ACAT FOIA Repository 20

Comments Submitted by Vi Waghiyi ForProposed Plan for Remedial ActionGAMBELL FUnS SLI July 04 ReportPg. 5, Table 1. Soil and Groundwater Cleanup Levels for All Sites and Sites 5 & 12:Why are the Cleanup Levels different for DRO, RRO, Arsenic, Cadmium and Chromiumdifferent as noted in Table 1 for All Sites and Sites 5 && 12?Pg. 9, Site lA-North Beach, Army Land Area, Investigation Summary: It does notdisclose how many soil and groundwater samples were collected in 1994. The onesurface soil sample does not seem enough, the geophysical survey boundaries for thelandfill are not noted, does this one surface soil sample denotes that is sufficient for theArmy landfill?Pg. 9, Site 1B-North Beach, Air Force Landing Area: Do empty drumslbarrels have tobe tested to see what they contained?Pg. 10, Former Military Housing/Operations Burial Site: The discolored gravel, was itsampled?Pg. 11, Former Military Housing/Operations Burial Site: Investigation Summary:2nd paragraph, the sample from 1994 that exceeded the screening levels for chromium andlead. Which form of chromium is it? Form VI is a dangerous form of chromium and isvery mobile in groundwater and is almost always the result of human releases.The arsenic levels that exceed the ADEC cleanup level, and that are determined"consistent across sites in Gambell, and do not appear associated w/past military activity"The many sites that are referred to, the "consistent across sites in Gambell", are theymilitary sites in question? And has samples of arsenic ever been taken for backgroundlevels outside of the boundaries of the military bases in Gambell?Pg. 12, Preferred Alternative: Chromium VI is dangerous, the single chromiumexceedance that is considered an outlier, what form is it and have background levels ofchromium been sampled outside of military boundaries to determine if the singlechromium exceedance is an outlier indeed?Pg. 12, Preferred Alternative: NFA, The village drinking water source is down gradientof site 2 & 3, warrants further sampling and monitoring.Pg. 12, Investigation Summary, 3rd paragraph: Are beryllium and tallium (site 3levels) dangerous?Pg. 15 Site 4B-Former USAF Radar Station, Investigation Summary: 2ndParagraph, Do EPA regions have different "risk-based concentrations"? Since we are inRegion 10, does this US EPA, Region 3 risk-based concentration apply?200-1fF10AK069603_08.01_0063_aPg. 16, Site 4B-Former USAF Radar Station, Preferred Alternative: Were offmilitary boundary background samples taken to see if the elevated copper is an isolatedoccurrence?Pg. 18, Site 5-Former Tramway Site, Investigation Summary: Since the only evidentactivity is from the military, and this site is by the Village water supply, the exceeded,exceeded 'level ofDRO needs to be monitored and addressed.Pg. 20, Site 6-Military Landfill, Investigation Summary: Have off military boundarybackground samples of metals been taken to determine that the levels of metals arenaturally occurring?Pg. 21, Site 7-Former Military Power Facility, Investigation Summary, 4thparagraph: Since this site is by the Gambell School and the DRO and benzene resultsexceed the ADEC Table C groundwater cleanup levels, this site needs to be addressed.Benzene is a long term contaminant in groundwater, it cannot readily evaporateunderground and since little microbial activity occurs in underground water, it is notdegraded.Pg. 27, Site 12, North Nayvaghat Lakes Disposal Site, Investigation Summary, 2ndparagraph: The background levels for groundwater and surface water taken from MW14 located at the base of Sevoukuk Mt. are from Site 5, so therefore NOTBACKGROUND.Pg. 32, Site 22-Former eAACAA Housing, Preferred Alternative: Since the housing hasthe possibility that asbestos-containing materials may be present in the structures, this siteneeds to be addressed to determine if the buildings do indeed pose a risk to the occupantsor local resident owners, they have a right to know!!Pg. 34, Site 26-Possible Debris Burial Site: Since this site is by the Gambell School, itwarrants cleanup since Local residents reported finding metal debris, machinery, oilydebris, and TRANSFORMERS in the vicinity, NFA is not an option due to the riskassociated with the site.Pg. 35, Site 28-Disturbed Ground, Site Description: The Army's use of the land leasedJanuary 1955 to May 1958 needs to be determined, the community has a right to know ifit poses a risk!Until credible samples of background arsenic levels are collected outside of the militaryboundaries in Gambell, Sites lA, 1B, 2, 6, 7, 9, 12, 13, 16, 17, 18, 25A, 26 and 28 needto be taken off of "Preferred remedial alternatives NFA" proposed plans until if indeedthe arsenic levels are not associated w/past military activity.Are the following sites with buried debris scoped under NALEMP and will be removed?Sites lA, 1B, 1C, 2, 3,11, 13,14, 15, 16, 17, 18,21,23 &13,14,15,16,17,18,21,23& 24.Sites 3, 4A, 4B, 5, and any other site that had samples that initially had elevated levelsand are a risk to human health and the environment, and after additional samples weretaken a year or years later, the results showed decreased levels, goes to show that thecommunities knowledge that the groundwater migrates and as a result the differences inthe contaminant levels needs to addressed and long term monitoring are warranted andmust remediate and cleanup the contaminants when concentration levels are above risk tohuman health and the environmentlVi Waghiyi, CoordinatorSLI EHJ ProjectAugust. 29, 2004