.... ..Comments on the Proposed Plan for Remedial ActionGambell Formerly Used Defense Site, St. Lawrence Island, AKReviewed by Pamela Miller, S1. Lawrence Island RAB member andDirector of Alaska Community Action on ToxicsAugust 31, 2004Thank you for extending the comment period on the Proposed Plan for Remedial Action.However, I remain concerned that residents of St. Lawrence Island (SLI) have not had sufficientopportunity or time to review and formally comment on this document. It is especially criticalthat people of SLI be given ample opportunity to comment, as this is a critical phase of theCERCLA process. I suggest that the Corps of Engineers provide time at the September 9 RABmeeting for additional public comments from RAB members and other residents on the proposedplan.The proposed plan for remedial action does not sufficiently respond to community concerns andsome suggested courses of action. Particularly, the proposed plan does not provide measures toensure proper monitoring and protection of the community drinking water source. At least onceyearly, water from monitoring wells in and around the vicinity of the community drinking watersource should be sampled and analyzed for heavy metals, VOCs, pesticides, and PCBs. Duringthe public meeting, a Gambell resident raised a significant point about the vulnerability of thedrinking water source because of the permeability of the gravel substrate and susceptibility tocontamination from storm surges and flooding. Contamination can readily migrate in thisenvironment. The sites cannot be viewed as isolated from one another because the potential forcross contamination is high given the permeability of the substrate.The proposed plan does not include adequate data to justify no further action determinations forall but 4 of the 38 sites. Many of the sites warrant further investigation and cleanup. Thedocument must identify sources of contamination, including thallium, beryllium, arsenic, lead,chromium, VOCs, benzene, fuels, and PCBs. Pesticides should be included among the potentialcontaminants of concern (including DDT metabolites, mirex, endosulfan, lindane, and otherpesticides known to be used during the time of the military occupation) especially since we havereason to assume that DDT and possibly other pesticides were used at the site. Analysis ofhistorical records and interviews with former military personnel should be thoroughly conductedto determine other possible sources of contamination and contaminants of concern. Theperception of most community members is that the Corps of Engineers has not adequatelyinvestigated reports of buried hazardous materials, including reports of munitions (includinggrenades and larger caliber UXO). Contamination may pose a hazard to health and safety, yet theconcerns of the community have been too easily dismissed. In addition, although the Corps statesthat buried debris is not subject to remedial action under the RIDsFUDs program, the proposed planmust make provisions to remediate debris and other hazardous material should it surface througherosion or frost heaving.The proposed plan for remedial action must include provisions for sampling of indoor air forvolatile organics in the Gambell High School, other community buildings, and homes in thevicinity oftheof the landfill and power facility sites (including sites 6,7, and 17).Throughout the document, arsenic levels are considered "attributable to background" and not ofmilitary source. In some cases, arsenic levels are averaged and no further action is justified based200-1f200-HF10AK069603_08.01_0064_a, .'.on an average concentration. This is inappropriate and unjustified. True background levels are notprovided. Often arsenic levels exceed ADEC cleanup standards. These sites should be remediatedso that arsenic levels are below ADEC cleanup standards.The document should cite screening levels for all contaminants of concern. Further, it is incorrectto make the assumption that certain data points are simply outliers. For example, the Site 2sampling in 1994 indicated that levels for lead and chromium exceeded screening levels. 1996samples were tested for lead only and do not provide a basis for assuming that levels for othercontaminants are below the ADEC cleanup threshold. Site 2 requires further investigation andcleanup. The NFA determination is unjustified.Site 3, p 12. Thallium and beryllium exceeded screening levels and other metals (includingmercury and others) have been detected. Results cannot be dismissed as anomalies. This sitewarrants further investigation and cleanup.Site 4 A, P 14. Although the document states that no significant volume of contaminated soilremains at the site, elevated levels of contaminants are present. Remedial action should includecomplete removal of all contaminated soil and coverage/reclamation of the area with clean soilsand re-vegetation.Site 4 B, P 14. The document states that "The concentration of dioxins decreased significantly asa result of removing the soils." However, dioxins and additional contaminants remain at levels ofconcern. Further removal actions are warranted here because of the potential for downgradientcontamination. Dioxin contamination warrants special remedial actions due to the extreme healthhazards posed by even low concentrations.Site 5, P 18. Further action to identify and remove the source of DRO contamination must betaken. Monitoring of water for PAHs, DRO, solventsNOCs, and PCBs from a close series ofmonitoring wells in the vicinity of the drinking water source is mandatory.Site 7, p 21. Benzene sources and other contamination must be remediated at this site, and not justarsenic.Site 12, P 26. I support the proposed alternative to remove sources of heavy metal contamination.Additional sampling should be done to delineate the full extent of contamination.Site 14, P 28. Further investigation is necessary to determine whether the plane was carryinghazardous and/or radioactive material.CcADECRABMembers2