notice of proposed activity...

NOTICE OF PROPOSED ACTIVITY (NPA-12-001.0)

KWAJALEIN ATOLL REMEDIATION ACTIVITIES

U.S. ARMY KWAJALEIN ATOLL/REAGAN TEST SITE

REPUBLIC OF THE MARSHALL ISLANDS

MAY 2012

Contract No. DASG60-03-C-0081

Prepared for: U. S. Army Space and Missile Defense Command

Von Braun Complex Building 5220

Redstone Arsenal, Alabama 35898

Prepared by:

3150 C Street, Suite 250

Anchorage, Alaska 99503

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Notice of Proposed Activity (NPA-12-001.0) 1

Activity: Kwajalein Atoll Remediation Activities 2

Date Submitted: 3

References 4

Craib, J., T. Bonhomme, J. Clevenger, N. Farrell, O. Sage and A. Schilz. 1989. 5 Archaeological Reconnaissance Survey and Sampling, U.S. Army Kwajalein Atoll 6 Facility (USAKA), Kwajalein Atoll, Republic of the Marshall Islands, Micronesia. Report 7 submitted by ERC Environmental and Energy Services Company, San Diego, California, 8 to US Army Engineer District, Fort Shafter, Honolulu, Hawaii. 9

Document of Environmental Protection, Protection of Cultural Resources. November 10 2004. 11

Document of Environmental Protection, Reclaimed Water Systems. August 2005. 12

Kwajalein Range Services, LLC (KRS, 2004). PCB Vault Contamination. Transmittal-13 05-0010. November 24, 2004. 14

Panamerican Consultants, Inc., 1994. Comprehensive Resource Inventory and 15 Preservation Planning Study for World War II Cultural Resources at the United States 16 Army Kwajalein Atoll. Prepared for EARTH TECH, Inc., under contract to the United 17 States Army Space and Strategic Defense Command, Huntsville, Alabama. 18

Raytheon Service Company Range Systems Engineering (RSE, 2001). Restoration 19 Report – Transformer Vault 713. July 5, 2001. 20

Sivuniq, Inc. (Sivuniq, 2012a). United States Army Kwajalein Atoll (USAKA) Kwajalein 21 Harbor Yard Removal Action Memorandum (Draft). February 2012. 22

Sivuniq. (Sivuniq, 2012b). United States Army Kwajalein Atoll (USAKA) Rio-Namur 23 POL Yard Removal Action Memorandum (Draft). February 2012. 24

Sivuniq. (Sivuniq, 2011b). United States Army Kwajalein Atoll (USAKA) Carlos Power 25 Plant Site Investigation (Draft). November 2011. 26

Sivuniq. (Sivuniq, 2012c). United States Army Kwajalein Atoll (USAKA) Carlos Power 27 Plant Removal Action Memorandum (Draft). February 2012. 28

Sivuniq. (Sivuniq, 2012d). United States Army Kwajalein Atoll (USAKA) Kwajalein PCB 29 Vault Building 713 Removal Action Memorandum (Draft). February 2012. 30

Sivuniq. (Sivuniq, 2011a). United States Army Kwajalein Atoll (USAKA) Kwajalein Tank 31 Farm Site Investigation (Draft). November 2011. 32

Sivuniq. (Sivuniq, 2012e). United States Army Kwajalein Atoll (USAKA) Kwajalein Tank 1 Farm Removal Action Memorandum. February 2012. 2

Sivuniq. (Sivuniq, 2011b). United States Army Kwajalein Atoll (USAKA) Roi-Namur 3 Drinking Water Well 8151 PCE/TCE Site Investigation. November 2012. 4

Sivuniq. (Sivuniq, 2012f). United States Army Kwajalein Atoll (USAKA) Roi-Namur 5 Drinking Water Well 8151 PCE/TCE Removal Action Memorandum. February 2012. 6

Sivuniq. (Sivuniq, 2012g). United States Army Kwajalein Atoll (USAKA) Gagan Power 7 Plant Fuel Spill Removal Action Memorandum. February 2012. 8

Sivuniq, Inc. (Sivuniq, 2011c). Draft 2011 Supplemental Site Investigation Work Plan, 9 U.S. Army Kwajalein Atoll/Reagan Test Site (USAKA/RTS), Republic of Marshall 10 Islands. December 2011. 11

Sivuniq, Inc. (Sivuniq, 2010). Final 2010 Work Plan, Investigation of Nine Sites at the 12 U.S. Army Kwajalein Atoll/Reagan Test Site (USAKA/RTS), Republic of Marshall 13 Islands. October 2010. 14

U.S. Army Kwajalein Atoll (USAKA, 2011). Environmental Standards and Procedures 15 for United States Army Kwajalein Atoll (USAKA) Activities in the Republic of the 16 Marshall Islands. Twelfth Edition. August 2011. 17

Type of Activity 18

This activity provides human health and environmental protection by implementing a variety of 19 remediation technologies to address soil and groundwater contamination at a number of USAKA 20 sites. This activity is not previously covered by any Document of Environmental Protection. 21

Location of Activity 22

This Notice of Proposed Activity (NPA) covers the United State Army Kwajalein Atoll 23 (USAKA) leased inlets in the Kwajalein Atoll, Republic of the Marshall Islands (RMI); 24 including, but not limited to, the islets of Kwajalein, Roi-Namur, Gagan, and Carlos. 25

Compliance Status 26

Although several of the sites have a time-critical component related to interim removal actions in 27 advance of full remedial system installation, none of the activities associated with this document 28 are currently out of compliance with the current USAKA Environmental Standards (UES). As 29 proposed, all planned remedial/removal activities at USAKA will also be in compliance with 30 UES requirements. 31

Notice of Proposed Activity (NPA 12-001.0) i Sivuniq, Inc. Kwajalein Atoll Restoration Activities May 2012

TABLE OF CONTENTS 1

Section Page 2

1.0 TECHNICAL DESCRIPTION OF PROPOSED ACTIVITY ........................................................ 1 3 1.1 General ......................................................................................................................................... 1 4 1.2 Related Documents of Environmental Protection ........................................................................ 1 5 1.3 Remediation Activities ................................................................................................................. 2 6 1.4 Current Locations for Proposed Remediation Activities ............................................................. 2 7 1.5 Proposed Remediation Activities ................................................................................................. 3 8

1.5.1 Presumptive Remedies .............................................................................................. 3 9 1.5.2 Soil Excavation / Dig and Haul / Dredging .............................................................. 4 10 1.5.3 Groundwater Pumping / Extraction .......................................................................... 4 11 1.5.4 Monitored Natural Attenuation ................................................................................. 4 12 1.5.5 Enhanced Bioremediation ......................................................................................... 4 13 1.5.6 Bioventing / Biopiles / Bioreactors ........................................................................... 5 14 1.5.7 Soil Flushing ............................................................................................................. 8 15 1.5.8 Soil Vapor Extraction / Air Sparging / Air Stripping / In-well air stripping ............ 9 16 1.5.9 Chemical Oxidation / Incineration / Open Burning-Open Detonation ................... 13 17 1.5.10 Composting / Landfarming ..................................................................................... 15 18 1.5.11 Dual Phase Extraction / Bioslurping ....................................................................... 17 19 1.5.12 Infiltration Galleries ................................................................................................ 19 20 1.5.13 Adsorption / Absorption ......................................................................................... 20 21 1.5.14 Thermal Desorption ................................................................................................ 21 22 1.5.15 Containment Barriers / Stabilization ....................................................................... 22 23 1.5.16 Phytoremediation .................................................................................................... 24 24 1.5.17 Offsite Disposal ...................................................................................................... 25 25

1.6 Current Sites ............................................................................................................................... 25 26 1.6.1 KWAJ001-Kwajalein Harbor ................................................................................. 25 27 1.6.2 KWAJ003-Roi-Namur POL Yard .......................................................................... 27 28 1.6.3 KWAJ004-Carlos Power Plant ............................................................................... 29 29 1.6.4 KWAJ005-Kwajalein PCB Vaults .......................................................................... 30 30 1.6.5 KWAJ006-Kwajalein Tank Farm ........................................................................... 33 31 1.6.6 KWAJ008-Roi–Namur Drinking Water Well 8151 ............................................... 35 32 1.6.7 KWAJ009-Gagan Power Plant Fuel Spill ............................................................... 36 33

1.7 Project Procedures ...................................................................................................................... 37 34 1.8 Projects Not Covered. ................................................................................................................ 37 35 1.9 NEPA Documentation ................................................................................................................ 37 36

2.0 DESCRIPTION OF ACTIVITY ENVIRONMENTAL SETTING .............................................. 37 37 2.1 Land and Reef Area .................................................................................................................... 37 38 2.2 Geology ...................................................................................................................................... 38 39 2.3 Hydrogeology ............................................................................................................................. 38 40

3.0 ENVIRONMENTAL AREAS POTENTIALLY AFFECTED BY PROPOSED ACTIVITY ..... 39 41 3.1 Air Quality .................................................................................................................................. 39 42

Notice of Proposed Activity (NPA 12-001.0) ii Sivuniq, Inc. Kwajalein Atoll Restoration Activities May 2012

3.2 Water Quality and Reef Protection ............................................................................................ 39 1 3.3 Material and Waste Management ............................................................................................... 39 2 3.4 Cultural Resources ..................................................................................................................... 39 3

4.0 ANALYSIS OF EFFECT OF ACTIVITY ON ENVIRONMENTAL AREAS IN ABSENCE OF 4 ENVIRONMENTAL CONTROLS ............................................................................................... 40 5

4.1 Air Quality .................................................................................................................................. 40 6 4.2 Water Quality and Reef Protection ............................................................................................ 40 7 4.3 Material and Waste Management ............................................................................................... 40 8 4.4 Cultural Resources ..................................................................................................................... 41 9

5.0 TECHNICAL DESCRIPTION AND ANALYSIS OF ENVIRONMENTAL CONTROLS USED 10 IN ACTIVITY ............................................................................................................................... 41 11

5.1 General Controls for all Remedial Actions ................................................................................ 41 12 5.1.1 Air Quality .............................................................................................................. 41 13 5.1.2 Water Quality and Reef Protection ......................................................................... 41 14 5.1.3 Material and Waste Management ........................................................................... 42 15 5.1.4 Cultural Resources .................................................................................................. 42 16

6.0 DISPERSION MODEL FOR MODELING AIR SOURCES ....................................................... 43 17 7.0 ANALYSIS OF WASTE DISCHARGE FOR POINT SOURCE WASTE DISCHARGE TO 18

WATER ......................................................................................................................................... 43 19 8.0 INFORMATION FOR HAZARDOUS WASTE TREATMENT, STORAGE, OR DISPOSAL 20

FACILITIES .................................................................................................................................. 43 21 9.0 BIOLOGICAL ASSESSMENT IF ENDANGERED RESOURCES MAY BE AFFECTED ...... 44 22 10.0 INFORMATION ON RECEIVING-WATER QUALITY FOR WATER DISCHARGES .......... 44 23 11.0 INFORMATION ON MARINE LIFE, CURRENTS, AND OTHER CHARACTERISTICS OF 24

OCEAN DISPOSAL SITE ............................................................................................................ 44 25 12.0 INFORMATION ON MARINE LIFE AND ENVIRONMENT IN DREDGING OR FILLING 26

AREAS .......................................................................................................................................... 44 27 13.0 SPECIES AND NUMBERS OF MIGRATORY BIRDS AND OTHER WILDLIFE 28

RESOURCES AND HABITATS THAT MAY BE TAKEN ....................................................... 44 29 14.0 NOTIFICATION ........................................................................................................................... 45 30

14.1 Emergency Actions .................................................................................................................... 45 31 14.1.1 Public Notifications ................................................................................................ 45 32

15.0 RECORDS KEEPING ................................................................................................................... 45 33 16.0 RESOLUTION OF NONCOMPLIANT AREAS ......................................................................... 46 34

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Notice of Proposed Activity (NPA 12-001.0) iii Sivuniq, Inc. Kwajalein Atoll Restoration Activities May 2012

List of Figures 1 Figure 1-1 USAKA Locations ............................................................................................................... 3 2 Figure 1-2 Bioventing System Schematic .............................................................................................. 5 3 Figure 1-3 Biopile System Schematic .................................................................................................... 6 4 Figure 1-4 Bioreactor System Schematic ............................................................................................... 7 5 Figure 1-5 Soil Flushing System Schematic ........................................................................................... 8 6 Figure 1-6 Soil Vapor Extraction System Schematic ............................................................................. 9 7 Figure 1-7 Air Sparging System Schematic ......................................................................................... 10 8 Figure 1-8 Air Stripping System Schematic ......................................................................................... 11 9 Figure 1-9 In-Well Air Stripping System Schematic ........................................................................... 12 10 Figure 1-10 Chemical Oxidation System Schematic .......................................................................... 13 11 Figure 1-11 Incineration System Flow Chart ...................................................................................... 14 12 Figure 1-12 Composting System Flowchart ....................................................................................... 15 13 Figure 1-13 Landfarming System Schematic ...................................................................................... 16 14 Figure 1-14 Dual Phase Extraction System Flow Chart ..................................................................... 17 15 Figure 1-15 Bioslurping System Schematic ........................................................................................ 18 16 Figure 1-16 Infiltration Galleries System Schematic .......................................................................... 19 17 Figure 1-17 Adsorption / Absorption System Schematic ................................................................... 20 18 Figure 1-18 Thermal Desorption System Flow Chart ......................................................................... 22 19 Figure 1-19 Physical / Reactive Barrier System Schematic ............................................................... 23 20 Figure 1-20 Phytoremediation ............................................................................................................ 25 21 Figure 1-21 Kwajalein Harbor Site Areas ........................................................................................... 26 22 Figure 1-22 Roi Power Plant ............................................................................................................... 28 23 Figure 1-23 Carlos Power Plant .......................................................................................................... 29 24 Figure 1-24 Kwajalein PCB Vaults .................................................................................................... 30 25 Figure 1-25 Kwajalein Tank Farm ...................................................................................................... 33 26 Figure 1-26 Kwajalein Tank Farm Bioslurping Well Conceptual Layout .......................................... 34 27 Figure 1-27 Roi-Namur Drinking Water Well 8151 ........................................................................... 35 28 Figure 1-28 Gagan Power Plant .......................................................................................................... 36 29 30

Notice of Proposed Activity (NPA 12-001.0) iv Sivuniq, Inc. Kwajalein Atoll Restoration Activities May 2012

LIST OF ACRONYMS 1

AST Above ground Storage Tank bgs below ground surface CY Cubic Yards DCE Dichloroethene DEP Document of Environmental Protection DRO Diesel Range Organics EOD Explosive Ordnance Disposal FN Facility Number FRTR Federal Remediation Technologies RoundtableFS Feasibility Study GAC granulated activated carbon GEPA Guam Environmental Protection Agency GRO Gasoline Range Organics GWE Groundwater Extraction KRS Kwajalein Range Services lbs Pounds LNAPL light non-aqueous phase liquid µg/100 cm2 microgram per 100 square centimeter mg/kg milligram per kilogram mi2 square mile ml Milliliter MSL mean sea level NAPL Non-aqueous phase liquids NPA Notice of Proposed Activity PCB Polychlorinated biphenyls PCE Tetrachloroethene POL Petroleum, Oil, & Lubricants ppm parts per million RAM Removal Action Memorandum RSE Range Systems Engineering SI Site Investigation SMDC Space and Missile Defense Command TCE Trichloroethene UES USAKA Environmental Standards USACE U.S. Army Corps of Engineers USAEHA U.S. Army Environmental Hygiene Agency USAKA U.S. Army Kwajalein Atoll USEPA U.S. Environmental Protection Agency USGS U. S. Geological Survey

CONTROL NUMBER NPA-12-001.0

Notice of Proposed Activity (NPA 12-001.0) 1 Sivuniq, Inc. Kwajalein Atoll Restoration Activities May 2012

1.0 TECHNICAL DESCRIPTION OF PROPOSED ACTIVITY 1

1.1 GENERAL 2

The purpose of this Notice of Proposed Activity (NPA) provides information about the proposed 3 activity for enabling the appropriate agencies to evaluate the environmental effects of the 4 activity, and to determine if the activity will comply with all applicable standards. 5

This NPA addresses proposed technologies to remediate contaminated sites throughout USAKA. 6 The USAKA Environmental Standards (UES) specifies the remediation process (UES §3-6.5.8) 7 and distinguishes between time-critical removal actions and follow-up or non-time critical 8 remedial actions (which may involve material removal) and in regulating air, water, hazardous 9 materials and cultural resources that may be effected by remedial actions. This NPA addresses 10 proposed technologies that are determined to be non-time critical or “remediation” under Phase 11 III (UES 3-6.5.8(k)) actions. 12

Phase III remedial actions are defined as those taking place when all immediate hazards have 13 been mitigated, but are a potential chronic threat to human health and safety or the environment, 14 the remediation pathway shall be followed (Phase III). This process will facilitate the deliberate 15 examination of mitigation alternatives that correspond to the materials and threat remaining. 16 Because of the information already considered and accumulated, this “non-time critical” 17 approach may begin at the “Site Investigation” phase of the remediation process (UES [3-18 6.5.8(f)(2)(i)]). A Phase III action may also be initiated directly as a result of the Phase I 19 process, when it is determined that such a threat does not exist, yet mitigation still appears 20 necessary for the benefit of the public, the routine remedial process (Phase III) shall be initiated 21 (UES [3-6.5.8(d)]). 22

This NPA addresses the proposed remedial actives on all eleven (11) islets throughout USAKA. 23 The areas include current and yet to be identified contaminated sites on Kwajalein, Roi-Namur, 24 Meck, Illeginni, Ennylabegan (Carlos), Legan, Gagan, Gellinam, Omelek, Eniwetak, and 25 Ennugarret. There are proposed remedial activities located on Kwajalein Atoll, Kwajalein, Roi-26 Namur, Gaga, and Carlos (Figure 1). The nature and extent of contamination at these sites is 27 discussed in section 1.6. 28

1.2 RELATED DOCUMENTS OF ENVIRONMENTAL PROTECTION 29

Document of Environmental Protection, Protection of Cultural Recourses, Nov 2004. 30

Document of Environmental Protection, Point-Source Discharge at USAKA, June 2007, 31

Modified August 2008. 32

Document of Environmental Protection, Shore Protection, Jan 2008. 33



Document of Environmental Protection, Air Emissions from Stationary Sources, May 2006, 1

Modified Dec 2010. 2

Document of Environmental Protection, Dredge and Filling, Feb 2011. 3

1.3 REMEDIATION ACTIVITIES 4

The candidate remediation technologies listed below are described in Section 1.5 of this 5 document: 6

Section 1.5.1 Presumptive Remedies 7 Section 1.5.2 Soil Excavation / Dig and Haul / Dredging 8 Section 1.5.3 Groundwater Pumping / Extraction 9 Section 1.5.4 Monitored Natural Attenuation 10 Section 1.5.5 Enhanced Bioremediation 11 Section 1.5.6 Bioventing / Biopiles / Bioreactors 12 Section 1.5.7 Soil Flushing 13 Section 1.5.8 Soil Vapor Extraction / Air Sparging / Air Stripping / In-well air stripping 14 Section 1.5.9 Chemical oxidation / Incineration / Open Burning-Open Detonation 15 Section 1.5.10 Composting / Landfarming 16 Section 1.5.11 Dual Phase Extraction / Bioslurping 17 Section 1.5.12 Infiltration Galleries 18 Section 1.5.13 Adsorption / Absorption 19 Section 1.5.14 Thermal Desorption 20 Section 1.5.15 Containment Barriers / Stabilization 21 Section 1.5.16 Phytoremediation 22 Section 1.5.17 Offsite Disposal 23

1.4 CURRENT LOCATIONS FOR PROPOSED REMEDIATION ACTIVITIES 24

The candidate technologies for proposed activities take place at identified sites on four islets of 25 the Kwajalein Atoll – Kwajalein, Roi-Namur, Gagan, and Carlos (Figure 1-1); individual sites 26 are discussed in section 1.6 of this document. Sites include: 27

KWAJ001 – Kwajalein Harbor (Section 1.6.1) 28

KWAJ003 – Roi-Namur Power Plant (Section 1.6.2) 29

KWAJ004 – Ennylabegan (Carlos) Power Plant (Section 1.6.3) 30

KWAJ005 – Kwajalein Polychlorinated Biphenyl (PCB) Vaults (Section 1.6.4) 31

KWAJ006 – Kwajalein Tank Farm (Section 1.6.5) 32

KWAJ008 – Roi-Namur Drinking Water Well 8151 (Section 1.6.6) 33

KWAJ009 – Gagan Power Plant Fuel Spill (Section 1.6.7) 34



Figure 1-1 USAKA Locations 1

2

1.5 PROPOSED REMEDIATION ACTIVITIES 3

1.5.1 Presumptive Remedies 4

A presumptive remedy is a technology that, based upon experience, generally provides the most 5 appropriate remedy for a specified type of site, contaminant, and affected media. Use of 6 established presumptive remedies can accelerate the site-specific analyses by focusing the 7 feasibility study efforts. In general, the USEPA recommends presumptive remedies when 8 available, except under unusual circumstances. 9

Examples of presumptive remedies include: 10

Soil vapor extraction, thermal desorption, and incineration for volatile organic chemicals in 11

excavated soils 12

Bioventing for fuel-contaminated soils 13

A combination of vacuum-enhanced product recovery and bioremediation for light non-14

aqueous phase liquid (LNAPL) product 15

Natural attenuation for petroleum hydrocarbon-contaminated ground water 16



Remedy selections always include consideration of site conditions and stakeholder concerns to 1 ensure appropriate implementation. 2

1.5.2 Soil Excavation / Dig and Haul / Dredging 3

Soil excavation provides a direct means for removing contamination sources in surface soils. 4 This process typically uses an excavator, backhoe, or hand shovels; a vacuum system can be 5 helpful in areas with utilities or other potential hazards. Dredging is excavation underwater and 6 is employed in exceptional situations to address contaminated sediments. Contaminated material 7 is removed and transported to off-site treatment and disposal facilities. 8

1.5.3 Groundwater Pumping / Extraction 9

Groundwater pumping and extraction provides a direct method to capture and remove dissolved 10 and separate phase contamination in the subsurface. Groundwater pumping is not a standalone 11 technology; further treatment ensures the contaminants are neutralized, removed, or otherwise 12 eliminated. 13

1.5.4 Monitored Natural Attenuation 14

In many contaminated systems, natural subsurface processes such as dilution, volatilization, 15 biodegradation, adsorption, and chemical reactions with subsurface materials reduce contaminant 16 concentrations to acceptable levels. Natural attenuation is not a "technology" in the classic 17 sense, and technical experts often debate its appropriate use at hazardous waste sites. 18

Consideration of this option requires evaluation of contaminant degradation rates and pathways, 19 and modeling to predict contaminant concentration at receptor points, especially when plume is 20 still changing. The primary objective of site modeling is to demonstrate that natural processes of 21 contaminant degradation will reduce contaminant concentrations below regulatory standards or 22 risk-based levels before potential exposure pathways are completed. In addition, long term 23 monitoring conducted throughout the process provides that degradation is proceeding at rates 24 consistent with meeting cleanup objectives. 25

Natural attenuation is not the same as "no action," although it often is perceived as such. 26 CERCLA requires evaluation of a "no action" alternative but does not require evaluation of 27 natural attenuation. Natural attenuation is considered in the Superfund program on a case-by-28 case basis, and guidance on its use is still evolving. 29

1.5.5 Enhanced Bioremediation 30

Enhanced bioremediation uses existing site conditions to promote passive restoration of 31 contaminated soil and groundwater systems. The activity of the naturally occurring microbes is 32 usually stimulated by circulating water-based solutions through contaminated soils to enhance in 33



situ biological degradation of organic contaminants or immobilization of inorganic contaminants. 1 Nutrients, oxygen, or other amendments may be used to enhance bioremediation and 2 contaminant desorption from subsurface materials. 3

Enhanced bioremediation is a process in which indigenous or inoculated micro-organisms (e.g., 4 fungi, bacteria, and other microbes) degrade (metabolize) organic contaminants found in soil 5 and/or ground water, converting them to innocuous end products. 6

Enhanced bioremediation of soil typically involves the percolation or injection of water mixed 7 with nutrients and saturated with dissolved oxygen. Sometimes acclimated microorganisms 8 (bioaugmentation) and/or another oxygen source such as hydrogen peroxide are also added. 9 Infiltration galleries or spray irrigation is typically used for shallow contaminated soils, and 10 injection wells are used for deeper contaminated soils. 11

1.5.6 Bioventing / Biopiles / Bioreactors 12

Bioventing, depicted in Figure 1-2, is a promising new technology that stimulates the natural in 13 situ biodegradation of any aerobically degradable compounds in soil by providing oxygen to 14 existing soil microorganisms. Oxygen is delivered to contaminated unsaturated soils by forced 15 air movement (either extraction or injection of air) to increase oxygen concentrations and 16 stimulate biodegradation. In contrast to soil vapor vacuum extraction, bioventing uses low 17 airflow rates to provide only enough oxygen to sustain microbial activity. Oxygen is most 18 commonly supplied through direct air injection into residual contamination in soil. In addition to 19 degradation of adsorbed fuel residuals, volatile compounds are biodegraded as vapors move 20 slowly through biologically active soil. 21

Figure 1-2 Bioventing System Schematic 22

23



Biopile treatment is a full-scale, batch technology in which excavated soils are mixed with soil 1 amendments and placed on a treatment area that includes leachate collection systems and some 2 form of aeration. It is used to reduce concentrations of petroleum constituents in excavated soils 3 through the use of biodegradation. Moisture, heat, nutrients, oxygen, and pH can be controlled 4 to enhance biodegradation. Figure 1-3 provides a biopile system schematic. 5

The treatment area will generally be covered or contained with an impermeable liner to minimize 6 the risk of contaminants leaching into uncontaminated soil. The drainage itself may be treated in 7 a bioreactor before recycling. Vendors have developed proprietary nutrient and additive 8 formulations and methods for incorporating the formulation into the soil to stimulate 9 biodegradation. The formulations are usually modified for site-specific conditions. 10

Biopile is a short-term technology. Duration of operation and maintenance may last a few weeks 11 to several months. Treatment alternatives include static processes such as: prepared treatment 12 beds, biotreatment cells, soil piles, and composting. 13

Figure 1-3 Biopile System Schematic 14

15



Bioreactor technologies, illustrated in Figure 1-4, degrade contaminants in water with 1 microorganisms through attached or suspended biological systems. In suspended growth 2 systems, such as activated sludge, fluidized beds, or sequencing batch reactors, contaminated 3 ground water is circulated in an aeration basin where a microbial population aerobically degrades 4 organic matter and produces CO2, H2O, and new cells. The cells form a sludge, which is settled 5 out in a clarifier, and is either recycled to the aeration basin or disposed. 6

In attached growth systems, such as up-flow, fixed film bioreactors, rotating biological 7 contactors (RBCs), and trickling filters, microorganisms are established on an inert support 8 matrix to aerobically degrade water contaminants. Nutrients are often added to the bioreactors to 9 support the growth of microorganisms. Bioreactors are a long-term technology and require 10 dedicated equipment and other utility support. The treatment process may take up to several 11 years. 12

Figure 1-4 Bioreactor System Schematic 13

14



1.5.7 Soil Flushing 1

In situ soil flushing technology involves the extraction of contaminants from the soil with water 2 or other suitable aqueous solutions. Soil flushing is accomplished by passing the extraction fluid 3 through in-place soils using an injection, or surface-spray and infiltration process as shown in 4 Figure 1-5. 5

After application, the extraction fluids must be recovered from the underlying aquifer and, when 6 possible, they are recycled. Recovered ground water and flushing fluids with the desorbed 7 contaminants may need treatment to meet appropriate discharge standards prior to recycle or 8 release to wastewater treatment works or receiving streams. To the maximum extent practical, 9 recovered fluids should be reused in the flushing process. The separation of surfactants from 10 recovered flushing fluid, for reuse in the process, is a major factor in the cost of soil flushing. 11

Treatment of the recovered fluids results in process sludge and residual solids, such as spent 12 carbon and spent ion exchange resin, which must be appropriately treated before disposal. Air 13 emissions of volatile contaminants from recovered flushing fluids should be collected and 14 treated, as appropriate, to meet applicable regulatory standards. Residual flushing additives in 15 the soil may be a concern and should be evaluated on a site-specific basis. The duration of soil 16 flushing process is generally short- to medium-term. 17

Figure 1-5 Soil Flushing System Schematic 18

19



1.5.8 Soil Vapor Extraction / Air Sparging / Air Stripping / In-well air stripping 1

Vapor phase partitioning technologies can actively volatilize fuels, solvents, and other volatile 2 organic chemicals from contaminated soil and groundwater. All of these technologies require 3 wells or vents installed in the ground, pumps for removing the vapors, and treatment systems for 4 the extracted gases. 5

Soil vapor extraction is an in situ unsaturated (vadose) zone soil remediation technology in 6 which a vacuum is applied to the soil to induce the controlled flow of air and remove volatile and 7 some semivolatile contaminants from the soil. The extracted soil gas pumped from the soil 8 receives downstream treatment to recover or destroy the contaminants as shown in Figure 1-6. 9

Vents placed in the contaminated soil can be placed vertically and/or horizontally to maximize 10 contact with the contamination. Vertical extraction vents are typically used at depths of 1.5 11 meters (5 feet) or greater and have been successfully applied as deep as 91 meters (300 feet). 12 Horizontal extraction vents (installed in trenches or horizontal borings) can be used as warranted 13 by contaminant zone geometry, drill rig access, or other site-specific factors. On the soil surface, 14 geomembrane covers are often placed over soil surface to prevent short circuiting and to increase 15 the radius of influence of the wells. 16

Figure 1-6 Soil Vapor Extraction System Schematic 17

18



1

Air sparging is an in situ technology in which air is injected through a contaminated aquifer. As 2 shown in Figure 1-7, injected air traverses horizontally and vertically in channels through the soil 3 column, creating an underground stripper that removes contaminants by volatilization. This 4 injected air helps to flush (bubble) the contaminants up into the unsaturated zone where a vapor 5 extraction system is usually implemented in conjunction with air sparging to remove the 6 generated vapor phase contamination. This technology is designed to operate at high flow rates 7 to maintain increased contact between ground water and soil and strip more ground water by 8 sparging. 9

Oxygen added to contaminated ground water and vadose zone soils can also enhance 10 biodegradation of contaminants below and above the water table. Air sparging has a medium to 11 long duration which may last, generally, up to a few years. 12

Figure 1-7 Air Sparging System Schematic 13

14



Air stripping involves the mass transfer of volatile contaminants from water to air. For ground 1 water remediation, this process is typically conducted in a packed tower or an aeration tank. The 2 typical packed tower air stripper, shown in Figure 1-8, includes a spray nozzle at the top of the 3 tower to distribute contaminated water over the packing in the column, a fan to force air 4 countercurrent to the water flow, and a sump at the bottom of the tower to collect 5 decontaminated water. Auxiliary equipment that can be added to the basic air stripper includes 6 an air heater to improve removal efficiencies; automated control systems with sump level 7 switches and safety features, such as differential pressure monitors, high sump level switches, 8 and explosion-proof components; and air emission control and treatment systems, such as 9 activated carbon units, catalytic oxidizers, or thermal oxidizers. Packed tower air strippers are 10 installed either as permanent installations on concrete pads or on a skid or a trailer. 11

Aeration tanks strip volatile compounds by bubbling air into a tank through which contaminated 12 waters flow countercurrent. A forced air blower and a distribution manifold are designed to 13 ensure air-water contact without the need for any packing materials. The baffles and multiple 14 units ensure adequate residence time for stripping to occur. Aeration tanks are typically sold as 15 continuously operated skid-mounted units. The advantages offered by aeration tanks are 16 considerably lower profiles (less than 2 meters or 6 feet high) than packed towers (5 to 12 meters 17 or 15 to 40 feet high) where height may be a problem, and the ability to modify performance or 18 adapt to changing feed composition by adding or removing trays or chambers. The discharge air 19 from aeration tanks can be treated using the same technology as for packed tower air discharge 20 treatment. 21

Figure 1-8 Air Stripping System Schematic 22

23



For In-well stripping, Figure 1-9, air is injected into a double screened well, lifting the water in 1 the well and forcing it out the upper screen. Simultaneously, additional water is drawn in the 2 lower screen. Once in the well, some of the VOCs in the contaminated ground water are 3 transferred from the dissolved phase to the vapor phase by air bubbles. The contaminated air 4 rises in the well to the water surface where vapors are drawn off and treated by a soil vapor 5 extraction system. 6

Figure 1-9 In-Well Air Stripping System Schematic 7

8



1.5.9 Chemical Oxidation / Incineration / Open Burning-Open Detonation 1

Chemical oxidation converts hazardous contaminants to non-hazardous or less toxic compounds 2 that are more stable, less mobile, and/or inert. The oxidizing agents most commonly used are 3 ozone, hydrogen peroxide, hypochlorites, chlorine, and chlorine dioxide. These oxidants have 4 been able to cause the rapid and complete chemical destruction of many toxic organic chemicals; 5 other organics are amenable to partial degradation as an aid to subsequent bioremediation. In 6 general the oxidants have been capable of achieving high treatment efficiencies (e.g., > 90 7 percent) for unsaturated aliphatic (e.g., trichloroethylene [TCE]) and aromatic compounds (e.g., 8 benzene), with very fast reaction rates (90 percent destruction in minutes). Field applications, 9 like the example shown in Figure 1-10, have clearly affirmed that matching the oxidant and in 10 situ delivery system to the contaminants of concern and the site conditions is the key to 11 successful implementation and achieving performance goals. 12

Figure 1-10 Chemical Oxidation System Schematic 13

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Incineration, illustrated in Figure 1-11, uses high temperatures, 870 to 1,200 °C (1,400 to 2,200 1 °F), to volatilize and combust (in the presence of oxygen) halogenated and other refractory 2 organics in hazardous wastes. Auxiliary fuels are usually required to initiate and sustain 3 combustion. The destruction and removal efficiency for properly operated incinerators exceeds 4 the 99.99% requirement for hazardous waste and can be operated to meet the 99.9999% 5 requirement for PCBs and dioxins. Off gases and combustion residuals generally require 6 secondary treatment. 7

Figure 1-11 Incineration System Flow Chart 8

9

Open Burn (OB) and Open Detonation (OD) operations may occur if munitions are 10 encountered. In accordance the Disposal of Munitions and Other Explosive Material Document 11 of Environmental Protection, any discovered explosives become the responsibility of the 12 Kwajalein Bomb Disposal team. These trained Explosive Ordnance Disposal (EOD) technicians 13 are contacted immediately for safe removal and disposition. The EOD team will make a 14 determination as to whether explosives can be removed from the site of discovery. Munitions 15 items include, but are not limited to, fireworks, flares and small arms rounds.1 16

1 Document of Environmental Protection (DEP-01-001.1). Activity: Disposal of Munitions and Other Explosive Material. January 2003.



1.5.10 Composting / Landfarming 1

Composting is a controlled biological process by which organic contaminants are converted by 2 microorganisms (under aerobic and anaerobic conditions) to innocuous, stabilized byproducts. 3 Typically, thermophilic conditions (54 to 65 °C) must be maintained to properly compost soil 4 contaminated with hazardous organic contaminants. The increased temperatures result from heat 5 produced by microorganisms during the degradation of the organic material in the waste. In most 6 cases, this is achieved by the use of indigenous microorganisms. 7

Operationally, the soils are excavated and mixed with bulking agents and organic amendments, 8 such as wood chips, animal, and vegetative wastes, to enhance the porosity of the mixture to be 9 decomposed. Maximum degradation efficiency is achieved through maintaining oxygenation 10 (e.g., daily windrow turning), irrigation as necessary, and closely monitoring moisture content, 11 and temperature. 12

There are three process designs used in composting: aerated static pile composting (compost is 13 formed into piles and aerated with blowers or vacuum pumps), mechanically agitated in-vessel 14 composting (compost is placed in a reactor vessel where it is mixed and aerated), and windrow 15 composting (compost is placed in long piles known as windrows and periodically mixed with 16 mobile equipment) (Figure 1-12). Windrow composting is usually considered to be the most 17 cost-effective composting alternative. Meanwhile, it may also have the highest fugitive 18 emissions. If VOC or SVOC contaminants are present in soils, off-gas control may be required. 19

Figure 1-12 Composting System Flowchart 20

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Landfarming (Figure 1-13) is a full-scale bioremediation technology, which usually 1 incorporates liners and other methods to control leaching of contaminants, which requires 2 excavation and placement of contaminated soils, sediments, or sludges. Contaminated media is 3 applied into lined beds and periodically turned over or tilled to aerate the waste. 4

Soil conditions are often controlled to optimize the rate of contaminant degradation. Conditions 5 normally controlled include: 6

Moisture content (usually by irrigation or spraying). 7 Aeration (by tilling the soil with a predetermined frequency, the soil is mixed and aerated). 8 pH (buffered near neutral pH by adding crushed limestone or agricultural lime). 9 Other amendments (e.g., Soil bulking agents, nutrients, etc.). 10

Contaminated media is usually treated in lifts that are up to 18 inches thick. When the desired 11 level of treatment is achieved, the lift is removed and a new lift is constructed. It may be 12 desirable to only remove the top of the remediated lift, then construct the new lift by adding 13 more contaminated media to the remaining material and mixing. This serves to inoculate the 14 freshly added material with an actively degrading microbial culture, and can reduce treatment 15 times. 16

Figure 1-13 Landfarming System Schematic 17

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1.5.11 Dual Phase Extraction / Bioslurping 1

Groundwater extraction technologies provide short- and long-term response options for 2 groundwater with separate phase contamination. In short-term applications, the separate phase 3 extraction technologies can draw down and remove significant amounts of floating product as an 4 emergency response or interim removal action. In longer-term applications, these technologies 5 can provide continuous product removal with other treatment systems promote groundwater 6 restoration. 7

Dual-phase extraction (DPE), also known as multi-phase extraction, vacuum-enhanced 8 extraction, or sometimes bioslurping (as shown in Figure 1-14), is a technology that uses a high 9 vacuum system to remove various combinations of contaminated ground water, separate-phase 10 petroleum product, and hydrocarbon vapor from the subsurface. Extracted liquids and vapor are 11 treated and collected for disposal, or re-injected to the subsurface (where permissible under 12 applicable state laws). 13

In DPE systems for liquid/vapor treatment, a high vacuum system is utilized to remove liquid 14 and gas from low permeability or heterogeneous formations. The vacuum extraction well 15 includes a screened section in the zone of contaminated soils and ground water. It removes 16 contaminants from above and below the water table. The system lowers the water table around 17 the well, exposing more of the formation. Contaminants in the newly exposed vadose zone are 18 then accessible to vapor extraction. Once above ground, the extracted vapors or liquid-phase 19 organics and ground water are separated and treated. DPE for liquid/vapor treatment is generally 20 combined with bioremediation, air sparging, or bioventing when the target contaminants include 21 long-chained hydrocarbons. Use of dual phase extraction with these technologies can shorten the 22 cleanup time at a site. It also can be used with pump-and-treat technologies to recover ground 23 water in higher-yielding aquifers. 24

Figure 1-14 Dual Phase Extraction System Flow Chart 25

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Bioslurping is the adaptation and application of vacuum-enhanced dewatering technologies to 1 remediate hydrocarbon-contaminated sites. Bioslurping, shown in Figure 1-15 utilizes elements 2 of both, bioventing and free product recovery, to address two separate contaminant media. 3 Bioslurping combines elements of both technologies to simultaneously recover free product and 4 bioremediate vadose zone soils. 5

Bioslurping can improve free-product recovery efficiency without extracting large quantities of 6 ground water. In bioslurping, vacuum-enhanced pumping allows LNAPL to be lifted off the 7 water table and released from the capillary fringe. This minimizes changes in the water table 8 elevation which minimizes the creation of a smear zone. Bioventing of vadose zone soils is 9 achieved by drawing air into the soil due to withdrawing soil gas via the recovery well. The 10 system is designed to minimize environmental discharge of ground water and soil gas. 11

When free-product removal activities are completed, the bioslurping system is easily converted 12 to a conventional bioventing system to complete the remediation. Operation and maintenance 13 duration for bioslurping varies from a few months to years, depending on specific site conditions. 14

Figure 1-15 Bioslurping System Schematic 15

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1.5.12 Infiltration Galleries 1

Infiltration galleries provide a hybrid technology for and promote the passive removal of 2 separate phase soil and groundwater contamination. In construction and landscaping 3 applications, they are often referred to as “French drains” which are placed underground to 4 capture and divert groundwater in saturated areas. 5

For applications with LNAPL contamination, the infiltration gallery (shown in Figure 1-16) is a 6 network of large diameter perforated pipes installed horizontally in trenches straddling the 7 groundwater-vadose zone interface. These structures allow floating, separate phase LNAPL to 8 accumulate inside and facilitate collection with mechanical belt skimmers. The infiltration 9 gallery provides significantly greater surface contact with the free product and operates without 10 the need of pumps or extensive utility support. Removed product is collected and disposed, or 11 reused as fuel if appropriate. 12

Figure 1-16 Infiltration Galleries System Schematic 13

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1.5.13 Adsorption / Absorption 1

Adsorption mechanisms are generally categorized as either physical adsorption, chemisorption, 2 or electrostatic adsorption. Weak molecular attractions, such as Van der Waals forces, provide 3 the driving force for physical adsorption, while a chemical reaction forms a chemical bond 4 between the compound and the surface of the solid in chemisorption. Electrostatic adsorption 5 involves the adsorption of ions through Coulombic forces, and is normally referred to as ion 6 exchange, which is addressed separately in the ion exchange modules. 7

The most common adsorbent is granulated activated carbon (GAC), commercially available in 8 canisters and drums. Other natural and synthetic adsorbents include activated alumina, forage 9 sponge, lignin adsorption, sorption clays, and synthetic resins. 10

Liquid phase carbon adsorption is a full-scale (shown in the illustration in Figure 1-17) in which 11 groundwater is pumped through one or more vessels containing activated carbon to which 12 dissolved organic contaminants adsorb. When the contaminant loading exceeds the adsorption 13 capacity of the material, the carbon is replaced and regenerated at an off-site facility; or simply 14 disposed. 15

Figure 1-17 Adsorption / Absorption System Schematic 16

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The two most common reactor configurations for carbon adsorption systems are the fixed bed 1 and fluid bed. The fixed-bed configuration is the most widely used for adsorption from liquids. 2 Pretreatment for removal of suspended solids from streams to be treated is an important design 3 consideration to prevent clogging. When blinding occurs, the accumulated solids must be 4 removed, for example, by backwashing. The solids removal process creates adsorber downtime 5 and may result in carbon loss and disruption of the mass transfer zone. 6

Due to the intense maintenance requirement, the duration of a GAC-based treatment system is 7 usually short-term; however, if concentrations are low enough, the duration may be long-term. 8 The duration of operation and maintenance is dependent on contaminant type, concentration, and 9 volume; regulatory cleanup requirements; and metal concentrations. 10

1.5.14 Thermal Desorption 11

Thermal desorption is a physical separation process and is not designed to destroy organics. 12 Wastes are heated to volatilize water and organic contaminants. As depicted in Figure 1-18, a 13 carrier gas or vacuum system transports volatilized water and organics to the gas treatment 14 system. The bed temperatures and residence times designed into these systems will volatilize 15 selected contaminants but will typically not oxidize them. 16

Two common thermal desorption designs are the rotary dryer and thermal screw. Rotary dryers 17 are horizontal cylinders that can be indirect- or direct-fired. The dryer is normally inclined and 18 rotated. For the thermal screw units, screw conveyors or hollow augers are used to transport the 19 medium through an enclosed trough. Hot oil or steam circulates through the auger to indirectly 20 heat the medium. All thermal desorption systems require treatment of the off-gas to remove 21 particulates and contaminants. Particulates are removed by conventional particulate removal 22 equipment, such as wet scrubbers or fabric filters. Contaminants are removed through 23 condensation followed by carbon adsorption, or they are destroyed in a secondary combustion 24 chamber or a catalytic oxidizer. Many of these units are transportable. 25



Figure 1-18 Thermal Desorption System Flow Chart 1

2

1.5.15 Containment Barriers / Stabilization 3

Physical barriers (or slurry walls) are used to contain contaminated ground water, divert 4 contaminated ground water from the drinking water intake, divert uncontaminated ground water 5 flow, and/or provide a barrier for the ground water treatment system (Figure 1-19). 6

These subsurface barriers consist of a vertically excavated trench that is filled with slurry. The 7 slurry hydraulically shores the trench to prevent collapse and forms a filter cake to reduce ground 8 water flow. Slurry walls often are used where the waste mass is too large for treatment and 9 where soluble and mobile constituents pose an imminent threat to a source of drinking water. 10

Slurry walls are a full-scale technology that have been used for decades as long-term solutions 11 for controlling seepage. They are often used in conjunction with capping. The technology has 12 demonstrated its effectiveness in containing greater than 95% of the uncontaminated ground 13 water; however, in contaminated ground water applications, specific contaminant types may 14 degrade the slurry wall components and reduce the long-term effectiveness. 15

Most slurry walls are constructed of a soil, bentonite, and water mixture. The bentonite slurry is 16 used primarily for wall stabilization during trench excavation. A soil-bentonite backfill material 17 is then placed into the trench (displacing the slurry) to create the cutoff wall. Walls of this 18 composition provide a barrier with low permeability and chemical resistance at low cost. Other 19 wall compositions, such as cement/bentonite, pozzolan/bentonite, attapulgite, organically 20 modified bentonite, or slurry/geomembrane composite, may be used if greater structural strength 21 is required or if chemical incompatibilities between bentonite and site contaminants exist. 22



Slurry walls are typically placed at depths up to 30 meters (100 feet) and are generally 0.6 to 1.2 1 meters (2 to 4 feet) in thickness. Installation depths over 30 m (100 ft) are implementable using 2 clam shell bucket excavation, but the cost per unit area of wall increases by about a factor of 3 three. 4

The most effective application of the slurry wall for site remediation or pollution control is to 5 base (or key) the slurry wall 0.6 to 0.9 meters (2 to 3 feet) into a low permeability layer such as 6 clay or bedrock, as shown in the preceding figure. This "keying-in" provides for an effective 7 foundation with minimum leakage potential. 8

An alternate configuration for slurry wall installation is a "hanging" wall in which the wall 9 projects into the ground water table to block the movement of lower density or floating 10 contaminants such as oils, fuels, or gases. Hanging walls are used less frequently than keyed-in 11 walls. 12

Figure 1-19 Physical / Reactive Barrier System Schematic 13

14

Solidification/stabilization (S/S) technologies, physically bind or enclose contaminants within a 15 stabilized mass (solidification), or chemical reactions are induced between the stabilizing agent 16 and contaminants to reduce their mobility (stabilization). Ex situ S/S typically requires disposal 17 of the resultant materials. Often, the stabilized materials can be replaced on site. 18

There are many innovations in the stabilization and solidification technology. Most of the 19 innovations are modifications of proven processes and are directed to encapsulation or 20 immobilizing the harmful constituents and involve processing of the waste or contaminated soil. 21 Nine distinct innovative processes or groups of processes include: (1) bituminization, (2) 22



emulsified asphalt, (3) modified sulfur cement, (4) polyethylene extrusion, (5) pozzolan / 1 Portland cement, (6) radioactive waste solidification, (7) sludge stabilization, (8) soluble 2 phosphates, and (9) vitrification / molten glass. Typical ex situ S/S is a short- to medium-term 3 technology. 4

1.5.16 Phytoremediation 5

Phytoremediation is a process that uses plants to remove, transfer, stabilize, and destroy 6 contaminants in soil and sediment. The concept is illustrated in Figure 1-20. This technology is 7 applied as a follow-up method because it has the capability to reduce soil petroleum 8 contamination to lower levels than other types of remedial technologies. The mechanisms of 9 phytoremediation include enhanced rhizosphere biodegradation, phyto-extraction (also called 10 phyto-accumulation), phyto-degradation, and phyto-stabilization. 11

Enhanced rhizosphere biodegradation takes place in the soil immediately surrounding plant 12 roots. Natural substances released by plant roots supply nutrients to microorganisms, which 13 enhances their biological activities. Plant roots also loosen the soil and then die, leaving paths 14 for transport of water and aeration. This process tends to pull water to the surface zone and dry 15 the lower saturated zones. 16

The most commonly used flora in phytoremediation projects are trees that can draw large 17 amounts of water as it passes through soil or directly from an aquifer. This may draw greater 18 amounts of dissolved pollutants from contaminated media and reduce the amount of water that 19 may pass through soil or an aquifer, thereby reducing the amount of contaminant flushed though 20 or out of the soil or aquifer. 21

Phyto-accumulation is the uptake of contaminants by plant roots and the 22 translocation/accumulation (phytoextraction) of contaminants into plant shoots and leaves. 23

Phyto-degradation is the metabolism of contaminants within plant tissues. Plants produce 24 enzymes, such as dehalogenase and oxygenase, which help catalyze degradation. Investigations 25 are proceeding to determine if both aromatic and chlorinated aliphatic compounds are amenable 26 to phyto-degradation. 27

Phyto-stabilization is the phenomenon of production of chemical compounds by plants to 28 immobilize contaminants at the interface of roots and soil. 29



Figure 1-20 Phytoremediation 1

2

3

1.5.17 Offsite Disposal 4

All contaminated materials will be managed in accordance with the established procedures 5 USAKA uses for waste/equipment disposal. Waste from PCB contaminated materials, will be 6 containerized onsite in bulk bags, sampled for characterization analysis, loaded into shipping 7 containers, and backhauled to a licensed disposal facility in the United States. Specifically, 8 materials will be barged to the United States; and then to an approved PCB waste disposal 9 facility. 10

1.6 CURRENT SITES 11

1.6.1 KWAJ001-Kwajalein Harbor 12

The Kwajalein Harbor site consists of the stormwater drainage basis that flow into the harbor. 13 The drainage basins are a possible source of the PCBs/pesticides found in fish tissue. Kwajalein 14 Harbor and storm drains are located on the lagoon side of Kwajalein Island (Figure 1-21) directly 15 inland from Echo Prier. This location has been the primary embarkation point for barges and 16 ships for all of the islets in the Kwajalein Atoll since the U.S. military assumed control of the 17 atoll in 1944. 18

During the last several decades, human activities and industrial processes have contributed to 19 contaminants entering the harbor. The corrosive environment at Kwajalein necessitates routine 20 sandblasting to remove rust from equipment; previous investigations indicate that sandblasting 21 activities at the dry dock, the former vehicle paint and preparation shop and sandblasting right at 22 Echo Pier provide the primary source of contamination into the harbor (U.S. Army 23 Environmental Hygiene Agency (USAEHA), 1991). Marine vessel coatings contain copper, 24 butyltins, and/or pesticides (as antifouling agents), lead (as a stabilizer), and PCBs (as a 25



component of coatings). Additionally, contaminants are suspected to migrate to the harbor via 1 wind and nonpoint-source runoff. 2

Figure 1-21 Kwajalein Harbor Site Areas 3

4



The goal of the proposed actions is to eliminate onshore contamination from continuing to 1 accumulate in the harbor. The harbor sediments contain metals (chromium, lead, copper, and 2 zinc), PCBs and pesticides. PCBs and pesticides have been detected in limited sections of the 3 Kwajalein islet stormwater basins and stormwater discharge may be contributing to the 4 contamination of harbor sediments. 5

Sampling of the accumulated soil and materials in storm drains that discharge to the harbor 6 indicate low levels of previously detected contaminants across the entire drainage. Only one 7 drain discharge (SW05) had detections that exceed UES standards; the affect portion of the drain 8 is immediately adjacent to the former power plant at Building 803. The proposed action is to 9 remove accumulated soils and materials that are in this storm drain to prevent ongoing transport 10 and discharge into the harbor. 11

1.6.2 KWAJ003-Roi-Namur POL Yard 12

The Roi-Namur POL Yard Spill Site is the POL storage area for the power plant that includes 13 two diesel fuel aboveground storage tanks (ASTs) (Facilities 8046 and 8047). This site as shown 14 in Figure 1-22 is located at the middle of the south side of the island. 15

A large diesel fuel release of approximately 22,500 gallons occurred at one of the ASTs on 16 January 30, 1996. The 350,000-gallon AST #8047 was overfilled and there was no secondary 17 containment around the petroleum, oil and lubricants (POL) tanks (Raspiller, 1998). The fuel 18 release occurred at the overflow pipe at the base of the tank. Emergency response teams and 19 follow up recovery activities (skimming operations from trenches and sumps) yielded 20 approximately 75 % of the spill volume. 21

Prior to this fuel release there were several sites of potential environmental contamination 22 identified; an unlined oil/solvent storage pit to the south of the POL storage tanks, and a wash 23 rack discharge ditch to the north and east of the POL storage tanks (USAHEA, 1991). 24 Contamination is concentrated around the tanks, with the groundwater contamination plume 25 extending into the lagoon and covering an area of approximately 216,500 square feet. 26

The measurable quantities of contamination exists inside an area of approximately 150,000 27 square feet around the fuel tanks. Contamination is primarily along the top of groundwater 28 within this area. 29

Proposed remedial technologies for the Roi-Namur POL Yard Spill Site include infiltration 30 galleries to collect and remove fuel that exists in the soil as a LNAPL, followed by biosparging 31 to treat residual groundwater and soil contamination in situ. Soil removed during installation of 32 injection wells and extraction trenches will be treated by landfarming. 33



Figure 1-22 Roi Power Plant 1

2



1.6.3 KWAJ004-Carlos Power Plant 1

The Carlos Power Plant generated power for telemetry stations located on Carlos Island as 2 shown in Figure 1-23. Beginning in October 2011, the plant is no longer operational. USAKA 3 control is limited to roughly the middle third of the island and the site is located near the center 4 of the USAKA control area. 5

Petroleum contamination was discovered during an excavation project in the area. Sivuniq 6 performed a site investigation and detected soil and groundwater contamination, and that the 7 ASTs are the source (Sivuniq, 2011). This risk of exposure for inhalation is the primary driver 8 for site cleanup. 9

Figure 1-23 Carlos Power Plant 10

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The proposed remedial activity is a removal action of contaminated soils. The soils will be 1 treated using landfarming techniques at a proposed facility on Kwajalein. 2

1.6.4 KWAJ005-Kwajalein PCB Vaults 3

Electrical equipment at several transformer “vaults” on Kwajalein Island leaked PCB-containing 4 fluids. Although response actions at these locations removed fluids and, in some cases, 5 contaminated concrete, the effectiveness of the efforts was not well documented. These sites 6 may be contributing to the Kwajalein Harbor sediment contamination. The sites, identified by the 7 associated building numbers, include Buildings 713, 803, 1011, and 1017 are shown in Figure 8 1-24. 9

Figure 1-24 Kwajalein PCB Vaults 10

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1.6.4.1 Building 713 12

Facility number (FN) 713 was constructed in 1953 on the eastern side of Kwajalein Island, 13 located at the northeast corner of Supply Road and 8th Street (Figure 1-24) and was used as a 14



power transformer substation. Demolition of the 187 square foot building sometime shortly 1 before 2004 left this site vacant. 2

Historical reports document PCB contamination in soils and groundwater. The transformer, 3 vault, and all associated electrical equipment were removed during demolition activities (KRS, 4 2004). A former electrical transformer located within an electrical vault leaked approximately 4 5 pounds (lbs) of PCB-containing dielectric fluid to the concrete floor of the vault in June 1991. 6 An additional release from a ruptured discharge line of approximately 0.8 lbs of PCBs occurred 7 in 1991 while draining the transformer prior to removing it from the vault on September 13, 8 1991. Transformer fluids sprayed onto the vault’s ceiling, into the discharge pump housing, and 9 onto the floor of the vault (RSE, 2001). 10

A 1992 response effort was conducted by cleaning (using diesel fuel as a solvent) and later 11 removing a section of the concrete flooring (55 inches by 104 inches) of the vault. The impacted 12 soil beneath the flooring was excavated to the hard coral base at approximately 3 feet below 13 ground surface (bgs) (to groundwater), eventually extending under the existing flooring at the 14 west wall of the vault. RSE performed additional soil removal (1 cubic yard [CY]) in 1995 15 (RSE, 2001), and again in 1998. Sampling conducted in 2000 showed PCB concentrations that 16 were below the UES cleanup level, but the water beneath the vault exceeded the UES primary 17 standard. The vault is not in the area of groundwater withdrawl. 18

Sampling results during a 2011 site investigation found PCBs detections in soil borings at 19 concentrations ranging from 0.0236 mg/kg to 9.54 mg/kg. Based on UES requirements, further 20 action is needed to address exceedences above 1.0 mg/kg. 21

The proposed remediation is to excavate soils with PCB contamination concentrations above 1.0 22 mg/kg. Excavated materials will be disposed of at an approved, off-site disposal facility. 23

1.6.4.2 Building 803 24

Building 803 shown in Figure 1-24 is near the corner of 9th and Lagoon Street and currently 25 used as a vehicle maintenance facility. The facility was a former power plant with a switchgear 26 maintenance shop. 27

PCB transformers and equipment were stored and maintained at the facility in the 1970s. In 28 1992, one of the transformers leaked approximately 40 milliliters (ml) of PCB containing fluids. 29 Previous results indicate PCBs in concrete at the site. 30

The 2011 site investigation confirmed that the concrete floor has PCB contamination levels 31 exceeding UES criteria (Sivuniq, 2011). Solid samples collected from the concrete floor and two 32 below grade concrete utility corridor vaults within the building contained PCB concentrations 33 above UES screening standards. Potentially associated with this contamination, materials in 34



three storm drain catch basins immediately east, southeast, and southwest of facility number 1 (FN) 803 also contained actionable quantities of PCBs. 2

The proposed remedy involves removing the contaminated concrete inside the building and 3 utility corridors and PCB-contaminated materials adjacent to the indicated storm drains. All 4 PCB contaminated materials will be contained, hauled off-island by registered carrier, and 5 disposed at an appropriate facility in the United States. 6

1.6.4.3 Building 1011 7

Building 1011, built in 1960, is located near the western end of the runway, just south of Lagoon 8 Road on Kwajalein Island. The building is currently used as the Range Safety Center. 9

The PCBs leaked from an apparent bad bushing on the transformer in 1995. The vault was listed 10 as requiring further remediation in the Annual USAKA Inventory of PCB Items and Equipment 11 (KRS, 2004a). The USAKA Environmental Office PCB spill events summary notes that wipe 12 results were greater than 500 parts per million (ppm) before cleanup, and 7.1 micrograms per 13 100 square centimeters (µg/100 cm2) after decontamination activities occurred. 14

During the 2011 sampling, three of six wipe samples within that area contained PCBs above the 15 10 µg/100 cm2 UES action level. 16

The proposed remedy involves removing the contaminated concrete identified inside the 17 building. All PCB contaminated materials will be contained, hauled off-island by registered 18 carrier, and disposed at an appropriate facility in the United States. 19

1.6.4.4 Building 1017 20

Building 1017, built in 1961, is located on the western end of Kwajalein Island near the terminus 21 of Lagoon Road (Figure 1-24). The building is currently used for communications. Reports of 22 leaked transformer oils were not secured during records review, but the USAKA Environmental 23 Office PCB spill events summary notes indicate 350,000 ppm PCBs were detected at this site. 24

Concrete wipe and concrete chip samples collected in 2011 and 2012 identified and delineated 25 the extent of PCB contamination; results show concentrations of PCBs above the UES screening 26 criteria in 13 of the 15 samples. 27

The proposed remedy involves removing the contaminated concrete identified inside the 28 building. All PCB contaminated materials will be contained, hauled off-island by registered 29 carrier, and disposed at an appropriate facility in the United States. 30



1.6.5 KWAJ006-Kwajalein Tank Farm 1

The Kwajalein Tank Farm, location shown in Figure 1-25, occupies a 13-acre area northwest of 2 the end of the runway between Lagoon Road and Marine Road, on Kwajalein Islet. The 3 Kwajalein Tank Farm includes two distinct areas: a main facility with 13 ASTs, and a smaller 4 area that includes four abandoned ASTs. Lined dikes provide secondary containment for the bulk 5 fuel storage, and all tanks have inventory gauging and leak detection equipment. 6

Figure 1-25 Kwajalein Tank Farm 7

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In 2011, a site investigation revealed significant soil and groundwater contamination. Diesel 1 range organics (DRO) and gasoline range organics (GRO) both exceeded applicable screening 2 criteria in soil and groundwater. In soil, the polycyclic aromatic hydrocarbon (PAH) compounds 3 benzo(a)pyrene, benzo(g,h,i)perylene, and dibenz(a,h)anthracene also exceeded screening levels. 4 In groundwater, benzene and naphthalene were also above UES maximum contaminant levels. 5 A DRO-to-GRO ratio evaluation indicates there are three distinct plumes at the site: West of the 6 Equipment Yard Area, Main Fuel Farm Area, and Four Abandoned ASTs Area. 7

Removing any mobile, free-phase oil is a first step to cleaning the groundwater at the site. 8

The proposed initial phase removes oil product through bioslurping at the Main Fuel Farm and 9

the area immediately to the south around the Four Abandoned ASTs (Figure 1-26). During this 10

phase, enhancements (vacuum, forced air, and/or biosurfactants produced by indigenous 11

organisms) may be used to promote effectiveness. The proposed process uses approximately 20 12

injection/sparging wells in a high-density spacing around the perimeter of the source area. If 13

successful, enhancements will then be deployed and implemented at the rest of the site. 14

Figure 1-26 Kwajalein Tank Farm Bioslurping Well Conceptual Layout 15

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1.6.6 KWAJ008-Roi–Namur Drinking Water Well 8151 1

Drinking Water Well 8151 is located northwest of the Roi-Namur runway, between the runway 2 and Speedball Road, shown in Figure 1-27. 3

Figure 1-27 Roi-Namur Drinking Water Well 8151 4

5

The well, fed by a number of horizontal infiltration pipes in the freshwater lens, is impacted with 6 solvents including tetrachloroethene (PCE), trichloroethene (TCE), and isomers of 7 dichloroethene (DCE). Historically, the PCE and TCE concentrations at the 8151 site exceeded 8 drinking water standards by a factor of three (USAEHA, 1991). This well is unused because of 9 the solvent contamination. Groundwater restoration would enable reuse of this well. 10



During the 2011 site investigation, soil samples showed only benzene as a potential chemical of 1 concern; it was detected in 2 of 15 soil samples above screening levels. The groundwater 2 samples provided detections of PCE and TCE, but only one TCE detection exceeded the U.S. 3 Army Kwajalein Atoll Environmental Standard for drinking water. 4

Although the detected levels of solvent make this site a candidate for monitored natural 5 attenuation, proposed remediation using air stripping remediation technologies enable 6 accelerated restoration of this aquifer. 7

1.6.7 KWAJ009-Gagan Power Plant Fuel Spill 8

The power plant site (Figure 1-28), is on Gagan Islet, just inland from the harbor. In 2006, a 9 pressure gauge ruptured at the generator building on Gagan Island (Facility 7510) causing the 10 release of approximately 5,000 gallons of diesel fuel. Subsequent emergency response actions 11 removed and treated, through landfarming, approximately 60 cubic yards (CY) of contaminated 12 soil. 13

Figure 1-28 Gagan Power Plant 14

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In November 2010, Sivuniq performed a site investigation to evaluate impacts near the generator 1 building and landfarm area, and to support the assessment of the various remedial options. 2

There are currently localized amounts of petroleum residues immediately adjacent to the 3 generator building from the 2006 spill, containing diesel-range organic compounds. The area 4 surrounding the former landfarm also shows hydrocarbon contamination. 5

The proposed action is to excavate contaminated soils and barge them to an authorized 6 landfarming treatment area on Roi-Namur. 7

1.7 PROJECT PROCEDURES 8

All remedial projects that meet the criteria of a Phase III remedial action within the eleven (11) 9 islets throughout USAK are covered by this NPA; Kwajalein, Roi-Namur, Meck, Illeginni, 10 Ennylabegan, Legan, Gagan, Gellinam, Omelek, Eniwetak, and Ennugarret. Projects that 11 utilized a technology described in this NPA, do not involve a discharge to the marine 12 environment except through an approved wastewater treatment facility, do not affect species of 13 concern, and are potentially covered by this NPA. These projects are subject to USAKA and 14 UES agency approval. 15

1.8 PROJECTS NOT COVERED. 16

Projects that utilize technologies, contaminates, or locations not identified in the NPA. Projects 17 that may affect species of concern or a direct discharge to the marine environment are not 18 covered by this NPA. 19

1.9 NEPA DOCUMENTATION 20

The public and regulatory interaction process in the UES restoration procedures is equivalent to 21 and approved as satisfying the NEPA requirement. 22

2.0 DESCRIPTION OF ACTIVITY ENVIRONMENTAL SETTING 23

2.1 LAND AND REEF AREA 24

The Kwajalein Atoll is located in western chain of the Marshall Islands in the West Central 25 Pacific Ocean, just west of the international dateline. It is 2,100 nautical miles southwest of 26 Honolulu, Hawaii and approximately 4,200 nautical miles southwest of San Francisco, 27 California. Less than 700 miles north of the equator, Kwajalein is in the latitude of Panama and 28 the southern Philippines, and in the longitude of New Zealand (2,300 miles south), and the 29 Kamchatka Peninsula of the former Soviet Union (2,600 miles north). 30



Kwajalein Atoll is a coral reef formation in the shape of a crescent loop enclosing a lagoon. The 1 approximately 100 small islands share a total land area of 5.6 square miles (mi2). The largest 2 islands are Kwajalein (1.2 mi2), Roi-Namur (0.6 mi2), and Ebadon at the extremities of the atoll; 3 together they account for nearly half the total land area. While the “typical” size of the remaining 4 islands may be about 450 feet by 2,100 feet, the smallest islands are no more than sand cays that 5 merely break the water's surface at high tide. 6

The Kwajalein Atoll lagoon enclosed by the reef is the world’s largest, with a surface area of 902 7 mi2, and a depth that is generally between 120 feet to 180 feet (Sugerman, 1972). One notable 8 characteristic of the atolls is the steep slopes of the mounts seaward of the reef. Around 9 Kwajalein Atoll the depth plunges to as much as 6,000 feet within 2 miles, and 13,200 feet 10 within 10 miles. 11

2.2 GEOLOGY 12

Coral atolls are seamounts that have been capped by calcareous marine growth constructed by 13 lime-secreting organisms (coral polyps and algae). The lower parts of atolls are composed of 14 noncalcareous rocks, most often volcanic materials. The overlying coral superstructures may be 15 hundreds or even thousands of feet thick. Emergent portions of the reef and islands tend to be 16 composed of loose, poorly consolidated calcareous materials derived from foraminifera, coral, 17 shells, and marine algae, or their debris resulting from destructive action of the elements. All of 18 the islands that comprise the atoll are relatively flat with few natural points exceeding 15 feet 19 above mean sea level (msl) (Sugerman, 1972). 20

The detailed geology of Kwajalein Atoll is primarily based on shallow boring logs prepared by 21 the U.S. Army Corps of Engineers (USACE) and drilling logs prepared during the construction 22 of monitoring wells by the U.S. Geological Survey (USGS) (Hunt, 1995). 23

Soils on Kwajalein Atoll mainly consist of unconsolidated, reef-derived calcium carbonate sand 24 and gravel with minor consolidated layers of coral, sandstone, and conglomerate. Core samples 25 and drilling logs at Kwajalein Island indicate mostly unconsolidated carbonate sediments down 26 to 111.5 feet bgs. The lagoon side of the island consists of unconsolidated sediments that are 27 thicker and contain a greater proportion of low-permeability back-reef sand than the ocean side. 28 Drilling logs suggest a greater proportion of coarse, high-permeability rubble on the ocean side 29 (Hunt, 1995). 30

2.3 HYDROGEOLOGY 31

The thick accumulation of limestone layers, unconformities caused by sea level changes over 32 time, and tidal activity play an important role in the fresh groundwater dynamics. Groundwater is 33 very shallow throughout the atoll; a thin freshwater lens lies atop the brackish groundwater on 34 the largest islands, including Kwajalein and Roi-Namur. Freshwater lens thickness is generally 35



proportional to island width and rate of groundwater recharge, and inversely proportional to 1 hydraulic conductivity (Hunt, 1995). 2

3.0 ENVIRONMENTAL AREAS POTENTIALLY AFFECTED BY PROPOSED 3 ACTIVITY 4

3.1 AIR QUALITY 5

Bioslurping, biosparging, landfarming, air stripping, and enhanced bioremediation all may 6 produce limited quantities of contamination into the air. Bioslurping, proposed for the Kwajalein 7 fuel farm, involves vacuuming up free product and groundwater and produce exhaust air. 8

Biosparging and landfarming are forms of bioremediation that are proposed for sites requiring 9 petroleum remediation on Kwajalein, Roi Namur, Carlos and Gagan. 10

Air stripping technology variants are proposed for the Drinking Water Well 8151 on Roi-Namur. 11

3.2 WATER QUALITY AND REEF PROTECTION 12

Groundwater extraction, biosparging, infiltration trenches, and landfarming are anticipated to 13 create some discharge water. In all cases the run-off is collected, tested, and treated and will not 14 be released until it meets UES water quality standards. Any discharged waters will be through 15 current wastewater treatment facilities. 16

Infiltration trenches allow for the exposure of NAPL for skimming purposes. This is part of an 17 overall groundwater treatment process. All collected NAPL will be properly contained and if 18 feasible, utilized for energy recovery. 19

No activities will be conducted in or immediately adjacent to any shoreline. 20

3.3 MATERIAL AND WASTE MANAGEMENT 21

Remedial activities will potentially produce concrete and soil waste contaminated waste with 22 PCB, soils contaminated with petroleum products, and possibly GAC filters contaminated with 23 organic contaminants such as solvents and petroleum. All PCB and solvent contaminated 24 materials will be properly packaged and transported to an off-island disposal/treatment location. 25 Petroleum contaminated soils will be treated at the installation with authorized in-situ or ex-situ 26 techniques at an approved location. 27

3.4 CULTURAL RESOURCES 28

Bioslurping, biosparging, landfarming (excavation of material to be farmed), and enhanced 29 bioremediation on “original island” lands have the potential for inadvertent discoveries and 30



significant impact to cultural resources. The identified technologies for activities within fill or 1 profoundly disturbed areas have a reduced potential for both inadvertent discoveries and impact 2 to cultural resources. 3

4.0 ANALYSIS OF EFFECT OF ACTIVITY ON ENVIRONMENTAL AREAS IN 4 ABSENCE OF ENVIRONMENTAL CONTROLS 5

4.1 AIR QUALITY 6

Bioslurping, biosparging, landfarming, dual phase extraction, air stripping, low-temperature 7 thermal desorption, soil vapor extraction and enhanced bioremediation will volatize some 8 contaminants and while it is anticipated emissions will be within the UES air quality standards, 9 the potential exists for air emissions to exceed these standards without control. 10

4.2 WATER QUALITY AND REEF PROTECTION 11

Air stripping produces treated water that has to be re-introduced back into the environment; this 12 qualifies it as a discharge from a process. Without controls in the form of testing, treated water 13 prior to sending it to a water treatment facility, the potential for exceeding the UES or DEP 14 discharge requirements exists. Produced treated water that meets standards will be either re-15 injected back into the ground, used for irrigation of the golf course, or treated and discharged 16 through the water treatment facility. If necessary, water will be filtered through granulated active 17 carbon (GAC) filter to remove any residual contamination prior to discharge. 18

The landfarming process produces leachate, which will be re-applied to the landfarm or 19 transferred to a wastewater treatment facility. 20

No activities will be conducted in or immediately adjacent to any shoreline or will negatively 21 influence any reef environments and there will be no direct discharge to marine waters. 22

4.3 MATERIAL AND WASTE MANAGEMENT 23

Remediation of the PCB sites will produce PCB contaminated concrete and soil. Controls need 24 because the treatment of these materials on site is not allowed and to assure waste will be 25 properly containerized and shipped to an approved landfill that accepts PCB contaminated waste. 26

Air stripping and the use of GAC filters will create GAC filters containing solvents. This 27 material will be properly containerized and shipped to an approved facility. 28

Landfarming and infiltration trenches will produce POL free product. The free product will be 29 properly containerized and incinerated on site or, if feasible, utilized for energy recovery. 30



4.4 CULTURAL RESOURCES 1

All proposed remediation technologies requiring ground disturbance, especially in areas not 2 comprised of fill material, may lead to inadvertent discoveries and possible significant impact to 3 cultural resources. 4

5.0 TECHNICAL DESCRIPTION AND ANALYSIS OF ENVIRONMENTAL 5 CONTROLS USED IN ACTIVITY 6

5.1 GENERAL CONTROLS FOR ALL REMEDIAL ACTIONS 7

5.1.1 Air Quality 8

Air discharges related to landfarming and biosparging are not anticipated to be at levels that 9 exceed UES (3-1) air quality standards. The proposed remediation processes will undergo an 10 examination in the pending Document of Environmental Protection to identify potential air 11 emissions issues, quantify emissions potential, and define air quality issues. The complexity of 12 the technologies, contaminants, and applications require specific remedial design standards, 13 control technologies and commensurate monitoring to verify integrity and attainment of UES 14 performance standards. 15

5.1.2 Water Quality and Reef Protection 16

All wastewaters produced directly by, or recovered indirectly at remediation systems 17 shall be subject to strict inventory and management controls from the moment of 18 collection to disposal. Generic inventory and management protocols shall include 19 collection logs, periodic inventory reconciliation, routine containment inspections, and 20 recordkeeping. Specific remediation system requirements are outlined in the pending 21 Document of Environmental Protection and the applicable remedial designs. 22

Produced waters from the air stripping process will be collected in holding tanks and 23 tested prior to discharge. Water meeting UES water quality standards will be beneficially 24 reused for irrigation or non-consumption purposes such as vehicle washing or dust 25 suppression. Water that does not meet UES water quality standards will be verified to 26 meet pretreatment standards and hauled for disposal at the wastewater treatment facility. 27 All primary and secondary discharges will meet UES Performance Standards (§3-2.5). 28

Landfarming is expected to be a zero discharge activity, as the system is operated beneath 29 a cover, and metabolic and physical processes promote evapotranspiration. Any 30 produced leachate or precipitation collected from the landfarm pad will be beneficially 31 used to augment landfarm operations. In the unlikely event that excess water is produced 32 and requires disposal, it will be tested to verify attainment of all pretreatment standards, 33 hauled, and discharged at the wastewater treatment facility. 34



All produced waters will be tested prior to discharge or release to the wastewater 1 treatment facility. Any wastewaters deemed unsuitable for discharge at the installation 2 wastewater treatment facility shall be managed as regulated waste and disposed 3 accordingly, at a permitted disposal facility. 4

Direct discharge to marine waters or surface impoundments are specifically prohibited. 5

5.1.3 Material and Waste Management 6

All collected PCB contaminated concrete, soil, and sediments will be properly 7 containerized and shipped to an off-site approved landfill for disposal/treatment. 8

All collected contaminated GAC filter material will be properly containerized and 9 shipped to an approved off-site disposal/treatment location. 10

All collected POL free-product will be properly containerized and incinerated on site 11 (Kwajalein), or if feasible, utilized for energy recovery. 12

5.1.4 Cultural Resources 13

Cultural resources are a concern at all sites requiring ground disturbing remedial technologies. 14

5.1.4.1 Controls 15

The following controls will be implemented to assure compliance pursuant to the UES and the 16 Document of Environmental Protection, Protection of Cultural Recourses, Nov 2004 to protect 17 any cultural resources that may be present: 18

All remedial actions will have an approved site-specific final remedial execution plan that 19 includes a site-specific archeological monitoring plan in compliance with the UES. 20

All personnel working on site will read and understand the approved site-specific 21 archeological monitoring plan in the final remedial execution plan. 22

Sites determined to have little probability of affecting cultural or historical resources, 23 based on results of previous archaeological monitoring in the area of the proposed 24 excavation, require no archaeological monitoring. 25

Sites or proposed technologies that may pose concerns for protecting and preserving 26 cultural and historical resources will have a qualified professional archaeologist 27 implement the requirements of the approved archeological monitoring plan. 28

5.1.4.2 Mitigation 29

Should artifacts, remains or any other archaeological resources be encountered, work will stop, 30 and the USAKA archaeologist will be notified (UES 3-7.5.7(a)). Controls applied will be in 31 accordance with the approved site remedial plan, UES, and the Protection of Cultural Resources 32 DEP. 33



6.0 DISPERSION MODEL FOR MODELING AIR SOURCES 1

Emissions will be controlled by process adjustments in accordance with the approved remedial 2 design plan and will create no significant stationary air emission sources (Sec 4.1 of this NPA). 3

At Drinking Water Well 8151 on Roi-Namur there is no potential that the air stripping (Section 4 1.5.7) to exceed standards as a major stationary source (UES 3-1.5.2(a)(1)) or will contribute 10 5 tons per year of any one substance or a combination of any substance that exceeds 25 tons per 6 year (UES 3.1.5.2(a)(3). Considering the low concentrations of solvents found, calculations 7 confirm that there is not sufficient volume of solvent at Roi-Namur Drinking Water Well 8151 8 Site to exceed standards pursuant to the UES. 9

A rough estimate of the emission potential uses the site investigation groundwater data and 10 physical characteristics of the 8151 site. Assuming an extreme worst-case impact of 200-foot 11 solvent plume (exaggerated extent), 15 foot thick freshwater lens, and constant (highest 12 measured) concentrations of PCE (2.65 µg/L) and TCE (5.45µg/L) inside this extent, a system 13 with 100% extraction efficiency produces only 320 lbs. and 600 lbs. of PCE and TCE, 14 respectively. Even if the remediation occurred over a (very short) 1-year period, the remediation 15 system would not qualify as a significant new stationary source emissions as these pollutant 16 masses are well below the 10 ton emissions threshold. 17

7.0 ANALYSIS OF WASTE DISCHARGE FOR POINT SOURCE WASTE 18 DISCHARGE TO WATER 19

Groundwater extraction, biosparging, infiltration trenches, and landfarming may produce some 20 discharge that is specifically addressed (Sec 5.1.2 of this NPA). No activities will be conducted 21 in or immediately adjacent to shorelines or negatively influence any reef environments, all 22 waters will meet standards pursuant to the UES prior to release to a current treatment facility, or 23 used in irrigation or groundwater recharge (Sec 4.2 and 5.1.2 of this NPA). 24

8.0 INFORMATION FOR HAZARDOUS WASTE TREATMENT, STORAGE, OR 25 DISPOSAL FACILITIES 26

The remediation process at several locations will produce PCB contaminated concrete, soil and 27 sediments. These items will be properly containerized and shipped to an off-island, approved 28 disposal facility. See sections 4.3 and 5.1.3 for more information. 29

The air stripping and wastewater treatment may produce waste granulated activated carbon filters 30 contaminated with chlorinated solvents (PCE, TCE, and DCE isomers). These filters will be 31 properly contained and shipped to an off-island, approved regeneration or disposal facility. See 32 sections 4.3 and 5.1.3 for more information. 33



The pending Document of Environmental Protection provides a detailed analysis of the waste 1 streams associated with each remediation technology proposal. The analysis breaks down the 2 processes, character, and classification of the waste streams, as well as the management 3 strategies. 4

9.0 BIOLOGICAL ASSESSMENT IF ENDANGERED RESOURCES MAY BE 5 AFFECTED 6

No endangered resources are anticipated to be affected by the proposed activities. Detailed 7 analysis of impacts are included in a pending Document of Environmental Protection. 8

10.0 INFORMATION ON RECEIVING-WATER QUALITY FOR WATER 9 DISCHARGES 10

Some proposed actions will create a discharge through the treatment of groundwater. All 11 produced waters from the proposed action will be collected, treated, and tested to meet UES 12 water quality standards as described in sections 4.2 and 5.1.2. No direct discharge to marine 13 waters will occur. 14

11.0 INFORMATION ON MARINE LIFE, CURRENTS, AND OTHER 15 CHARACTERISTICS OF OCEAN DISPOSAL SITE 16

None of the proposed remediation technologies include direct or secondary ocean disposal 17 activities. The pending Document of Environmental Protection provides a detailed examination 18 of the proposed remediation technologies and their implementation to assess any potential 19 indirect impacts associated with implementation. 20

12.0 INFORMATION ON MARINE LIFE AND ENVIRONMENT IN DREDGING OR 21 FILLING AREAS 22

Although one potentially applicable technology (dredging) is scoped within the excavation 23 technologies, no specific remedies under immediate consideration include this approach. The 24 Document of Environmental Protection provides full analysis of the dredging technology as 25 pertaining to remediation and assesses impacts to marine life and the associated environment. 26

13.0 SPECIES AND NUMBERS OF MIGRATORY BIRDS AND OTHER WILDLIFE 27 RESOURCES AND HABITATS THAT MAY BE TAKEN 28

During installation of remedial technologies, noise and human activity could displace any birds 29 that forage, feed, or nest within a short distance surrounding the activity. This period should be 30



short. Landfarm site selection considerations include locating activities away from sensitive and 1 critical habitats of migratory birds and other wildlife. All activities are in close proximately to 2 developed areas and once in place, will not be disruptive, no migratory bird species or other 3 wildlife resources are expected to be taken as a result of this activity. Although no known 4 nesting occurs in the project areas, personnel will be instructed to avoid all contact with any nest 5 that may be encountered. 6

14.0 NOTIFICATION 7

14.1 EMERGENCY ACTIONS 8

Within 24 hours of discovery of an emergency environmental condition, USAKA shall notify the 9 public affected or potentially affected by the condition and the Appropriate Agencies by the most 10 expeditious means available. Emergency environmental conditions are those that pose an 11 immediate threat to human health and safety, incidental take of protected species or habitats, and 12 unplanned impacts to sensitive natural and cultural resources. Within 10 days following 13 emergency notification, USAKA shall submit written notification of the event to the Appropriate 14 Agencies that contains, at a minimum, the relevant information described in UES Section 2-15 7.2.2. Emergency notifications shall be made for any condition that the Commander, USAKA, 16 determines to constitute an emergency condition. 17

14.1.1 Public Notifications 18

Public notifications shall be made by USAKA to advise the public of an activity or action that 19 USAKA has taken or is planning. Public notification shall be made through means that are 20 widely available and consulted by the public at USAKA and the RMI. This normally includes 21 publication in The Kwajalein Hourglass and The Marshall Islands Journal, posters or bulletins 22 displayed in public places, announcements on the television “Roller,” and radio announcements 23 and shall be effective for the locations affected. 24

15.0 RECORDS KEEPING 25

UES requirements dictate that the NPA, Environmental Comments, and Recommendations 26 (ECRs), and DEP that allows remedial activities at USAKA shall be preserved for the duration of 27 the activity plus ten years or for ten years after expiration of the DEP, whichever is less. 28 USAKA environmental records on remedial activities for soil, water, and groundwater 29 contamination will be maintained for demonstrating external auditing (UES §2-13.1). All 30 records associated with contamination remedial activities will be maintained for at least five 31 years (UES §2-13.2). 32



16.0 RESOLUTION OF NONCOMPLIANT AREAS 1

Currently there are no known non-compliant activities associated with remedial activities. The 2 pending Document of Environmental Protection shall provide a detailed compliance matrix for 3 all associated activities. 4