CCP 09-03-2002 - Laserfiche WebLink

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Comments on, "Draft Technical Memorandum for Shallow Soils site Alternatives Evalnation". Submitted by Paul R. Bloom On behalf of the TCAAP RAB 8-12-02 . We ofthe RAB acknowledge that with the current high wateT table it would be difficult and likely expensive to meet the requiTements of the ROD. The Temedial desigu associated with the existing wOTk plan will not meet the TequiTements of the ROD for complete removal to cleanup goals agreed to in the ROD. Therefore, a modification of the ROD is needed. We also acknowledge that except for areas affected by the phytoTemediation disaster and small areas of hydrocaTbon contamination the contaminants of concern are immobile and do not represent a risk to ground water at the present time. Weare concerned, however, that a hasty decision may have potential serious consequences fOT the future use of property. We acknowledge that funding is available for the current fiscal year and that delay could be costly. HoweveT, no cost estimates weTe pTovided as is TequiTed for decisions on Temedial alternatives for a ROD. Concurrence for a modification in work plan before completing the slow process of ROD modification could be risky. It should be borne in mind that future discussions may result in changes that will require Teturmng for additional work. The property in question is in the area designated fOT transfer to the local community. In addition to protection of health and safety the future use of the property by non-Army users must be considered. . When a public hearing is held for the ROD modification both health and safety and utilization of the property will be important topics of discussion. The public hearing may not be without controversy. We conclude that none of the alternatives in the Memorandum are acceptable. Alternative 1. (Continue on the current wOTk plan that limits digging when the wateT table is encounteTed, even if cleanup is not completed, and cover with a minimum of 2 feet of fill), This does not assure that theTe will be a deep enough cover oveT all ofthe remaining polluted soil and theTe is not enough characterization data to provide information fOT good institutional controls. At the meeting on August 7, 2002 the MPCA suggested that with a cover of only 2 ft. the institutional controls would include Tequirements for a fence and long-term monitoring, Alternative 2 (DewateT and Temove all the COC to the Temediation goals). The Army has stated that this is expensive, but provided no cost estimates. Alternative 3. (Wait until the dry season), This pTobably will not wOTk given the current exceedingly high water table. Alternative 4 (Bring in 2 feet of cover for the Temaining problem grids, then do subsurface sampling of the extent of the Temaining pToblem). As with Alternative 1 this would require institutional controls that would include treating the site as a landfill and requiTe both a fence and long-term monitoring, At the August 7, 2002, meeting the Army stated that they would be willing to consider a 3 ft. cover. The . MPCA stated that with a 4 ft cover no fence is necessary. A 4 ft coveT will be much more pTotective and limited uses of the land would be possible if characterization is competed, monitoring is instituted, and institutional controls are put in place. Depending on the contouT of the land, piling 4 ft of soil on the