The Adak Restoration Advisory Board (RAB) met for its regular monthly meeting on September 15, 1999 at 6:00 p.m. (Adak time). The RAB met at the CSO Conference Room, Caretaker Side Office, Adak, Alaska. Some RAB members participated by telephone conference from 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.

Due to poor teleconference connections, communications between Adak and Anchorage were difficult and portions of the tape recording are of poor quality. The RAB is encouraged to carefully review the minutes and/or the tape recording.

1. Welcome, Introductions, and Meeting Purpose

   Mr. Gromoff called the meeting to order at 7:12 p.m. A quorum was present. The agenda was unanimously approved.

   1. Approval of Previous Meeting Minutes

      Mr. Gromoff deferred approval of the August 10, 1999 minutes to allow additional time for review and correction by absent members.

   2. General Announcements
      1. Administrative Issues

         Mr. Oates said he had been “on loan” from the EPA to the State of Alaska for over two years, and will return to EPA full-time beginning 10/1/99. He will take Mr. Cora’s position on the Adak project. No replacement for ADEC has been hired yet. Jennifer Roberts will likely represent ADEC in the interim. Mr. Mitchell asked if Mr. Oates would still be able to present information from a state perspective, and if there were unresolved state issues that the RAB should continue to monitor. Mr. Oates said he would work closely with ADEC to pass on his institutional knowledge concerning the petroleum sites.

      2. Concerns, Issues, and Questions

         Mr. Krukoff said he had talked with the community and had prepared an updated list of 26 community concerns. The list was distributed. Mr. Krukoff explained these concerns still need to be addressed and requested that they be attached to the minutes. In addition, Mr. Krukoff asked if a consultant could be employed to work with the Adak community regarding OUA and OUB decisions.

         Mr. Mitchell asked what the plans were for Dr. Scudato’s continued involvement. Mr. Oates said he sent Dr. Scudato a letter after the last meeting and offered his help in reviewing the information. A teleconference will be scheduled soon to discuss Dr. Scudato’s concerns and issues and to answer his questions. Mr. Murphy said $8,000.00 of the grant money remains. Dr. Scudato was asked to contact the RAB to discuss how best to direct his efforts given the funding limitations. Mr. Mitchell requested that the RAB be notified of the time of the briefing with Dr. Scudato so that RAB members could attend.

2. Project Updates and Questions and Answers
   1. EPA and ADEC discuss whether there are enough monitoring stations in place to identify problems and to review sampling data.

      Mr. Cora questioned what kind of information EPA was expected to present. Ms. Miller said her question was not just specifically about the monitoring stations. Ms. Miller said she wanted EPA and ADEC to review the major components of the ROD and discuss why they concurred on unresolved issues raised by the RAB. Mr. Cora asked if that meant an overview of all the data that resulted in specific decisions. Ms. Miller referred to last month’s minutes and felt she had been clear. Mr. Cora said the data that resulted in the remedy was supported and approved by the EPA. EPA feels there is sufficient information, monitoring and data to select an appropriate remedy. EPA would not have proceeded with the proposed plan without that.

      Ms. Miller said the RAB has had continuing concerns about Sweeper Cove and Finger Bay. Ms. Miller said her request was a basic question regarding whether there is sufficient long-term monitoring in place to detect new problems. Mr. Cora said the monitoring plan for the marine environment is currently being developed. Mr. Oates added that the site-wide monitoring plan is being written. The first draft will be placed in the information repository for comments.

      Mr. Murphy said that the first year of the marine monitoring program is complete. That work plan was developed after consultation with the RAB, the biological assistance group, the agencies and stakeholders.

      Ms. Miller said she wanted a more complete ROD review, major issue by major issue, and the justification for signing off on particular points of contention raised by the RAB. Mr. Gromoff said he felt Mr. Cora and Mr. Oates were not prepared to brief those issues. Mr. Gromoff said he believed the RAB’s concerns with the ROD should be clarified. Ms. Miller agreed.

      Mr. Cora said the ROD is based on the information in the RI/FS. He said that the briefing would be on existing data that has been available in the information repository for about two years. Mr. Cora felt the issues had been gone through many times before. He cautioned there were many, many data points and thousands of monitoring wells. There is an enormous amount of information in the documents. The ROD simply analyzes and summarizes existing information and comes to a determination. Mr. Cora said the briefing would be a large undertaking. Ms. Miller said the RAB had reviewed the RI/FS and the proposed plan. From her perspective, there are still a number issues that were inadequately resolved by the ROD. Ms. Miller said every data point and monitoring well did not need to be briefed, but felt some decisions were made too quickly. Mr. Cora asked for specific areas and acknowledged he knew Sweeper Cove, Finger Bay and landfills, in general, were of concern. Ms. Miller agreed. Mr. Cora said he did not feel the ROD was a quick process in that the Superfund work began in 1993. In that process, 28 removal actions were done. Mr. Murphy said a responsiveness summary was provided. In that summary, there is a listing of every comment received on the proposed plan and how those comments were addressed. Mr. Murphy said the responsiveness summary might answer some remaining questions. Ms. Miller felt the responsive summary dealt with some of the RAB’s concerns superficially. The latest ROD draft has some revisions relating to those comments. Ms. Miller requested more responses from the agencies on landfills, Sweeper Cove and Finger Bay.

      Mr. Gromoff requested that at the next meeting, the presentation provide specific information about how conclusions were determined. He also asked that a more formal format be used for future presentations. Mr. Gromoff said general statements did not satisfy the RAB members. Mr. Gromoff said in-depth presentations on the landfills, Sweeper Cove and Finger Bay need to explain how decisions were made. When detailed information is provided, the RAB would then be able to ask more specific questions.

      Mr. Cora said he agreed with Mr. Gromoff in the sense that the RI/FS contains very technical information that can be difficult to understand. The agencies have attempted briefings, but when, for example, screening levels are brought up, very often they are rejected as an acceptable approach to characterization. In Mr. Cora’s professional opinion if, after two years of sampling, nothing is found above an exceedence level, monitoring should stop. The RAB continues to discuss the same information in the RI/FS. All the data and screening levels in the RI/FS are very conservative and are protective of human health. Mr. Cora felt the agencies had not been able to communicate that well enough to the RAB. The RAB has not been able to define why the screening levels and methods are unacceptable. Mr. Cora explained the methods used are part of the law and the required process. These methods have been used at 1,500 sites across the United States. Some of the uncertainties cannot be addressed. Mr. Cora said he read “Will Risk-Based Cleanup Work at Navy Facilities?” where it said that the EPA does not use very quantitative evaluation of uncertainties. However, EPA has shied away from uncertainties and selected very conservative risk numbers that has led to an over-estimation of risk at some sites. Mr. Cora said that policy has led people to disbelieve the EPA. Mr. Cora agreed with Mr. Gromoff that better communication was needed. Mr. Cora explained the project’s purpose is to address contamination. It does not make everything perfect. Mr. Cora said that very specific information is needed to stop a ROD from going forward. Mr. Cora said EPA stands behind the data. It is very difficult to justify why the data or a site should be re-evaluated just because someone is not satisfied with the information.

      Mr. Gromoff said the agencies did a good job educating the RAB, however, the EPA and ADEC each had separate evaluation criteria. It appears now that ADEC and EPA agree on the criteria. The RAB was never told ADEC’s position had changed. Mr. Cora said there are two cleanup procedures, one for petroleum sites and one for Superfund cleanup. EPA has no criteria for petroleum. EPA has a wider range of acceptable risks than the State. The EPA chose to use the State’s more conservative cleanup levels. Mr. Gromoff said that was the first time the RAB had heard that. The lack of information probably added to the confusion. Mr. Krukoff requested that the record show that Mr. Cora said the methodology used was pursuant to the more stringent State standards versus federal standards. Mr. Cora said that comment should not be taken out of context. For example, both the EPA and the State use the Clean Water Act, which is a federal standard. Mr. Mitchell asked if the State standards applied to both CERCLA and non-CERCLA sites. Mr. Oates said State standards applied to non-CERCLA sites because there were no federal petroleum standards.

      Ms. Miller requested briefings from EPA and ADEC to understand the decision making process in the ROD for Finger Bay, Sweeper Cove and the landfill sites. Mr. Merculief agreed that more information on how decisions were made was needed.

   2. Schedule for record of decision: signing of the ROD.

      Mr. Cora said that there is a briefing set for 9/21/99 to present the ROD to EPA’s assistant regional administrator. In that process, Mr. Cora will identify concerns from the community, UAN and API/A. The regional administrator makes the decisions. Mr. Cora could not predict how the administrator would react to the UAN or API/A’s requests, or the comments submitted by the Adak community. Mr. Oates said the State’s role is to concur after the EPA and the Navy has signed. Michelle Brown was asked to delay signing the ROD and she responded that there was not enough reason to delay.

      Mr. Gromoff said he understood there was correspondence to and from the Navy regarding tribal status. No answer is available yet.

      Mr. Cora said another draft ROD will be prepared stemming from comments made by EPA, ADEC and the community. Mr. Murphy said the new draft would be ready in about 10 days. Mr. Gromoff requested that the new draft be submitted to UAN. Ms. Miller also requested that the next draft ROD be put into the information repository.

   3. National RAB Caucus and BECT and BTAG Meeting Briefings.

      Ms. Miller reported the National RAB Caucus is an organization brought together by ARCecology of San Francisco in an effort to change policies that affect cleanup decisions through Superfund and other military site cleanup laws. About 60 RABs were represented over five days in July 1999. The Caucus prepared a series of papers and had lengthy meetings with Pentagon officials, EPA and the Federal Facilities office. Ms. Miller will make available copies of the discussion papers to attach to the minutes which include topics such as public participation, environmental justice, depleted uranium use, policies around institutional controls and natural attenuation, the national lead decision making process, risk assessment and its use in CERCLA decisions, etc. The decision papers were presented to EPA and DoD. Yearly meetings will be held in an effort to gain better cleanup. The Caucus sees a disturbing trend toward more reliance on institutional controls and natural attenuation. The Barrow and Elim (Moses Point) RABs also participated.

   4. OUB Dispute Resolution Meeting Briefings.

      Mr. Oates said the dispute resolution process is part of the FFA signed in 1994. When the project managers cannot agree on some aspect of the investigation and cleanup, a formal dispute resolution process is triggered. Such a process occurred with UXO. Some of the dispute related to EPA’s and DoD’s incompatible policies. The problems on Adak are the same problems that the National Working Group has been unable to resolve.

      A meeting was held in Seattle, Washington on 7/22/99 where EPA and the State made a joint presentation regarding the problems. The Navy made a response. The Navy’s response was very similar to what the EPA and the State suggested should be done differently. Tasks that arose from the meeting included a working team whose purpose is to come up with new solutions. The project managers said that the working team could focus on what would work on Adak, rather than attempting to solve the national issues at the same time. It was also agreed that TAC, API/A and FWS would participate as well.

      Another subject discussed was what area should be investigated. The Navy wanted to focus on the northern half even though information suggested UXO existed on the south half.

      Since the Seattle meeting, three full team meetings have been held to start the investigation again. The teams reviewed the technology available and how the work could be accomplished. Potential solutions will be presented to the community for comment. Mr. Oates said he was very encouraged with the outcome of the meetings and felt that something positive could be accomplished on Adak.

      Mr. Oates confirmed that the State has sent the Navy a nuisance abatement order to move the Rommel stakes at Adak.

   5. Logistics and Planning for Future RAB Meetings.

      Mr. Gromoff felt the meeting on Adak was very positive and well attended by community members. Some of the presentations were difficult by teleconference, and reiterated it was important that minutes and handouts be distributed promptly.

3. Public Comments.

   Mr. Gates, speaking in a private citizen capacity, said he was very encouraged about the progress made on the OUB, particularly regarding the Rommel stakes and community involvement.

   Mr. Gates said he felt it was premature to sign the OUA ROD. The tribes, community, and the RAB are against signing now. Delaying the ROD would prevent a lot of problems with the public. There is a fundamental problem with the ROD in that there has been no discussion concerning the interrelationship between sites. For example, no discussion has been had about gasoline mixing with PCB’s. The solutions were designed for single, separate sites when in fact the sites inter-react. Another problem is with Sweeper Cove. The community must aggressively use Sweeper Cove for the fuel farm and Docks 3 and 5. Sediments will be disturbed in Sweeper Cove. The OUA does not consider disturbing sediments and does not analyze the effects on the water column. Mr. Gates felt the existing analysis only considered in-place sediments and the surface associated with those. There is a lack of good information on what is below the surface of sediments.

   Although a delay of the ROD had been requested, Mr. Gates appreciated all the work and positive attitudes from the Navy and the agencies.

   Mr. Murphy pointed out that one of the objectives of the RI/FS was to address the interrelationship of sites. A lot of work done in Sweeper Cove, Kuluk Bay, Andrew Lake and Clam Lagoon was done regarding the impact on receiving water bodies and the interrelationship of sites to each other as well as the cumulative impact. Mr. Murphy said he felt there was a need to better educate the stakeholders on how the RI/FS did address those concerns.

   Mr. Foutz said he had been considering a water export project on Adak. Mr. Foutz asked if anyone was adding up the cumulative fiscal impact of all the potential cleanups and if there were unlimited funds. He also wanted to know what would happen if there were not enough funds to address cleanup issues. Mr. Foutz said he felt it was important to keep an eye on the big picture and in particular select solutions that would best serve the Adak community.

   Ms. Villa said she distributed some questionnaires to the community. Mr. Gromoff said that Ms. Villa should submit the questions to ARC. Mr. Murphy commended Ms. Villa for soliciting community concerns.

4. Set Date and Tenative Topics for Next Meeting

   Ms. Miller requested briefings from EPA and ADEC to understand the decision making process in the ROD for Finger Bay, Sweeper Cove and the landfill sites. Mr. Gromoff requested that RAB members prepare specific questions and submit them to the Navy co-chair. Mr. Gromoff asked that on landfills, the briefing should include an engineering evaluation on topics such as why a certain cap was chosen, drainage problems, costs, etc. Regarding Sweeper Cove and Finger Bay, the presentation should include a location of where samples were taken, the lab results, how the site was characterized, etc. Mr. Gromoff said at low tide residents see black muck and a sheen that cause concern.

   Mr. Mitchell reiterated his request at the last meeting for a briefing on the adequacy of the assumptions that went into the risk assessment and the guidelines for institutional controls as they relate to fish consumption, particularly in light of Dr. Scudato’s concerns. Mr. Oates said he did not have a response yet.

   Mr. Gromoff requested that the 26 concerns presented by Mr. Krukoff from the Adak community be addressed.

   Mr. Gromoff requested that the discussion continue regarding the UXO formal dispute resolution process.

5. Meeting Adjourned.

   The next meeting was scheduled for October 20, 1999 in Anchorage (6:00 p.m. Adak time, 7:00 p.m. Anchorage time). The meeting was adjourned at approximately 9:23 p.m.

BACKGROUND INFORMATION | ENVIRONMENTAL SETTING | BASE REALIGNMENT AND CLOSURE | ENVIRONMENTAL RESTORATION | UNEXPLODED ORDNANCE ISSUES | CHEMICAL AND PETROLEUM CLEANUP | GLOSSARY OF TERMS | ADAK MAPS | INSTITUTIONAL CONTROLS | WEBSITE MAP | | WHAT'S NEW? | NEWSLETTERS & FACT SHEETS | TECHNICAL DOCUMENTS | RESTORATION ADVISORY BOARD MINUTES | WHERE TO GET MORE INFORMATION | INFORMATION REPOSITORY | LINKS OF INTEREST | HOME