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2003 OU A ROD AMENDMENT PROPOSED PLAN, MAY 16, 2003
This Proposed Plan describes the Navy's, Environmental Protection Agency's (EPA), and the Alaska Department of Environmental Conservation's (ADEC) rationale for Amending the Former Adak Naval Complex Operable Unit A Record of Decision (OU A ROD). It is provided in accordance with the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA) and the National Oil and Hazardous Substances Pollution Contingency Plan (NCP), 40 CFR Section 300.435(c)(2).
The purpose of the proposed OU A ROD Amendment is to:
- Replace subsistence fish advisory signs along Kuluk Bay and Sweeper Cove with fish advisory fact sheets for Adak residents; and
- Remove sixty-two (62) petroleum sites from the OU A ROD, consistent with the Naval Air Station Adak Federal Facility Agreement (FFA) and the State-Adak Environmental Restoration Agreement (SAERA) as amended in March 2002.
Scope and Role of Fundamental Change
Navy, EPA, and ADEC signed the OU A ROD in October 1999, March 2000, and April 2000, respectively. The OU A ROD included petroleum site remedies, consistent with the SAERA, an agreement between Navy and ADEC, and consistent with the FFA, a separate agreement among the Navy, EPA, and the ADEC. This proposed OU A ROD Amendment modifies the requirements for the subsistence fish advisory signs along the shores of Sweeper Cove and Kuluk Bay, and replaces them with fact sheets to target the residents of the City of Adak. The fact sheets will provide a greater level of detail on the presence of polychlorinated biphenyls (PCBs) in specific species, and will also discuss potential health risks and benefits associated with fish consumption. Since recreational fishing does not pose a health risk, advisory or educational materials will not be prepared regarding these exposure scenarios.
This proposed OU A ROD Amendment also removes sixty-two (62) petroleum sites (listed further down the page) from the OU A ROD and clearly establishes 18 AAC 75 as the basis for regulatory procedures and requirements for future petroleum cleanup decisions. The OU A ROD selected final decisions for forty-eight (48) of the sixty-two (62) petroleum sites. The petroleum sites are included in this Amendment in order to streamline regulatory oversight of the petroleum cleanup, and to potentially expedite the partial delisting of the Downtown Area from the NPL. The OU A ROD selected interim remedies for fourteen of the petroleum sites without defining the process for selecting a final remedy. The Amendment establishes that the final remedies for these 14 sites, known as the petroleum free-product recovery sites will not be selected under a CERCLA ROD, but will instead be selected by the Navy and the State of Alaska using the state's petroleum release regulations. These regulations have been changed significantly since the OU A ROD (see below) and can be found in 18 AAC 75.
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This proposed OU A ROD Amendment would remove forty-eight petroleum sites that have final remedies and fourteen petroleum free-product recovery sites that were selected for interim remedies from the federal CERCLA Record of Decision and confirm Alaska's regulations 18 AAC 75 as the basis for regulatory procedures and requirements for future petroleum cleanup decisions. |
The OU A ROD and SAERA maintain that the primary regulatory authority for the petroleum-contaminated sites is Alaska's regulations. The revisions, grouped under Article 3 as 75.300 to 75.396, constituted a comprehensive reorganization and revision of the petroleum cleanup regulations. It is the intent of the OU A ROD to have the petroleum sites cleaned up in accordance with these applicable state regulations. |
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In order to meet the ADEC cleanup standards, recoverable free-product had to be first removed by using product-recovery systems. This first step is referred to in the OU A ROD as the Interim Remedial Action. After it becomes obvious that free-product can no longer be efficiently removed using these systems due to the presence of small amounts of petroleum, a final remedy must be chosen. The Navy will use a focused feasibility-like process to evaluate several potential remedies that might work to clean up the remaining petroleum contamination. This process looks at the risks associated with the presence of the remaining petroleum at the sites and gives the best cleanup choice to complete the cleanup (Final Remedy). The cleanup and decision process is presented as guidance to ADEC project managers in the Guidance on Decision Documentation Under the Site Cleanup Rules (18 AAC 75.325 - 18 AAC 75.390). For the forty-eight other petroleum sites, final remedies were selected in the OU A ROD. These sites are included in this proposed OU A ROD Amendment in order to streamline regulatory oversight of the petroleum cleanup, and to potentially expedite the partial delisting of the Downtown Area from the National Priority List of contaminated sites. This proposed Amendment also contains a significant difference from the OU A ROD. The requirements for the subsistence fish advisory signs at Sweeper Cove and Kuluk Bay are modified allowing the signs to be replaced by fact sheets. The fact sheets will target the residents of the City of Adak and provide a greater detail on the presence of PCBs (polychlorinated biphenyls) in specific species. They will also discuss potential health risks and benefits associated with fish consumption. Since recreational fishing poses no unacceptable health risks, no advisory or educational materials will be prepared regarding these exposure scenarios. The proposed OU A ROD Amendment is based on available information in the administrative record, located at Naval Engineering Field Activity, Northwest, 19917 7th Avenue NE, Poulsbo, WA 98370. |
Petroleum sites addressed in this proposed OU A ROD Amendment (14 Free-Product Sites Shown in Bold)
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How You Can Participate
The Navy, EPA, and ADEC encourage you to comment on this proposed OU A ROD Amendment. You may comment in person at the public meeting to held on May 28, 2003 in Anchorage, or you may submit your written comments to: |
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