ACAT FOIA Repository 22

Gambell Plan CommentsR. J. ScrudatoSeptember 1, 2004One factor is clear from the data collected on the effects of the military occupancy is thatit is very difficult to effectively characterize and assess the environmental impacts withinthe Gambell area due to the complex hydrology and geology of the area. The highlypermeable and coarse grained nature of the cobble deposits are difficult to sample. Thepresence of permafrost, as well as the proximity of the impacted sites to the Bering Seaand the relative hydrologic influences of Troutman Lake, makes it difficult to effectivelycharacterize impacts to the various sites known to have been impacted by the release ofcontaminants during the time the military occupied the area.Additional complications are imposed by the difficulties in gaining an understanding ofthe relationships of the Gambell cobble deposits (the spit) to the bedrock especially thetransition at the base of the elevated mountainous area, including the interrelationship ofthe fractured bedrock, the talus and the on-lapping cobble deposits, This transition zone isparticularly important to the source of the Gambell water supply since the infiltrationgallery is charged by the groundwater deriving from this complex interrelationship. Thisinterrelationship is also subject to seasonal changes and further complicated by thepresence of contaminated cobble soils within the recharge gallery area. As I havementioned in earlier correspondence, the hydrology of the infiltration gallery andrelations to the contaminants identified in the sites located in proximity to the infiltrationgallery are less than well defined.As I mentioned in my comments on the Gambell Feasability Report, it is important toprovide the Gambell residents with assurances that the environmental impacts derivingfrom the former military occupancy and release of contaminants at the various definedsites will not continue to affect their natural resources. The most effective way to providethis assurance is to establish a broad based monitoring program that will take intoconsideration the uncertainties inherent in effective site characterization due to thecomplex nature of the Gambell geology, hydrology, and relationship to permafrost,climatic changes and future land use to ensure that potential impacts will be identifiedand defined.I recommend a more comprehensive series of monitoring wells be established andmonitored throughout the Gambell area to ensure detection of contaminants will not goundetected. The Gambell residents should be provide a measure of confidence that futurepotential impacts will be detected and once detected effectively eliminated.200-H200-1fF10AK069603_08.01_0065_a