APE | ACAT FOIA Repository 13

Document: ACAT FOIA Repository 13, Date Received July 2023
Year: 2004
Pages: 74
Document Title: Feasibility Study: Gambell, St Lawrence Island, Alaska

Agency/Organization:
US Army Corps of Engineers (Alaska)

Document Summary:
Feasibility Study for Gambell, form letter inviting feedback, and three comments on the F.S.

LINK TO THIS ARTICLE

https://www.apeoplesepa.org/modules/acat13

SOURCE

ACAT/EDGI FOIA, July 2023

CITATION

For academic footnote/endnote styles:
Gretchen Gehrke, Pam Miller, Jessica Varner, and Vi Waghiyi, ACAT/EDGI FOIA Repository, Environmental Data & Governance Initiative, and Alaska Community Action on Toxics, 2024. https://www.apeoplesepa.org/home/acat-foia-repository

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United States ArmyCorps of EngineersAlaska DistrictPO Box 6898Anchorage, AK99506-6898Feasibility StudyGambellSt. Lawrence IslandAlaskaFINALFebruary 2004F10AK069603_04.09_0500_a200-1eExecutive SummaryThis Feasibility Study evaluates alternatives for potential future remedial actions atselected sites (4A, 4B, 6, 7, 8, and 12) in Gambell, Alaska. These sites wererecommended for potential remedial action in the 2001 Supplemental RemedialInvestigation (MWH, 2002) and the EE/CA (USACE, 2002). The Feasibility Study wasconducted in accordance with the Comprehensive Environmental Response,Compensation, and Liability Act (CERCLA), using the standard evaluation criteria. Thestudy provides information sufficient to support an informed risk management decisionregarding the most appropriate remedy for each Gambell site. The Native Village ofGambell is located on St. Lawrence Island, in the western portion of the Bering Sea,approximately 200 air miles southwest of Nome, Alaska. During the 1950s, the militaryconstructed and operated facilities in Gambell as part of a surveillance and intelligencegathering network. The sites have undergone remedial investigation and prior removalactions. Petroleum and/or metals-contaminated soils were identified at Sites 4A, 4B, 6,7, and 12. An evaluation of the site-specific exposure pathways indicated that ingestionof soils was the most relevant exposure pathway. The level of petroleum contaminationin soils at Sites 4A, 4B, 6, 7, and 12 do not exceed ADEC cleanup levels based on theingestion pathway. However, Site 12 has lead-contaminated soil, which exceeds theresidential soil cleanup level. Debris that poses a physical hazard is present at Site 8 andSite D. The alternatives evaluated included: no-action; removal of debris only (Site 8and D); off-island disposal of debris (Site 8 and D) and lead-contaminated soil (Site 12);and off-island disposal of debris (Site 8 and D) and in situ treatment of lead contaminatedsoil.FinaliiTable of ContentsExecutive Summary ..................................................................................................................................... iiList of Acronyms ...........................................................................................................................................v1.Introduction..........................................................................................................................................11.1Purpose and Organization of Report ...........................................................................................11.2Background Information ..............................................................................................................11.2.1Site Description .......................................................................................................................21.2.2Site History..............................................................................................................................31.2.3Nature and Extent of Contamination .......................................................................................41.2.3.1Site 4A – Quonset Huts Near Former USAF Radar Site ...............................................41.2.3.2Site 4B –Former USAF Radar Site ................................................................................51.2.3.3Site 6 – Military Landfill................................................................................................71.2.3.4Site 7 – Former Military Power Facility ........................................................................81.2.3.5Site 8 – West Beach/Army Landfill ...............................................................................91.2.3.6Site 12 – Nayvaghaq Lake Disposal Site .......................................................................92.Identification and Screening of Technologies..................................................................................122.1Remedial Action Objectives........................................................................................................122.1.1Site 4A – Quonset Huts Near Former USAF Radar Site.......................................................132.1.2Site 4B – Former USAF Radar Site.......................................................................................142.1.3Site 6 – Military Landfill .......................................................................................................142.1.4Site 7 – Former Military Power Facility................................................................................152.1.5Site 8 – West Beach/Army Landfill.......................................................................................162.1.6Site 12 – Nayvaghaq Lake Disposal Site...............................................................................162.2Applicable or Relevant and Appropriate Requirements (ARARs)..............................................172.2.1Chemical-Specific ARARs and TBCs .....................................................................................172.2.2Location-specific ARARs and TBCs.....................................................................................182.2.3Action-Specific ARARs and TBCs .......................................................................................182.3Identification of General Response Actions, Remedial Technologies and Process Options......182.3.1General Response Actions.....................................................................................................182.3.2Identification and Screening of Remedial Technologies .......................................................192.3.3Evaluation of Technologies and Selection of Representative Technologies .........................192.3.3.1No Action.....................................................................................................................192.3.3.2Limited Actions............................................................................................................192.3.3.3Containment .................................................................................................................212.3.3.4On-Island Treatment ....................................................................................................212.3.3.5Off-site Disposal ..........................................................................................................223.Development and Screening of Alternatives....................................................................................243.1Descriptions of Alternatives .......................................................................................................243.1.1Alternative 1 : No Action ......................................................................................................243.1.2Alternative 2 : Removal of Exposed Debris Only .................................................................243.1.3Alternative 3: Off-Island Disposal ........................................................................................24Finaliii4.Detailed Analysis of Alternatives......................................................................................................264.1Individual Analysis of Alternatives.............................................................................................264.1.1Alternative 1 – No Action .....................................................................................................274.1.1.1Evaluation ....................................................................................................................274.1.2Alternative 2 – Removal of Exposed Debris Only ................................................................284.1.2.1Evaluation ....................................................................................................................284.1.3Alternative 3 – Off-Island Disposal of Lead Contaminated Soil and Exposed Debris .........294.1.3.1Evaluation ....................................................................................................................294.2Comparative Analysis ................................................................................................................314.2.1Overall Protection of Human Health and the Environment...................................................314.2.2Compliance with ARARs ......................................................................................................314.2.3Short-Term Effectiveness ......................................................................................................314.2.4Long-Term Effectiveness ......................................................................................................324.2.5Reduction of Toxicity, Mobility, or Volume Through Treatment.........................................324.2.6Implementability....................................................................................................................324.2.7Cost........................................................................................................................................32Bibliography ................................................................................................................................................33List of TablesTable 2-1: Technology Screening SummaryTable 2-2: Summary of Applicable or Relevant and Appropriate RequirementsTable 4-1: Cost Comparison SummaryList of Figures and PhotographsFigure 1-1: Gambell, Alaska, Location MapFigure 1-2: Gambell Vicinity MapFigure 1-3: Location of Village Water SupplyFigure 2-1: Technology ScreeningAppendixAppendix A - Cost Estimates for Feasibility StudyAppendix B – Figures from Previous ReportsFinalivList of AcronymsAACADECADOTPFAlaska DistrictARARATVbgsBIABTEXCERCLACFRDERPDoDDROE&EEE/CAFSFUDSGROHTSAMWMWHmg/kgmg/LNALEMPNCPNDO&MOEOSCIPAHPCBPIDRAORCRARIRROSARASBSPIPTALTBCTECFinalAlaska Administrative CodeAlaska Department of Environmental ConservationAlaska Department of Transportation and Public FacilitiesUnited States Army Engineer District, Alaskaapplicable and relevant or appropriate requirementsall-terrain vehiclebelow ground surfaceBureau of Indian Affairsbenzene, toluene, ethylbenzene, and xylenesComprehensive Environmental Response, Compensation and Liability ActCode of Federal RegulationsDefense Environmental Restoration ProgramUnited States Department of Defensediesel range organicsEcology & EnvironmentEngineering Evaluation / Cost AnalysisFeasibility StudyFormerly Used Defense Sitesgasoline range organicsHistorical Time Sequence AnalysisMontgomery Watson or monitoring wellsMontgomery Watson Harzamilligrams per kilogrammilligrams per literNative American Lands Environmental Mitigation ProgramNational Contingency Plannon-detectoperations and maintenanceordnance and explosivesOil Spill Consultants, Inc.polynuclear aromatic hydrocarbonpolychlorinated biphenylphotoionization detectorremedial action objectiveResource Conservation and Recovery ActRemedial Investigationresidual range organicsSuperfund Amendments and Reauthorization Actsoil boringStrategic Project Implementation PlanTarget Analyte Listto be consideredTopographic Engineering Center, USAEDvTRPHUSACEUSAFUSEPAURSVOCFinaltotal recoverable petroleum hydrocarbonsUnited States Army Corps of EngineersUnited State Air ForceUnited States Environmental Protection AgencyURS Corporationvolatile organic compoundvi1. IntroductionThe United States Army Corps of Engineers (USACE), Alaska District, has performed aFeasibility Study (FS) at several sites in Gambell, Alaska. These sites include 4A, 4B, 6,7, 8 and 12. The Gambell site is a Formerly Used Defense Site (FUDS), and is not listedon the National Priorities List (NPL). This project was authorized by the DefenseEnvironmental Restoration Program (DERP) of the United States Department of Defense(DoD), and was conducted in accordance with the Comprehensive EnvironmentalResponse, Compensation, and Liability Act (CERCLA).1.1 Purpose and Organization of ReportThe FS report is intended to provide information sufficient to support an informed riskmanagement decision regarding which remedy appears to be most appropriate for theGambell sites. The FS is based on data collected during previous investigations and willbe used during preparation of the Proposed Plan and, following public comment on theProposed Plan, the Record of Decision for the site remedy. The development of the FSfollows guidance for conducting a feasibility study under CERCLA (USEPA, 1988), andalternatives were developed and evaluated using standard criteria.The purpose of the FS is to develop remedial action objectives (RAOs); identify andscreen general response actions, remedial technologies, and process options; and developand evaluate remedial alternatives.The FS report is organized as follows. Section 1.0, Introduction, presents the purposeand approach of the FS and a summary of previous investigations. Section 2.0,Identification and Screening of Remedial Technologies and Process Options, containsremedial action objectives; the identification of general response actions, remedialtechnologies and process options; and screening of remedial technologies and processoptions. Section 3.0, Development of Alternatives, is a summary of the development ofeach of the alternatives chosen for Gambell. Section 4.0, Analysis of Alternatives,includes a detailed analysis of alternatives; a comparative analysis of remedialalternatives; and conclusions. Section 5.0, References, contains a list of documents usedin preparation of the FS. Appendix A contains applicable or relevant and appropriaterequirements (ARARs).1.2 Background InformationThe site history and previous investigation information contained in this FS have beensummarized from reports documenting previous investigation results from the Gambellarea. More detailed site descriptions and background information, including results offield investigations, can be found in the documents listed below:•Work Plan, 2001 Supplemental Remedial Investigation, Gambell, St. LawrenceIsland, Alaska. MWH Americas, Inc., September 2001.Gambell Feasibility StudyFinal❏ Page 1February 2004••••••••••Final Remedial Action Report for Debris Removal and Containerized HazardousWaste and Toxic Waste Removal, Gambell, Alaska. Oil Spill Consultants, Inc.,February 15, 2001.Final Strategic Project Implementation Plan, Gambell, St. Lawrence Island, Alaska.Montgomery Watson, December 2000.GIS-Based Historical Time Sequence Analysis (Historical Photographic Analysis),Gambell Sites, St. Lawrence Island Alaska. United States Army Corps of Engineers,Engineer Research and Development Center, TEC, September 2000.Site 5 Remedial Investigation, Gambell, St. Lawrence Island, Alaska. MontgomeryWatson, 1999.Final Phase II Remedial Investigation, Gambell, St. Lawrence Island, Alaska.Montgomery Watson, December 1998.Final Investigation of Geophysical Anomaly, Gambell, St. Lawrence Island, Alaska.Montgomery Watson, December 1997.Remedial Action Alternatives Technical Memorandum, Gambell, St. LawrenceIsland, Alaska. Montgomery Watson, November 1995.Remedial Investigation, Gambell, St. Lawrence Island, Alaska. MontgomeryWatson, January 1995.Chemical Data Acquisition Plan, Site Inventory Update, Gambell, St. LawrenceIsland, Alaska. Ecology & Environment (E&E), February 1993.Site Inventory Report, Gambell Formerly Used Defense Site, St. Lawrence Island,Alaska. E&E, December 1992.1.2.1 Site DescriptionGambell is located off the coast of western Alaska on the northwest tip of St. LawrenceIsland, in the western portion of the Bering Sea, approximately 200 air miles southwestof Nome, Alaska, and 39 air miles from the Siberian Chukotsk Peninsula (Figure 1-1).The village of Gambell, at an elevation of approximately 30 feet above mean sea level, issituated on a gravel spit that projects northward and westward from the island (Figure 12). St. Lawrence Island is currently owned jointly by Sivuqaq, Inc., in Gambell, Alaska,and Savoonga Native Corporation in Savoonga, Alaska. Non-Native land on St.Lawrence Island is limited to state land used for airstrips and related facilities in Gambelland Savoonga (MW, 1995a).The Village of Gambell is inhabited primarily by Native St. Lawrence Island Yupikpeople, who lead a subsistence-based lifestyle. The Gambell area supports habitat for avariety of seabirds, waterfowl, and mammals that either breed in or visit the area. Thearea surrounding the top of Sevuokuk Mountain, above the Village of Gambell, supportsa large bird rookery. The birds and bird eggs serve as a subsistence food source for localinhabitants. The ocean surrounding the Gambell area is used extensively for subsistencehunting of whales, walrus, seals, sea birds, and fish.Gambell Feasibility StudyFinal❏ Page 2February 20041.2.2 Site HistorySeveral phases of a release investigation and/or removal actions have been conducted atGambell. URS Corporation (URS) conducted a file search and preliminaryreconnaissance of the Gambell area in 1985. The site reconnaissance included aninventory of all materials left by the military and collection of a limited number of soiland water samples. In 1991 and 1992, Ecology and Environment, Inc. (E&E) conducteda more detailed site reconnaissance visit and interviewed individuals living at Gambellduring the period of DoD occupation. E&E then prepared a Chemical Data AcquisitionPlan for investigation of 18 areas of concern (sites) based on information gathered duringthe interviews and information reported in the URS document (E&E, 1993).Montgomery Watson (MW) implemented the Chemical Data Acquisition Plan in 1994 aspart of a Phase I Remedial Investigation (RI). The objectives of the 1994 RI were togather sufficient chemical, geophysical, and hydrological data to characterize the natureand extent of contamination at the sites.A Phase II RI was conducted in 1996 to fill data gaps from the Phase I RI. The followingsites were included in the RI: Site 1 (Area 1A and 1B), Site 2, Site 3, Site 4 (Area 4Band 4D), and Site 5. The investigation included collection of soil and groundwatersamples to further delineate the extent of contamination, a debris reconnaissance, and ageophysical survey. All visible surface debris was removed from the island in 1997(MW, 1997).After the 1997 removal action, frost jacking forced additional debris to surface. Duringthe 1999 field season, Oil Spill Consultants, Inc. (OSCI) performed cleanup activities atGambell including Sites 2, 3, 4A, 4B, 5, 6, 7, 8, 10, 12, and 13. The fieldworkaccomplished the removal of 26.8 tons of hazardous and non-hazardous containerizedwastes such as asphalt drums, paint, generators, batteries, empty drums, and transformercarcasses; removal of 71 tons of exposed metal debris such as runway matting, cable, fueltanks and equipment parts; and excavation of 72 tons of contaminated soil.During 2000, under the Native American Lands Environmental Mitigation Program(NALEMP), the Native Village of Gambell conducted strategic project planningactivities, including the completion of community questionnaires and geophysicalsurveys. Based upon the results of the geophysical surveys and questionnaires, severalnewly identified sites were targeted for further investigation (MW 2000).In 2000 and 2001, the Army Engineering and Support Center (Huntsville) conductedextensive research and investigations to locate possible ordnance and explosives (OE)materials left behind by the military. At the request of the Huntsville office, theTopographic Engineering Center (TEC 2000) completed a review of historical aerialphotos and other documentation as part of the ordnance investigation. The HistoricalTime Sequence Analysis (HTSA) combined data from historic aerial photographs withcurrent maps of Gambell to identify and confirm areas of possible former military use.During the OE field surveys, very little OE was found, consisting primarily of highlyweathered 30-caliber small arms ammunition at a beach burial pit southwest of TroutmanLake (Area D of Site 8).Gambell Feasibility StudyFinal❏ Page 3February 2004A Supplemental Remedial Investigation was conducted by Montgomery Watson Harza(MWH 2002) during the 2001 field season, to investigate the nature and extent ofcontamination based on new information in the HTSA (TEC 2000), the NALEMPStrategic Project Implementation Plan (MW 2000), and the Final Remedial ActionReport (OSCI 2001). The HTSA identified four new sites for investigation - Sites 25B,26, 27, and 28. Additional soil and groundwater data was also collected at Sites 6, 7, 16,and 25A. The results of previous confirmation sampling data were verified for areaswhere contaminated soils had been removed - Sites 4A, 4B, 6, 8, and 12.The Summary Report for the 2001 Supplemental RI recommended further action at thefollowing sites: 4A, 4B, 6, 7, and 12. The recommended actions were removal of soil“hot spots” based on the presence of metals and/or fuel contamination. The SummaryReport recommended “no action warranted” at the remaining sites: 8, 16, 18A, 24, 25A,25B, 26, 27, and 28. However, the RI report did not give consideration to the small armsammunition debris buried in the beach gravels at Area D within Site 8.1.2.3 Nature and Extent of ContaminationThe nature and extent of contamination or hazard debris at Sites 4A, 4B, 6, 7, 8, and 12are described in the following sections. The descriptions are based on a review ofprevious investigation results.1.2.3.1 Site 4A – Quonset Huts Near Former USAF Radar SiteSite 4A, located on Sevuokuk Mountain, formerly contained two Quonset huts (seeFigure 1-2). During the 1994 RI, surface soil samples were collected from Site 4A andanalyzed for fuel-related contaminants, PCBs, solvents, and dioxins. No contaminantswere detected above method detection limits. In 1999, OSCI removed metal debris,drums, and 1,877 pounds (0.93 tons) of visibly stained soil from Site 4A. OSCI collectedconfirmation soil samples following the removal action. The soil samples were collectedfrom within and outside the two Quonset hut footprints, following removal of the framesand contaminated soil. The confirmation samples contained DRO at concentrations of upto 1,310 mg/kg, arsenic concentrations from 1.6 to 8.3 mg/kg, chromium concentrationsup to 422 mg/kg, and lead concentrations up to 311 mg/kg. There is no significantvolume of contaminated soil remaining at Site 4A. Site 4A consists of large boulders ontop of bedrock with small amounts of soil.During 2001, supplemental investigation was done at Site 4A to verify the 1999confirmation sampling results because the referenced latitude and longitude coordinateswere not documented by OSCI. Thirty-six surface soil samples (nine each from fourtriangular grids) were collected and screened in the field using a photo-ionizationdetector (PID) and PetroFlag™ screening kits. The four triangular sampling grids wereestablished using the approximate locations of the 1999 samples as the grid centerpoints.Four soil samples (one from each of the four grids with the highest field screeningresults) were submitted for laboratory analysis of GRO, DRO, RRO, and ResourceConservation and Recovery Act (RCRA) metals. Two samples corresponding toGambell Feasibility StudyFinal❏ Page 4February 2004previous samples were analyzed for hexavalent chromium, because of the high totalchromium results detected in the 1999 samples.The 2001 sampling results confirmed the 1999 sampling results for arsenic. In 1999,arsenic concentrations ranged from 1.6 to 8.3 mg/kg; in 2001, arsenic concentrationsranged from 1.6 to 3.9 mg/kg. For both sets of samples, results generally exceeded thedefault ADEC Method 2 Migration to Groundwater arsenic cleanup level of 2 mg/kg.However, these observed concentrations may be due to naturally occurring levels ofarsenic. Arsenic results generally exceeded 2 mg/kg at all soil-sampling locations(surface and subsurface) in the Gambell area during the 2001 Supplemental RI, as well asprevious investigations. All arsenic sample results are for total arsenic. A backgroundsurface soil sample collected northeast of Site 4B had arsenic results of 1.3 and 2.0 mg/kg(duplicate).High chromium levels (up to 422 mg/kg) identified during the 1999-sampling event werenot confirmed by 2001 sample results (up to 12.1 mg/kg total chromium). The two 1999sample locations with the highest chromium concentrations were resampled in 2001. Theresults were less than 12.1 mg/kg for total chromium and non-detect for hexavalentchromium. The ADEC Method 2 cleanup level for total chromium is 26 mg/kg.The 1999 sampling results had lead concentrations of up to 311 mg/kg. The highest leadconcentration detected in 2001 was 44 mg/kg. The Method 2 cleanup level for lead (400mg/kg) was not exceeded in either sample set.The 2001 sampling results for DRO confirmed the 1999 sampling results. DRO resultsfrom 1999 ranged from 15.3 to 1,310 mg/kg and in 2001 ranged from 7.2 to 970 mg/kg.None of the samples exceeded the Method 2 Ingestion cleanup level of 10,250 mg/kg.The 2001 sampling results for RRO did not match the 1999 sampling results. RROresults from 1999 ranged from 47.7 to 930 mg/kg and in 2001 ranged from 21 to 110mg/kg. However, none of the RRO sample results exceeded the 11,000 mg/kg Method 2ingestion cleanup level.The Quonset hut frames were not sampled for lead paint or asbestos during the initialinvestigation. However, soil samples collected in 1994 around the fallen Quonset hutswere non-detect for asbestos.No other analytes were detected during the 2001 sampling event at concentrationsexceeding the Method 2, under 40-inch zone, migration-to-groundwater cleanup levels.1.2.3.2 Site 4B –Former USAF Radar SiteSite 4B, the Former United States Air Force (USAF) Site, is also located on SevuokukMountain and covers an area approximately 375 feet by 500 feet (see Figure 1-2). Thissite housed buildings that burned and caused ordnance to explode and scatter debris.Analysis of soil samples collected during the Phase II RI, in 1995, showed elevated levelsof metals and dioxins. Soil and debris removal actions were performed by OSCI in 1999.Gambell Feasibility StudyFinal❏ Page 5February 2004The OSCI Site 4B map (OSCI Figure 6, shown in Appendix A) showed an areaapproximately 29 by 37 feet, partly covered by boulders, and with localized heavystaining and an oily substance. This area had 52 tons of soil excavated in 1999 to a depthof approximately 24 inches. Confirmation samples collected after the soil excavationshowed DRO at concentrations ranging from non-detect to 13,900 mg/kg. Theconcentration of dioxins also decreased as a result of removing the soil. The OSCI reportstates that the concentration of dioxins dropped by 75%.In 2001, supplemental RI fieldwork was done at Site 4B to verify the 1999 confirmationsampling results because the referenced latitude and longitude coordinates were notdocumented by OSCI. Thirty-six surface soil samples (nine each from the four triangulargrids) were collected and screened in the field using a PID and PetroFlag™ screeningkits. Four soil samples (one from each of the grids) with the highest field screeningresults were submitted for laboratory analysis of GRO, DRO, RRO, and RCRA metals.The 2001 sample results confirmed the 1999 sample results for arsenic. In 1999, arsenicconcentrations ranged from 0.604 to 1.57 mg/kg; in 2001, arsenic concentrations rangedfrom 1.4 to 4.3 mg/kg. For both sets of samples, results did not exceed the Method 2arsenic ingestion cleanup level of 5.5 mg/kg. All arsenic results are for total arsenic.The 1999 and 2001 lead sampling results at Site 4B did not agree. The highest leadconcentrations were 396 and 96 mg/kg in 1999 and 2001, respectively. The Method 2residential cleanup level for lead (400 mg/kg) was not exceeded in either sample set.The 2001 sample results for DRO confirmed the results for the 1999 samples. High DROconcentrations in 2001 (10,000 and 2,000 mg/kg) corresponded to high DROconcentrations in 1999 (13,700 and 643 mg/kg). Only the 13,700 mg/kg detection in1999 exceeded the Method 2 Ingestion cleanup level (10,250 mg/kg).GRO sample results from 2001 contained two notable differences from the 1999 sampleresults. The 1999 sample 99GAM021SL had a GRO concentration of 34.7 mg/kg, butthe corresponding 2001 sample had a GRO concentration of 310 mg/kg, slightlyexceeding the Method 2 migration to groundwater cleanup level for GRO of 300 mg/kg.Furthermore, the 2001 result was flagged as biased low, indicating that the actual GROconcentration may have been higher than 310 mg/kg. In 1999, the GRO result for sample99GAM023SL was non-detect (ND) (2.68 mg/kg), and the corresponding 2001 sampleresult was 240 mg/kg. Both results are below the Method 2 cleanup level.No other analytes were detected in the 2001 samples at concentrations exceeding theMethod 2, under 40-inch zone, migration-to-groundwater cleanup levels, including RRO.Gambell Feasibility StudyFinal❏ Page 6February 20041.2.3.3 Site 6 – Military LandfillSite 6 is located north of Gambell High School and east of the new housing area (seeFigure 1-2). This landfill was used to dispose of building materials, vehicles, machinery,drums, and miscellaneous debris. An investigation was performed in 1994. Exposeddrums (7,897 pounds) and other metal debris (1,748 pounds) were removed in 1999 byOSCI. A confirmation soil sample (99GAM026SL) collected from the approximatecenter of the removed drum stockpile had low levels of RRO and arsenic; no other fuelrelated contaminants, solvents, PCBs, or pesticides were detected.In 2001, community concerns, aerial photos and prior investigation results promptedsupplemental RI fieldwork at Site 6 to verify the 1999 confirmation sampling results andto further define the nature and extent of soil and groundwater contamination. Toconfirm the 1999 sampling results, nine surface soil samples from a triangular grid werecollected and screened in the field using a PID and PetroFlag™ screening kits. The twosoil samples with the highest field screening results were submitted for laboratoryanalysis of GRO, DRO, RRO, and RCRA metals.To further define the nature and extent of soil contamination, five soil borings (three asscheduled in the work plan plus two discretionary boreholes) were advanced to frozensoil. Soil boring locations were selected, in part, by the locations of depressionsidentified from aerial photographs in the HTSA report. The two discretionary boreholes(SB6-12 and SB6-13) were placed to help delineate the extent of contaminationsuspected at borehole SB6-11. Boreholes were continuously split-spoon sampled, andeach sample was field-screened using a PID. Soil samples were collected for laboratoryanalysis at the near-surface and at the near-bottom of each borehole, and from midborehole locations in two of the boreholes based on the highest PID readings. Sampleswere submitted for laboratory analysis of GRO, DRO, RRO, VOCs, and TAL metals.Groundwater was not encountered in any of the five soil borings at Site 6 during theSeptember 2001 sampling event. Groundwater was previously encountered in two of fivesoil borings installed in June 1994. Groundwater was measured at 8.0 feet bgs in SB6and 8.0 feet bgs in SB8. All soil borings drilled in 1994 and 2001 were drilled topermafrost. Figure 3-1 in Appendix B shows the location of soil borings drilled at Site 6in 1994 and 2001. The figure was originally prepared for the 1995 RemedialInvestigation Report. The locations of soil borings drilled in 2001 have been added.The 2001 surface soil grid sample results confirmed the 1999 sample results for arsenic.In 1999, arsenic was found at a concentration of 5.3 mg/kg; in 2001, arsenicconcentrations ranged from 6 to 7.7 mg/kg. For both sets of samples, results exceededthe default Method 2 arsenic cleanup level of 2 mg/kg. Additionally, previouslyanalyzed soil samples from various depths in all Site 6 boreholes exceeded Method 2cleanup levels for arsenic, with concentrations ranging from 3.7 to 13.2 mg/kg. Allarsenic results are for total arsenic.Gambell Feasibility StudyFinal❏ Page 7February 2004In borehole SB6-10, the soil sample collected from 2 feet below ground surface (bgs)contained antimony, total chromium, and nickel at concentrations of 7.3, 59, and 120mg/kg, respectively. These concentrations exceeded the Method 2 migration togroundwater cleanup levels for antimony (3.6 mg/kg), total chromium (26 mg/kg), andnickel (87 mg/kg). Unlike arsenic, these metals did not consistently exceed screeninglevels in other samples from the site, suggesting that the concentrations of antimony, totalchromium, and nickel may be related to debris or former military activities.DRO was found at a concentration of 1,200 mg/kg at 7 feet bgs in SB6-11. In SB6-12,the two DRO sample at 8 feet bgs had concentrations of 200 and 300 mg/kg. None of theresults exceeded the Method 2 Ingestion cleanup level (10,250 mg/kg). SB6-9, SB6-10and SB6-12 were drilled to 10 feet bgs, SB6-11 was drilled to 7.5 feet bgs, and SB6-13was drilled to 6.8 feet bgs.No other analytes were detected in the soil samples at concentrations exceeding theMethod 2, under 40-inch zone, migration-to-groundwater cleanup levels.1.2.3.4 Site 7 – Former Military Power FacilityThe Former Military Power Facility was reportedly demolished and buried north of thepresent Gambell Municipal Building. The burial site of this former military facilitycomprises Site 7 (see Figure 1-2). Electrical transformers were also reportedly disposedat this site. Additionally, Gambell residents have reported that the military may havedumped partially full barrels of oil or other petroleum products on the ground near thissite. During previous investigations, DRO was detected in shallow soils atconcentrations up to 1,950 mg/kg. Benzene (19 micrograms per liter - µg/l in MW-24)and DRO (19.4 mg/l in MW-25) were detected in groundwater samples from Site 7 in1994.Five soil borings were drilled in 1994 and four were completed as monitoring wells. Oneof the three monitoring wells (MW26) was abandoned due to lack of water. The threesoil borings were drilled in 2001 to 10, 7.2 and 6.2 feet bgs. Groundwater was notencountered in the soil borings drilled in 2001. All soil borings were drilled topermafrost in 1994 and 2001. Figure 3-1 in Appendix B shows the location of soilborings and monitoring wells installed at Site 7 in 1994 and 2001. The figure wasoriginally prepared for the 1995 Remedial Investigation Report. The locations of soilborings drilled in 2001 have been added.DRO was detected in soil samples collected while drilling MW-24, MW-25, and MW-26in 1994. Generally the DRO concentrations were higher (180 to 1,840 mg/kg) in shallow(2.5 to 5 feet bgs) soils and lower (13 to 400 mg/kg) in deeper (10 to 14 feet bgs) soilsamples. The same pattern was observed in soil samples collected from SB 7-20 in 2001.The DRO concentration was 710 mg/kg at 2 feet bgs and 160 mg/kg (duplicate was 460mg/kg) at 7 feet bgs. None of the DRO results exceeded the Method 2 Ingestion cleanuplevel for DRO (10,250 mg/kg).Gambell Feasibility StudyFinal❏ Page 8February 2004In 2001, supplemental RI fieldwork was done at Site 7 to further define the nature andextent of fuel and groundwater contamination, to determine the source of soilcontamination, and to evaluate the presence of PCBs. To determine the nature and extentof soil contamination, three soil borings were advanced to frozen soil. Soil boringlocations were selected, in part, by the locations of pits and buildings identified from1955 aerial photographs in the HTSA report. Soil samples were collected for laboratoryanalysis at the near-surface and at the near-bottom of each borehole, and from midborehole locations in two of the boreholes. Samples were submitted for laboratoryanalysis of DRO, RRO, PCBs, and Target Analyte List metals.The Site 7 borehole soil samples contained arsenic in concentrations ranging from 4.5 to10.2 mg/kg in the 2001 Supplemental RI. Arsenic concentrations ranged from 1 to 4mg/kg in the 1994 RI. The 1994 results are less than the ADEC Method 2 arsenicingestion cleanup level of 5.5 mg/kg. Six of the eleven arsenic results in 2001 exceededthe ADEC Method 2 arsenic ingestion cleanup level of 5.5 mg/kg. All arsenic results arefor total arsenic.Because of community concerns, regarding a report that transformers had been buried atSite 7, PCB samples were collected during the 2001 RI. PCBs were not detected in theseSite 7 samples. No other analytes were detected in the soil samples at concentrationsexceeding the Method 2, under 40-inch zone, migration-to-groundwater cleanup levels.1.2.3.5 Site 8 – West Beach/Army LandfillSite 8 encompasses the area surrounding the airstrip from west beach (north of theairfield), east to the western edge of Troutman Lake, and south to the northern shore ofNayvaghaq Lake. The site has been investigated and all detected analytes were belowADEC Method 2 cleanup level, except for arsenic. Surface debris removed by OSCI in1999 included scattered metal, small quantities of wood and concrete, drums containingtar, and an exposed layer of metal landing mat (Marston matting) approximately 30 feetwide and 4,500 feet long. Removal of the Marston matting was stopped because buriedelectrical lines interfered with the excavation. There is 1,820 lineal feet of metal landingmat remaining on site.Small-arms ammunition rounds are located at Area D along the beach south of TroutmanLake. Approximately 800 rounds were removed from Area D in July 2000. The FinalGambell Site EE/CA (USACE, 2002) states that additional rounds remain inapproximately 100 cubic yards of soil.1.2.3.6 Site 12 – Nayvaghaq Lake Disposal SiteSite 12 is located north of Nayvaghaq Lake on the southwest side of an all-terrain vehicle(ATV) trail. The site is divided into a north area and a south area. The north areacontained approximately 120 drums, battery remnants, and household refuse. The southarea contained approximately 50 drums, 18 of which were found to be full of garbage.Gambell Feasibility StudyFinal❏ Page 9February 2004The debris and drums were removed by OSCI in 1999. The OSCI report states that mostof the drums at Site 12 were punctured and empty. All drums were empty or contained afew ounces of rainwater (OSCI, 2001).Two monitoring wells were installed at the site in 1994. Permafrost was encountered inMW-17 and MW-18 at 5.5 and 6.0 feet bgs, respectively. Water was measured in MW17 and MW-18 at 2.5 and 4.0 feet bgs, respectively. Samples collected in 1994 includeone surface water sample from Nayvaghaq Lake, three surface soil samples, and twosubsurface soil samples. The soil samples were analyzed for VOCs, GRO, DRO, TRPH,priority pollutant metals, and PCBs. Total Recoverable Petroleum Hydrocarbons(TRPH) were detected in the three surface soil samples at concentrations ranging from 22to 75 mg/kg. The concentrations of metals detected in all soil samples were belowbackground. No other analytes were detected in the soil samples. Groundwater andsurface water samples were analyzed for VOCs, GRO, DRO, TRPH, PCBs, and prioritypollutant metals. DRO was detected in the surface water sample at a concentration of0.06 mg/L, below ADEC Table C levels. The only analytes detected in the groundwaterwere metals, which were below background. Background levels for groundwater andsurface water were determined from a sample taken from MW-14 located at the base ofSevoukuk Mountain. The only other analytes detected in the surface water were metals,which were below background.OSCI removed 798 pounds of metal debris, 8,702 pounds of HTW debris, and 7,237pounds of stained soil during the 1999 fieldwork. Following the debris removal,confirmation soil samples were collected. The OSCI map of Site 12 (OSCI, 2001)showed confirmation sample locations 99GAM009, -010, and -011SL, which hadconcentrations of DRO and lead of up to 463 mg/kg and 562 mg/kg, respectively.Arsenic concentrations in these samples ranged from 3.06 to 6.02 mg/kg, and the highesttotal chromium concentration was 20 mg/kg in 1999. GRO was not detected at Site 12 in1999.In 2001, supplemental RI fieldwork was done at Site 12 to verify the 1999 confirmationsampling results. Because exact locations of the 1999 samples were not surveyed orpermanently marked, triangular sampling grids were established using the approximatelocations of the 1999 samples as the grid center points. The grids approximated theprevious sample locations, which were not recorded. To confirm the 1999 samplingresults, 27 surface soil samples (9 each from 3 triangular grids) were collected andscreened in the field using a PID and PetroFlag™ screening kits. Locations andorientations of the triangular grids were decided in the field based on site observations.The four soil samples with the highest field screening results (the highest from each gridplus the next highest) were submitted for laboratory analysis of GRO, DRO, RRO, andRCRA metals.The 2001 sampling results confirmed the 1999 sampling results for arsenic. In 1999,arsenic concentrations ranged from 3.06 to 6.02 mg/kg; in 2001, arsenic concentrationsranged from 6.0 to 9.4 mg/kg. For both sets of samples, several results exceeded thearsenic ingestion cleanup level of 5.5 mg/kg.Gambell Feasibility StudyFinal❏ Page 10February 2004The 1999 confirmation sampling results for total chromium were not corroborated by the2001 sample results. In 1999, the highest total chromium concentration was 20 mg/kgversus 162 mg/kg in 2001. The 2001 results exceeded the ADEC Method 2 migration togroundwater cleanup level for total chromium (26 mg/kg)The lead level (562 mg/kg) found during the 1999 sampling event was confirmed by the2001 sampling results (7 mg/kg up to 1,530 mg/kg lead). For both sets of samples,results exceeded the residential lead cleanup level of 400 mg/kg.DRO levels (up to 463 mg/kg) found during the 1999 sampling event were not confirmedby 2001 sampling results (up to 46 mg/kg DRO). None of the DRO results exceeded theMethod 2 Ingestion cleanup level (10,250 mg/kg). The 2001 GRO results generallyconfirmed the 1999 GRO sample results. In 1999, GRO was not detected at Site 12; in2001, GRO was not detected in the primary sample but was detected at the lowconcentration of 13 mg/kg in a duplicate surface soil sample.No other analytes were detected in the 2001 samples at concentrations exceeding theMethod 2, under 40-inch zone, migration-to-groundwater cleanup levels.Gambell Feasibility StudyFinal❏ Page 11February 20042. Identification and Screening of TechnologiesThis section identifies the remedial action objectives (RAOs), general response actions,technology types, and specific process options for each site. Identification of theseelements was conducted following USEPA’s Guidance for Conducting RemedialInvestigation and Feasibility Studies Under CERCLA (USEPA 1988).Remedial action objectives are medium-specific (soil, groundwater, surface water, etc.)objectives for protecting human health and the environment. RAOs are discussed inSection 2.1. After RAOs have been established, Section 2.2 identifies the generalresponse actions, technology types, and applicable process options for each site,including volumes and areas of media to be remediated. The various technologies andprocess options are then screened in Section 2.3.2.1 Remedial Action ObjectivesThis section evaluates the applicable soil cleanup levels for each site. During theremedial investigation phase, concentrations of contaminants in soil were compared tothe ADEC Method 2, Table B cleanup levels (under 40 inch zone, migration togroundwater cleanup pathway). The migration to groundwater pathway is typicallyselected for comparison purposes, since it is usually the most conservative cleanup value.The migration to groundwater pathway assumes that contaminants in soil are likely toimpact a potential drinking water source. A site-specific evaluation of the exposurescenarios and pathways demonstrates that the migration of contaminants from each site toa drinking water source is unlikely to occur.The sites evaluated in this Feasibility Study – 4A, 4B, 6, 7, 8, and 12 – do not containgroundwater that could potentially be used as a current or future source of drinkingwater. The sites located at the top of Sevuokuk Mountain – Sites 4A and 4B – aresituated on a bedrock outcropping. Very little soil is found at the top of SevuokukMountain and groundwater is expected to run off the side of the mountain or enterbedrock fractures. It is unlikely that groundwater from Sites 4A and 4B could impact theaquifer at the base of the mountain. Figure 1-3 shows the location of the village watersupply well in relation to Sites 4A and 4B.Sites 6 and 7 are located near the east end of the Village of Gambell. Groundwaterencountered at these sites has been limited in quantity, and only sporadically detected.All soil borings were drilled to permafrost. In 1994, groundwater around Sites 6 and 7was measured to flow north from Troutman Lake to the Bering Sea. Appendix Bincludes Figure 3-1 from the 1995 Remedial Investigation. Also included in Appendix Bare Figures 3-2, 3-3, and 3-4, which show the cross-sections noted on Figure 3-1. Theshallow groundwater, when present, is found on top of the permafrost and is within theactive layer. The active layer is defined as the interval of soil that freezes and thaws eachyear. Soil below the active layer either remains frozen (permafrost) or unfrozen.Gambell Feasibility StudyFinal❏ Page 12February 2004Groundwater found on top of permafrost is usually not considered drinking water.Monitoring wells installed in this area typically have low recovery. Groundwater was notencountered in any of the eight borings drilled at Sites 6 and 7 in 2001.Site 12 is located south of Troutman Lake and north of Navaqaq Lake. The onlygroundwater encountered at this location in 1994 was at very shallow depths (2.5 and 4.0feet bgs). No contaminants were detected in groundwater samples collected in 1994.Groundwater in this area is likely influenced by saltwater intrusion (brackish water ofNayvaghaq Lake). Field observations indicate the water is most likely melted porewateron top of an active permafrost layer, or surface water infiltration that is perched above thepermafrost.It is unlikely that groundwater from the gravel spit will be used as a source of drinkingwater. Groundwater in the gravels is often saline, sporadically distributed, difficult torecover in useable quantities, and located over permafrost. Drinking water wells installedin the gravel have been abandoned in the past. A recent article from the Nome Nuggethad the following quote: “Our drinking water problem goes back to the 1930s and theold well dug by the BIA down by the old school which eventually went dry. Feasibilitystudies have more recently shown that we can obtain a better quality drinking water if wetap into Troutman Creek.” The current drinking water source is located at the base ofSevoukuk Mountain (see Figure 1-3).Therefore, the migration to groundwater pathway can be eliminated as a reasonableexposure route for all sites considered in this FS. The relevant ADEC cleanup levels arethe Method 2, Table B, under 40-inch zone, ingestion or inhalation pathway. The ADECMethod 2 cleanup levels are also considered conservative compared to Method 3 orMethod 4, which would likely result in higher cleanup levels. Further information isincluded below in the discussion of RAOs for each site.The default ADEC Method 2 cleanup level for arsenic is 2 mg/kg (under 40 inch zone,migration to groundwater pathway). Arsenic has been detected at concentrations abovethis level in almost every soil sample analyzed throughout the remedial investigation(1994-2001) at Gambell. The presence of arsenic in soil/gravel at Gambell may benaturally occurring. Since the arsenic concentrations are consistent across the site, anddo not appear associated with past military activity; arsenic is not considered acontaminant of concern which requires further remedial action.2.1.1 Site 4A – Quonset Huts Near Former USAF Radar SiteThe ADEC Method 2 ingestion cleanup level is appropriate and protective of humanhealth at Site 4A. Groundwater at the site is not used for private or public drinkingwater. It is very unlikely that a drinking water well would be installed at Site 4A. Thissite is at the top of Sevoukuk Mountain (615 feet above sea level). Bedrock eitheroutcrops here, or is very shallow, and the site abuts a steep natural slope. This geologicsetting would likely require a very deep well to reach a groundwater aquifer.Gambell Feasibility StudyFinal❏ Page 13February 2004Water resulting from rainfall or snowmelt at the site is an unlikely potential source ofdrinking water due to the accessibility of the site. Water potentially impacted by Site 4Acontamination cannot reasonably be expected to be transported to the village watersupply at the base of mountain farther to the south.Water near Site 4A likely flows to the northwest, the direction of the slope at Site 4A (seeFigure 1-3). Unconsolidated gravels at the base of the mountain constitute adiscontinuous aquifer. The flow of groundwater along the base of Sevuokuk Mountainwas assessed in 1994 and 1998, and found to flow to the north-northeast, away from thevillage water supply well. Site 4A is located roughly 1/2 mile northwest from the villagewater supply well. Monitoring wells MW-13 and MW-14 are located in theunconsolidated gravels near the area where groundwater from Site 4A would be expectedto flow down the side of the mountain. MW-13 is located almost directly down slopefrom Site 4A. MW-14 is south of MW-13 (closer to the village water supply) anddetermined to be upgradient of MW-13. DRO was not detected in the most recent (1994)sampling results from MW-13 and MW-14. These two monitoring wells could functionas sentry wells to the drinking water aquifer.The Method 2, under 40-inch zone ingestion cleanup level for DRO is 10,250 mg/kg.The highest levels detected at Site 4A do not exceed the ingestion cleanup level. Nofurther work is recommended for Site 4A.2.1.2 Site 4B – Former USAF Radar SiteThe ADEC Method 2 ingestion cleanup level is appropriate and protective of humanhealth at Site 4B. Conditions at Site 4B are similar to those at Site 4A, with Site 4Bbeing even further north, farther from the village water supply. Groundwater at the site isnot used for a private or public drinking water system, or within the zone of contributionor recharge area for a private or public drinking water well. Groundwater at the site isnot a reasonably expected potential source of drinking water due to the location of thesite. It is very unlikely that a drinking water well will be installed at Site 4B.Groundwater potentially impacted by Site 4B is not reasonably expected to betransported to a groundwater source. Groundwater from Site 4B likely flows to thenorthwest, and into the Bering Sea (see Figure 1-3).The Method 2, under 40-inch zone, ingestion, cleanup level for DRO is 10,250 mg/kg.The highest DRO concentration detected at Site 4B in 1999 was 13,700 mg/kg. Thehighest DRO concentration detected in 2001 was 10,000 mg/kg. The Method 2, under40-inch zone, ingestion cleanup level for GRO is 1,400 mg/kg. The highest GROdetection was 310 mg/kg, which does not exceed the ingestion cleanup level. Because ofthe removal action that occurred in 1999, there is only a small amount of soil remainingat Site 4B. No further work is recommended for Site 4B.2.1.3 Site 6 – Military LandfillGambell Feasibility StudyFinal❏ Page 14February 2004The Method 2 Ingestion cleanup level is appropriate and protective of human health atSite 6. Groundwater at the site is not used for a private or public drinking water system.Nor is it within the zone of contribution or recharge area for a private or public drinkingwater well. Groundwater was encountered in two out of three soil borings in 1994 and innone of the five soil borings drilled in 2001. Figure 1-3 shows where groundwater hasbeen encountered and the estimated groundwater flow direction. Groundwater at the siteis not a reasonably expected potential source of drinking water due to the limited quantityof groundwater at the site. It is very unlikely that a drinking water well will be installedat Site 6. Groundwater potentially impacted by Site 6 is not reasonably expected to betransported to another groundwater zone of contribution since groundwater at Site 6would flow to the Bering Sea, 1200 feet north. Pore water samples were collected in1994 from four soil borings at Site 6. The samples were analyzed for VOCs, GRO, DRO,TRPH, priority pollutant metals, and PCBs. DRO was the only analyte detected. Theconcentration of DRO ranged from 0.079 to 0.88 mg/L in three of the samples and wasnon-detect in the fourth. These concentrations do not exceed the ADEC Table CGroundwater Cleanup Level of 1.5 mg/L. Groundwater observed at Site 6 is found overpermafrost and is not usually considered drinking water.The media of concern at Site 6 are surface and subsurface soils. In borehole SB6-10, thesoil sample collected from 2 feet below ground surface (bgs) contained antimony, totalchromium, and nickel at concentrations of 7.3, 59, and 120 mg/kg, respectively. Theseconcentrations are less than Method 2 ingestion cleanup levels for antimony (41 mg/kg),total chromium (300 mg/kg), and nickel (2000 mg/kg). Arsenic concentrations insubsurface soil samples collected in 2001, ranged from 3.7 to 13.2 mg/kg. 7 of the 14arsenic results were less than the ADEC Method 2 ingestion cleanup level for arsenic(5.5 mg/kg).DRO has not been detected at levels exceeding the Method 2 ingestion cleanup level(10,250 mg/kg) at Site 6.Except for arsenic, no contaminants have been detected above ADEC Method 2 IngestionCleanup Levels. No further work is recommended for Site 6.2.1.4 Site 7 – Former Military Power FacilityThe Method 2 ingestion cleanup level is appropriate and protective of human health atSite 7. Groundwater at the site is not used for a private or public drinking water system,or within the zone of contribution or recharge area for a private or public drinking waterwell. Groundwater at the site is not a reasonably expected potential source of drinkingwater due to the limited quantity of groundwater. Groundwater was encountered in twoout of five soil borings in 1994 and in none of the three soil borings drilled in 2001. It isunlikely that a drinking water well will be installed at Site 7. Groundwater observed atSite 7 is found over permafrost and is not considered drinking water. Groundwaterpotentially impacted by Site 7 is not reasonably expected to be transported to anothergroundwater source since groundwater at Site 7 would flow to the Bering Sea, 2000 feetnorth.Gambell Feasibility StudyFinal❏ Page 15February 2004The media of concern for Site 7 is subsurface soil. DRO has not been detected at levelsexceeding the Method 2 ingestion cleanup level (10,250 mg/kg) at Site 7. The Site 7borehole soil samples contained arsenic in concentrations ranging from 4.5 to 10.2 mg/kgin the 2001 Supplemental RI. Arsenic concentrations ranged from 1 to 4 mg/kg in the1994 RI. The 1994 results are less than the ADEC Method 2 arsenic ingestion cleanuplevel of 5.5 mg/kg. Six of the eleven arsenic results in 2001 exceeded the ADEC Method2 arsenic ingestion cleanup level of 5.5 mg/kg.Except for arsenic, no contaminants have been detected above ADEC Method 2 IngestionCleanup Levels. No further work is recommended for Site 7.2.1.5 Site 8 – West Beach/Army LandfillThe media of concern at Site 8 is exposed debris, including Marsten matting and smallcaliber ammunition rounds.The first remedial action objective at Site 8 is to complete the removal of Marstenmatting along the east side of the runway. The OSCI Final Remedial Action Report(OSCI, 2001) notes that 1,820 lineal feet of Marsten matting remain.The second remedial action objective at Site 8 is to remove small arms rounds from AreaD along the beach south of Troutman Lake. Approximately 800 rounds were removedfrom Area D in July 2000. The Final Gambell Site EE/CA (USACE, 2002) states thatadditional rounds need to be removed from approximately 100 cubic yards of soil. Therounds will have to be sifted or hand-picked from the gravelly soils.2.1.6 Site 12 – Nayvaghaq Lake Disposal SiteThe ADEC Method 2 ingestion cleanup level is appropriate and protective of humanhealth at Site 12. Groundwater at the site is not used for a private or public drinkingwater system, or within the zone of contribution or recharge area for a private or publicdrinking water well. Groundwater was observed in two monitoring wells installed in1994, at 2.5 and 4 feet bgs. The site is located 100 to 200 feet west (cross gradient) ofthe Septic Disposal Area. It is very unlikely that a drinking water well will be installed atSite 12. Groundwater potentially impacted by Site 12 is not reasonably expected to betransported to another groundwater zone.The media of concern at Site 12 is surface soil. The highest total chromiumconcentration detected in 1999 at Site 12 was 20 mg/kg; in 2001, total chromiumconcentrations ranged up to 162 mg/kg. The 2001 results were less the Method 2Ingestion cleanup level for total chromium of 300 mg/kg. In 1999, arsenic concentrationsranged from 3.06 to 6.02 mg/kg; in 2001, arsenic concentrations ranged from 6.0 to 9.4mg/kg. For both sets of samples, several results exceeded the arsenic ingestion cleanuplevel of 5.5 mg/kg.Gambell Feasibility StudyFinal❏ Page 16February 2004The elevated lead level (562 mg/kg) found during the 1999 sampling event wasconfirmed by 2001 sample results (up to 1,530 mg/kg lead). For both sets of samples,results exceeded the residential lead cleanup level of 400 mg/kg.Elevated DRO levels (up to 463 mg/kg) found during the 1999 sampling event were notconfirmed by 2001 sample results (up to 46 mg/kg DRO). DRO has not been detected atlevels exceeding the Method 2 Ingestion cleanup level (10,250 mg/kg) at Site 12.Except for lead and arsenic, contaminants at Site 12 do not exceed the ADEC Method 2Ingestion Cleanup Levels. Additional work will be required to address the elevatedconcentration of lead in the soil.The following RAOs were developed for the Site 12:1. Prevent surface soil from continuing to act as a source of lead contamination tohuman and ecological receptors.2.2 Applicable or Relevant and Appropriate Requirements (ARARs)A review of potential applicable or relevant and appropriate requirements (ARARs) andto be considered (TBCs) was performed to facilitate selecting remedial alternatives.ARARs are those cleanup standards, standards of control, and other substantiveenvironmental protection requirements, criteria or limitations, established under federalor state law, that specifically address or regulate a hazardous substance, pollutant,contaminant, remedial action, location or other circumstance associated with the plannedremedial actions. If existing ARARs do not ensure protectiveness in all situations or siteconditions, then advisories, criteria, or guidelines will be used as TBCs to set cleanuptargets. ARARs and TBCs can be divided into three categories: (1) chemical-specific,(2) location-specific, and (3) action-specific.This project is a remedial action to address specific risks and hazards at the Gambell site.The following text describes ARARs and TBCs that affect tasks to be conducted under theremedial action, as proposed.2.2.1 Chemical-Specific ARARs and TBCsChemical-specific requirements are based on health or risk-based concentrations inenvironmental media (e.g. water or soil) for specific hazardous chemicals. Theserequirements may be used to set cleanup levels for the chemicals of concern in thedesignated media. The proposed chemical-specific action levels for contaminated soilare based on the State of Alaska Oil and Hazardous Substances Pollution Controlregulations , 18 AAC 75, Tables B1 and B2 (see Table 2.2).The Toxic Substances Control Act (TSCA) may also provide chemical specific actionlevels. TSCA is the primary Federal statute regulating the use of certain chemicals andsubstances, including asbestos, PCBs, radon and lead.Gambell Feasibility StudyFinal❏ Page 17February 20042.2.2 Location-specific ARARs and TBCsLocation-specific ARARs and TBCs are related to the geographical or physical position ofthe site. These requirements may limit the type of actions that can be implemented and maypose additional constraints on cleanup actions. No location-specific ARARs or TBCs wereidentified for the Gambell site. However, remedial actions must be coordinated with thelocal landowners, municipality, and tribal government.2.2.3 Action-Specific ARARs and TBCsAction-specific ARARs and TBCs are requirements that define acceptable treatment anddisposal procedures for hazardous substances. ARARs and TBCs set generalperformance, design or other similar action-specific controls or restrictions on particularkinds of activities related to management of hazardous substances or pollutants.Removal of the lead-contaminated soil must comply the requirements for identificationand proper disposal of hazardous wastes under RCRA (see Table 2.2). The process forinvestigating contaminated sites, selecting remedial actions, and implementing remedialactions is defined in the Comprehensive Environmental Response, Compensation andLiability Act (CERCLA), as amended by Superfund Amendments and ReauthorizationAct, October 17, 1987.2.3 Identification of General Response Actions, Remedial Technologies and ProcessOptionsSites 4A, 4B, 6, and 7 do not require additional response actions, therefore they are notevaluated further in this FS. Section 2.1 established RAOs for Sites 8 and 12. Generalresponse actions, remedial technologies, and process options are developed below forSites 8 and 12.General response actions include the following: no action, limited actions, containment,on-island treatment, and off-site treatment or disposal. Remedial technologies includetypes of actions (i.e., biological treatment, thermal treatment, and capping). Processoptions may include “specific types” of treatment. The general response actions,remedial technologies, and process options which meet the RAOs identified for Sites 8and 12 are described in the following sections.2.3.1 General Response ActionsThe general response actions applicable to the Gambell sites are the following:•••No ActionLimited ActionsContainmentGambell Feasibility StudyFinal❏ Page 18February 2004••On-Island TreatmentOff-Site Disposal2.3.2 Identification and Screening of Remedial TechnologiesThe remedial technologies identified for each general response action are shown on Table2-1. The No Action general response action includes no remedial technologies. Threetechnologies were identified for the Limited Action general response action: site controls,institutional controls, and monitoring. One technology was identified for theContainment general response action: capping. Three technologies were identified forthe On-Island Treatment general response action: physical, thermal, and biologicaltreatment. Two technologies were identified for the Off-site Disposal general responseoption: off-island treatment and landfilling.2.3.3 Evaluation of Technologies and Selection of Representative TechnologiesThis section presents an evaluation of the remedial technologies and process optionsidentified in the previous section. The effectiveness, implementability, and relative costof each remedial technology type and process option will be reviewed. The costinformation at this stage is based on engineering judgment. Relative capital andoperation and maintenance (O&M) costs are used rather than detailed estimates. Thecosts are presented in low, medium, and high terms relative to other process options inthe same remedial technology type. This evaluation will provide a selection of remedialtechnologies and process options that will be considered for further evaluation. Asummary of the process options that were retained or eliminated from furtherconsideration is presented in Figure 2-1.2.3.3.1 No ActionNo Action is required for consideration in the FS process by the National ContingencyPlan (NCP) as a baseline condition. The No Action option is retained for furtherevaluation. There are no capital costs associated with this option, and minimal costs forproject closeout activities only.2.3.3.2 Limited ActionsLimited Actions are designed to minimize exposure to hazardous materials and debris byrestricting site access or land use. Three remedial technologies for institutional controlswere screened: site controls, institutional controls, and long-term monitoring.Site ControlsEffectiveness. Access restrictions (such as fencing) can prevent exposure to surface soil,exposed debris, and the small arms burial pit. Access restrictions would not preventerosion or migration of contaminated soils.Gambell Feasibility StudyFinal❏ Page 19February 2004Implementability and Cost. No implementability limitations have been identified forinitiating access restrictions at Site 12. However, installation of fencing near the runwayat Site 8 would require coordination with and approval from the landowner, the AlaskaDepartment of Transportation and Public Facilities. Construction of fencing mayadversely affect maintenance of airport lighting/navigation aids or snow removalactivities. Installation of fencing around Area D would also impede snow machine travelduring the winter, when obstacles are difficult to observe in poor weather conditions.The construction costs are relatively low.Evaluation. Access restrictions are not retained for further evaluation, because they arenot effective at reducing long term potential risk to human health, would likely meet withlocal opposition, and would require extensive coordination and permission from theADOTPF.Institutional ControlsEffectiveness. Use restrictions are potentially effective methods to prevent exposure bysensitive populations (for example, children) or to prevent chronic exposure to soils. Userestrictions, such as deed or zoning restrictions, could prevent ingestion of soil from thesite by restricting specific site uses. For example, restrict future use of the area to nonresidential use. Use restrictions would probably have little effect on preventinginteraction with exposed debris near the airport and the west beach.Implementability and Cost. One implementability limitation identified for userestrictions is the lack of a mechanism for recording and enforcing the restriction. Thecost is relatively low.Evaluation. Access restrictions are not retained for further evaluation, because they arenot implementable and would likely meet with local opposition.Monitoring/Natural AttenuationEffectiveness. Soil sampling can be an effective technique for monitoring the progress ofnatural attenuation. However, soil-sampling results can vary significantly due to samplelocations, and sampling and analytical methods. Monitoring is only applicable forcontaminants that have the potential to naturally degrade over time. It is not likely thatmetals contamination in soil will measurably degrade over time. Monitoring/naturalattenuation is not applicable to the exposed metal debris at Site 8 and the small armsammunition at Area D.Implementability and Cost. No implementability issues have been identified for soilsampling. Due to the long distance to the Gambell site, the cost for sampling ismoderate.Evaluation. Monitoring soil for metals is not retained for further evaluation due to thelimited effectiveness of the process.Gambell Feasibility StudyFinal❏ Page 20February 20042.3.3.3 ContainmentContainment is designed to limit exposure to hazardous materials by creating a barrierbetween the impacted soil or debris and potential receptors. The only remedialtechnology considered for containment is capping.CappingThe process options are:••Compacted Clay – Compacted clay covered with sand and gravelSynthetic liner – Synthetic membrane without secondary barrierEffectiveness. Capping can be effective at minimizing exposure and minimizing theamount of surface water recharge to ground water at the site. Contaminants wouldremain on-site if this process option were selected.Implementability and Cost. Significant implementability limitations and relatively highcosts have been identified for capping. The severe weather conditions in Gambell, whichincrease the probability of damage from frost heaving and erosion, will impact the designconsiderations and construction costs. Yearly maintenance and monitoring costs toensure a successful cap would result in relatively high costs for this technology. Inaddition, constructing a cap over exposed debris on the slope adjacent to the airfieldwould require coordination with and approval from the ADOTPF.Evaluation. Containment is not retained for further evaluation, because of the highpotential maintenance costs.2.3.3.4 On-Island TreatmentThree on-island soil treatment technologies are considered: physical, thermal andbiological treatment. Each of the process options listed requires excavating the soil fortreatment. These technologies do not apply to the exposed metal debris at Site 8 or thesmall arms ammunition at Area D.Physical/ChemicalThe process options considered for the physical/chemical remedial technology are:••Soil Solidification/Stabilization –Binders such as cement/ash, silicates, orpozzolans are added to the soil to physically limit the solubility or mobility of themetals.Chemical Stabilization – Chemicals are added to the soil to convert heavy metalsinto mineral crystals, lowering the leachability of the metals.Gambell Feasibility StudyFinal❏ Page 21February 2004Effectiveness. Soil solidification/stabilization effectively immobilizes heavy metals byincorporating the contaminants into an inert matrix. Chemical stabilization chemicallybonds the heavy metals into a mineral crystal.Implementability and Cost. Implementability issues have been identified for physicaltreatment of the soil. It would be difficult and costly to implement asolidification/stabilization remediation system for a small quantity of soil at this remotesite. The cost to mobilize the equipment and supplies necessary to implement physicalstabilization, would be nearly the same as excavation and removal. Compared tophysical binders, smaller amounts of chemical stabilizer would be required, reducingshipping costs.Evaluation. Physical treatment of the soil in situ is not retained for further evaluation.Chemical stabilization of the soil is retained for further evaluation, because it appears to apotentially cost effective method for reducing the mobility of the contaminants.ThermalThermal processes are not effective at reducing concentrations of, or destroying metals incontaminated soil. Thermal processes are not retained for further consideration becausethey are not applicable technologies for lead-contaminated soil.BiologicalBiological remediation would have no impact on the concentration of metals (lead) in thesoil, and is not retained for further consideration.2.3.3.5 Off-site DisposalTwo off-site disposal technologies are considered: landfilling and thermal treatment.Each of the process options listed requires excavating and transporting the soil and debrisoff-island for treatment or disposal.LandfillingThe process option considered for the landfilling technology is:•Landfilling – Dispose of scrap metal in an approved, off-island, solid wastelandfill, dispose of metals-contaminated soil in an approved hazardous wastelandfill.Effectiveness. While landfilling would not remove contaminants from the soil, it is aneffective method of disposal. Landfilling would permanently remove the exposed debrisfrom the island.Gambell Feasibility StudyFinal❏ Page 22February 2004Implementability and Cost. Landfilling is relatively difficult to implement for largevolumes of soil or debris due to the challenge of shipping materials off-island. However,large volumes of soil are not expected based on current information, and the amount ofdebris is moderate. An additional challenge would be locating a landfill to take the leadcontaminated soil. Given the concentration of total lead in the soil, it is assumed the soilwould require disposal at a hazardous waste landfill. There are no landfills permitted toaccept RCRA wastes in Alaska. The scrap metal could also be taken to a recycler. Thecosts would be moderate.Evaluation. Landfilling is retained for further evaluation.Gambell Feasibility StudyFinal❏ Page 23February 2004Table 2-1Gambell Technology ScreeningMediaGeneralResponse ActionNo ActionTechnology Process OptionNo ActionSite ControlsLimited ActionsInstitutional ControlsMonitoring/Natural AttenuationTechnologiesfor Soil orContainmentCappingSedimentSolidification/StabilizationOn-IslandThermal TreatmentTreatmentBiologicalLandfill DisposalOff-Island Action- Retained for the development of alternatives- Eliminated from further considerationSite 8Site 12TABLE 2-2. SUMMARY OF APPLICABLE OR RELEVANT AND APPROPRIATEREQUIREMENTSStandard, Requirement, orDescriptionCriteriaCHEMICAL-SPECIFICAlaska Department of Environmental ConservationOil and Hazardous SubstancesEstablishes cleanup criteria for POL and nonPollution Control, as amendedPOL contamination in soil. The Method 2,January 30, 2003, 18 AAC 75.Table B1, Under 40-Inch Zone, IngestionMethod 2, Tables B1 and B2,Pathway applies to this particular action for theUnder 40-Inch Zone, Ingestionidentified chemicals of concern:PathwayDRO – 10,250 mg/kgRRO – 10,000 mg/kgGRO – 1,400 mg/kgAntimony – 41 mg/kgChromium – 300 mg/kgLead – 400 mg/kgNickel – 2,000 mg/kgToxic Substances Control Act, 15 The Toxic Substances Control Act (TSCA) ofU.S.C. s/s 2601 et seq (1976)1976 was enacted by Congress to give EPA theability to track the 75,000 industrial chemicalscurrently produced or imported into the US.CommentMay be relevant andappropriate to contaminatedsoils, for the identifiedchemicals of concern.May be relevant andappropriate to contaminatedsoils, for the identifiedchemicals of concern.Resource, Conservation andRecovery Act (RCRA).Identification and Listing ofHazardous Waste (40 CFR 261)Establishes criteria for identification ofmaterials as hazardous waste under RCRA.To be considered potentiallyapplicable to contaminatedsoil.EPA Region 9 PreliminaryRemediation Goals (PRGs)Provides risk-based preliminary remediationgoals for soil ingestion and inhalation underresidential and industrial exposure scenarios.Also provides soil screening levels formigration to groundwater.To be considered potentiallyapplicable to contaminatedsoil.EPA Region 3 Risk BasedConcentrations (RBCs)Provides risk-based concentrations for soilTo be considered potentiallyunder residential and industrial exposureapplicable to contaminatedscenarios, fish, ambient air, and tap water. Also soil.provides screening levels for migration togroundwater.ACTION-SPECIFICResource, Conservation and Recovery Act (RCRA)Identification and Listing ofEstablishes Criteria for identification ofHazardous Waste (40 CFR 261) materials as hazardous waste under RCRA.Lead-contaminated soil mustbe properly identified as asolid or hazardous waste.Comprehensive EnvironmentalResponse, Compensation andLiability Act (CERCLA),amended by SuperfundAmendments andReauthorization Act October 17,1987. Title 42, Chapter 103LOCATION-SPECIFICNone identifiedEstablishes a process for investigating andaddressing contaminated sites.May be relevant andappropriate to contaminatedsoils, for the identifiedchemicals of concern.Remedial actions will require coordination with Work activities near thethe local landowners, municipality, and tribalairfield must be coordinatedgovernment.with the ADOTPF.Figure 2-1Technology ScreeningGeneral ResponseActionRemedialTechnologyNo ActionNo ActionProcess OptionNo ActionInstitutionalControlsLimited ActionLimited ActionSite ControlsLong-TermMonitoringContainmentOn-siteTreatmentOff-siteDisposalEffectivenessImplementabilityCostCommentsDoes not reduce contaminant concentrationsor prevent migration of contamination. Doesnot achieve RAOs in timely manner.Easy to implement; however, state andcommunity acceptance is unlikely.No CostDoes not reduce contaminant concentrationsor prevent contaminant migration. Whenused alone, does not achieve RAOs in atimely manner. Effectiveness at preventingfuture exposure depends on continuedimplementation.Access restrictions (such as fencing) canprevent exposure to surface soil. Accessrestrictions do not reduce the volume orconcentration of contaminants on site.Long-term monitoring is not effective atremoving or degrading contamination.State and community acceptance is unlikely,unless active treatment metals. Enforcementof the restrictions may be difficult without alocal authority to implement.LowState and community acceptance is unlikely.Regular maintenance of a fence or otherbarrier would be expensive given thedistance to the site.Easy to implement, however, state andcommunity acceptance of monitoring alone isunlikely.Construction of an impermeable cap wouldrequire that large quantities of constructionmaterials be brought to the site. This wouldinclude some materials not available inGambell. The cap would need to beprotected from vehicular traffic.Soil excavation is relatively easy toimplement at Site 12.LowEliminated from consideration due toimplementability issues.ModerateEliminated from consideration due toimplementability issues.ModerateEliminated from consideration due toimplementability issues.ModerateRetained for further consideration.Excavation may be combined with a varietyof ex situ treatment technologies in thedevelopment of alternatives.Stabilization/solidification eliminated fromfurther consideration due to implementabilityissues.Thermal treatment is eliminated from furtherconsideration due to high concentrations oflead-contaminated soil.An impermeable cap would reduce themigration of soluble contaminants togroundwater. It would not remove or destroycontaminants.ContainmentImpermeableCapExcavationExcavationPhysicalTreatmentStabilization/SolidificationPhysicalTreatmentThermalTreatmentChemicalTreatmentChemicalTreatmentBiologicalTreatmentBiologicalTreatmentBiological technologies are effective atremoving degraded diesel fuel from soil.Biological remediation would have no impacton the concentration of metals in the soil.Off-siteDisposalLandfillingEffective for a variety of contaminants. Ifcontaminants are not destroyed and aremixed with other wastes, could createadditional liability for the Army.All ex situ technologies rely on excavation toaccess contaminated soils. To be effective,excavation must be combined with treatmenttechnologies.Soil stabilization/solidification can beeffective at immobilizing metals in soil.Thermal technologies can be effective atremoving VOCs from soil and less effective atremoving degraded diesel. Thermalremediation would have no impact on theconcentration of metals in the soil.Chemical technologies can be effective atreducing the toxicity and mobility ofcontaminants.=Technology or process option eliminated from further consideration.=Technology or process option retained for further consideration.Required under CERCLA as a baselineagainst which remedial alternatives arecompared. Because ADEC residentialcleanup levels are exceeded, this is not aviable option for lead-contaminated soil.Eliminated from consideration due toimplementability issues.Gambell is a remote location to ship, setupand operate a stabilization/solidificationsystem.Gambell is a remote location to ship, setupand operate a thermal treatment system.HighGambell is a remote location to apply achemical treatment. The remoteness willresult in higher costs and the extremeweather conditions will slow treatment.Gambell is a remote location to setup andoperate a biological treatment system. Theremoteness will result in higher costs and theextreme weather conditions will slowtreatment.Moderate difficulty to implement for smallvolumes of soil. Key implementability issuesinclude transporting soil from remote locationto RCRA-permitted landfill.ModerateRetained for further consideration.HighEliminated from consideration due toimplementability issues.HighRetained for further consideration. Offsitedisposal offers suitable location for metalscontaminated soil, and is particularlyappropriate in dealing with small volumes ofwaste.High3. Development and Screening of AlternativesIn this section, general response actions and the process options chosen to represent thevarious technology types are combined to form alternatives for the Gambell sites.Alternatives were developed to represent a range of potential remedial actions.The alternatives include:• No action (Alternative 1);• Removal of exposed debris only (Alternative 2); and• Off-island disposal of exposed debris and contaminated soil (Alternative 3).• In-situ treatment of contaminated soil and off-island disposal of exposeddebris (Alternative 4).3.1 Descriptions of AlternativesThe following sections describe the conceptual designs for these alternatives and thebasis for the design approach. The conceptual designs of the alternatives presented inthis section are based on the best available information at the time that this report wasprepared.3.1.1 Alternative 1 : No ActionThe No Action Alternative involves no additional actions at the site. This alternative isrequired by the NCP.3.1.2 Alternative 2 : Removal of Exposed Debris OnlyThe Removal of Exposed Debris Only Alternative includes removal of exposed debris,including Marsten matting from Site 8 and small caliber ammunition from Site D. Nocontaminated soil would be removed under this alternative. Metallic debris would bedisposed off site.3.1.3 Alternative 3: Off-Island DisposalThe Off-Island Disposal Alternative includes the following:•••Excavation of metals (lead) contaminated soil from Site 12.Removal of exposed debris, including marsten matting from Site 8 and smallcaliber ammunition from Site D.Off-island disposal of debris and metals-contaminated soil.3.1.4 Alternative 4: In-situ Soil Treatment and Off-Island Disposal of DebrisThe In-Situ Soil Treatment Alternative includes the following:Gambell Feasibility StudyFinal❏ Page 24February 2004•••In-situ chemical treatment of metals (lead) contaminated soil from site 12.Removal of exposed debris, including marsten matting from Site 8 and smallcaliber ammunition from Site D.Off-island disposal of debris and ammunition.Gambell Feasibility StudyFinal❏ Page 25February 20044. Detailed Analysis of AlternativesThis section provides the results of the evaluation for the alternatives developed for theGambell Sites in Section 3.0. First the individual analysis of alternatives is presentedusing the seven evaluation criteria described in Section 4.1. A comparative analysis ofalternatives is then presented using the same evaluation criteria.4.1 Individual Analysis of AlternativesThis section presents an analysis of each of the alternatives by comparing them to sevenspecific criteria:•••••••Overall protection to human health and the environmentAttainment of cleanup standards and compliance with applicable state and federallaws, and local requirements.Short-term effectivenessLong-term effectivenessReduction of toxicity, mobility and volume through treatmentImplementabilityCostThese factors are described below:Overall protection to human health and the environment. This assessment focuses onwhether a specific alternative achieves adequate protection of human health and theenvironment, and describes how site risks are eliminated, reduced, or controlled throughtreatment or institutional controls.Attainment of cleanup standards and compliance with applicable state and federal laws,and local requirements. This addresses the federal, state, and/or local requirementswhich are applicable or relevant and appropriate for a specific alternative and how thealternative meets these requirements.Short-term effectiveness. Short-term effectiveness considers the protection of publichealth, worker health and the environment during the construction and implementation ofa remedy until remedial action objections are met.Long-term effectiveness. Long-term effectiveness considers the effectiveness of eachalternative in maintaining protection of human health and the environment after responseaction objectives have been met. The magnitude of remaining risk from untreated soil ortreatment residuals, if any, and the adequacy and reliability of controls for providingprotection from residuals, are considered in this assessment.Reduction of toxicity, mobility, and volume through treatment. This criterion considersthe type and quantity of residuals that will remain following treatment, and the degree toGambell Feasibility StudyFinal❏ Page 26February 2004which the treatment reduces the hazards posed by the site. Where possible, numericalcomparisons before and after remediation are presented.Implementability. The technical and administrative feasibility of each alternative isevaluated in this criterion. Technical feasibility includes the ability to construct thesystem used, the ability to operate and maintain the equipment, and the ability to monitorthe effectiveness of operations. Administrative feasibility refers to the ability to obtainnecessary permits and approvals from applicable regulatory agencies and the likelihoodof favorable community response.Cost. The capital cost associated with the development and construction, and the annualO&M costs of each alternative are evaluated in this step. The cost estimates are preparedfor guidance in project evaluation and implementation from the information available atthe time of the estimate. The actual cost of remediation depend on many variables,including volume of contaminated soil, concentration and total mass of contaminantstreated, distance to contaminated site, cleanup levels, health and safety regulations, laborand equipment costs, and the final project scope. As a result, the final project costs willvary from the estimates presented herein. Because of this, project feasibility and fundingneeds must be carefully reviewed prior to making specific financial decisions to helpensure proper evaluation and adequate funding. Costs are expected to be within therange of accuracy typical of FS-level costs estimates (-30 to +50 percent).4.1.1 Alternative 1 – No ActionAnalysis of the No Action Alternative is required by the NCP. This alternative involvesno further action at the site and is sometimes referred to as the “walk-away” alternative.4.1.1.1 EvaluationOverall protection. The No Action Alternative does not reduce the risk currently posedby the Gambell sites. The contaminant concentrations at Site 12 exceed regulatorylimits, and may pose a significant risk to human health or the environment. The exposeddebris would continue to pose a physical hazard to local residents.Compliance with ARARs. The No Action Alternative does not comply with theidentified ADEC soil cleanup levels for lead at Site 12, since there would be no reductionin the concentration or quantity of contaminants in soil at that site.Short-term effectiveness. There are no short-term risks posed by the site orimplementation of Alternative 1, since there are no actions included in this alternative.Long-term effectiveness. The No Action Alternative does not reduce the long-term risksassociated with the site.Gambell Feasibility StudyFinal❏ Page 27February 2004Reduction of Toxicity, Mobility, or Volume. The No Action Alternative will not reducethe toxicity, mobility, or volume of contaminated soil. The No Action Alternative wouldnot reduce the physical hazards associated with the exposed debris.Implementability. No technical or administrative implementability issues have beenidentified for the No Action Alternative. This alternative will likely be met with localopposition.Cost. The estimated cost for Alternative 1 is $39,700.4.1.2 Alternative 2 – Removal of Exposed Debris OnlyThe Removal of Exposed Debris Only Alternative only includes removal of exposeddebris from Site 8 and small caliber ammunition from Site D. Site 8 debris includesMarsten matting located along the eastside of the runway. Site D debris includes thebeach ammunition dump located 1 1/3 miles south of the runway. Debris would betransported to an off-site landfill or sent to a recycling facility. There is no soil removalincluded with this alternative.4.1.2.1 EvaluationOverall protection. The Removal of Exposed Debris Only Alternative reduces thephysical hazard posed by the debris. However, this Alternative does not reduce thepotential risk associated with the lead-contaminated soils present at Site 12.Compliance with ARARs. The Removal of Exposed Debris Only Alternative complieswith ARARs by requiring disposal of the debris in an approved landfill. However, thisalternative does not comply with identified ADEC soil cleanup levels at Site 12, sincelead-contaminated soil is left in place.Short-term effectiveness. There are no short-term risks posed by implementation ofAlternative 1. Since there are no know chemical hazards in the areas where debrisremoval would occur, implementation of this alternative would be protective of publicand worker health. A health and safety plan will be followed to ensure general safeworking conditions.Long-term effectiveness. The Removal of Exposed Debris Only Alternative effectivelyreduces the long-term physical hazard posed by the debris. Site 8 and Site D do notcurrently pose a chemical hazard. However, this alternative does not reduce the longterm risks associated with Site 12.Reduction of Toxicity, Mobility, or Volume. The Removal of Exposed DebrisAlternative will reduce the volume of exposed debris at Site 8 and Site D. Thisalternative will not reduce the toxicity, mobility, or volume of contaminated soil at Site12.Gambell Feasibility StudyFinal❏ Page 28February 2004Implementability. Implementation of this alternative will require coordination with theState of Alaska Department of Transportation and Public Facilities (DOTPF). Electricalwiring for the runway lights will need to be rerouted to allow removal of the Marstenmatting. There may also be working hour restrictions due to runway operations. Theremay be difficultly encountered when trying to sift the .30 cal ammunition from thegravels. There should be no difficultly locating an approved off-site landfill or recyclingfacility once the debris is removed.Cost. The estimated cost for Alternative 2 is $370,000.4.1.3 Alternative 3 – Off-Island Disposal of Lead Contaminated Soil and ExposedDebrisThe Off-Island Disposal Alternative includes excavation of metals-contaminated soilfrom Site 12, and removal of exposed debris from Site 8 and Site D. Site 12 contains soilcontaminated with lead. Site 8 debris includes marsten matting located along the eastside of the runway. Site D debris includes the beach ammunition dump located 1 1/3miles south of the runway. Debris and contaminated soil would be transported to an offsite landfill, or sent to a recycling facility.4.1.3.1 EvaluationOverall protection. Alternative 3 would remove the risk posed by Site 12 by excavatingsoil containing lead above regulatory concentrations. This alternative also reduces thephysical hazard posed by the debris at Site 8 and Site D.Compliance with ARARs. This alternative would reduce the level of contamination tomeet ARARs that apply to the Gambell site. All contaminated soil and debris would beremoved and properly disposed at an approved off-site landfill.Short-term effectiveness. There is a potential for exposure to site workers whileexcavating, transporting and treating the contaminated soil. Following a health andsafety plan and using appropriate personal protective equipment, would minimizeexposure of site workers to contaminants. Additional measures would be taken toprevent exposure to residents entering the areas during implementation of the alternative.The short-term risks are manageable.Long-term effectiveness. The residual risk posed by the site would be reduced by thisalternative because the contaminated soil and exposed debris would be removed.Institutional controls would not be necessary since no soil with contaminants aboveregulator levels would remain on site.Reduction of toxicity, mobility, and volume. The lead-contaminated soil would not betreated, so there would be no reduction in the toxicity, mobility or volume.Gambell Feasibility StudyFinal❏ Page 29February 2004Implementability. Implementation of the debris removal portion of this alternative willrequire coordination with the State of Alaska Department of Transportation and PublicFacilities (DOTPF). Electrical wiring for the runway lights will need to be rerouted toallow removal of the Marsten matting. There may also be working hour restrictions dueto runway operations. There may be difficulty encountered when trying to sift the .30 calammunition from the gravels. There should be no difficulty locating an approved off-sitelandfill or recycling facility once the debris is removed. There should be no difficultyexcavating or transporting the lead contaminated soil from Site 12. There should also beno difficulty locating an approved landfill for the contaminated soil.Cost. The estimated cost for Alternative 3 is $418,200.4.1.4 Alternative 4 – In-situ Treatment of Lead Contaminated Soil and Off-IslandDisposal of Exposed DebrisThe In-situ Treatment Alternative includes treatment of metals-contaminated soil fromSite 12, and removal of exposed debris from Site 8 and Site D. Site 12 contains soilcontaminated with lead. Site 8 debris includes marsten matting located along the eastside of the runway. Site D debris includes the beach ammunition dump located 1 1/3miles south of the runway. Debris would be transported to an off site landfill, or sent to arecycling facility. Soil at Site 12 would be treated to chemically bind the leadcontamination into a compound, reducing the leachability of the metals.4.1.4.1 EvaluationOverall protection. Alternative 4 would reduce the risk posed by Site 12 by treating soilcontaining lead above regulatory concentrations. This alternative also reduces thephysical hazard posed by the debris at Site 8 and Site D.Compliance with ARARs. This alternative would not reduce the level of contaminationand would not meet all ARARs that apply to the Gambell site. All debris would beremoved and properly disposed at an approved off-site landfill.Short-term effectiveness. There is a potential for exposure to site workers while treatingthe contaminated soil. Following a health and safety plan and using appropriate personalprotective equipment, would minimize exposure of site workers to contaminants.Additional measures would be taken to prevent exposure to residents entering the areasduring implementation of the alternative. The short-term risks are manageable.Long-term effectiveness. The residual risk posed by the site would be reduced by thisalternative because the leachability of the contaminants in soil would be reduced andexposed debris would be removed. Institutional controls would not be necessary sincethe leachability of contaminants in soil would be reduced.Gambell Feasibility StudyFinal❏ Page 30February 2004Reduction of toxicity, mobility, and volume. The lead-contaminated soil would betreated in-situ, resulting in a reduction in the toxicity and mobility of the contaminants.The volume of the contaminated soil would not be reduced.Implementability. Implementation of the debris removal portion of this alternative willrequire coordination with the State of Alaska Department of Transportation and PublicFacilities (DOTPF). Electrical wiring for the runway lights will need to be rerouted toallow removal of the Marsten matting. There may also be working hour restrictions dueto runway operations. There may be difficulty encountered when trying to sift the .30 calammunition from the gravels. There should be no difficulty locating an approved off-sitelandfill or recycling facility once the debris is removed.There should be no difficulty applying chemical treatment to lead contaminated soil atSite 12. The lead contamination is not expected to extend more than 2 to 4 feet into thesubsurface.Cost. The estimated cost for Alternative 4 is $432,800.4.2 Comparative AnalysisIn this section of the FS, the alternatives developed in Chapter 3 and evaluated withrespect to specific criteria in Section 4.1 are compared to one another to allow forselection of the remedial action at the Gambell sites.4.2.1 Overall Protection of Human Health and the EnvironmentAlternatives 1 and 2 would not reduce the chemical risk posed to human health and theenvironment since no actions would be taken to address the lead-contaminated soil.Alternatives 2, 3, and 4 address the physical hazard posed by exposed debris. Alternative3 would be most protective because the lead-contaminated soil would be permanentlyremoved and disposed off-site. Alternative 4 would be less protective than Alternative 3,because the treated soil would remain in place.4.2.2 Compliance with ARARsAlternatives 1 and 2 would not reduce or remove lead contaminants in soil at Site 12 andwould therefore not meet ARARs. Alternative 3 would comply with ARARs since thelead-contaminated soil would be removed from Site 12 and disposed off-island.Alternative 4 would not comply with ARARs, since the concentration of lead in soilwould not be reduced. Additional tests would have to be performed on the soil followingtreatment to document the reduced leachability of the lead.4.2.3 Short-Term EffectivenessGambell Feasibility StudyFinal❏ Page 31February 2004None of the alternatives represent an unacceptable risk to the community, workers or theenvironment during implementation.4.2.4 Long-Term EffectivenessAlternative 3 has the highest long-term effectiveness because this alternative has thehighest potential to permanently remove the lead-contaminated soil. Alternatives 1 and 2provide the least long-term effectiveness since neither includes action to reduce theamount of lead-contaminated soil. Alternative 4 has a long-term effectiveness that is lessthan Alternative 3 because Alternative 4 leaves the treated soil on-site. Alternative 4 hasa long-term effectiveness that is greater than Alternatives 1 and 2, because Alternative 4treats the lead contaminated soil in-situ.4.2.5 Reduction of Toxicity, Mobility, or Volume Through TreatmentAlternatives 1 and 2 do not reduce the toxicity, mobility, or volume of the leadcontaminated soil. Alternative 3 reduces the volume of contaminants left on site throughremoval. Alternative 4 reduces the mobility and toxicity of the lead, but not the volume.4.2.6 ImplementabilityAll of the alternatives can be implemented using commercially available services.Alternative 1 and 2 could be easily implemented and few technical challenges would beexpected. Alternative 3 is more challenging. This alternative includes excavation andoff-island disposal of the metals contaminated soil. Alternative 4 would be the mostchallenging to implement. Alternative 4 would require the application and mixing of areagent with the lead contaminated soil.4.2.7 CostTable 4-1 presents a summary of the total estimated costs for each of the alternatives.Alternative 1 has the lowest cost ($39,700) and Alternative 2 has the second lowest cost($370,000). Alternative 4 has the highest costs ($432,800) and Alternative 3 has thesecond highest cost ($418,200). Overall, the additional cost to remove and dispose of thelead-contaminated soil is not significantly higher than Alternative 2 (Remove of ExposedDebris Only) and less than Alternative 4 (Treat Lead Contaminated Soil In-situ).4.2.8 Preferred AlternativeAlternative 3 is the preferred alternative. Alternative 3 is less complex than Alternative 4and will permanently reduce the risk posed by lead contaminated soil at Site 12.Alternative 4 may reduce the mobility and toxicity of the lead, but it will not reduce thevolume of lead contaminated soil.Gambell Feasibility StudyFinal❏ Page 32February 2004AlternativesAlternative 1 - No ActionAlternative 2 - RemoveExposed Debris OnlyAlternative 3 - RemoveExposed Debris and LeadContaminated SoilAlternative 4 - Treat LeadContaminated Soil andRemove Exposed DebrisGambell Feasibility StudyDraftTable 4-1Cost Comparison SummaryActionsCategoriesProject Close outProject Close OutCostsTotal:$39,700Total:$53,400$184,400$117,600$14,600$370,000Total:$77,300$192,100$131,100$17,700$418,200Total:$77,300$192,100$145,700$17,700$432,800Work Plans and ReportsMobilization/DemobilizationOff-site disposal ofField Workdebris in landfillProject ManagementWork Plans and ReportsOff-site disposal of Mobilization/Demobilizationdebris and soil in Field WorklandfillProject ManagementWork Plans and ReportsOn-site treatment of Mobilization/Demobilizationsoil and off-siteField Workdisposal of debris Project ManagementNovember 2003BibliographyEcology and Environment, Inc. (E&E). 1992. Inventory Report, Gambell, FormerlyUsed Defense Site, St. Lawrence Island, Alaska. Contract No. DACA85-91-D003. December.E&E. 1992. Site Inventory Report, Gambell Formerly Used Defense Site, St. LawrenceIsland, Alaska. December.E&E. 1993. Chemical Data Acquisition Plan, Site Inventory Update, Gambell, St.Lawrence Island, Alaska. February.Golder Associates Inc. (GAI). 1994. Final Report Geophysical Survey Investigation –St. Lawrence Island, Alaska, USA. November 3.GAI. 1996. Geophysical Survey Investigation, Gambell, Alaska. August 22.Montgomery Watson (MW). 1995a. Remedial Investigation, Gambell, St. LawrenceIsland, Alaska. January.MW. 1995b. Remedial Action Alternatives Technical Memorandum, Gambell, St.Lawrence Island, Alaska. November 6.MW. 1995c. Building Demolition and Debris Removal Technical Memorandum,Gambell, St. Lawrence Island, Alaska. December 8.MW. 1997. Investigation of Geophysical Anomaly, Gambell, St. Lawrence Island,Alaska. Final. December.MW. 1998. Phase II Remedial Investigation, Gambell, St. Lawrence Island, Alaska.Final. December.MW. 1999a. Site 5 Remedial Investigation, Gambell, St. Lawrence Island, Alaska.MW. 1999b. Final Investigation of Geophysical Anomaly, Gambell, St. LawrenceIsland, Alaska. Final. December.MW. 2000. Strategic Project Implementation Plan, Gambell, St. Lawrence Island,Alaska. Final. December.MWH Americas, Inc. (MWH). 2002. Summary Report 2001 Supplemental RemedialInvestigation, Gambell, St. Lawrence Island, Alaska. Final. May.Oil Spill Consultants, Inc. (OSCI). 2001. Remedial Action Report for Debris Removaland Containerized Hazardous Waste and Toxic Waste Removal, Gambell, Alaska.Final. February 15.Gambell Feasibility StudyFinal❏ Page 33February 2004United States Army Corps of Engineers Engineer Research and Development Center,Topographic Engineering Center (TEC). 2000. GIS-Based Historical TimeSequence Analysis (Historical Photographic Analysis), Gambell Sites, St.Lawrence Island, Alaska. Final. September.United States Army Corps of Engineers (USACE). 2002. Engineering Evaluation / CostAnalysis (EE/CA), Gambell sites, St. Lawrence Island, Alaska. Final.November.United States Environmental Protection Agency (USEPA). 1988. Guidance forConducting Remedial Investigations and Feasibility Studies Under CERCLA.EPA/540/G-89/004. Interim Final. October.URS Corporation and Rittenhaus-Zeman & Associates (URS). 1985. DefenseEnvironmental Restoration Program (DERP), Gambell, St. Lawrence Island,Alaska, Geotechnical, Geophysical, Soil, and Groundwater Quality Studies,Prepared for URS Engineers, W-4581. August.Gambell Feasibility StudyFinal❏ Page 34February 2004Appendix ASUMMARY SHEETActivityCostAlternative 1 - No ActionReportingCoordinationTravel$23,700$13,000$3,000Total$39,700Alternative 2 - Debris Removal OnlyPlanning and Pre-Mob ActivitiesMobilizationField WorkDemobilizationReportingProject ManagementTotal$33,300$88,000$117,600$96,400$20,100$14,600$370,000Alternative 3 - Contaminated Soil and Debris RemovalPlanning and Pre-Mob ActivitiesMobilizationField WorkDemobilizationLab SamplesReportingProject ManagementTotal$47,400$90,500$127,100$101,600$4,000$29,900$17,700$418,200Alternative 4 - Contaminated Soil Treatment and Debris RemovalPlanning and Pre-Mob ActivitiesMobilizationField WorkDemobilizationLab SamplesReportingProject ManagementTotal$47,400$90,500$141,700$101,600$4,000$29,900$17,700$432,800Project Close OutGambell Feasibility StudyItemHoursRateTotalPrepare Draft Site Closeout ReportProject ManagerEnvironmental EngineerOE Technician IIIClerical20802040$70.00$70.00$60.00$29.75$1,400$5,600$1,200$1,190Prepare Responses to commentsProject ManagerEnvironmental EngineerOE Technician IIIClerical10201010$70.00$70.00$60.00$29.75$700$1,400$600$298Review ConferenceProject ManagerEnvironmental Engineer88$70.00$70.00$560$560Community Involvement ActivitiesProject ManagerEnvironmental Engineer2020$70.00$70.00$1,400$1,400Attend RAB meetingProject ManagerEnvironmental Engineer2424$70.00$70.00$1,680$1,680Coordinate with RegulatorsProject ManagerEnvironmental Engineer4020$70.00$70.00$2,800$1,400Prepare Final Site Closeout ReportProject ManagerEnvironmental EngineerOE Technician IIIClerical16401020$70.00$70.00$60.00$29.75$1,120$2,800$600$595SubtotalOther Direct and Indirect Costs (15%)Travel Costs (2 persons)Profit (10%)Grand Total$28,983$4,347$3,000$3,333$39,663Round up to nearest hundred$39,700Planning and Pre-Mob ActivitiesGambell Feasibility StudyItemNumberSite D - Subsurface OE ClearanceWork Plan and Health/Safety PlanPreparation1Site 8 - Marsten Matting Debris CleanupPrepare Draft Health and Safety PlanEnvironmental EngineerIndustrial HygenistClericalPrepare Draft Work PlanEnvironmental EngineerChemistClericalPrepare Responses to commentsEnvironmental EngineerIndustrial HygenistChemistClericalReview ConferenceEnvironmental EngineerIndustrial HygenistChemistPrepare Final Health and Safety PlanEnvironmental EngineerIndustrial HygenistClericalSubcontractingScope of WorkEnvironmental EngineerCost EstimatorContract SpecialistNegotiationsEnvironmental EngineerContract SpecialistAwardContract SpecialistBarging SubScope of WorkEnvironmental EngineerCost EstimatorContract SpecialistNegotiationsEnvironmental EngineerContract SpecialistAwardContract SpecialistTDU SubScope of WorkEnvironmental EngineerCost EstimatorContract SpecialistUnitRateTotalLump Sum$12,000.00$12,00044040$70.00$50.75$29.75$280$2,030$1,190201620$70.00$59.50$29.75$1,400$952$5958888$70.00$50.75$59.50$29.75$560$406$476$238444$70.00$50.75$59.50$280$203$23822020$70.00$50.75$29.75$140$1,015$595410$70.00$59.50$57.75$280$60$044$70.00$57.75$280$2314$57.75$231004$70.00$59.50$57.75$0$0$23104$70.00$57.75$0$2314$57.75$231400$70.00$59.50$57.75$280$0$0Planning and Pre-Mob ActivitiesNegotiationsEnvironmental EngineerContract SpecialistAwardContract SpecialistPre-construction MeetingField ForemanEnvironmental EngineerGambell Feasibility Study04$70.00$57.75$0$2314$57.75$23188$77.00$70.00SubtotalOther Direct and Indirect Costs (15%)Profit (10%)Grand TotalRound up to nearest hundredSite 12 - Lead Contaminated Soil ExcavationPrepare Draft Sampling and Analysis PlanEnvironmental EngineerChemistClericalPrepare Draft Work PlanEnvironmental EngineerChemistClericalPrepare Responses to commentsEnvironmental EngineerIndustrial HygenistChemistClericalReview ConferenceEnvironmental EngineerIndustrial HygenistChemistPrepare Final Work PlanEnvironmental EngineerChemistClericalLaboratory SubScope of WorkChemistCost EstimatorContract SpecialistNegotiationsChemistContract SpecialistAwardContract Specialist$616$560$26,291$3,944$3,023$33,257$33,30082020$70.00$59.50$29.75$560$1,190$595201620$70.00$59.50$29.75$1,400$952$5958888$70.00$50.75$59.50$29.75$560$406$476$238444$70.00$50.75$59.50$280$203$23820820$70.00$59.50$29.75$1,400$476$595411$59.50$59.50$57.75$238$60$5842$70.00$57.75$280$1164$57.75SubtotalOther Direct and Indirect Costs (15%)Profit (10%)Grand TotalRound up to nearest hundred$231$11,146$1,672$1,282$14,099$14,100DemobilizationGambell Feasibility StudyItemNumberSite D - Subsurface OE ClearanceLabor (Travel and Construct Gravel Sieve in Anchorage)UXO Technician III0*Project Manager0*Supplies and ServicesAirfare (Roundtrip to Gambell from East Coast)0*Per Diem (Lodging, Anchorage)0*Per Diem (3/4 Meals, Anchorage)0*Per Diem (Meals, Anchorage)0*Truck Rental (Anchorage)0*Air Cargo (Gambell to Nome)2400Air Cargo (Nome to Anchorage)2400Site 8 - Marsten Matting Debris CleanupLabor for Travel (all rates burdoned)Foreman/QCLgt Equipment OperatorTruck DriverSupplies and ServicesAirfare (Roundtrip Anchorage to Gambell)Per Diem (Gambell)Barge Equipment from Site (reg. Schedule)Gambell to AnchorageDebris-filled Connexes (Gambell to Seattle)Site 12 - Lead Contaminated Soil ExcavationLabor for Travel (all rates burdoned)ChemistSupplies and ServicesAirfare (Roundtrip Anchorage to Gambell)Air Cargo (Gambell to Nome)Air Cargo (Nome to Anchorage)Per Diem (Gambell)Soil-filled Connexes (Gambell to Seattle)Site 12 - Lead Contaminated Soil TreatmentLabor for Travel (all rates burdoned)ChemistUnitUnit CostTotal CostHoursHours$60.00$70.00$0$0EachNightsDaysDaysDaysPoundsPounds$2,400.00$120.00$51.00$68.00$95.00$1.38$0.87$0$0$0$0$0$3,312$2,088121212HoursHoursHours$77.00$59.50$50.75$924$714$6090*3EachMan-Days$878.50$153.00$0$45932000150000Poundslbs$0.3738$0.3738$11,962$56,070TotalOther Direct and Indirect Costs (15%)Profit (10%)Grand Total$76,138$11,421$8,756$96,314Round up to nearest hundred$96,40012Hours0*10010018000EachPoundsPoundsMan-Dayslbs$59.50$714$878.50$1.38$0.87$153.00$0.3738$0$138$87$153$2,990TotalOther Direct and Indirect Costs (15%)Profit (10%)Grand Total$4,082$612$469$5,164Round up to nearest hundred$5,20012Hours$59.50$714DemobilizationGambell Feasibility StudySupplies and ServicesAirfare (Roundtrip Anchorage to Gambell)Air Cargo (Gambell to Nome)Air Cargo (Nome to Anchorage)Per Diem (Gambell)* included in mobilization0*1001001EachPoundsPoundsMan-Days$878.50$1.38$0.87$153.00$0$138$87$153TotalOther Direct and Indirect Costs (15%)Profit (10%)Grand Total$1,092$164$126$1,381Round up to nearest hundred$1,400MobilizationGambell Feasibility StudyItemNumberSite D - Subsurface OE ClearanceLabor (Travel and Construct Gravel Sieve in Anchorage)UXO Technician III62Project Manager62Supplies and ServicesAirfare (Roundtrip to Gambell from East Coast)2Per Diem (Lodging, Anchorage)8Per Diem (3/4 Meals, Anchorage)4Per Diem (Meals, Anchorage)8Truck Rental (Anchorage)4Air Cargo (Anchorage to Nome)2400Air Cargo (Nome to Gambell)2400Site 8 - Marsten Matting Debris CleanupLabor for Travel (all rates burdoned)Foreman/QCLgt Equipment OperatorTruck DriverSupplies and ServicesAirfare (Roundtrip Anchorage to Gambell)Barge Equipment/Connexes (Seattle to Gambell)Barge Equipment (Anchorage to Gambell)Per Diem (Gambell)UnitUnit CostHoursHours$60.00$70.00$3,720$4,340EachNightsDaysDaysDaysPoundsPounds$2,400.00$120.00$51.00$68.00$95.00$0.87$1.38$4,800$960$204$544$380$2,088$3,312121212HoursHoursHours$77.00$59.50$50.75$924$714$609350000320003EachPoundsPoundsMan-Days$878.50$0.5400$0.5400$153.00TotalOther Direct and Indirect Costs (15%)Profit (10%)Grand Total$2,636$27,000$17,280$459$69,511$10,427$7,994$87,931Round up to nearest hundredSite 12 - Lead Contaminated Soil ExcavationLabor for Travel (all rates burdoned)ChemistSupplies and ServicesAirfare (Roundtrip Anchorage to Gambell)Air Cargo (Anchorage to Nome)Air Cargo (Nome to Gambell)Per Diem (Gambell)Total Cost$88,00012Hours$59.50$71411001001EachPoundsPoundsMan-Days$878.50$0.87$1.38$153.00$879$87$138$153TotalOther Direct and Indirect Costs (15%)Profit (10%)Grand Total$1,971$296$227$2,493Round up to nearest hundred$2,500Field WorkItemSite D - Subsurface OE ClearanceField WorkUXO Technician IIIProject ManagerLocal Laborers (2)Supplies and ServicesRTK GPS Equipment rentalMetal DetectorGravel Sieve (materials)Back Hoe Rental (w/operator) - LocalShipping ContainersATV rentalPPEAmmunition Disposal Shipment (Gambell to Nome)Ammunition Disposal Shipment (Nome to Anchorage)Ammunition Disposal FeePer DiemPer Diem (Lodging Gambell)Per Diem (Meals, Gambell)Gambell Feasibility StudyNumberUnitUnit Cost*Total Cost5050100HoursHoursHours$60.00$70.00$30.00$3,000$3,500$3,000221501014500500400WeekWeekEachHoursEachWeekPersonPoundsPoundsPounds$2,100.00$100.00$16,000.00$130.00$30.00$875.00$20.00$0.87$1.38$4.09$4,200$200$16,000$6,500$300$875$80$435$690$1,6361210NightsDays$85.00$54.00$1,020$540222HoursHoursHours$29.75$59.50$50.75$60$119$102707070140MHMHMHMH$77.00$59.50$50.75$29.75$5,390$4,165$3,553$4,1651010HoursHours$59.50$50.75$595$50811421104570015011MonthMonthdaysEachEachEachEachGalUnit-DayMonthLS$2,100.00$4,000.00$150.00$520.00$80.00$100.00$9.00$3.00$4.00$3,000.00$2,000.0010MH$50.75$50850tons$45.00$2,25021DaysSite 8 - Marsten Matting Debris CleanupUnload Barge Materials in GambellLaborerLgt Equipment OperatorTruck DriverField WorkForeman/QCLgt Equipment OperatorTruck DriverLaborersLoad ConnexesLgt Equipment OperatorTruck DriverEquipmentSmall Dump Truck (5 CY)Backhoe Loader (416 C or D)ATVs with Trailer (3)Field screening equipment (Hanby Kit)Supersacks for contaminated soilRadiosDisposable CameraDiesel Fuel for EquipmentConnex Rental for removal of debris and soile Loader CAT 426C IT (w/connexes to load them on-site)Plastic Fencing, tarps, etc for winter storageMove Debris from Dock to Landfill in SeattleTruck DriverLandfill Tipping FeeLodging and Per Diem for WorkersForeman/Operator/Truck Driver$153.00$2,100$4,000$6,300$520$800$400$45$2,100$600$3,000$2,000$3,213Field WorkGambell Feasibility StudySubtotalSmall Tools/Consumables and PPE (5%)TotalOther Direct and Indirect Costs (15%)Profit (10%)Grand Total$88,467$4,423$92,890$13,933$10,682$117,506Round up to nearest hundred$117,600Site 12 - Lead Contaminated Soil ExcavationField WorkForeman/QCLgt Equipment OperatorTruck DriverLaborersChemistMove Soil to TDU from Dock to TDU in SeattleTruck DriverLandfill Tipping FeeLodging and Per Diem for WorkersForeman/Operator/Truck Driver/ChemistMHMHMHMHMH$77.00$59.50$50.75$29.75$59.50$1,540$1,190$1,015$595$1,1904MH$50.75$2034tons$45.00$1808Days$153.00$1,224SubtotalSmall Tools/Consumables and PPE (5%)TotalOther Direct and Indirect Costs (15%)Profit (10%)Grand Total$7,137$357$7,494$1,124$862$9,480Round up to nearest hundred$9,500Site 12 - Lead Contaminated Soil TreatmentField WorkForeman/QCLgt Equipment OperatorTruck DriverLaborersChemistTreatment ChemicalsTreatment ChemicalsLodging and Per Diem for WorkersForeman/Operator/Truck Driver/Chemist* Labor rates are all loaded.20202020204040204040MHMHMHMHMH$77.00$59.50$50.75$29.75$59.50$3,080$2,380$1,015$1,190$2,3801LS$5,000.00$5,00020Days$153.00$3,060SubtotalSmall Tools/Consumables and PPE (5%)TotalOther Direct and Indirect Costs (15%)Profit (10%)Grand Total$18,105$905$19,010$2,852$2,186$24,048Round up to nearest hundred$24,100Lab SamplesTest MethodProject Samples8RCRAAK102/103labGambell Feasibility StudyItemNumberUnit8 RCRA MetalsDRO/RROTOC101010SampleSampleSample$130.00$125.00$60.00$1,300.00$1,250.00$600.00UnitSampleSampleSampleUnit Cost$130.00$125.00$60.00Total Cost$130.00$125.00$60.00CoolersBags$250.00$17.00TotalRound Up$500.00$17.00$3,982.00$4,000.00QA/QC Samples (10% of project samples)Test MethodItemNumber8RCRA8 RCRA Metals1AK102/103DRO/RRO1labTOC1Total Samples33Cooler Shipping2Vermaculite1All per sample cost includes data review.Unit CostTotal CostReportingGambell Feasibility StudyItemSite D - Subsurface OE ClearancePrepare Draft Removal Action ReportProject ManagerOE Technician IIIClericalSite 8 - Marsten Matting Debris CleanupPrepare Draft Removal Action ReportEnvironmental EngineerIndustrial HygenistClericalPrepare Responses to commentsEnvironmental EngineerIndustrial HygenistClericalReview ConferenceEnvironmental EngineerPrepare Final Removal Action ReportEnvironmental EngineerIndustrial HygenistClericalHoursRate84020$70.00$60.00$29.75$560$2,400$59580440$70.00$50.75$29.75$5,600$203$1,1901648$70.00$50.75$29.75$1,120$203$2384$70.00$280$70.00$50.75$29.75SubtotalOther Direct and Indirect Costs (15%)Profit (10%)Grand Total$2,800$102$595$15,886$2,383$1,827$20,095Round up to nearest hundred$20,100Site 12 - Lead Contaminated Soil ExcavationPrepare Draft Chemical Data ReportEnvironmental EngineerChemistClericalPrepare Responses to commentsChemistClericalReview ConferenceChemistPrepare Final Chemical Data ReportEnvironmental EngineerChemistClerical40220Total44020$70.00$59.50$29.75$280$2,380$595164$59.50$29.75$952$1194$59.50$23824020$70.00$59.50$29.75SubtotalOther Direct and Indirect Costs (15%)Profit (10%)Grand TotalRound up to nearest hundred$140$2,380$595$7,679$1,152$883$9,714$9,800Project ManagementGambell Feasibility Study(6% of total hours for all phases)PhaseLabor Hours for PhasePlanning and Pre-Mob Activities383Mobilization160Field Work576Demobilization52Reporting286Total Project Management HoursPM RateTotalOther Direct and Indirect Costs (15%)Profit (10%)Grand TotalRound up to nearest hundredPhaseLabor Hours for PhasePlanning and Pre-Mob Activities212Mobilization12Field Work116Demobilization12Reporting150Total Project Management HoursPM RateTotalOther Direct and Indirect Costs (15%)Profit (10%)Grand TotalRound up to nearest hundred10%381658529146$78.75$11,473.88$1,721.08$1,319.50$14,514.45$14,60010%13171930$78.75$2,371.95$355.79$272.77$3,000.52$3,100Appendix BGambell Feasibility StudyDraftNovember 2003- 1994X Soil Boring - 2001X SB6-10SB6-13XSB6-9 XSB6-12 XSB6-11 XSB7-18XSB7-20XXSB7-19DEPARTMENT OF THE ARMYU.S. ARMY ENGINEER DISTRICT, ALASKAP.O. BOX 6898ELMENDORF AFB, ALASKA 99506-6898REPLY TOATTENTION OF:April 19, 2004Programs and Project Management DivisionCivil Works Management Branch«Title»

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