Document: ACAT FOIA Repository 24, Date Received July 2023
Year: 2004
Pages: 4
Document Title: Draft Record of Decision Comments by ADEC
Agency/Organization:
US Army Corps of Engineers (Alaska)
Document Summary:
Comments by Jeff Brownlee on the draft Record of Decision document for Gambell. The most encompassing comment is to address the lack of community support for the No Further Action decision at most sites.
LINK TO THIS ARTICLE
https://apeoplesepa.org/modules/acat24SOURCE
ACAT/EDGI FOIA, July 2023
CITATION
Chambers, Mark, Gretchen Gehrke, Pam Miller, Chris Sellers, Jessica Varner, and Vi Waghiyi, "ACAT FOIA Repository 24" ACAT/EDGI FOIA Repository, Alaska: Environmental Data & Governance Initiative and Community Against Toxics, 2023. https://apeoplesepa.org/panel/pages/home+acat-foia-repository
RELATED TAGS
~ 11 ~ 11 ~Jo ULr~\ lJ LsM(~n"'] I~ f6\ fl~ !V1 0\,~, U L~ l1 LJU~) lr\\ ij,JFRANK H. MURKOWSKI, GOVERNORDEPT. OF ENVIRONMENTAL CONSERVATIONDIVISION OF SPILL PREVENTION AND RESPONSECONTAMINATED SITES PROGRAM555 Cordova StreetAnchorage, AK 99501-2617Phone: (907)269-7558269-7649Fax: (907)(907)269-7649http://www.state.ak.us/dec/htto://www.state.ak.us/dec/December 21, 2004U.S. Anny Engineer District, Alaskau.s.Attn: Carey CossaboomP.O. Box 6898Anchorage, AK 99506-6898RE:Draft Decision Document, Gambell Site, St. Lawrence Island, AlaskaDear Mr. Cossaboom:Thank you for providing a copy of the subject document for department review. We received it onNovember 3, 2004. Typically the draft Record of Decision (ROD) is reviewed by the ADECproject manager then the revised ROD is reviewed with Contaminated Sites management. ThisROD had little in the way of structural or substantive comments so management was briefed withthe draft copy.The most significant issue that should be further addressed in the final ROD is the lack ofcommunity acceptance of the No Further Action determinations for the majority of sites.Providing a few alternative solutions to perceived problems may help positively influence opinionsuch as:• Reiterating the reopen clause in the document in Section 1.10.3.• Emphasize NALEMP involvement with debris projects and future involvement in thecommunity (as applicable)• Possible assistance from other agency programs that can address issues that FUDS can not(CAA Housing asbestos with the BIA, Village Safe Water monitoring of the pump well)• Provide a more formal vehicle for the institutional controls such as a map of buried debristhat can be used during future meetings and community construction efforts.If you have any questions concerning these comments or would like to meet to discuss them,please contact me at 269-3053.Sincerely,rownleeJJeef:fifrownleeEnvironmental Specialist200-1fF10AK069603_05.08_0004_a...'#'.·ro ...'roJ~REVIEWCOMMENTSPROJECT: Gambell, AlaskaDOCUMENT: Draft Decision DocumentLOCATION: Gambell, Saint Lawrence Island, AlaskaU.S. ARMY CORPSOF ENGINEERSCEPOA-EN-EE-TEDATE: 12/20/04REVIEWER:Jeff Brownlee(ADEC)PHONE: (907) 269-3053ItemNo.1DrawingSht. No.,Spec. Para.DeclarationSite Name andLocation2DeclarationofDescriptionSelected RemedyAction taken on comment by:COMMENTSREVJCONFERENCEA - comment acceptedW-commentwithdrawn(if neither. explain)Please clarify whether the Decision Documents is specific for theindividual projects or the entire property.Please note that there are multiple Reckeys for Gambell in theADEC database.In the first sentence please change the "or" to "and" as in "arsenicand lead". With the continued groundwater sampling at Site 5,please explain what will happen if the monitoring wells are cleanand what would happen if monitoring welles) were impacted; NFAor continued sampling rather than open ended.In the last bullet please make a note that the NFA sites have beeninspected and/or cleaned up during previous investigations/removalactions. The list ofNFA sites looks disturbingly long without somesort of explanation that they have been previously addressed.3StatutoryDeterminationsThe third sentence in this section seems out of place. The sentenceseems to be referring to an alternatively considered remedy (insitu). Please review.4DeclarationIn the first sentence of the last paragraph please add "FormerlyUsed Defense" between Gambell and Site.Signature page reopen clause5Section 1.2Site History6Section 1.2 SiteHistoryIn the Jennifer Roberts signature block please change the "DOD"to "Federal Facilities".In the fifth paragraph, please specify the institutional controls thatwere implemented and the vehicle used; education with publicmeetings. Is this ongoing? Is there any land management planestablished in the community?In the sixth paragraph four new sites are mentioned.Pleasereference the source of discovery for these sites (SPIP, TECReport, etc.) Finding new sites this late in the process coulddiminish a reader's confidence in the earlier investigative work.C:\Documents and Settings\mbriggslLocal Settings\Temporary Internet Files\OLK8\Draft Gambell DD Comments 12 04.docMWRESPONSEUSAEDRESPONSEACCEPTANCE(A-AGREE)(D-DISAGREE)REVIEWCOlVIMENTSPROJECT: Gambell, AlaskaDOCUMENT: Draft Decision DocumentLOCATION: Gambell, Saint Lawrence Island, AlaskaU.S. ARMY CORPSOF ENGINEERSCEPOA-EN-EE-TEDATE: 12/20/04REVIEWER:Jeff Brownlee(ADEC)PHONE: (907) 269-3053ItemNo.DrawingSht. No.,Spec. Para.Action taken on comment by:COMMENTSREVJCONFERENCEA - comment acceptedW-commentwithdrawn(if neither, explain)7ConununityParticipationYou may want to mention under the RAB bullet or separately thatthere was (is) a village liaison available to help conununitymembers with accessing technical information and agencyconununication.8Section 1.5.2Please note that early maps of the village show a drinking waterwell in the middle of the old village. This well was abandonedeither because of poor water quality (salt water intrusion) or poorwater quantity. Either way it may be worth mentioning assupporting evidence for using the ingestion cleanup levels.9Section 1.7.1In the second sentence, please add "may" before "pose".10Section 1.7.2The fIrst paragraph mentions a tar-stained area. The thirdparagraph mentions a rust stained area I believe referring to thesame location. Please clarify.11Table 5Please clarify the Dioxin units. These are usually in parts pertrillion. The cleanup level could be referenced as EPA Region 9Preliminary Remediation Goals for Residential Soil = 39 ppt.Please clarify if there were any post-excavation samples taken in2001.12Table 10Please add the arsenic in soil samples that are a concern at Site 7 tothis table.13Section 1.7.15In the second sentence, please add "of' after "Drums".14Section 1.7.32Please clarify if 18 AAC 75, Table B is the screening level referredto at the end of the second paragraph.15GeneralBreaksPageThe document may be a bit more presentable to the reader withsome negative space between sections, for example between theend of section 1.7.35 and 1.8.16Section 1.8, SitesThe last sentence of the second paragraph states that sites 7 and 12-C:\Docwnents and SettingslmbriggslLocal SettingslTemporary Internet FileslOLK8IDraft Gambell DD Comments 12 04.docMWRESPONSEUSAEDRESPONSEACCEPTANCE(A-AGREE)(D-DISAGREE)REVIEWCOMMENTSPROJECT: Gambell, AlaskaDOCUMENT: Draft Decision DocumentLOCATION: Gambell, Saint Lawrence Island, AlaskaU.S. ARMY CORPSOF ENGINEERSCEPOA-EN-EE-TEDATE: 12/20/04Jeff BrownleeREVIEWER:(ADEC)PHONE: (907) 269-3053ItemNo.17DrawingSht. No.,Spec. Para.Action taken on comment by:COMMENTSREVJCONFERENCEA - comment acceptedW-commentwithdrawn(if neither, explain)7 and 12 andgeneralare available for unrestricted use. These locations and other knowndebris sites should be documented on a map for use by thecommunity to avoid situations like that which occurred when thehigh school foundation was excavated. The map could serve as aninstitutional control with soil management information at those siteswhere the migration to groundwater cleanup level is not used.Table 14Please add another note "c" = Table B - ingestion level and changethe note on RRO from b to c.In the short paragraph prior to Table 14, please add "and ingestion"after "groundwater" for "... groundwater and ingestion pathwayssoil cleanup levels.18Section 1.1 0.3CommunityAcceptancePlease expand on this response. Was the public disagreementprimarily from Gambell residents or nonprofit watchdog groups?Was the disagreement centered on the FUDS program not beingable address buried debris or are the alternative cleanup levels adifficulty?Alternative solutions toward community acceptance could bediscussed such as the previously mentioned buried debris map, theuse of NALEMP to address some of the debris problems and thepossibility of BIA participation of asbestos problems if any at Site22 - CAA Housing.19FiguresPlease put the Site Vicinity and Site Location Maps toward thefront of the document and place the more specific figures at themost applicable sections. One or two higher resolution maps of theindividual sites would aid a reader in visualizing the site locationsand interactions.20ResponsivenessSummaryScrudato #43Can the NALEMP program address monitoring well or drinkingwater well monitoring at Site 5?C:\Docwnents and Settings\mbriggsILocal Settings\Temporary Internet Files\OLK8\Draft Gambell DD Comments 12 04.docMWRESPONSEUSAEDRESPONSEACCEPTANCE(A-AGREE)(D-DISAGREE)