The Adak Restoration Advisory Board (RAB) met for its regular meeting on March 10, 1999 at 7:00 p.m. The RAB met at the Holiday Inn, located at 239 West Fourth Avenue, Anchorage, Alaska.

Administrative Note: The summary of discussions during RAB meetings is not intended as a transcript of the meeting. A recording of the RAB meeting is obtained at every meeting and in the event that a more complete transcript of a discussion is needed for a specific issue, this recording can be accessed. While participants at RAB meetings are strongly encouraged to review the meeting minutes prior to finalization of the minutes, it is recognized that there is the possibility that participants in the discussions have not reviewed the minutes to confirm that they accurately reflect the content of the discussion.

1. Welcome, Introductions, and Meeting Purpose

   Mr. Stoll called the meeting to order at 7:05 p.m. A quorum was not present. The agenda was approved.

   1. Approval of the December 9, 1998 and January 13, 1999 meeting minutes.

      Approval of the December 9, 1998 and January 13, 1999 meeting minutes was deferred because a quorum was not present.

   2. General Announcements

      There were no general announcements.

      1. Administrative Issues

         Mr. Gromoff was on vacation and Mr. Arterburn took his place. Adak community members planned to call at 7:30 p.m. to participate in the meeting by teleconference.

      2. Concerns, Issues, and Questions

         There were no concerns, issues, or questions.

2. PROJECT UPDATES AND QUESTIONS AND ANSWERS
   1. TAPP Grant Projected Timeline and Approval Process.

      Mr. Stoll reported that he and Ms. Miller had completed a revised scope of work (SOW) and that SOW had been sent to headquarters. Headquarters had not yet responded.

      A copy of the TAPP grant on Mr. Murphy's computer was displayed during the break.

      Mr. Stoll stated that a consensus statement is needed from the RAB.

      Ms. Goldstein of URS Greiner/Woodward Clyde was charged with distributing the TAPP proposal and the scope of work to the RAB members in order to get RAB approval by the end of the next week.

      The contractor will review documents pertaining to Adak, including the work plan for Sweeper cove. Ms. Miller agreed that while $25,000 is somewhat limiting to get technical assistance on all the major issues outlined, Sweeper Cove was the number one priority in the TAPP proposal.

      Mr. Stoll said the TAPP grant prohibited the consultant from collecting samples. What the consultant will do, is review documents and advise and educate the RAB about technical issues. Ms. Miller said that Dr. Ron Scudato from the State University of New York is one of the nation's foremost experts in PCB remediation issues. Ms. Miller hoped that Dr. Scudato could attend the next RAB meeting. The RAB will set the contract priorities in consultation with Mr. Stoll.

   2. ADEC/EPA/Navy positions on UXO Characterization and Cleanup.

      Mr. Murphy briefed the RAB regarding what issues were under discussion regarding UXO, the basis for agreement and disagreement between the agencies, and how the three Federal Facilities Agreement (FFA) parties were managing that. Originally, the UXO concern on Adak was limited to four sites; an OBOD area, a former minefield, a mortar impact area, and a seawall. Later, under the FFA, investigations were conducted for UXO and chemical contamination and a proposed plan was prepared. The proposed plan for those four sites was briefed to the RAB around January 1998. At that time, the proposed plan for the known UXO was to clear the former minefield, and to implement institutional controls to limit access and retain ownership by the Navy of the other three UXO contaminated sites. Following that, no further UXO investigation or clearance was recommended.

      In April 1998, after the proposed plan had gone out and preparation of the ROD began, the Navy became aware of an extensive amount of archival documentation that suggested there were other potential minefields and combat ranges. That information was the basis for extending the scope of the UXO investigation and remediation. Mr. Cora added that public comments were received during the proposed plan that were concerned about institutional controls being applied on the property in perpetuity, and the safety of having UXO on a piece of property. Those comments also led to a new phase of evaluating what the remedy would be.

      Mr. Murphy said that until the new documentation was discovered, the assumption was pursued that institutional controls would be used, as opposed to more UXO clearance and investigation.

      Mr. Murphy indicated on a map the areas of potential UXO identified in the documentation discovered in April 1998. The only evidence that combat ranges and minefields existed are defensive plans. There is no documentation or any other evidence that suggest that those defensive plans were ever carried out.

      Since the April 1998 archival information was discovered, the agencies and the Navy decided to split all the UXO contamination issues into a separate operable unit and they are now designated as CERCLA Operable Unit B (OUB). To accomplish land transfer, EPA must concur that the Navy has done all that is needed to protect human health and the environment. DDESB's recently issued guidance for UXO contamination and potentially UXO contaminated real estate for transfer to a non-federal party (Document No. 6055.14) is being followed. Document No. 6055.14 specifies the criteria to be considered in the absence of some land use information and the use of alternative criteria or site specific assessment to determine what level of investigation and clearance is needed to support a particular end use.

      There is no agreed upon guidance or methodology to carry out the investigation and remediation of UXO on a particular site. Currently, there is no available technology that will detect 100% of all the UXO items that might exist to a specific depth below ground surface. In the absence of technology, the only way to guarantee that all UXO has been removed is to excavate and inspect. There are technologies that give some degree of confidence that UXO have been detected and removed, but nothing approaching 100% confidence.

      The Navy's position on UXO is that the DDESB Document No. 6055.14 allows the Navy to use a site-specific approach for dealing with UXO. In other words, the Navy may consider all the factors that are unique to Adak in terms of land use since WWII, the nature of non-military uses that have occurred on the military reservation since WWII, and the incidents of discovery of UXO that have happened. The Navy also believes that the fact that nobody has been injured in the last 50 years related to ordnance encounters is also relevant. Future land use is considered to be similar, although less intensive in most cases, to the past land uses. Institutional controls that have been used to manage the UXO risk on Adak can continue to be effective. The Navy's current proposal is to maintain the level of institutional controls, and in many cases, increase institutional controls, improve educational programs, improve restrictions and signage, and be more specific about land use restrictions. The Navy also relies on the previous investigation results that suggest that there is a very low ordnance and explosives density in the area. The Navy believes a risk-based approach for the ordnance contamination on Adak is allowable and sensible.

      Mr. Stoll said that the downtown area contained no ordnance and explosives, but some ordnance explosive related items, with the exception of some items found in the landfill. He said this was a low density area. Mr. Murphy said that in 2,500 acres of downtown area, a total of 7 ordnance-related items were found. None of the items found were considered an imminent threat to anyone who might have encountered them. However, if they were picked up and deliberately mishandled, they could have caused in an injury. Investigations of 20 of the 27 potential minefields were finished 1998. None of those 20 sites had any items discovered that were related in any way to a mine or ordnance. The Navy suggests that the ordnance density on Adak is very low and the risk associated with it manageable.

      Mr. Cora reported that EPA has to select a remedy that is protective of human health and the environment. Prior to transferring the site, EPA insures that the remedy is in place, operational and functional. EPA is not willing to say it's acceptable to have an item that is lethal or that if you encounter it, there is no way of predicting what the risk would be. For example, it might not explode, but it could also kill someone. EPA has a very difficult time saying that a remedy of only institutional controls is adequate for the level of ordnance indicated in the archive report. The Navy has to comply with the munitions rule. The Superfund law requires that all other laws be complied with. EPA disagrees with the Navy that they are meeting the standard in the DDESB regulations.

      Mr. Cora said that this issue is also part of a current national debate. The EPA, DoD and the states are working on a plan to characterize ranges and cleanup as a regulatory mechanism. In the past, ordnance has been out of the realm of EPA's regulatory mechanism.

      The main issue is the Navy's proposal to use a procedure developed by the Army called Grid Stats/Site Stats. The procedure has not been tested by anyone besides the Army and has been successfully challenged in court.

      EPA must make a decision based on the criteria of Superfund. The two biggest criteria in Superfund are that a remedy has to be protective of human health and the environment, and it has to comply with all applicable laws and regulations. At this time, EPA does not believe that it is protective to leave ordnance on a piece of property that people have access to. While it is true that no one has been hurt in 50 years by ordnance on Adak, there were many encounters with ordnance. No one got hurt, but there were cases were people were playing with a grenade, or they had a mortar. That makes it very difficult for EPA to agree that no action is required. EPA would like to see more characterization and clearance. Institutional controls can be used as a temporary mechanism or as a mechanism to enhance an engineered control such as a landfill. Institutional controls are not generally used as permanent remedies if there is a high risk of injury. EPA wants a larger commitment that ordnance will be removed for whatever the land use is going to be. There is disagreement on the DDESB standards because EPA believes those standards are based on protectiveness of people doing a certain activity. On Adak, one of the problems is that activities are not limited, for instance, if land was characterized as a wildlife refuge, in Alaska, wildlife refuges require public access.

      Mr. Arterburn asked about the status of the range rule. Mr. Cora said it was on hold. DoD is revising it following a large number of comments. EPA is not willing to accept the risk model that they're using, and said it's a contentious issue.

      Ms. Miller inquired about the characterization issue where the Navy sampled approximately 1% of the areas and was using that for characterization. Mr. Cora said that issue had not been resolved. EPA is not comfortable with that level of characterization because the likelihood of making false conclusions is too great. The Superfund law requires that EPA find that the area "is" protected, not that it "might be" protected. Mr. Cora said he wasn't sure that EPA was even willing to accept a 5% or 10% sample. There have been court cases that have ruled that 100% coverage must be done to have confidence that there is no risk.

      Mr. Oates suggested that the RAB review the work plan and submit comments. Mr. Murphy invited comments at the RAB meetings.

      Mr. Oates said that the state is concerned about the level of investigation, and extrapolating a small percentage of coverage. Mr. Oates said that even if money were no object, the current technology would not result in 100% coverage, short of strip mining Adak. That kind of invasive procedure would destroy the very environment being protected. The investigation may take more years than anticipated. There are some remote sensing technologies that are getting close to field application level and these technologies should be reviewed.

      Mr. Oates said the state agrees with EPA that when UXO is considered, there should be a higher standard from an investigation standpoint. All it takes is one encounter to have an injury or a fatality, as opposed to a long-term exposure to a chemical that may or may not cause an episode. This situation requires careful consideration because Adak is one of the first large-scale investigations in the Aleutian Islands. There will be more in the future so the state is very concerned.

      Mr. Oates also pointed out that Alaska law includes provisions for protection of public safety. The federal and environmental laws have words such as protection of human health and the environment. Public safety, in the legal sense, is a different interpretation. Public safety can include things such as physical hazards. The state feels that the UXO policy must be reviewed from a legal standpoint, as well as an obligation to the citizens of the state.

      r. Oates said he was not sure how these issues would affect land transfer. It may mean that some parcels are released before others.

      The work plan has been received. Mr. Oates felt that all agreed this would end up being formally disputed in the FFA. Formal dispute will require increased time frames to get these issues resolved.

      Mr. Murphy added that it is not known how long the dispute resolution will take. The 1999 fieldwork contract has already been awarded, and the BRAC contractor is preparing to mobilize and carry out the OE Site Stats/Grid Stats statistical approach. It's not always less than 1%, but it varies between less than 2% and sometimes less than 1% for a particular area. That characterization will be carried out this season, regardless of how this dispute process proceeds. Mr. Oates said that the work would be executed pending comments on the work plan.

      Mr. Arterburn asked whether there are areas that more suspect than others within the 80,000 acres, and if there is a range of acceptable sampling levels based on records and anecdotal information. Mr. Oates said he would consider that issue when reviewing the work plan, and perhaps suggest that effort should focused in certain areas and not in others. For instance, a 75-degree slope cannot be investigated, as opposed to a flat field with a path running through it. Mr. Murphy said that all areas with a greater than 50% slope must be excluded because there is no way to get detection equipment to those areas. Mr. Cora added that a priority setting scheme is needed based on the location of ordnance and use by people.

      Mr. Mitchell asked if the UXO is degrading. Mr. Murphy said ordnance is physically corroding.

      Ms. Miller said she perceived EPA's concerns are focused on a human safety perspective or the explosive potential for UXO encounters. Ms. Miller stated she still is not convinced that the Navy has done adequate characterization on the toxicological issues. Ms. Miller asked how EPA is evaluating that. Mr. Cora said that when the RI/FS was performed, samples were taken from SWMU 1 which were open burn/open detonation areas. Samples were collected from the detonation areas, from the sediments that ran into Andrew Lake, and areas down gradient. No levels of ordnance-related contaminants were found that posed an unacceptable risk. Based on that data, it did not seem that ordnance-related contaminants posed a big risk on Adak. If large areas of buried ordnance are discovered, then that conclusion may change.

      Mr. Arterburn asked about the sampling level used in the downtown area. Mr. Murphy said a surface clearance was done first. Next, a geophysical survey was done on a selected area within that 2,500 acres. The Site Stats/Grid Stats model determined which grids to conduct the geophysical survey in. The geophysical work detected thousands of anomalies. 10% of the total anomalies were excavated. These results of these excavations are the basis for the conclusion that there is no ordnance contamination in the downtown areas. Mr. Cora added that the downtown has been lived in, it had known no range activities, and no large disposal areas were located there. Based on this data, Mr. Cora felt the characterization of the downtown area was sufficient.

   3. Adak Community Concerns.

      The Adak community resolution was circulated to the RAB by Mr. Gates. Mr. Krukoff said the Adak community is becoming more active, and is growing. The community is becoming more aware of concerns and topics that may have been discussed earlier in the RAB. The community council wanted to know if the RAB is adequately covering the areas of environmental concern, and whether ADEC is insuring proper and adequate cleanup of the island. Mr. Krukoff said the resolution was written to address the community council's concern that certain subjects are being disregarded because of the bureaucracy involved. The community would like to be more involved. Mr. Krukoff asked if a public hearing could be held in Adak before ROD approval.

      Mr. Stoll said that provisions have been made to provide for teleconference participation at every RAB meeting if the community was amenable. Mr. Krukoff said they were. Mr. Krukoff expressed concern that the RAB process was not adequately addressing the community's concerns. Mr. Arterburn said the RAB members have been long frustrated by distance between the Adak and the RAB. Mr. Arterburn welcomed the community's desire to participate in the process. Mr. Arterburn requested that the telephone conference equipment be improved for future meetings. Mr. Stoll added that the RAB's purpose is to listen to the community's concerns, and that he would like to include Adak citizens on the RAB. Mr. Stoll noted that the resolution came from the community council and that the RAB is for citizens. Citizens that are members of the community council are welcome to put forth their views, suggestions and comments and are eligible to be RAB members.

      Mr. Darrington said that the Navy is forgetting the families on Adak and their viewpoints. The community on Adak believes that the town should be completely cleaned up with no restricted areas, because children don't understand restricted areas. Whatever the future brings, it needs to be planned for and as many dangers as possible removed. Institutional controls are viable if the Navy maintains its presence on Adak for as long as they are needed. Otherwise, a cleanup is necessary. Adak community members are not soldiers or sailors. Adak community members are isolated from the information repository by cost and distance. Mr. Arterburn asked Mr. Darrington to fax his comments so that they can be included in the record [these comments have not been received].

      Mr. Krukoff said that others had comments and will submit them in writing. Ms. Miller said that she supports the community resolution, and would like the RAB to take a formal position. She would also like to have community representation on the RAB. Mr. Oates noted that the resolution requested a hearing on the island. He will note the request, and assured Mr. Krukoff that ADEC is looking out for the community's interests.

      Ms. Grisco asked about the community's access to written materials. Mr. Murphy said he wasn't sure that all the documents in the information repository were on Adak, but the Adak CSO Environmental Department has been sent copies of everything that's in the information repository. Mr. Murphy is willing to provide documents to community members. No Freedom of Information Act request is necessary. Mr. Murphy said that through the command channel on Adak, they could advertise the availability of materials in the environmental library.

      When a quorum is in attendance, Robert Darrington, P.O. Box 1838, Adak, Alaska 99546 will be added as the community RAB representative. Agafon Krukoff, Jr. will be Mr. Darrington's alternate. Mr. Arterburn said that Mr. Darrington and Mr. Krukoff as well as others could be seated as members. Mr. Mitchell recommended that whomever is seated as a RAB member make a commitment to attend as many meetings as possible due to quorum problems. Mr. Cora said he is concerned about where the community is. It seemed to Mr. Cora that if there is a community on Adak, the RAB should be where the community is. Mr. Stoll pointed out that RAB's purpose is to hear the opinions of stakeholders and interested citizens whomever they may be, wherever they may be. Mr. Cora said that, for instance, a RAB for Spokane does not meet in Seattle. Mr. Cora stated it will be very difficult to go back to his management and tell them that there is community input from Anchorage, but that there a lot of people on Adak that are tied in by phone only. Mr. Stoll said that the RAB should discuss the issue. Mr. Arterburn said the RAB has expressed a desire to have a meeting on Adak. Mr. Stoll said that there is no funding to pay for a meeting on Adak.

      Mr. Tutikoff (ph) said that he hoped the RAB seriously looks at the comments made by the community. Mr. Darrington has about 38 written follow-up comments. Mr. Stoll asked Mr. Darrington to fax his comments to Ms. Graham.

   4. ARC Concerns.

      Mr. Gates stated that the ARC is the federal and state designated team to plan and implement the reuse of former NAF Adak. Mr. Gates said it was good to have the community participating by telephone because he felt he has been the communicator for the community for too long. The only time the RAB has really reached out to Adak for comments was about nine months ago. The community put together about 80 comments to the Navy and the RAB regarding what it thought about environmental issues. Responses to the comments were just received in the last 10 days, even though they were published in December. There is great concern in the community about the care taken to answer those questions. The community considered some of the answers unacceptable.

      There are now 34 children in school. There are about 50 people beginning work for Adak Seafoods and a new cod processing plant in Sweeper Cove. The port is starting active operations. The airfield is handling mid-Pacific refueling and ferry flights, military operations, and search and rescue operations. The Canadian Coast Guard will use the airfield in about a month and a half for fisheries enforcement issues.

      ARC has been watching the environmental decisions made by the Navy and the RAB and has several concerns. The first is the poor answers to the 88 questions from the community. For example, the community is not happy with the answer from the Navy regarding clearing the Rommel stakes. The ARC believes that an adequate answer should be offered before the first ROD is signed.

      The second concern is regarding the minefields. The areas that justified additional work by the Navy were 27 additional minefields, impact areas and combat ranges. Mr. Gates that combat ranges are not shown where 100,000 troops were practicing to take back United States territory from the Japanese. Mr. Murphy said that is not correct. There are combat ranges shown on the north half of the island. The map is meant to represent what is being investigated this field season. Numerous graphics have been presented that show potential minefields in previous meetings. Mr. Gates said ARC has concerns that the 22 minefields investigated last year were not investigated adequately. The sampling done in the minefields by the Navy was not good enough, for the same reasons stated by EPA and ADEC that a 1% sampling is not good enough for the bombing ranges and the combat areas. ARC would like the Navy to do a better sampling job.

      ARC has grave concerns about Sweeper Cove. ARC has to have industrial use of Adak's harbor to support a town. The docks and harbors must be used for fishing and general cargo. To get permits to develop new facilities or keep up existing facilities, ARC must know what contamination the Navy is leaving in Sweeper Cove. There are many areas where there are 10 acres between sampling points. Only 20 sample points have been collected in Sweeper Cove. ARC does not think that's enough sampling, and hopes that more sampling will be required.

      ARC has spent a little money to look at the characterization in Sweeper Cove for the RAB and for the agencies. ARC hopes that this letter will be looked at carefully by Todd McGovern. ARC is asking for more characterization in Sweeper Cove. In addition, ARC hopes there will be some work done to find out what is in the chemical munitions dumping area north of the island. That could affect the perceptions of the future use of Adak, and the ability to develop a viable community. Mr. Gates requested that the 38 comments from the Adak community comments be considered before the final ROD is published.

   5. BECT and BTAG Meeting Briefings.

      Mr. Cora said that Jim Estes and Wally Jarman attended the BTAG meeting and gave input on the Navy's sampling proposal in Sweeper Cove for PCBs. The remedy EPA is selecting is to warn people not to subsistence fish for certain species until PCB levels go down to a designated level. No one at the BTAG meeting questioned the sampling of Sweeper Cove except Mr. Gates. All agree that there is contamination in the sediments, but not at a level that requires cleanup. The impacted biological resources are being reviewed.

      The BTAG meeting was discussed at the BECT meeting, including giving a UXO presentation for the RAB. Mr. Oates said they discussed writing the ROD for OUA.

   6. Davis Lake and Lake Leone Update

      Mr. Murphy deferred the Davis Lake and Lake Leone update until after the meeting for those interested.

   7. Comments on the Sweeper Creek Remedial Plan.

      Mr. Murphy said the remedial design deadline for Sweeper Creek and SWMU17 was delayed until March 15, 1999. There will be a 30 day comment period. The work will be executed this field season so timely comments are important. Sediments contaminated above 1 part per million will be dredged, burned and the burned material will be disposed of in the landfill. About 4,000 cubic yards of sediments will be removed from the lower end of Sweeper Creek.

   8. Petroleum Sites.

      Mr. Oates said that Mr. Kuboi prepared a summary of activities that have occurred since the proposed plan was issued. Two proposed plans were issued over a year ago, one for the CERCLA sites and UXO, and one for petroleum. A number of things have happened since that time. When the proposed plan was issued, information was still being gathered on the petroleum sites. There were free product sites where free product recovery would continue. Those sites are still in that category. There were a number of sites that were reviewed for monitored natural attenuation. After reviewing the data, the number of those sites has shifted back and forth by three or four. Primarily, a few more sites were added to that category. There were a large number of sites that were looked at for no further action. All of these sites have had some remedial action such as tanks, pipes, or soil taken out. Another group of sites included where the data was reviewed after the tanks and soils were removed, and the confirmatory sampling was done. In many cases, 8 or 9 samples out of 10 were clean or below levels of concern. A second look was taken at those sites to see if there was any potential risk from exposure to soils or potential for migration to groundwater.

      The state regulations regarding cleanup of hazardous waste and petroleum substances were finalized in January 1999. As a further check, the final decisions were reviewed to make sure they were consistent with the final regulations. Mr. Oates was very comfortable that the decisions made earlier are consistent with the final regulations.

      Initially, free product recovery and monitored natural attenuation time frames were not considered. A lot of modeling work has been done. The Navy returned and did intensive sampling of two sites to demonstrate that natural attenuation is happening. That data was inserted into two models: one for transport and one for biodegradation. The volatile fraction of benzene, ethylbenzene, toluene and xylenes should degrade relatively rapidly in about 20 to 30 years. The diesel range organics are more persistent and are probably going to take twice that time range to degrade. The Institutional controls considered are not using groundwater for drinking water for a period of 75 years. That will be evaluated through intensive monitoring for a year on a quarterly basis. The next four years will either be annual or semi-annual monitoring so a database can be created that will indicate if the concentrations are degrading at a rate that will meet acceptable time frames. A CERCLA five year review concept will be used. If it looks like the degradation rates cannot be achieved, then additional work will be done.

      Mr. Gates asked if active remediation was performed would the restriction be less than 75 years? Mr. Oates said that at some sites, particularly in the downtown area, there might be a monitored natural attenuation site that is surrounded by building. To remove the residual contamination in the soil, the building would have to be removed. The contamination can be removed mechanically, but it would destroy the downtown infrastructure. That issue was considered, and also that the water in the downtown area sits largely in a bowl and is not migrating. There are three key aspects to the monitoring plan: the plumes should be shrinking, that un-impacted groundwater remains un-impacted, and that surface water is protected.

3. Public Comments.

   There were no public comments.

4. Set Date and Tenative Topics for Next Meeting

   Mr. Cora suggested that a review of the OUA ROD would be useful, along with a better connection with the Adak community. Mr. Cora said he felt they were being very protective, particularly in the downtown area.

   Mr. Stoll suggested that the RAB should be briefed on discussions with Dr. Scudato.

   Ms. Grisco said that Adak community members will need documents ahead of time so they can participate meaningfully.

   Ms. Grisco also requested a list of all the projects that will occur this field season.

   Mr. Arterburn asked that the Davis Lake report be added to the agenda.

5. Meeting Adjourned.

   The next meeting was scheduled for May 12, 1999 at 7:00 p.m. The meeting was adjourned at 9:53 p.m.

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