Alaska
The work plan describes the design and operation of a
contractor staging facility for support of environmental
investigations and restoration at Fun Richardson. The
proposed facility includes an equipment
decontamination area and a liquid IDW treatment
system.
ENSR
USAED Alaska
.S7«/ 67
-------
Fort Richardson, Alaska Administrative Record Index Update for 1998
Page Numbers OU Cat No Date Title
31293 31319
FTR Book 8
'¥8 Update
FTR 3.1.3 9/23/97
Work Plan and Site Safely and
Health Plan, Fort Richardson
Methane Gas Survey
Abstract
A work plan to perform a methane gas survey to meet
the requirements of the landfill closure plan. A general
overview of known site condition!!, a description of the
sampling equipment and methods to be used, and a
description of (he survey approach are presented.
Author
Han Crowser
Recipient
USAED Alaska
19718 19731 FTR 3.1.4 7/16/92 Groundwater Moniloring Network,
FTR Book 4 Fort Richardson
As part of the Fort Richardson basewide groundwater
monitoring program begun in 1990, groundwater
samples are collected and analyzed twice a year; this
report summarizes the 1991 data.
Dclwyn Thomas
USAED-Alaska
None Given
19732 19744 FTR 3.1.4
FTK Book 4
4/15/94 Installation Restoration Program
FY94 Second Quarter Update
Includes FY94 second quarter updates lor the OU-A
RI/FS management plan, OU-D, groundwater
monitoring, Polcline Road Disposal Area, and Eagle
River Flats Impact Area.
Army
None Given
19751 19751
FTR Bi.uk 4
FTR 3.1.4 5/10/94
Compliance ol Containerized Purge
Water with AWWU Discharge
Limitations
Containerized purge water resulting from the fall 1991
groundwater study is cleared lor disposal in the Fort
Richardson sewer system without violating (he Fort's
Anchorage Water and Waste Water Utility permit.
Delwyn Thomas
USAEL) Alaska
None Given
19752 19763
FTR Book 4
FTR 3.1.4 6/15/94
Installation Restoration Program,
FY94, Fourth Quarter Update
Project summaries for each OU at Fort Richardson. Army
None Given
19746 19750
FTR Book 4
FTR 3.1.4 9/15/94
Installation Restoration Program
FY94 Third Quarter Update
Includes FY94 third quarter updates for the Polcline Army
Road Disposal Area, USTs, and Eagle River Flats.
None Given
5,V../ t>7
-------
Fort Richardson, Alaska Administrative Record Index Update for 1998
Page Numbers OU Cat No Date Title
19764 19769 FTR 3.1.4 12/15/94 Installation Restoration Program
FTR Book 4 FY94 Third Quarter Update
Abstract
Includes FY94 ihird quarter updates for the OU-A
RI/FS management plan, OU-D groundwater
monitoring, Polcline Road Disposal Area, and Eagle
River Flats Impact Area.
Author
Army
Recipient
None Given
19770 19782 FTR 3.1.4
FTR Book 4
6/15/95 Installation Restoration Program
FY95 Second Quarter Update
Includes FY94 second quarter updates for ihe OU-A
management plan, OU-D groundwater monitoring,
Poleline Road Disposal Area, and Eagle River Flats
Impact Area.
Army
None Given
19783 19845 FTR 3.1.4
FTR Book 4
IO/15/95 Draft Background Data Analysis
Report
A study performed to determine the background E & E
concentrations of various chemicals at Fort Richardson,
using previously existing data for soil and groundwater.
USAED Alaska
19846 20036
FTR Book 4
FTR 3.1.4 I I/I5/95 Chemical Data Report, Groundwater
Study, Fall 1994 and Spring 1995
Data results from two sampling events conducted to
continue a basewide groundwater quality study.
USAED Alaska
None Given
27342 27463
FTR Book 6
•97 Update
FTR 3.1.4 4/1/96
Final Background Data Analysis
Report, Fort Richardson, Alaska
An analysis of analytical data at Fort Richardson to
determine background levels of various inorganic
compounds and pesticides in soil and ground water.
E&E
USAED Alaska
31320 31359
FTR Book 8
'98 Update
FTR 3.1.4 5/15/97
Landfill Closure Study, Fort
Richardson, Alaska
Presents analytical results for groundwater sampling
performed by Ihe Technical Engineering Section of
USAED Alaska. Water samples were collected from
nine of 13 monitoring wells located around the landfill
Brian D. West
USAEU Alaska
DPW
59 »/ 67
-------
Fort Richardson, Alaska Administrative Record Index Update for 1998
Page Numbers OU Cat No Date Title ' Abstract
31360 31371 FTR 3.1.4 12/15/97 Installation Restoration Program
KTR Hook 8 FY97 Fourth Quarter Update
•98 Update
Presents a summary of environmental restoration
projects at Fort Richardson.
Author
Army
Recipient
Public
20037 20037 FTR 3.1.5 11/16/95 Comments, Background Data
FTR Book 4 Analysis Report, October 1995
Comments on the background data analysis report.
Louis Howard
A DEC
Kevin Gardner
DPW
20038 20041 FTR 3.1.5 12/7/95 Comments on the Background Study Comments on the background data analysis report. Matthew Wilkening Kevin Gardner
FTR Book 4 for Fort Richardson EPA DPW
27464 27476 FTR 3.1.5 1/1/97 Installation Restoration Program, FY Includes FY96 third and fourth quarter updates lor OU- USAED Alaska
FTR Book 6 96, Third and Fourth Quarter Updates A' OU-B, OU-C, and OU-D; UST; and community
'97 Update relations plan.
None Given
27477 27841 FTR 3.2 2/1/96 Geolechnical Report for A study to provide additional information and
FTR Book 6 Groundwater Monitoring Network, understanding of the groundwater regime at Fort
•97 Update Fort Richardson. Alaska Richardson.
USAED Alaska USAED Alaska
27842 28204 FTR 3.2 5/10/96 Chemical Data Report, Groundwaler Presents sample results lor 60 wells sampled during USAED Alaska
FTR Book 6 Study, Fall 1995, Fort Richardson, October 1995 as part of the biannual post wide
•«7 Update Alaska groundwater study.
None Given
t>7
-------
Fort Richardson, Alaska Administrative Record Index Update for 1998
Page Numbers Oil Cat No Dale Title Abstract Author
28205 28212 FTR 3.3
FTR Book 7
•97 Update
28213 28242 FTR 4.3
FTR Book 7
•97 Update
20042 20066 FTR 6.1
FTR Book 4
20067 20144 FTR 7.4
FTR Book 4
5/23/96 Memorandum: Final Background
Data Analysis Report, Fort
Richardson, Alaska
12/24/96 Draft Approach Documcnl, Poslwide
Risk Assessment
3/28/94 Fort Richardson Environmental
Restoration Agreement
12/20/94 Federal Facility Agreement Under
CERCLA
Minor errors were found on a lew pages of the final Elaine Hourigan
Background Data Analysis Report, Fort Richardson, USAED Alaska
Alaska. The errata sheets have the correct information
and should be included in the report.
Presents a proposed methodology for generating a Army
basewide RA based on RAs conducted for all OUs and
sites addressed under the Federal Facilities Agreement.
Executed Two-Parly Agreement between the Army and Breck Tostevin
ADEC. Alaska Attorney General
Presents (he EPA requirements for hazardous waste site Dean Ingemansen
investigation and remediation work to be completed at EPA
Recipient
Kevin Gardner
OPW
None Given
Thomas Cook
CofS
Thomas Cook
CofS .
Fon Richardson.
20145 20152 FTR
FTR Book 4
8.1 2/1/95 ATSDR Site Summary and Site
Ranking
ATSDR site summary and site ranking for Fort Sandra Isaacs
Richardson. PHS
Thomas Nccdham
CO
28243 28272
HTR Book 7
•97 Update
FTR 8.1 7/23/96
Public Health Assessment for Fort
Richardson, CERCLIS No.
AK62I4522I57
A Public health assessment was conducted for each site
within each OU. The public health assessment
compiles and analyzes relevant health and
environmental data, community health concerns, and
contaminant exposure pathways.
Max Huwie
Army Toxicology Division
Kevin Gardner
DPW
01 nj 67
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Fort Richardson, Alaska Administrative Record Index Update for 1998
Page Numbers OU Cat No Date Title Abstract
20153 20154 FTR 10.0 7/13/95 Administrative Record Review
FTR Book 4 Meeting Minutes
Meeting minutes concerning the approach tor the
administrative record for Fort Richardson.
Author
Louise Flynn
E&E
Recipient
None Given
20159 20161 FTR 10.1 3/3/95 Comments, Community Relations Review comments on the Fon Richardson community Matthew Wilkening Kevin Gardner
FTR Book 4 p|an, Fort Richardson relations plan. EPA DHW
20155 20155 FTR 10.1 9/21/95 Comments. Administrative Record ADEC comments concerning documents in the Louis Howard Kevin Gardner
FTR Book 4 administrative record for Fort Richardson. ADEC DPW
20156 20158 FTR 10.1 10/10/95 Comments, Administrative Record EPA comments concerning documents in the
FTR Book 4 administrative record.
Matthew Wilkeninj; Kevin Gardner
EPA UPW
20162 20162 FTR 10.2 10/25/94 Fort Richardson Community
FTR Book 4 Relations Plan Interview Questions,
Draft
Interview questions tor the public regarding the Janet Kaps
CERCLA/Superfund process at Fon Richardson. E & E
None Given
20166 20166 FTR 10.3 5/15/94 National Priorities List, Fort
FTK Book 4 Richardson, Anchorage, Alaska
Uriel summary of proposed siies for ihe NPL. EPA
None Given
o.' a/ f>7
-------
Fort Richardson, Alaska Administrative Record Index Update for 1998
Page Numbers OU Cat No Date Title Abstract
Author
20170 20259 FTR 10.4 7/15/95 Summary Report of the Fort
FTR Book 4 Richardson Information Meeting
Held June 29, 1995, Anchorage,
Alaska
Summary of the public meeting regarding (he status of E & E
environmental cleanup at Fon Richardson.
Recipient
USAED Alaska
28280 28357 FTR 10.4 3/14/96 Summary Report, Fort Richardson Summarizes the March 14, 1996. public meeting to E&E
FTR Book 7 Public Meeting, March 14, 1996, inform citizens of Anchorage and Fort Richardson
•97 Update Anchorage Alaska about the progress at the four OUs at Fort Richardson.
USAED Alaska
31372 31448 FTR 10.4 3/19/97 Meeting Minutes, Fort Richardson Meeting minutes and support documents from a March Army
FTR Book 8 Restoration Advisory Board Public 19, 1997 public meeting held at Russian Jack Chalet.
•»8 tpdau Information Meeting
Public
31449 31465 1-TR 10.4 10/9/97 Restoration Advisory Board Meeting Minutes IromtheOctober9, 1997, meetingol'ihc Fon Thomas Reed KcvinGardner
FTK Hooka Minutes Richardson Restoration Advisory Board. USAED Alaska DPW
'98 Update
31466 31482 FTR 10.4 11/19/97 Draft Meeting Minutes from October Contains meeting minutes and other documentation David Brown
FTR Book 8 9, 1997 Restoration Advisory Board from lne October 9, 1997, Restoration Advisory Board DPW
'98 Update Meeting. meeting conducted at the Russian Jack Chalet.
Restoration Advisor
20163 20165 FTR 10.6 6/18/93 EPA News: National Priorities List Press release reporting the proposal ol'Fori Richardson EPA
FTR Book 4 Proposal on the NPL.
None Given
6J „] 67
-------
Fort Richardson, Alaska Administrative Record Index Update for 1998
Page Numbers OU Cat No Date Title Abstract
20260 20263 FTR 10.6 6/1/94 Draft Press Release: Forl Richardson Fon Richardson is placed on the NPL.
FTR Book 4 on the National Priorities List
Author
Army
Recipient
None Given
20167 20167 FTR 10.6 6/1/94 EPA News Release: Fort Richardson Fon Richardson is placed on the NPL.
FTR Book 4 on the National Priorities List
EPA
None Given
20168 20168 FTR 10.6 10/30/94 Fort Richardson Schedule lor
FTR Book 4 Superfund Investigation
List ol OUs and due dates tor associated RI/FS
management plans.
Matthew Wilkcning None Given
EPA
20169 20169 FTR 10.6
FTK Book 4
6/5/95 Public Meeting Notice lor Fort
Richardson, in Environmental
Restoration News
Public meeting notice lor Fort Richardson.
Kevin Gardner
DPW
None Given
20264 20264 FTR 10.6
FTR Book 4
6/6/95 Fort Richardson Public Meeting
Background, action taken, and action required lor a Kevin Gardner
public meeting to describe the Fort Richardson Federal L)PW
Facilities Agreement.
None Given
20265 20272 FTR 10.6 6/15/95 Environmental Restoration News,
FTR Book 4 Vol. I, No. I
Review of [he Superfund process at Fort Richardson Army
and announcement of the public meeting.
Public
Mo) t>7
-------
Fort Richardson, Alaska Administrative Record Index Update for 1998
Page Numbers OU Cat No Date Title Abstract
20273 20280
FTR Book 4
FTR 10.6 10/15/95
Environrnenial Restoration News,
Vol. I, No. 2
Author
Provides the status of the Oils, and discusses the June Army
29, 1995, public meeting and remediation technologies.
Recipient
Public
31483 31488
FTR Book 8
'98 Update
FTR 10.6 1/15/96
Environmental Restoration News,
Vol. 2. No. 1
This document provides an update on OU-A, OU-B,
OU-C, and OU-D. Includes a questionnaire to
determine public interest regarding formation of a
Restoration Advisory Board. Defines what a PSE is.
Army
Public
28273 28273
FTR Book 7
•97 Update
FTR 10.6 4/1/96
Public Notice. Establishment of
Administrative Record
The notice announces the establishment of the Fort
Richardson administrative record at Fort Richardson
and the information repositories
USAED Alaska
Public
31489 31492
FTR Book 8
'98 Update
28274 28274
FTR Book 7
'97 Update
FTR 10.6 4/15/96
FTR 10.6 5/1/96
Environmental Restoration News,
Vol. 2, No. 2
Public Notice: Public Health
Assessment for Fort Richardson
This document provides an update on OU-A, OU-B, Army
OU-C, and OU-D. Presents results of the Restoration
Advisory Board questionnaire. Also discusses the Fort
Richardson background data analysis study; the UST
restoration compliance agreement; and information
about a public meeting on March 14, 1997, at the
Russian Jack Chalet.
The notice announces availability of the public health ATSDR
assessment for Fort Richardson as completed by the
ATSDR.
Public
Public
28275 28278
FTR Book 7
'97 Update
FTR 10.6 7/1/96
Environmental Restoration News,
Vol. 2, No. 3
This document provides an update on the Restoration
Advisory Board and information about the Two-Party
Agreement sites at Fort Richardson. Also, explains the
Supcrlund process and provides updates on OU-A, OU-
B, OU-C, and OU-D.
Army
Public
65 <»/ 67
-------
Fort Richardson, Alaska Administrative Record Index Update for 1998
Page Numbers OU Cat No Date Title
28279 28279
FTR Book 7
'97 Update
31493 31496
FTR Book 8
'98 Update
FTR 10.6 9/22/96
FTR 10.6 10/15/96
Public Notice: Forl Richardson
Advisory Board Membership
Environmental Restoration News,
Vol. 2, No. 4
Abstract
The Army invites the public 10 participate in the
decision-making process tor the environmental cleanup
of Fort Richardson by completing and mailing
Restoration Advisory Board interest forms. All names
received will be added to the Fort Richardson
Restoration Advisory Board mailing list.
This document provides an update on OU-A, OU-B,
OU-C, OU-D, and the Restoration Advisory Board.
Author
Army
Recipient
Public
Army
Public
31497 31500
FTR Book 8
'98 Update
FTR 10.6 3/7/97
Fact Sheet: Establishment of
Restoration Advisory Board
An information packet to invite the Fort Richardson and Army
Anchorage communities to participate in the decision-
making process during environmental investigation and
cleanup activities at Forl Richardson.
Public
31501 31506
FTR Bonk 8
'98 Update
1-TR 10.6 3/15/97
Environmental Restoration News,
Vol. 3, No. 4
This document provides an update on OU-A, OU-B,
OU-C, and OU-D, and information about a public-
meeting on January 29, 1997, at the Russian Jack
Chalet. Also defines the Superfund process and what a
proposed plan is.
Army
Public
31507 31510
FTR Book 8
•98 Update
FTR 10.6 3/19/97
Public Notice: Establishment of a
Restoration Advisory Board
Public notice placed in the Anchorage Daily News and
Alaska Star concerning a public meeting to establish a
Restoration Advisory Board.
DPW
Public
31511 31514
FTR Book 8
'98 Update
FTR 10.6 9/15/97
Environmental Restoration News,
Vol. 3, No. 2
This document provides an update on the Restoration Army
Advisory Board and information uboul a public meeting
on March 19. 1997, at the Russian Jack Chalet. Also
defines the Superfund process and provides updates on
OU-A, OLI-IV OU-C. and OU-D
Public
Mini ti?
-------
Fort Richardson, Alaska Administrative Record Index Update for 1998
Page Numbers OU Cat No Date TiUe Abstract Author Recipient
31515 31515 FTR 10.6 10/4/97 You Are Invited to Discuss Forl A public notice that appeared in (he Anchorage Daily Army Public
FTR Book 8 Richardson Environmental Cleanup News inviting the public to a Restoration Advisory
'98 Update Issues Board meeting at the Russian Jack Chalet on Thursday,
October 9, 1997.
67,ij 67
-------
Appendix B
Responsiveness Summary
ANOTHM93 DOC/980470002
-------
APPENDIX B
Responsiveness Summary
Overview
The U.S. Army Alaska (Army), U.S. Environmental Protection Agency (EPA), and Alaska
Department of Environmental Conservation (ADEC), collectively referred to as the
Agencies, distributed a Proposed Plan for remedial action at Operable Unit C (OU-C), Fort
Richardson, Alaska. OU-C consists of two source areas: the Eagle River Flats (ERF), an
ordnance impact area, and the former Open Burning/Open Detonation (OB/OD) Pad.
The Proposed Plan identified the preferred remedial alternative for ERF. No cleanup action
was recommended for the former OB/OD Pad. Institutional controls that control access to
the OB/OD Pad will continue. The major components of the remedial alternative for ERF
are as follows:
• Treatment of white phosphorus-contaminated sediment by draining ponds with pumps
and allowing sediments to dry and the white phosphorus to sublimate and oxidize
• Application of cap-and-fill material to areas of ponds that do not drain and dry
sufficiently to enable the white phosphorus to sublimate and oxidize
• Long-term monitoring of waterfowl use, waterfowl mortality, and white phosphorus in
sediment
• Sitewide institutional controls
Four written comments and one verbal comment about the Proposed Plan for OU-C were
received during the public comment period. The comments consisted of from one to several
specific questions or statements from each commenter. The comments are summarized and
presented in this Responsiveness Summary.
Background of Community Involvement
The public was encouraged to participate in selection of the final remedy for OU-C during a
public comment period from February 5 to March 6,1998. The Proposed Plan for Cleanup
Action at Operable Unit C, Fort Richardson, Alaska, presents four options considered by the
Agencies to address contamination in sediments at ERF. The Proposed Plan was released to
the public on February 4, and copies were sent to all known interested parties, including
elected officials and concerned citizens. Informational Fact Sheets, prepared quarterly since
July 1995, provided information about the Army's entire cleanup program at Fort
Richardson and were mailed to the addresses on the same mailing list.
The Proposed Plan summarizes available information about OU-C. Additional information
was placed into three information repositories: the University of Alaska Anchorage
Consortium Library, Alaska Resources Library, and Fort Richardson Post Library. An
Administrative Record, including all items placed into the information repositories and
other documents used in the selection of the remedial action, was established in
ANCAKB220.DOC /981150001 8-1
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RESPONSIVENESS SUMMARY
Building 724 on Fort Richardson. The public was encouraged 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 by mailing comments to the Fort Richardson project manager, by calling a toll-free
telephone number to record a comment, or by attending and commenting at a public
meeting conducted on February 12,1998 at the Russian Jack Springs Chalet in Anchorage.
The proceedings of the meeting were recorded by a court reporter, and the transcript
became a part of the Administrative Record for OU-C.
Basewide community relations activities conducted for Fort Richardson, which include
OU-C, have consisted of the following:
• December 1994—community interviews with local officials and interested parties
• April 1995—preparation of the Community Relations Plan
• June 1995—distribution of an informational Fact Sheet covering all OUs at Fort
Richardson
• June 29,1995—an informational public meeting covering all OUs
• October 1995—distribution of an informational Fact Sheet covering all OUs at Fort
Richardson
• January 1996—distribution of an informational Fact Sheet covering all OUs at Fort
Richardson
• March 1996—establishment of informational repositories at the University of Alaska
Anchorage Consortium Library, Alaska Resources Library, Fort Richardson Post
Library, and Administrative Record at Building 724 on Fort Richardson
• March 14,1996—an informational public meeting covering all OUs
• April 1996—distribution of an informational Fact Sheet covering all OUs at Fort
Richardson
• July 1996—distribution of an informational Fact Sheet covering all OUs at Fort
Richardson
• October 1996—distribution of an informational Fact Sheet covering all OUs at Fort
Richardson
• March 1997—distribution of a Fact Sheet soliciting interest from the community for the
formation of a Restoration Advisory Board (RAB) to support Fort Richardson
• September 1997—distribution of an informational Fact Sheet covering all OUs at Fort
Richardson
• October 1997—first Fort Richardson RAB meeting convened
• February 1998—second Fort Richardson RAB meeting convened
8-2 ANC/LKB220.DOC/981150001
-------
RESPONSIVENESS SUMMARY
Community relations activities specifically conducted for OU-C included the following:
• February 8, 9,10,11, and 12,1998-display advertisement announcing the public
comment period and public meeting in the Anchorage Daily News
• February-5,1998-display advertisement announcing the public comment period and
public meeting in the Alaska Star
• February 5,1998-distribution of the Proposed Plan for final remedial action at OU-C
• February 5 to March 6,1998-30-day public comment period for final remedial action at
OU-C
• February 5 to March 6,1998-availability of a toll-free number for citizens to provide
comments during the public comment period. The toll-free number was advertised in
the Proposed Plan and the newspaper display advertisement that announced the public
review period.
• February 12,1998-public meeting at the Russian Jack Springs Chalet to provide
information, a forum for questions and answers, and an opportunity for public
comment about OU-C
Summary of Comments Received During the Public Comment Period
and Agency Responses
Verbal Comment from the Public Meeting
Comment: My name is John Schoen and I'm representing the Alaska Audubon Society. I
certainly commend the Army for going ahead and trying to resolve this problem. It's a very
serious problem. And we support Alternative Three with minimal capping and filling. In
other words, we would like to see the wetlands and waterfowl habitat maintained as much
as we can, as long as there's no poison out there in the environment. But seems like
Alternative 3 is the best solution to us in terms of maintaining habitat and getting rid of the
white phosphorus. So thanks for the good work. We'd like to see the effort continue so that
we can reduce the problem as best we can in the long run.
Response: The Agencies appreciate input from community members.
Comment: I'm George Matz, president of Anchorage Audubon Society. And just
reviewing the material on this, it is tremendously important work that they're doing. I hope
to see it continue.
Response: The Agencies appreciate input from community members.
Written Comments
Comment: I [George Matz, Anchorage Audubon Society] was at the meeting last night
and I gave some comments during the break commending Fort Rich for this effort.... One
thing I forgot to mention is that Anchorage Audubon endorses the Alternative 3 that you
have in your plan. It looks like the most, not only effective in terms of rehabilitation but
most cost effective. I just wanted to have that on the record.
ANGLKB220.DOC *81150001 B-3
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RESPONSIVENESS SUMMARY
Response: The Agencies appreciate input from community members.
Comment: We [the Anchorage Waterways Council, Eric Paule, President] are pleased to
learn that the cleanup of the Eagle River Flats is proceeding. After reviewing the Proposed
Plan for Cleanup Action at Operable Unit C, Fort Richardson, Alaska we have the following
questions:
Question 1: During the pumping process utilized in Alternative 3, what is the possibility
that some of the white phosphorus could become suspended in the water column and be
transported to the pumping location?
Response: In the sediment and surface water at ERF, white phosphorus generally exists
in two sizes: smaller colloids (microgram-sized) and larger particles (milligram-sized). Both
sizes have persisted over time in the sediment. Laboratory and field experiments indicate
that the colloids are readily suspended, but there is no evidence that the larger particles can
be resuspended or transported. The smaller colloids can remain suspended for long periods
(approximately 40 seconds), whereas the larger particles settle in less than 1 second. The
larger particles are the ones of concern in relation to dabbling ducks and lethal white
phosphorus doses. More information regarding the fate and transport of white phosphorus
is provided in Section 5.4 of the May 1997 Operable Unit C Final Remedial Investigation (El)
Report.
Question 2: In the documentation, it is not clear where the pond water will end up;
please clarify.
Response: Pumped water will be transported from white phosphorus-contaminated
ponds to neighboring gullies through an 8-inch, a 10-inch, or a 12-inch pipeline. These
gullies feed to the Eagle River, which leads to the Knik Arm. More information about
Alternative 3 is presented in Appendix C of the September 1997 Operable Unit C Final
Feasibility Study (FS) Report. Itemized components are listed in the cost estimate
(Appendix E of that report).
Question 3: Where has the AquaBlok™ been used before and with what success rate?
Response: The use of AquaBlok™ as a cap for contaminated pond bottoms has been
evaluated first by bench-scale testing (1993) and then by treatability testing (1-acre in 1994)
at ERF. Results show that AquaBlok™ will not destroy habitat, but it may alter it.
Applications of AquaBlok™ will be limited to deeper portions of ponds. The feeding
habitat represented by the covered bottom sediments will be reduced until habitat is
reestablished. Sedimentation and plant establishment of the top of the AquaBlok™ are
expected to restore these areas for waterfowl feeding; however, the pond depth will be
permanently altered. It has been demonstrated that within 1 year of initial application,
vegetative growth over the barrier becomes lush and is inhibited only in areas where the
AquaBlok™ was the thickest. Fish and invertebrates also were observed in ponded areas
treated with AquaBlok™ . The new vegetation provides areas where waterfowl can hide or
loaf. Additional information about the performance of AquaBlok™ at ERF can be found in
Appendix C of the September 1997 final FS report. In addition, it has been reported that, on
a separate project, AquaBlok™ was planned for use in covering a section of the Ottawa
River to prevent polychlorinated biphenyls from flowing into Lake Erie.
Question 4: Has AquaBlok™ been used in cold regions before?
B-4 ANOLKB220.DOC/981150001
-------
RESPONSIVENESS SUMMARY
Response: Yes, as mentioned in the previous response, AquaBlok™ has been tested at
ERF. Ice-plucking is a concern in areas close to Eagle River. However, none of the
contaminated ponds that may be capped and filled are located close to the river.
Question 5: _The documentation does not specify the thickness of AquaBlok™ barrier;
please clarify.
Response: Approximately 5 to 10 centimeters (cm) of AquaBlok will be applied. The
material is expected to swell to 20 to 30 cm. Changes in AquaBlok™ thickness through time
(of material installed in 1994) are as follows:
1994 1995 1996
Center of AquaBlok™ drop approx. 30cm 20.3cm 20.0cm
Level ground 6.2 cm 5.2 cm 9.8 cm
Craters 16.0cm 14.5cm 7.4cm
The thickness of AquaBlok™ decreases over rime in the craters as the material sloughs from
the sides of the craters. A thicker layer of AquaBlok™ may be applied over craters. Areas
with craters will be closely monitored. More detailed information is provided in Appendix
C of the September 1997 final FS report.
Question 6: If the AquaBlok™ material supports vegetative growth, over time, would the
integrity of the barrier be compromised? What is the life span of the barrier?
Response: The reestablishment of vegetative habitat will improve the barrier
effectiveness of the material. The primary intent of AquaBlok™ is to prevent waterfowl
from feeding in contaminated sediment. Therefore, the barrier is not intended to be
hydraulically impermeable. The AquaBlok™ installed in 1994 is still performing to
specifications. Through time, the performance of the cover material is expected to continue
to improve with vegetative regrowth and sedimentation.
Question 7: If the AquaBlok™ will not be immediately available for revegetation, is a
thin layer of soil being considered to facilitate revegetation?
Response: Vegetation rebound is expected to occur within 1 to 2 years of application. A
thin layer of soil is not expected to be necessary to reestablish regrowth.
Question 8: Alternatives 1,2, and 4 are the least desirable remediation methods. We
would tend to agree with the documentation that 1 and 2 would not be the most proactive
method for remediating the problem and Alternative 4, permanent removal of the duck
habitat, is not an acceptable option to AWC.
Response: The Agencies appreciate input from community members.
Question 9: In the documentation, it is unclear if Alternative 3 will be carried out
consecutively or concurrently. If consecutively, would there be hazing on the ponds where
there is no remediation activity?
ANC1KB220.DOC /981150001 85
-------
RESPONSIVENESS SUMMARY
Response: Alternative 3 will likely be carried out consecutively. Therefore, hazing will
be performed in contaminated areas that are awaiting treatment.
The following five comments are from Alaska Community Action on Toxics, a project of the
Alaska Conservation Foundation, Pamela Miller, Project Director.
Comment 1: We are concerned about the level of damage and alteration of the Eagle River
flats wetlands caused by past and present detonation and burning of munitions within and
around the salt marsh and riparian habitat. The Eagle River riparian zone and delta are
ecologically significant and sensitive areas that must not be subjected to further abuse.
Munitions and explosives testing must stop immediately to prevent additional damage and
disruption of the hydrology and ecology of the Eagle River wetlands. Computer simulations
should be used instead of testing in such a fragile environment, if weapons must be
"tested."
Response: The issue being addressed by this Proposed Plan is remedial action at OU-C
for contamination from white phosphorus. Military uses of the ERF Impact Area not related
to remedial actions for white phosphorus contamination are not within the focus of this
plan.
Comment 2: The Army should intensively focus on the hydrological and ecological
restoration of the Eagle River wetlands. The Army should strive to remove UXO, spent
munitions, and white phosphorus to minimize continuing and long-term damage to the
environment, wildlife, human health and safety. While it is commendable that the Army
has ceased testing of white phosphorus in the Eagle River wetlands, all explosives testing
should also cease to prevent further environmental damage and human health and safety
hazards.
Response: The Army is presenting remedial action methodologies in the Proposed Plan that
are least disruptive to the hydrology and ecology of the ecosystem. Issues related to military
uses of the ERF Impact Area to fulfill its national security training mission that are not
related to the remedial action for white phosphorus contamination are not relevant to this
plan.
Comment 3: We question the assertion in the Proposed Plan that sampling during the RI
"found that all contaminants identified at OB/OD Pad were at levels low enough that
cleanup is not required." Recent studies demonstrate widespread contamination from
munitions at such bases as the Massachusetts Military Reserve Camp Edwards, the Army
Grafenwohr Training Area in Germany, and Fallen NAS. Large quantities of heavy metals
such as lead, copper, zinc, cadmium, as well as arsenic were deposited within and around
the weapons ranges. At the Grafenwohr Training Area, surface soils contaminated with
heavy metals had to be classified as hazardous waste (measured through toxic
characterization leaching procedures). The vegetation was contaminated with heavy metals.
At other sites, toxic components of the explosives/propellants contaminate ground and
surface waters with such chemicals as RDX, nitrobenzene, nirrotoluene, and
trinitrobenzene. Open detonation and burning could result in the formation of persistent
and toxic chemicals such as dioxins and furans. We are not convinced that an adequate
sampling program has been undertaken which identifies the nature and extent of
contamination and exposure pathways.
B-6 ANOIKB220.DOC ,'981150001
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RESPONSIVENESS SUMMARY
Response: An RI sampling program was conducted in 1996 to estimate the extent of
contamination at OB/OD Pad. The RI considered the past use of OB/OD Pad related to the
specific types and amounts of munitions that were disposed, the length of time the disposal
occurred, and-the physical features of the pad that would determine the fate and transport
of suspected .contamination. The RI also included a risk assessment that considered the
representativeness and validity of the samples collected within the pad to ensure they
represented the current conditions at the site, both from a contamination perspective as well
as from a geological, hydrogeological, and biological perspective. A direct comparison of
site-specific data needed for OB/OD Pad with data needed at other munitions bases would
not be helpful in determining site risks at OB/OD Pad and future action that may be
needed, because of the differences in chemicals used, time period of use, and the physical
features of the site that determine the fate and transport of suspected chemicals. Detailed
information about detected concentrations and extent of contamination can be found in
Section 6 of the May 1997 final RI report.
Comment 4: Action should be taken to oxidize the white phosphorus and render it
harmless to waterfowl. This should be done with as little damage to the hydrology and
ecology of the wetlands as possible. Alternative 3, with an emphasis on pond draining by
pumping, should be used in lieu of additional breaching with explosives. We prefer that
additional filling and capping be minimized to prevent further alteration to the habitat.
/
Response: White phosphorus will oxidize and sublimate under Alternative 3 with little
damage to the hydrology and ecology of the wetlands. No large-scale pond breaching will
be conducted; only limited localized explosives work will be performed to improve
drainage between ponds. Use of explosives is only anticipated in small areas to provide a
place for the pump to be located.
Comment 5: One alternative that the Army has not explored in the Proposed Plan is
oxidation through enhanced aeration, microbial activity, a workable form of
bioremediation. We understand that the white phosphorus will not break down in an
anaerobic environment, but it might be possible to enhance degradation using a
combination of aeration and oxidizing bacteria. The EPA Profile on White Phosphorus
states that polyphosphates are hydrolyzed by water and soil microorganisms indigenous to
the area.
Response: The Army has performed several studies on enhanced sublimation and
oxidation technologies. Air sparging was tested at a bench-scale level to determine whether
introducing air into white phosphorus-contaminated sediment would oxidize white
phosphorus. Laboratory scale tests also were performed to determine whether hydrogen
peroxide could be used to oxidize white phosphorus. Both technologies were ruled out
because of low effectiveness as well as implementability and/or safety issues. A field-scale
test of enhanced biodegradation with the use of sediment warming also was implemented.
Although sediment temperatures did increase, the increase was not sufficient to overcome
saturated conditions to foster white phosphorus sublimation.
The following two comments are from Elaine T. Swearingen.
Comment 1: If I understand the proposal correctly, the ultimate goal is to lose no more
than 50 birds per year. Currently, 1000 birds are lost, and the plan is to spend upwards of
$6M-$9.2M over the next 15 years to save 950 birds. That puts a value on the birds of S6.3K-
ANOIKB220.DOC/981150001 B-7
-------
RESPONSIVENESS SUMMARY
S9.7K each. I find those figures ludicrous. Over the next 15 years, hunters will actually pay
the state for the joy of shooting the birds, while the Federal government is proposing
spending severely restricted Federal dollars to save many of the same birds.
Response: By-using the assumptions presented in the Proposed Plan and in the above
comment, the cost per duck under Alternative 3 over 15 years would be 5421. Alternative 3
is estimated to cost approximately $6 million. 950 birds are estimated to be saved per year.
The cost per duck decreases if one considers that remedial action objectives, a re expected to
be maintained for many years after the 20-year monitoring time frame. Over 50 years and
100 years, the costs per duck are $126 and $63, respectively.
Comment 2: I recommend that signs posted on the Eagle River Flats read: "Don't eat what
you shoot on the Eagle River Flats." I would also submit to you that, should the Federal
government move ahead with this proposal, a letter will go to the Fraud, Waste and Abuse
hotline. As a taxpayer, I deeply resent that a proposal of this type has reached the stage it
obviously has without some voice of reason saying, "enough!". Although I applaud efforts
to clean up the environment, I strongly feel that simply having Federal fenced dollars
available does not suggest that those dollars must be spent. I believe that there should be a
stated value to the taxpayer. I do not find a rational value stated in this proposal.
Response: The human health risk assessment included an offsite hunter exposure
scenario and concluded that there is a very low risk to human health from consumption of
contaminated ducks. The low risk was due primarily to the amount of white phosphorus
potentially contained in a harvested duck and the number of ducks that would need to be
consumed for a human to receive a harmful dose of white phosphorus. Although hunting is
banned at Eagle River Flats, the risk assessment acknowledged that ducks may reside
temporarily in the area prior to being hunted in other parts of Cook Inlet. The percentage of
ducks hunted in the Cook Inlet area that have resided in ERF is very small, however,
further reducing the likelihood of white phosphorus exposure to humans from eating
contaminated harvested duck. On the basis of hunting statistics compiled by the Alaska
Department of Fish and Game and the risk assessment results, the Agencies concluded that
warning signs for consuming ducks are not warranted.
8-8 ANOIKB220.DOC/981150001
-------
Appendix C
Baseline Cost Estimates for Remedial Alternatives,
Operable Unit C Source Area, Fort Richardson
ANC/TRM93.00C/980470002
-------
APPENDIX C
Baseline Cost Estimates for Remedial
Alternatives
The following cost estimate spread sheets are included in this appendix:
• ERF-wide monitoring and Alternative 2 costs (presented by pond group), pages C-2 to
C-12
• Alternative 3 (Preferred Alternative) costs, page C-13
• Alternative 4 costs, page C-14
• Alternative 5 costs, page C-15
Costs were based on assumptions presented in the Final Operable Unit C Feasibility Study,
as well as capital and operation and maintenance costs for treatabiliry studies performed in
1996,1997, and 1998.
A table summarizing the cost estimates is provided below.
Cost Estimates for Cleanup Action Alternatives
Average Annual O&M1 20 Year O&M Total Cost-
Capital Cost Present Worth Present Worth2 20 Year O&M3
Location ($000) ($000) ($000) ($000)
Alternative 1 -No Action 0 0
Alternative 2-Detailed 150 286
Monitoring
Alternative 3-Pumping with 251 272
Capping and Filling
Alternative 4-Breaching and 2,064 353
0 0
5,700 5.850
5,434 5,685
7,068 9.132
Pumping with Capping and
Filling
Alternative 5-Capping and
Filling
2,694
174
3,471
6,165
Notes.
1 O&M = Operation and maintenance
2 Present worth means costs are expressed as U.S. dollars in 1998. The amount indicates monies needed in 1998 to
complete the project over 20 years. The majority of these costs will be used to achieve the 5-year cleanup goal. A
discount rate of 5 percent is used.
3 Costs include ERF-wide long-term monitoring.
ANC/rraml79.ooc/981140002
C-i
-------
Cost Estimate
Eagle River Flats
ERF-Wide Monitoring
6/25/97
Description
Annual O&M Costs
Telemetry
Aerial bird population surveys
Aerial bird population survey of ERF
Aerial bird population survey of Upper Cook Inlet
Aerial photography
ERF Remediation database maintenance
Hazing
O&M Subtotals
YearO
Year 1
Years
Year 3
Year 4
Years
Year 6
Year?
Years
Year 9
Year 10
Year 11
Year 12
Year 13
Year 14
Year 15
Year 16
Year 17
Year 18
Year 19
Present Worth ERF-wide monitoring cost (10-years. i=5%)
Present Worth ERF-wide monitoring cost (20-years. u5%)
Quantity Unit
Unit Cost Frequency
Incorporated into Alternative 2
40 survey
25 survey
2 annually
$400 /survey
$1,240 /survey
$12.900 ea
Cost
$ • 177,500
$ 16,000
$ 31,000
$ 25.800
$ 114,000
$ 30,000
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
394,300
394,300
394.300
394,300
394,300
364,300
364.300
364,300
364,300
364,300
364,300
364,300
364,300
364,300
364,300
364,300
364,300
364,300
364,300
364,300
$2,942,912
$4,669,868
ANC/T
.xls/981140001
-------
Cost Estimate
Eagle River Flats
Description
Capital Costs
Pond Survey
CRREL Engineer, field
CRREL Jr. Engineer, field
CRREL Technician, field
UXO clearance technician
UH-1 helicopter
Baseline WP Sampling
Sublimation Conditions Monitoring Equipment
Monitoring syst., data logger, sensors, w.l. indicator
Monitoring syst., data logger, sensors
Monitoring syst., sensors
Alternative 2 - Detailed Monitoring
Northern A Ponds
6/25/97
Quantity Unit
12 hr
12 hr
12 hr
8 hr
4 hr
16 site
2 ea
0 ea
0 ea
Unit Cost
$86.91 /stafl-hr
$64.65 /staff-hr
$30.66 /statl-hr
$80.00 /starf-hr
$547 /hr
$870.38 /site
$4,000 ea
$3,000 ea
$1,000 ea
Frequency
1 staff
1 staff
1 staff
1 staff
Cost
$1,043
$776
$368
$640
$2,188
$13,926
Subtotal
$8.000
$0
$0
$5.015
$ 13,926
8.000
Direct Cost
Bid Contingencies
Scope Contingencies
Subtotal
15 percent
20 percent
$26,941
$4,041
$5,388
$36,370
COE Administration
Reporting
Permitting and Legal
Bonding and Insurance
Subtotal
Total Capital Costs
O&M Costs
Annual sedimentation monitoring
Annual setup of monitoring equipment
Number of monitoring system installations
CRREL Engineer, field
CRREL Engineer, lield
CRREL Jr. engineer, field
CRREL staff per diem
UH-1 helicopter
10 percent
5 percent
5 percent
3 percent
2 system
4 hr/system
4 hr/system
4 hr/system
2 start
0 25 hr/syslem
$86.91 /hr
$86.91 /hr
$64.65 /hr
$339.06 /slatl-day
$547 /hr
2 systems
2 systems
2 systems
2 day
2 systems
$3,637
$1,819
$1.819
$1,091
$8,365
$44,735
$13,200
$ 13.200
$695
$695
$517
$1.356
$274
$ 3.538
ANC/Trm178.xlS/981140001
C-3
-------
Cost Estimate
Eagle River Flats
Annual removal of monitoring equipment
Number of monitoring system removals
CRREL Engineer, field
CRREL Engineer, field
CRREL Jr. engineer, field
CRREL staff per diem
UH-1 helicopter
Verification Sampling during Year 5
O&M Subtotals
YearO
Yean
Year 2
Year 3
Year 4
Years
Year 6
Year?
Year B
Year 9
Year 10
Year 11
Year 12
Year 13
Year 14
Year 15
Year 16
Year 17
Year 18
Year 19
Net Present Worth 10-year O&M (l=5%)
Net Present Worth 20-year O&M (l=5%)
Alternative Cost (10-year O&M)
Alternative Cost (20-year O&M)
Alternative 2 - Detailed Monitoring
Northern A Ponds
6/25/97
2 system
4 hr/system
4 hr/system
4 hr/system
2 staff
0.25 hr/system
16 sites
$86.91 /hr
$86.91 /hr
$64.65 /hr
$339.06 /staff-day
$547 /hr
$2,534 /site
2 systems
2 systems
2 systems
2 day
2 systems
$695
$695
$517
$1,356
$274
$ 3,538
$ 40.544
$20,275
$20,275
$20,275
$20.275
$20,275
$53,744
$13.200
$13.200
$13.200
$13,200
$13.200
$13,200
$13,200
$13.200
$13,200
$13,200
$13.200
$13,200
$13,200
$13,200
$162,813
$225,387
$207,548
$270,123
ANC/T
.xls/981140001
C-4
-------
Cost Estimate
Eagle River Flats
Description
Capital Costs
Pond Survey
CRREL Engineer, field
CRREL Jr. Engineer, field
CRREL Technician, tield
UXO clearance technician
UH-1 helicopter
Baseline WP Sampling
Sublimation Conditions Monitoring Equipment
Monitoring sysl., data logger, sensors, w.l. indicator
Monitoring sysl., data logger, sensors
Monitoring sysl, sensors
Direct Cost
Bid Contingencies
Scope Contingencies
Subtotal
COE Administration
Reporting
Permitting and Legal
Bonding and Insurance
Subtotal
Total Capital Costs
O&M Costs
Annual sedimentation monitoring
Annual setup of monitoring equipment
Number of monitoring system installations
CRREL Engineer, field
CRREL Engineer, field
CRREL Jr. engineer, held
CRREL staff per diem
Alternative 2 - Detailed Monitoring
Pond 290
6/25/97
Quantity Unit
6 hr
6 hr
6 hr
8 hr
2 hr
4 site
t ea
0 ea
0 ea
15 percent
20 percent
10 percent
5 percent
5 percent
3 percent
1 system
4 hr/syslem
4 hr/system
4 hr/system
2 staff
Unit Cost
$86.91 /staff-hr
$64.65 /staff-hr
$30.66 /staff-hr
$80.00 /staff-hr
$547 /hr
$870.38 /site
$4,000 ea
$3,000 ea
$1,000 ea
$86.91 /hr
$86.91 /hr
$64.65 /hr
$339.06 /staff-day
Frequency
1 staff
1 staff
1 staff
1 staff
1 systems
1 systems
1 systems
1 day
Cost
$521
$388
$184'
$640
$1,094
$3.482
$4,000
$0
$0
$10,309
$1,546
$2,062
$13.917
$1.392
$696
$696
$418
$3,201
$17,118
$6.600
$348
$348
$259
$678
$2.827
3,482
4.000
$ 6,600
ANCmm178.xls/981140001
C-5
-------
Cost Estimate
Eagle River Flats
UH-1 helicopter
Annual removal ol monitoring equipment
Number of monitoring system removals
CRREL Engineer, field
CRREL Engineer, tield
CRREL Jr. engineer, field
CRREL staff per diem
UH-1 helicopter
Verification Sampling during Year 5
O4M Subtotals
YearO
Yearl
Year 2
Year3
Year 4
Years
Year6
Year?
Years
Year 9
Year 10
Year 11
Year 12
Year 13
Year 14
Year 15
Year 16
Year 17
Year 18
Year 19
Net Present Worth 10-year O&M (l=5%)
Net Present Worth 20-year O&M (1=5%)
Alternative Cost (10-year O&M)
Alternative Cost (20-year O&M)
Alternative 2 - Detailed Monitoring
Pond 290
6/25/97
0.25 hr/system
1 system
4 hr/system
4 hr/system
4 hr/system
2 staff
0.25 hr/system
4 sites
$547 /hr
$86.91 /hr
$86.91 /hr
$64.65 /hr
$339.06 /staff-day
$547/hr
$2.534 /site
1 systems
1 systems
1 systems
1 systems
1 day
1 systems
$137
$ 1,769
$348
$348
$259'
$678
$137
$10,138
$10.138
$10,138
$10,138
$10,138
$16,736
$6,600
$6.600
$6,600
$6,600
$6.600
$6,600
$6.600
$6,600
$6,600
$6.600
$6.600
$6,600
$6,600
$6,600
$73,843
$105,130
$90,961
$122,248
1.769
$ 10,136
ANOTM^78.xlS/981140001
'./Toa^l
C-6
-------
Cost Estimate
Eagle River Flats
Alternative 2 - Detailed Monitoring
Northern C and C/D Ponds
6/25/97
Description
Capital Costs
Pond Survey
CRREL Engineer, field
CRREL Jr. Engineer, field
CRREL Technician, field
UXO clearance technician
UH-1 helicoptor
Quantity Unit
20 hr
20 hr
20 hr
8 hr
8 hr
Unit Cost
$86.91 /staff-hr
$64.65 /staft-hr
$30.66 /staff-hr
$80.00 /staff-hr
$547 /hr
Frequency
1 staff
1 staff
1 staff
1 staff
Cost
$1.738
$1.293
$613
$640
$4.376
$8.661
Baseline WP Sampling
Sublimation Conditions Monitoring Equipment
Monitoring syst.. data logger, sensors, w.l. indicator
Monitoring syst., data logger, sensors
Monitoring syst.. sensors
17 site
2 ea
0 ea
Oea
$870.38 /site
$4,000 ea
$3,000 ea
$1,000 ea
$14,796
$8,000
$0
$0
14,796
$ 8,000
Direct Cost
Bid Contingencies
Scope Contingencies
Subtotal
15 percent
20 percent
$31,457
$4,719
$6.291
$42,467
COE Administration
Reporting
Permitting and Legal
Bonding and Insurance
Subtotal
Total Capital Costs
O&M Costs
Annual sedimentation monitoring
Annual setup of monitoring equipment
Number of monitoring system installations
CRREL Engineer, field
CRREL Engineer, field
10 percent
5 percent
5 percent
3 percent
2 system
4 hr/system
4 hr/system
$86.91 /hr
$8691 /hr
2 systems
2 systems
$4,247
$2,123
$2,123
$1,274
$9.767
$52,234
$19.800
$ 19,800
$695
$695
ANC/Trm178.xls/981140001
C-7
-------
Cost Estimate
Eagle River Flats
CRREL Jr. engineer, field
CRREL staff per diem
UH-1 helicopter
Annual removal of monitoring equipment
Number of monitoring system removals
CRREL Engineer, field
CRREL Engineer, field
CRREL Jr. engineer, field
CRREL staff per diem
UH-1 helicoptor
Verification Sampling during Year 5
YearO
Year!
Year 2
Year 3
Year 4
Years
Year 6
Year?
Year8
Year 9
Year 10
Year 11
Year 12
Year 13
Year 14
YearlS
Year 16
Year 17
Year 18
Year 19
Net Present Worth 10-year O&M (l=5%)
Net Present Worth 20-year O&M (l=5%)
Alternative Cost (10-year O&M)
Alternative Cost (20-year O&M)
Alternative 2 - Detailed Monitoring
Northern C and C/D Ponds
6/25/97
4 hr/system
2 staff
0.25 hr/system
2 system
4 hr/system
4 hr/system
4 hr/system
2 staff
0.25 hr/system
17 sites
$64.65 /hr
$339.06 /staff-day
$547 /hr
$86.91 /hr
$86.91 /hr
$64.65 /hr
$339.06 /staff-day
$547 /hr
$2.534 /site
2 systems
2 day
2 systems
$517
$1.356
$274
2 systems
2 systems
2 systems
2 day
2 systems
$695'
$695
$517
$1,356
$274
$26,875
$26,875
$26,875
$26,875
$26,875
$62,878
$19,800
$19.800
$19,800
$19,800
$19,800
$19,800
$19,800
$19.800
$19,800
$19,800
$19,800
$19,800
$19,800
$19,800
$215,667
$309,529
$267,902
$361,763
3,538
3,538
$ 43.078
ANC/Tri
Is/981140001
C-8
-------
Cost Estimate
Eagle River Flats
Description
Capital Costs
Pond Survey
CRREL Engineer, field
CRREL Jr. Engineer, Held
CRREL Technician, field
UXO clearance technician
UH-1 helicopter
Baseline WP Sampling
Sublimation Conditions Monitoring Equipment
Monitoring syst., data logger, sensors, w.l. indicator
Monitoring syst., data logger, sensors
Monitoring syst., sensors
Alternative 2 - Detailed Monitoring
Pond 146
6/25/97
Quantity Unit
6 hr
6hr
6 hr
8 hr
2 hr
8 site
1 ea
0 ea
0 ea
Unit Cost
$86.91 /staff-hr
$64.65 /staff-hr
$30.66 /staff-hr
$80.00 /staff-hr
$547 /hr
$870.38 /site
$4,000 ea
$3,000 ea
$1,000 ea
Frequency
Cost
1 staff
1 staff
1 staff
1 staff
$521
$388
'$184
$640
$1,094
$6,963
$4,000
$0
$0
$2,827
6,963
$ 4,000
Direct Cost
Bid Contingencies
Scope Contingencies
Subtotal
15 percent
20 percent
$13,790
$2,069
$2,758
$18,617
COE Administration
Reporting
Permitting and Legal
Bonding and Insurance
Subtotal
Total Capital Costs
O&M Costs
Annual sedimentation monitoring
Annual setup of monitoring equipment
Number of monitoring system installations
CRREL Engineer, field
CRREL Engineer, field
10 percent
5 percent
5 percent
3 percent
1 system
4 hr/systern
4 hr/syslem
$86.91 /hr
$86.91 /hr
1 systems
1 systems
$1,862
$931
$931
$559
$4.282
$22,899
$13,200
$348
$348
13.200
ANC/Trm178.xls/981140001
C-9
-------
Cost Estimate
Eagle River Flats
CRREL Jr. engineer, field
CRREL staff per diem
UH-1 helicoptor
Annual removal of monitoring equipment
Number of monitoring system removals
CRREL Engineer, field
CRREL Engineer, field
CRREL Jr. engineer, field
CRREL staff per diem
UH-1 helicoptor
Verification Sampling during Year 5
O&M Subtotals
YearO
YeaM
Year 2
Year 3
Year 4
YearS
Year6
Year?
YearS
Year 9
Year 10
Year 11
Year 12
Year 13
Year 14
Year 15
Year 16
Year 17
Year 18
Year 19
Net Present Worth 10-year O&M (l=5%)
Net Present Worth 20-year O&M (l=5%)
Alternative Cost (10-year O&M)
Alternative Cost (20-year O&M)
Alternative 2 - Detailed Monitoring
Pond 146
6/25/97
4 hr/system
2 staff
0.25 hr/system
1 system
4 hr/system
4 hr/system
4 hr/system
2 staff
0.25 hr/system
8 sites
$64.65 /hr
$339.06 /staff-day
$547 /hr
$86.91 /hr
$86.91 /hr
$64.65 /hr
$339.06 /staff-day
$547 /hr
$2,534 /site
1 systems
1 day
1 systems
systems
systems
systems
day
systems
$259
$678
$137
$ 1,769
£348
$348
$259
$678
$137
$16.738
$16,738
$16.738
$16.738
$16,738
$33,472
$13,200
$13.200
$13.200
$13,200
$13.200
$13.200
$13,200
$13,200
$13,200
$13,200
$13,200
$13,200
$13,200
$13.200
$132,370
$194,944
$155,269
$217,843
1,769
20.272
ANC/T
xls/981140001
C-10
-------
Cost Estimate
Eagle River Flats
Description
Capital Costs
Pond Survey
CRREL Engineer, field
CRREL Jr. Engineer, field
CRREL Technician, field
UXO clearance technician
UH-1 helicopter
Baseline WP Sampling
Sublimation Conditions Monitoring Equipment
Monitoring syst., data logger, sensors, w.l. indicator
Monitoring syst., data logger, sensors
Monitoring syst., sensors
Alternative 2 • Detailed Monitoring
Pond 183
6/25/97
Quantity Unit
6 hr
6 hr
6hr
8 hr
2 hr
7 site
1 ea
0 ea
0 ea
Unit Cost
$86.91 /staff-hr
$64.65 /staff-hr
$30.66 /staff-hr
$80.00 /staff-hr
$547 /hr
$870.38 /site
$4,000 ea
$3,000 ea
$1,000ea
Frequency
Cost
1 staff
1 staff
1 staff
1 staff
$521
£388
$184'
$640
$1,094
$6,093
$4.000
$0
$0
$2,827
$ 6,093
$ 4,000
Direct Cost
Bid Contingencies
Scope Contingencies
Subtotal
15 percent
20 percent
$12,920
$1,938
$2,584
$17,442
COE Administration
Reporting
Permitting and Legal
Bonding and Insurance
Subtotal
Total Capital Costs
O&M Costs
Annual sedimentation monitoring
Annual setup of monitoring equipmenl
Number of monitoring system installations
CRREL Engineer, field
CRREL Engineer, field
10 percent
5 percent
5 percent
3 percent
1 system
4 hr/system
4 hr/system
$86.91 /hr
$8691 /hr
$1,744
$872
$872
$523
$4,012
$21,454
$13,200
$ 13,200
1 systems
1 systems
$348
$348
ANC/Trm 178. xls/981140001
C-11
-------
Cost Estimate
Eagle River Flats
CRREL Jr. engineer, field
CRREL statf per diem
UH-1 helicopter
Annual removal of monitoring equipment
Number of monitoring system removals
CRREL Engineer, field
CRREL Engineer, field
CRREL Jr. engineer, field
CRREL staff per diem
UH-1 helicopter
Verification Sampling during Year 5
OftM Subtotals
YearO
Yean
Year 2
Year 3
Year 4
YearS
Year 6
Year?
Year 8
Year 9
Year 10
Year 11
Year 12
Year 13
Year 14
Year 15
Year 16
Year 17
Year 18
Year 19
Net Present Worth 10-year O&M (1=5%)
Net Present Worth 20-year O&M (1=5%)
Alternative Cost (10-year O&M)
Alternative Cost (20-year O&M)
ANC/Trmt Taxis/981140001
Alternative 2 - Detailed Monitoring
Pond 183
6/25/97
4 hr/system
2 staff
0.25 hr/system
1 system
4 hr/system
4 hr/system
4 hr/system
2 staff.
0.25 hr/system
7 sites
$64.65 /hr
$339.06 /staff-day
$547 /hr
$86.91 /hr
$86.91 /hr
$64.65 /hr
$339.06 /staff-day
$547/hr
$2,534 /site
1 systems
1 day
1 systems
1 systems
1 systems
1 systems
1 day
1 systems
$259
$678
$137
$ 1,769
$348
$348
$259
$678
$137
$ 1,769
$ 17,738
$16.738
$16,738
$16.738
$16,738
$16.738
$30,938
$13.200
$13,200
$13.200
$13,200
$13.200
$13.200
$13,200
$13,200
$13,200
$13,200
$13,200
$13.200
$13.200
$13.200
$130,479
$193,053
$151,933
$214,507
mtT&xl!
C-12
-------
Alternative 3, Pumping with Capping and Filling
lot lf»aitfr*ni *'t»vttt»i(
OPW ^u|if>on (tugiktM.Y. &utlll>os tabu* I
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Ol'rt bii|ih*»' lh.yi-.in S Suiitt'O^ l)
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Total Cost for Alternative 3
Unit Costs
UXI'NKHMI
?/ M
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? MM) UU
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10WJ II
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iMBf.OOU
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10 (XX)
1 1 3 «
FYICM FyjOOO FYJOOI FVMO?
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1*0.000 ISO.OOC 150.000 ISO, 000
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30.000 30.000 30.000 30.000 30 OOO
671
FY2004 FY2005 FY2O06
W«( Dry Dry
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F»M07 FV20M FY2009 FVJOIO FYI01I FYJOIZ FY20I1 FYJOI4 ' FY20I5 FYJ016 FY20I7 FYWII
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150000 150 OUO
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JJiOUU JSIIOO V.IKJO 34000 35.100
2'- UUO 25 UUO 25 000 25.0OU 2S.OUU
7(I(1UO '0 UUO 'U OOU 70 OOU 70 OOU
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usomi
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20.000 20000, 20000
10 OOU
5000
10 OOO 10.000 10 OUO
IS OOU 1S.UOO IS OUO
40 UUO 40 000 4U UUO
'i OUO 2 OOU 1 OUU
20.000 2U OUU
20nn 5000 20000 20.000 2uoou 20 10 OUO 2 SOO 2 SOO 2 SOU ? Sdli UIOuU. 1 Sim ? sou i- SIM]
2 UOU 20000 2000 2 OUO iMKIO i' (mil ,'n l««l J OKI ;> OUO ?(»»l
;' uou .' • « • '
2000
211 UUO bOO
5.00
2SUU 10.00
2 UOO 20.00
200
.". W"l ." 2/000 // OIMI
2/000 ?«2 OC
kttumpKons
I AU>V« n-.M;.l«uU-i wifl b« (*rlmm*«l intbl Yeai S !>Mlin*Nil |n^i«ii «N| mcmtoting tdchi^u* !•'11 dIMf StlHllf^ QO ||M (ill 4«)lbtH>>l4ll .1 fttdtS <*.tl»l ACllVtl ptlt1l(»IKj !«, COttt)
;i Cap rf'fi MI Mi.ii*tii<«i «»• bt appkod h» u WJ ha o* |Kjml Oiinoms ai Year s u is assuflted n>ai s% i
4 Intt/ntHir <«IN| MMMUbty sluOev MII*! «aiertnw< surveys fKtuced WP santpling hmded OIS (JmUtJ<*s« (narktgie"ii-«i| ji«l->ii
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S I M44»(nfliy analily and h^lHlal letKHind MiH M (mr1o»m«d dunitg yiMfi IMI lelenwiry IM m>lc.i <* thnr «H|uiwtiWiil wnl I* avaiMil* hi suptnj't tuMtnieoi and rn*Hi»s
l'.o\t\ 4lsi< rtsMdi.e tlial lt>4> C.tit (XMxlv witt ml l»« |nNii|M>tf liut wiH bo sjir^rtwl tin Wl*
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AH(./lirnl .'II .I'./'Jfll MIKMII
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Estimate of Alternative 4 Costs
Capital Costs (new pumps, explosives, limited cap and fill)
Cost presented in the PP and FS $4,990,000
To baseline Alternative 4 against Alternative 3, the following indirects were removed: -$1.618,378
Bid Contingencies -15%
Scope Contingencies -20%
Reporting - - -5%
Permitting and Legal -5%
Bonding and Insurance -3%
Subtract the cost of the six pumps systems already owned by the Army (@$1 OOK/pump) -$600,000
Subtract out the cost of Cap and Fill Material orginally priced in FS ( 5.965 ha @$140k?ha) -$835,100
AquaBlok Application (summer helicopter delivery)
Application of Cap and Fill Material (assume 0.88 ha @ $140/K) $125,466
Cap and Fill Integrity Testing (@$2275/ha) $2,000
Capital Costs Subtotal $2,063,988
Net Present Worth 20-year O&M (1=5%) $7,068,440
average:
Total Alternative Cost $9,132,428
Note: It is still assumed at C/D area may be drained.The capital costs for Alt 4 is higher than Alt 3
because of explosives costs and less understanding about how some ponds may respond to
breaching therefore may need those extra pumps.
Active treatment is expected to be 2 years longer because of frequent reflooding.
Costs are based on estimates in the Final OU C FS.
$353.422
Alternative 4: Annual O&M and monitoring activities.
ID Activity
1 Telemetry, Aerial Surveys, WP sampling,
136,155
2 Telemetry, Aerial Surveys, WP sampling,
136, 155; Sampling @ C/D
3 Telemetry, Aerial Surveys, WP sampling,
136, 155; Sampling @ C/D
4 Telemetry, Aerial Surveys, WP sampling,
136, 155; Sampling @ C/D
5 Telemetry, Aerial Surveys, WP sampling,
Sampling @ C/D Ponds
6 Telemetry, Aerial Surveys, WP sampling,
Sampling @ C/D Ponds
7 Telemetry, Aerial Surveys, WP sampling,
AquaBlok Application
8 Telemetry, Aerial Surveys, WP sampling
9 Telemetry, Aerial Surveys, WP sampling
10 Telemetry, Aerial Surveys. WP sampling
11 Limited site visits
12 Limited site visits
13 No Activity
14 No Activity
15 Telemetry, Aerial Surveys, WP sampling
16 Limited site visits
17 No Activity
18 No Activity
19 No Activity
20 Telemetry, Aerial Surveys, WP sampling
Treatment ©183,290,
Treatment @ 183, 290,
Treatment @ 183, 290,
Treatment @ 183, 290,
Treatment @ A Ponds;
Treatment @ A Ponds;
Treatment @ A Ponds;
Year
1999
2000
2001
2002
2003
2004
2005
2006
2007
2008
2009
2010
2011
2012
2013
2014
2015
2016
2017
2018
Yearly O&M Comments
$800,000 wet year
$800,000
$1,000,000
$1,000.000
$1.000,000
$1,000.000
$1,000,000
$1,200,000
$275,000
$275,000
$275,000
$30.000
$30,000
$30,000
$275.000
$30.000
$30.000
$30,000
$30.000
$275,000
wet year
dry year
dry year
dry year
wet year
dry year
dry year
dry year
wet year
wet year
dry year
dry year
wet year
wet year
wet year
ANC/Trm178.xls/981140001
C-14
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Estimate of Alternative 5 Costs
Capital Costs (new pumps, explosives, limited cap and fill)
Application of Cap and Fill Material (assume 18.7 ha @ S140/K)
AquaBlok Integrity and Depth Testing (@$4000/ha)
Capital Costs Subtotal
Net Present Worth 20-year O&M (1=5%)
Total Alternative Cost
Note: It is assumed Cap and Fill Material will be applied to all the hot ponds.
Costs are based on estimates in the Final OUC FS.
Alternative 5: Annual O&M and monitoring activities.
ID Activity
1 Monitor Cap and Fill application and integrity, perform telemetry and
aerial surveys, GIS management, Project Management
2 Monitor Cap and Fill application and integrity, perform telemetry and
aerial surveys, GIS management, Project Management
3 Monitor Cap and Fill application and integrity, perform telemetry and
aerial surveys, GIS management. Project Management
4 Monitor Cap and Fill application and integrity, perform telemetry and
aerial surveys, GIS management, Project Management
5 Monitor Cap and Fill application and integrity, perform telemetry and
aerial surveys, GIS management. Project Management
6 Monitor Cap and Fill application and integrity, perform telemetry and
aerial surveys, GIS management, Project Management
7 Monitor Cap and Fill application and integrity, perform telemetry and
aerial surveys, GIS management, Project Management
8 Monitor Cap and Fill application and integrity, perform telemetry and
aerial surveys, GIS management, Project Management
9 Monitor Cap and Fill application and integrity, perform telemetry and
aerial surveys, GIS management, Project Management
10 Monitor Cap and Fill application and integrity, perform telemetry and
aerial surveys, GIS management, Project Management
11 Limited site visits
12 Limited site visits
13 Limited site visits
14 Limited site visits
15 Telemetry, Aerial Surveys, cap and fill material integrity
16 Limited site visits
17 Limited site visits
18 Limited site visits
19 Limited site visits
20 Telemetry, Aerial Surveys, cap and fill material integrity
average:
2,619,000
75,000
2,694,000
3,470,976
6,164,976
$173.549
Year
1999
2000
2001
2002
2003
2004
2005
2006
2007
2008
2009
2010
2011
2012
2013
2014
2015
2016
2017
2018
Yearly O&M
1,000,000
320,000
320,000
320,000
320,000
320,000
320,000
320,000
320,000
320,000
30,000
30,000
30,000
30,000
275,000
30,000
30,000
30.000
30.000
275,000
Comments
wet year
wet year
dry year
dry year
dry year
wet year
dry year
dry year
dry year
wet year
wet year
dry year
dry year
wet year
wet year
wet year
981140001
ANC/Trm178.xls/981140001
C-15
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