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ROI-NAMUR POL YARD
REMOVAL ACTION MEMORANDUM/
FEASIBILITY STUDY
U.S. ARMY KWAJALEIN ATOLL/REAGAN TEST SITE,
REPUBLIC OF MARSHALL ISLANDS
Site ID CCKWAJ-003
JULY 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
DISTRIBUTION STATEMENT A. Approved for public release. Distribution is unlimited.
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TABLE OF CONTENTS
EXECUTIVE SUMMARY .................................................................................................... ES-1
1.0 INTRODUCTION.......................................................................................................... 1-1
1.1 Project Information .............................................................................................. 1-1
1.2 Physical and Environmental Setting .................................................................... 1-3
1.2.1 Environmental Setting ................................................................................... 1-3 1.2.2 Climate ........................................................................................................... 1-3
1.2.3 Regional Geology .......................................................................................... 1-4 1.2.4 Soil Characteristics ........................................................................................ 1-5 1.2.5 Hydrogeology ................................................................................................ 1-5
1.3 Site Description and History ................................................................................ 1-6
1.3.1 Site History .................................................................................................... 1-7
1.4 Removal Action Objective ................................................................................... 1-7
2.0 PRE-DESIGN ACTIVITIES TO DATE ..................................................................... 2-1
2.1 Previous Investigations ........................................................................................ 2-1
2.1.1 Conceptual Site Model ................................................................................... 2-9
2.2 Cultural Resource Assessment ........................................................................... 2-11
3.0 APPLICABLE REMEDIAL TECHNOLOGIES ..................................................... 3-13
3.1 Scope and Purpose of Removal Action ............................................................. 3-13
3.2 Justification for the Proposed Action ................................................................. 3-14
3.3 Technology Identification and Description ....................................................... 3-15
3.3.1 NAPL Removal Options .............................................................................. 3-18 3.3.2 Remedial Options......................................................................................... 3-23
4.0 ENGINEERING EVAULATION AND COST ANALYSIS OF
ALTERNATIVES .......................................................................................................... 4-1
4.1 NAPL Removal Options ...................................................................................... 4-1
4.1.1 Dual Phase Extraction .................................................................................... 4-1 4.1.2 Bioslurping ..................................................................................................... 4-5
4.1.3 Infiltration Galleries ....................................................................................... 4-7
4.2 Remedial Options............................................................................................... 4-10
4.2.1 Enhanced Bioremediation ............................................................................ 4-10 4.2.2 Thermal Treatment....................................................................................... 4-15
4.3 Comparative Analysis of Alternatives ............................................................... 4-17
4.3.1 NAPL Removal ............................................................................................ 4-18
4.3.2 Remedial Technologies ................................................................................ 4-19
4.4 Remedy of Record ............................................................................................. 4-20
4.5 Cultural Resource Evaluation ............................................................................ 4-21
5.0 FUTURE PRE-REMOVAL ACTION ACTIVITIES ................................................ 5-1
6.0 REMOVAL ACTION SYSTEM DESIGN PROCESS .............................................. 6-1
6.1 Removal and Remedial Action System Elements ............................................... 6-1
6.2 Design and Performance Criteria ......................................................................... 6-2
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6.2.1 Cleanup Goals ................................................................................................ 6-2
6.2.2 Performance Criteria ...................................................................................... 6-3
6.3 System Design Concepts...................................................................................... 6-5
6.3.1 Infiltration Galleries ....................................................................................... 6-5 6.3.2 Enhanced Bioremediation ............................................................................ 6-11
6.4 Schedule ............................................................................................................. 6-11
7.0 PROPOSED WORK SUMMARY ............................................................................... 7-1
7.1 General Field Activities ....................................................................................... 7-1
7.2 Restoration Activities Approach .......................................................................... 7-2
7.2.1 Supplemental Data Collection ....................................................................... 7-3 7.2.2 Subsurface Modeling and Design Finalization .............................................. 7-3 7.2.3 Construction of Infiltration Galleries ............................................................. 7-3
7.2.4 Installation of NAPL Extraction Equipment.................................................. 7-3 7.2.5 Infiltration Galleries System Startup ............................................................. 7-4 7.2.6 NAPL Removal Monitoring and Operation ................................................... 7-4
7.2.7 Contaminated Soil Landfarming .................................................................... 7-4 7.2.8 NAPL Removal Verification Assessment and Reporting .............................. 7-5
7.2.9 Installation of Injection Wells ........................................................................ 7-5 7.2.10 Installation of Sparging Equipment and Pumps............................................. 7-6 7.2.11 Enhanced Bioremediation System Startup ..................................................... 7-6
7.2.12 Long-Term Monitoring .................................................................................. 7-6 7.2.13 Project Reporting ........................................................................................... 7-7
7.3 Sampling and Analysis Plan ................................................................................ 7-7
7.4 Quality Assurance Project Plan ......................................................................... 7-10
7.4.1 Data Quality Objectives ............................................................................... 7-11
7.5 Site Safety and Health Plan ................................................................................ 7-14
7.6 Archaeological Monitoring Plan ........................................................................ 7-16
8.0 REFERENCES ............................................................................................................... 8-1
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LIST OF TABLES
Table 1-1 Document Crosswalk ................................................................................................ 1-2
Table 2-1 Frequency and Magnitude of Compounds Detected During the 2010/11 SI ............ 2-4
Table 2-2 Roi-Namur Plan Spill Site CSM ............................................................................... 2-9
Table 3-1 FRTR Screening Matrix Preferred Options ............................................................ 3-16
Table 4-1 DPE Effectiveness Evaluation .................................................................................. 4-3
Table 4-2 Infiltration Galleries Effectiveness Evaluation ......................................................... 4-9
Table 4-3 Enhanced Bioremediation Effectiveness Evaluation .............................................. 4-13
Table 4-4 Thermal Treatment Effectiveness Evaluation ......................................................... 4-16
Table 6-1 Current and Target COC Concentrations .................................................................. 6-3
Table 7-1 Field Screening Methods for Soils ............................................................................ 7-8
Table 7-2 Field Screening Methods for Water .......................................................................... 7-8
Table 7-3 Laboratory Analytical Methods for Soils ................................................................. 7-9
Table 7-4 Laboratory Analytical Methods for Water ................................................................ 7-9
Table 7-5 Quality Control Parameters Corresponding to Data Quality Indicators ................. 7-12
Table 7-6 Hazard Analyses for General Jobsite Activities ..................................................... 7-15
LIST OF FIGURES
Figure 1-1 Roi-Namur POL Yard Spill Site Overview ............................................................... 1-9
Figure 2-1 Roi-Namur POL Yard Soil Boring Locations and Analytical Detections ................. 2-5
Figure 2-2 Roi-Namur POL Yard Piezometer Locations and Analytical Detections ................. 2-6
Figure 2-3 Roi-Namur POL Yard Product Thickness Map ......................................................... 2-7
Figure 2-4 Roi-Namur POL Yard DRO Plume in Groundwater ................................................. 2-8
Figure 2-5 Roi-Namur Island Freshwater Lens and Dredge Fill Map....................................... 2-12
Figure 3-1 Flow Diagram for DPE ............................................................................................ 3-21
Figure 3-2 Bioslurping Flow Diagram ...................................................................................... 3-22
Figure 6-1 Infiltration Gallery Side View and Installation Procedure ........................................ 6-8
Figure 6-2 Infiltration Gallery Planning-Level Schematic .......................................................... 6-9
Figure 6-3 Proposed Initial Locations for Infiltration Gallery Installation ............................... 6-10
LIST OF APPENDICES
Appendix A Schedule
Appendix B RACER Supporting Documentation
Appendix C Detailed Evaluation of Remedial Technologies
Appendix D Soil Boring Logs
Appendix E Cultural Resource Evaluation
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LIST OF ACRONYMS AND ABBREVIATIONS
% percent
%D percent difference
%Df percent drift
%R percent recovery
AMP Archaeological Monitoring Plan
ARSTRAT U.S. Army Forces Strategic Command
AST aboveground storage tank
ATSC Atmospheric Technology Services Company
bgs below ground surface
°C degrees Celsius
CEMML Center for Environmental Management of Military Lands
cm2
square centimeters
cm3/g cubic centimeters per gram
COC contaminant of concern
CRE Cultural Resource Evaluation
CSM conceptual site model
CY cubic yard
DCE dichloroethene
DEP Document of Environmental Protection
DO dissolved oxygen
DoD U.S. Department of Defense
DPE dual phase extraction
DQO data quality objectives
DQI data quality indicators
DRO diesel range organics
EE/CA Engineering Evaluation/Cost Analysis
EPA U.S. Environmental Protection Agency
ESL environmental screening level
°F degrees Fahrenheit
FRTR Federal Remediation Technologies Roundtable
FS Feasibility Study
g/cm3 grams per cubic centimeter
g/mL grams per milliliter
GIS Geographic Information System
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GEPA Guam Environmental Protection Agency
GRO gasoline range organics
HDH Hawai‟i Department of Health
ICBM intercontinental ballistic missile
KMR Kwajalein Missile Range
LCS/LCSD laboratory control sample/laboratory control sample duplicate
LNAPL light non-aqueous phase liquids
LOEL lowest observed effect level
µg microgram
µg/L micrograms per liter
µg/kg micrograms per kilogram
MCL maximum contaminant level
mg/kg milligram per kilogram
mg/L milligrams per liter
mi2 square miles
mmHg millimeters of mercury
mph miles per hour
MS/MSD matrix spike/matrix spike duplicate
MSL mean sea level
NA not analyzed
NAPL non-aqueous phase liquid
NC not calculated
NFA no further action
NOAA National Ocean and Atmospheric Administration
O2 oxygen
ORNL Oak Ridge National Laboratory
PAH polycyclic aromatic hydrocarbon
pH hydrogen concentration
PID photoionization detector
PMRF Pacific Missile Range Facility
POL petroleum, oil, and lubricants
ppm parts per million
PRG Preliminary Remediation Goal
QAPP Quality Assurance Project Plan
QC quality control
RACER Remedial Action Cost Engineering and Requirements
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RAM Removal Action Memorandum
RC response complete
RFH Radio frequency heating
RMI Republic of the Marshall Islands
RPD relative percent difference
RSE Raytheon Service Company Range Systems Engineering
RSL Regional Screening Levels
RTS Reagan Test Site
SAP Sampling Analysis Plan
SI site investigation
SMDC U.S. Army Space and Missile Defense Command
SQuiRTs Screening Quick Reference Tables (NOAA)
SSHP Site Safety and Health Plan
SVE soil vapor extraction
SVOC semivolatile organic compound
TEO U.S. Army Test and Evaluation Office
TOC total organic carbon
TPH total petroleum hydrocarbons
UCL95 95% upper confidence level
UES U.S. Army Kwajalein Atoll Environmental Standards
USACE U.S. Army Corps of Engineers
USAEHA U.S. Army Environmental Hygiene Agency
USAKA U.S. Army Kwajalein Atoll
USGS U.S. Geological Survey
VOC volatile organic compound
VPH volatile petroleum hydrocarbon
WWII World War II
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EXECUTIVE SUMMARY
This document provides a Removal Action Memorandum (RAM)/Feasibility Study (FS)
pursuant to requirements in the U.S. Army Kwajalein Atoll (USAKA) Environmental Standards
(UES) section 3-6.5.8(g) for proposed nonaqueous phase liquid (NAPL) product removal. This
document outlines a Feasibility Study (FS) as described in UES 3-6.5.8(n) for future remediation
at the Roi-Namur Petroleum, Oils and Lubricants (POL) Yard Spill Site on Kwajalein Atoll,
Republic of the Marshall Islands. The NAPL removal is included as part of the RAM/FS, as it is
a time-critical action since it must be removed before other remedial options can be
implemented.
The Roi-Namur POL Yard site is the primary fuel storage area for the power plant containing
two storage tanks (ASTs) (Facilities 8046 and 8047). A large diesel fuel oil release of
approximately 22,500 gallons occurred on January 30, 1996. Emergency response and follow-up
recovery activities yielded almost 17,000 gallons, or approximately 75% of the spill volume.
Prior to the fuel release, several sites of potential environmental contamination were identified
(USAHEA, 1991). These included an unlined oil/solvent storage pit to the south of the POL
storage tanks, and a wash rack discharge ditch to the north and east of the POL storage tanks.
In 2010 and 2011, Sivuniq conducted a follow-up Site Investigation (SI), which included soil and
groundwater sampling. The SI revealed that soil and groundwater contamination remains at the
site, including over a foot of NAPL on the groundwater surface in the most contaminated area.
Contaminants were also identified in piezometers at concentrations below screening levels that
were installed on the beach, indicating that that future monitoring should be performed to
determine the extent of the impact to the lagoon. The primary contaminant in soil and
groundwater was diesel range organics (DRO), although concentrations of gasoline range
organics (GRO), benzo(a)anthracene, naphthalene, and phenanthrene exceeded applicable
screening criteria in soil.
Three alternatives were evaluated for the NAPL removal action:
Alternative 1 – Dual Phase Extraction
Alternative 2 – Bioslurping
Alternative 3 – Infiltration Galleries
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Two alternatives were evaluated for remediation of residual contamination:
Alternative 1 – Enhanced Bioremediation
Alternative 2 – Thermal Treatment
Comparisons of effectiveness, implementability, and costs indicate that a treatment train of
infiltration galleries followed by enhanced bioremediation would be the most cost effective
strategy for NAPL removal and residual remediation at the Roi-Namur POL Yard Spill Site.
The NAPL removal action will be the first phase implemented at the site, scheduled for early
2012. While NAPL removal begins, Sivuniq will initiate landfarming for excavated soils and
also begin to install enhanced bioremediation injection wells at the edge of the contaminant
plume. As NAPL is removed from the source area, the area covered by injection wells will be
expanded.
Sivuniq also proposed additional assessment to be performed prior to the NAPL removal action.
The supplemental site investigation began in December 2011, and will focus on delineating the
lateral extent of soil and groundwater contamination around the site. Soil samples will be
collected from borings advanced outside of the 2011 perimeter borings that indicated
contamination was present. Permanent groundwater monitoring wells will be installed for long-
term monitoring of the groundwater contamination, water table elevation, and groundwater flow
direction. In addition, data to support the development of an enhanced bioremediation design
plan (i.e., nutrient requirements and formation details) will be collected.
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1.0 INTRODUCTION
1.1 PROJECT INFORMATION
The Kwajalein Atoll is located in western chain of the Marshall Islands in the Pacific Ocean, just
west of the international dateline. It is 2,100 nautical miles southwest of Honolulu, Hawaii and
approximately 4,200 nautical miles southwest of San Francisco, California. Less than 700 miles
north of the equator, Kwajalein is in the latitude of Panama and the southern Philippines, and in
the longitude of New Zealand (2,300 miles south), and the Kamchatka Peninsula of the former
Soviet Union (2,600 miles north). Kwajalein, at the atoll‟s southern tip, and Roi-Namur, at its
northern extremity, are the principal islands at U.S. Army Kwajalein Atoll (USAKA)/ Ronald
Reagan Ballistic Missile Defense Test Site (RTS) and are 50 miles apart; the other islands used
by USAKA/RTS are situated between these two. The atoll‟s remoteness from centers of
population and proximity to the sea has a major bearing on the operation and maintenance of
USAKA/RTS.
The U.S. Army utilizes 11 of the over 100 islands in the atoll, with active facilities on all or part
of the eleven islands (one of which is Roi-Namur). Two of the islands, Kwajalein and Roi-
Namur, were sites of extensive battles during World War II (WWII); thus, investigation and
remediation activities are further complicated by potential unexploded ordnance (UXO) and
cultural/historical resource discoveries, including human remains.
This document is described as a Removal Action Memorandum (RAM)/Feasibility Study (FS)
pursuant to U.S. Army Kwajalein Atoll Environmental Standards (UES) 3-6.5.8(g), and also
includes elements of a Feasibility Study (FS) report pursuant to UES 3-6.5.8(n). Table 1-1
presents how the elements for these documents are included in this RAM/FS. The document
includes elements for both RAMs and FSs because there are two proposed phases for
remediation at the site: a time-critical removal action for NAPL reduction that must occur before
other remedial options are implemented (covered by the RAM/FS elements), and the reduction of
residual contaminant concentrations following this removal action (covered by the FS elements).
While the FS elements are discussed in this document, the required Document of Environmental
Protection and Notice of Proposed Action will be separate documents delivered after the removal
action is complete (as required by the UES). Residual remediation (i.e., enhanced
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bioremediation, as described in Section 6.0) will be pursued under the non-time critical
mitigation approach after completion of the removal action.
Table 1-1 Document Crosswalk
UES Requirement Section
RAM - §3-6.5.8(g)
(1)(i)
Identify source and nature of contamination
Risk estimation
Extent of threat
Evaluation of factors
2.0
2.1
2.1
1.4, 2.1, 0, 4.3, 4.3.1
(1)(ii)Site background 1.1, 1.2, 1.3
(1)(iii)
EE/CA
SAP
QAPP
HSP
4.0
7.3
7.4
7.5
(1)(iv) Schedule Appendix A
(1)(v) Resource damage restoration 2.2, 4.5, 7.6
(2) Review by Appropriate Agencies Pending
(3) Waste management 7.0
FS - §3-6.5.8(n)
(1) Alternatives assessment 4.0
(2)(i)
Mitigation effectiveness
Technical feasibility
Cost effectiveness
4.0
4.0
4.0
(2)(ii) Proposed plan 3.0, 5.0
(2)(ii)(A) Summary description of remedial alternatives 4.2, 6.0
(2)(ii)(B) Summary of Appropriate Agency comments Pending
(2)(ii)(C) Rationale for preferred alternative 4.3, 4.3.2
(2)(ii)(D) Pertinent cleanup standards 3.0, 4.4, 6.2.1
(2)(iii) Public review and comment Pending
The Site Investigation (SI) performed by Sivuniq in 2010 and 2011 included many of the
components described in 3-6.5.8(g) (as well as those included in 3-6.5.8(k)). Specifically, the SI
included the components defined in 3-6.5.8(g)(1)(i) and (ii), so these components are
summarized here. Additionally, the sampling and analysis plan (SAP), quality assurance project
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plan (QAPP), and site safety and health plan (SSHP) were included in the work plan for the SI
and will be adapted for future work at this site; a simplified summary is presented in Section 7.0,
pursuant to 3-6.5.8(g)(iii). Resource damage restoration, as mentioned in 3-6.5.8(g)(1)(v), is
included in the cost estimates provided in Section 4.0.
1.2 PHYSICAL AND ENVIRONMENTAL SETTING
1.2.1 Environmental Setting
Kwajalein Atoll is a coral reef formation in the shape of a crescent loop enclosing a lagoon. The
approximately 100 small islands share a total land area of 5.6 square miles (mi2). The largest
islands are Kwajalein (1.2 mi2), Roi-Namur (0.6 mi
2), and Ebadon at the extremities of the atoll;
together they account for nearly half the total land area. While the “typical” size of the remaining
islands may be about 450 feet by 2,100 feet, the smallest islands are no more than sand cays that
merely break the water's surface at high tide.
The Kwajalein Atoll lagoon enclosed by the reef is the world‟s largest, with a surface area of 902
mi2, and a depth that is generally between 120 to 180 feet (Sugerman, 1972). One notable
characteristic of the atolls is the steep slopes of the mounts seaward of the reef. Around
Kwajalein Atoll, the depth plunges to as much as 6,000 feet within 2 miles of the atoll, and
13,200 feet within 10 miles. Coral atolls are seamounts that have been capped by calcareous
marine growth constructed by lime-secreting organisms (coral polyps and algae). The lower parts
of atolls are composed of noncalcareous rocks, most often volcanic materials. The overlying
coral superstructures may be hundreds or even thousands of feet in thickness. Emergent portions
of the reef and islands tend to be composed of loose, poorly consolidated calcareous materials
derived from foraminifera, coral, shells, and marine algae, or their debris resulting from
destructive action of the elements. All of the islands that comprise the atoll are relatively flat
with few natural points exceeding 15 feet above mean sea level (MSL) (Sugerman, 1972). This
condition presents a major problem for underground construction and allows spilled
contaminants to easily reach the water table.
1.2.2 Climate
Kwajalein‟s tropical marine climate exhibits little variation through the year. The atoll
experiences a relatively dry windy season from mid-December to mid-May, and a relatively wet
calm season from mid-May to mid-December. Normal annual rainfall is approximately 100
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inches; approximately 72 percent (%) of the annual rainfall occurs during the wet season and
28% during the dry season. On average, the prevailing wind direction is from the east-northeast
during the entire year, although winds may become more variable during the wet season when
occasional southerly or even westerly winds occur. The average wind speed is approximately 17
miles per hour (mph) from December to April, and 12 mph from May to November.
The average daily maximum temperature is 86.5 degrees Fahrenheit (ºF); the average minimum
temperature is 77.6 ºF. The extreme temperatures recorded at the atoll are 97 ºF and 68 ºF.
Average relative humidity ranges from 83% at local noon to 78% at midnight.
Most of the rainfall at Kwajalein comes from rain showers; thunderstorm occurrences are
infrequent. On average, thunderstorms occur fewer than 12 days each year. The frequency of
thunderstorms ranges from 0.1 per month from January to March to two per month in September.
During the modern era of recordkeeping, since 1919, a fully developed typhoon has never struck
Kwajalein Atoll; however, tropical storms with sustained winds from 40 to 74 mph impact the
atoll on average about once every four to seven years. Rainfall varies significantly across the
atoll with Roi-Namur receiving roughly 60% to 70% of the Kwajalein Island average of
approximately 100 inches per year (ATSC, 2010).
1.2.3 Regional Geology
The detailed geology of Kwajalein Atoll is primarily based on shallow boring logs prepared by
the U.S. Army Corps of Engineers (USACE) and drilling logs prepared during the construction
of monitoring wells by the U.S. Geological Survey (USGS) (Hunt, 1995).
Atolls have been studied intensively since the 1940s, and general models of atoll geology and
hydrology have emerged. Shallow subsurface materials are mainly unconsolidated, reef-derived,
carbonate sediments (sand, gravel, and rubble) with lesser amounts of consolidated rock (coral-
algal boundstone, sandstone, conglomerate, and recrystallized limestone) (Hunt, 1995).
Sediments of different ages are separated by erosional unconformities, which commonly are
marked by soils and leached zones (USGS, 1963).
Studies on Kwajalein Island have shown that the lagoon side of the island consists of
unconsolidated sediments that are thicker and contain a greater proportion of low-permeability
back-reef sand than the ocean side. Drilling logs suggest a greater proportion of coarse, high-
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permeability rubble on the ocean side (Hunt, 1995). Conditions are expected to be similar for
Roi-Namur Island.
1.2.4 Soil Characteristics
Soils on Kwajalein Atoll mainly consist of unconsolidated, reef-derived calcium carbonate sand
and gravel with minor consolidated layers of coral, sandstone, and conglomerate. Core samples
and drilling logs at Kwajalein Island indicate mostly unconsolidated carbonate sediments down
to 111.5 feet below ground surface (bgs), with hard layers being more prevalent on the ocean
side of the island (Hunt, 1995); Roi-Namur Island is expected to be of similar composition.
Most of the Roi-Namur Petroleum, Oils, and Lubricants (POL) Yard Spill Site sampling area is
located within post-WWII fill dredged from the reef. The areas south of the perimeter road were
clearly fill material, often saturated with diesel fuel, with the lower portion of the profile
occasionally revealing what appeared to be intact marine sand deposits (Sivuniq, 2011). Soil
samples collected during the Sivuniq SI indicate that the soils are primarily coralline sand, with
some large coral fragments and little finer materials.
1.2.5 Hydrogeology
The thick accumulation of limestone layers, unconformities caused by sea level changes over
time, and tidal activity play an important role in the fresh groundwater dynamics. Groundwater is
very shallow throughout the atoll; a thin freshwater lens lies atop the brackish groundwater on
the largest islands, including Kwajalein and Roi-Namur. Lens thickness is proportional to island
width and rate of groundwater recharge, and inversely proportional to hydraulic conductivity
(Hunt, 1995).
The groundwater lens was identified as thickest near the lagoon (on Kwajalein Island), where
unconsolidated sediments were thickest and contained a greater proportion of low-permeability
back-reef sand. The lens was thinner near the ocean, where drilling logs suggested a greater
proportion of coarse, high-permeability rubble and where core samples of conglomerate were
obtained at a shallower depth than at a more lagoon-ward site (Hunt, 1995).
Groundwater gradients radiate out from groundwater mounds near the center of the islands. The
shallow depth to groundwater and the high permeability of the soils make the groundwater
systems of the Kwajalein Atoll islands highly vulnerable to contamination by chemicals
(USAEHA, 1991).
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Studies on Kwajalein Island indicate that aquifer tidal efficiency (i.e. the ratio of feet of tidal
change to feet of change in aquifer water level) increases with depth and proximity to the ocean
and lagoon shores, and is somewhat higher on the ocean side (Hunt, 1995). This included areas
of native soil and areas created with dredge fill.
1.3 SITE DESCRIPTION AND HISTORY
The U.S. Army control of Kwajalein Atoll was established in 1964 after being transferred from
the U.S. Navy. The Navy operated the facility from 1944 to 1964 after the U.S. liberation of the
atoll from the Japanese during WWII. The USAKA/Kwajalein Missile Range (KMR) was
renamed to USAKA/RTS on June 15, 2001.
The naming designations of the installation at Kwajalein Island throughout recent history are as
follows:
USAKA from November 14, 1986 through September 30, 1997;
KMR from April 15, 1968 through November 13, 1986;
Kwajalein Test Site from July 1, 1964 through April 14, 1968;
Navy Operating Base Kwajalein, Naval Air Station Kwajalein, Naval Station
Kwajalein, and Pacific Missile Range Facility (PMRF) Kwajalein at various times
between 1945 and 1964.
The USAKA/RTS is a subordinate activity of the U.S. Army Space and Missile Defense
Command/U.S. Army Forces Strategic Command (SMDC/ARSTRAT), headquartered in
Huntsville, Alabama. Command of the site, with regard to its range mission as an element of the
Department of Defense‟s (DoD) Major Range and Test Facility Base (DoD Directive 3200.11),
is exercised under funding guidance from the U.S. Army Test and Evaluation Office (TEO).
The installation supports the RTS in support of theater missile defense, ballistic missile defense,
and intercontinental ballistic missile (ICBM) testing. Kwajalein also has a missile and space
objects tracking mission utilizing an array of powerful radar dishes located on Roi-Namur Island.
In addition, Kwajalein Island supports other DoD training activities as well as commercial space
launch operations.
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1.3.1 Site History
The Roi-Namur POL Yard Spill Site is the fuel storage area for the power plant that
encompasses two diesel fuel aboveground storage tanks (ASTs) (Facilities 8046 and 8047). A
large diesel fuel release of approximately 22,500 gallons occurred at one of the two power plant
ASTs on January 30, 1996. The 350,000-gallon AST #8047 was overfilled because the available
tank volume was erroneously calculated and, due to a faulty level sensing system, the release
was not noticed until the tank was overfilled because the operator apparently left the vicinity
(Raspiller, 1998). At the time of the release, there was no secondary containment around the
POL tanks (although secondary containment has since been added). The fuel release occurred at
the overflow pipe at the base of the tank. Figure 1-1 presents the Roi-Namur POL Yard Spill site.
Emergency response teams recovered approximately 5,640 gallons of released product during the
initial response. An additional 2,888 gallons of product was recovered within the first 24 hours
of the release. Follow up recovery activities (skimming operations from trenches and sumps)
yielded an additional 8,347 gallons of recovery. In total, almost 17,000 gallons, or approximately
75%, of the spill volume was reportedly recovered. Recovery efforts ceased because it was
presumed that at this point, the feasible recovery phase had been achieved (Raspiller, 1998).
Prior to the fuel release, several sites of potential environmental contamination were identified
(USAHEA, 1991). These included an unlined oil/solvent storage pit to the south of the POL
storage tanks, and a wash rack discharge ditch to the north and east of the POL storage tanks
In the 2001 restoration report, it was noted that no humans inhabit the spill site and that no viable
pathways of exposure exist unless construction activities are undertaken at the site (RSE, 2001).
Product removal from the groundwater is reportedly feasible because of the fine- to coarse-
grained calcareous sands, relatively shallow depth to groundwater, predictable tides, and constant
temperatures, which facilitate the remediation process.
1.4 REMOVAL ACTION OBJECTIVE
Per UES 3-6.5.8(g)(3), the scope of the removal action involves the mitigation of contamination
which may pose undue harm or threat prior to the completion of remedial action activities.
Primary considerations are the stability of the wastes and the potential for public contact with the
hazardous materials/wastes. This RAM/FS describes actions to remove/minimize the hazard
indicated by the presence of non-aqueous phase liquid (NAPL) in the subsurface.
Final Roi-Namur POL Yard RAM Sivuniq, Inc.
Kwajalein Atoll/Reagan Test Site 1-8 July 2012
The NAPL removal is considered time critical mitigation in this document because it must be
accomplished before contaminant concentrations can be reduced to risk-free levels. Additionally,
the potential for contaminant migration into the lagoon is possible, as detections for multiple
contaminants were found in piezometers installed along the lagoon shoreline. Initiating the time
critical approached described under the RAM/FS process [UES 3-6.5.8(g)] will ensure that this
potential is mitigated in a short timeframe, as well as the potential for human contact if
excavation activities are initiated at the site.
Final Roi-Namur POL Yard RAM Sivuniq, Inc.
Kwajalein Atoll/Reagan Test Site 1-9 July 2012
Figure 1-1 Roi-Namur POL Yard Spill Site Overview
Final Roi-Namur POL Yard RAM Sivuniq, Inc.
Kwajalein Atoll/Reagan Test Site 1-10 July 2012
[THIS PAGE LEFT INTENTIONALLY BLANK]
Final Roi-Namur POL Yard RAM Sivuniq, Inc.
Kwajalein Atoll/Reagan Test Site 2-1 July 2012
2.0 PRE-DESIGN ACTIVITIES TO DATE
2.1 PREVIOUS INVESTIGATIONS
Initial recovery efforts included recovering NAPL product from trenches and sumps, and the
recovery operations continued throughout 1996 primarily at one of the trenches where the
majority of the NAPL had accumulated. In addition to the trenches, four wells were installed
with skimmers to recover product. One of the wells continued to operate until March 1997, when
recovery operations ceased because it was presumed that at this point, the feasible recovery
phase had been achieved (Raspiller, 1998).
Historical contamination from previous activities at the site (the unlined oil/solvent pit, leaks
from fuel storage and associated piping, and/or the wash rack discharge ditch) became apparent
during the recovery operations because of weathered product that was being recovered. The 2001
RSE report indicates pipeline monitoring during transfer operations was conducted because of
previous leaks that had occurred that required rapid response to keep the product from entering
the lagoon. Also, this report suggests it was common practice to dispose of engine crank oil,
solvents, contaminated fuel, and petroleum sludge in an unlined pit adjacent to the site of the
1996 diesel fuel oil spill (RSE, 2001).
Prior to the spill, a study was conducted to preliminarily characterize potential contamination
associated with the oil/solvent pit and the wash rack discharge ditch (USAHEA, 1991). Aroclor
1260 and lead were identified as contaminants at the wash rack discharge ditch to the north of
the POL storage tanks. A monitoring well downgradient of the tanks (that has since been
removed) identified the presence of groundwater contamination by fuel oil, including NAPL
floating on the water table. 1,1-dichloroethane (DCE), naphthalene, and n-butyl-benzene were
detected at low levels (micrograms per liter [µg/L] range), while hydrocarbons were detected at
milligrams per liter (mg/L) levels. It was noted that a portion of the subsurface hydrocarbon
contamination at the site might have been due to a release of fuel from either the tanks or
associated piping, and not the oil/solvent pit. Additionally, human risk was not evaluated from
these results because the only identified risk pathway was due to excavation work at the site
(which was not expected to be performed). Since the scope of the study was limited, it is
uncertain how widespread POL and solvent contamination were prior to the 1996 spill.
Final Roi-Namur POL Yard RAM Sivuniq, Inc.
Kwajalein Atoll/Reagan Test Site 2-2 July 2012
An additional study conducted in 1991 references a limited SI at a power plant burn pit located
on Roi-Namur Island (ORNL, 1991). Although the report is ambiguous to the exact location of
this burn pit, it can be reasonably concluded that it was an investigation of the oil/solvent pit
mentioned above. From the limited data collected during this effort, the report concluded that the
power plant burn pit was contaminated by petroleum hydrocarbons (at milligrams per kilogram
[mg/kg] levels) and, to a lesser extent, lighter weight organics including some chlorinated
solvents (at micrograms per kilogram [µg/kg] levels). Total petroleum hydrocarbons were
present in the range of 5000 mg/kg near the pit and at appreciable but lower levels (500 mg/kg),
approximately 100 feet away and near the lagoon. These conclusions agree with the study
mentioned above.
The amount of fuel recovered from the 1996 spill was significantly less than the amount
suspected of being spilled. Since soil and groundwater were known to be contaminated, a follow-
up SI was conducted by Sivuniq in 2010 and 2011 to evaluate the nature and extent of remaining
contamination in the vicinity of the Roi-Namur POL Yard Spill Site (Sivuniq, 2011). The
investigation, which included soil (Figure 2-1) and groundwater (Figure 2-2) sampling, revealed
that soil and groundwater contamination remains at the site, including over a foot of emulsified
NAPL on the groundwater surface in the most contaminated area (Figure 2-3). Contaminants
were also identified in piezometers at concentrations below screening levels that were installed
on the beach, indicating that that future monitoring should be performed to determine the extent
of the impact to the lagoon. The primary contaminant in soil and groundwater was diesel range
organics (DRO), although concentrations of gasoline range organics (GRO), benzo(a)anthracene,
naphthalene, and phenanthrene exceeded applicable screening criteria in soil. The frequency and
range of detected compounds are presented in Table 2-1. Sampling near the former wash rack
discharge ditch did not identify unique contaminants; sampling was not conducted near the
former unlined oil/solvent pit as that area was presumed to be contaminated and the focus of the
investigation was on delineation. Samples were also taken for bioremediation and physical
parameters. These are discussed as part of the engineering analysis in Section 4.0.
Isolated oil-contaminated soil was identified around a soil boring to the northern extent of the
investigation (SB63) (Figure 2-1) and is likely a separate source of contamination since it is one
of the few soil borings that was located within the border of the original island shoreline.
Final Roi-Namur POL Yard RAM Sivuniq, Inc.
Kwajalein Atoll/Reagan Test Site 2-3 July 2012
Although DRO contamination was detected in this boring, it is likely bleed-over from residual
range organics contamination (i.e. oil). The source of this contamination is likely associated with
activities during or shortly after WWII, although this cannot be definitely concluded until further
data is collected.
Contaminant plumes were defined in soil and groundwater using DRO concentrations (Figure
2-4). The extent of contamination was delineated except to the southwest, where high screening
results and analytical detections indicate that a plume of lighter-weight, volatile contaminants
may have migrated in that direction (beyond the extent of the DRO plume). Clean analytical and
screening results bounded the contaminant plume in all other directions.
Final Roi-Namur POL Yard RAM Sivuniq, Inc.
Kwajalein Atoll/Reagan Test Site 2-4 July 2012
Table 2-1 Frequency and Magnitude of Compounds Detected During the 2010/11 SI
Soil
Analyte Frequency Range (mg/kg) Average
(mg/kg)
UCL 95
(mg/kg)
Screening
Criteria
(mg/kg)
2-Methylnaphthalene 25 / 64 0.00176 - 64 7.812 5.316 3101
Acenaphthene 26 / 64 0.00114 - 11.6 1.146 0.812 34001
Acenaphthylene 20 / 64 0.00116 - 2.04 0.4 0.2 12.722
Anthracene 28 / 64 0.00179 - 4.62 0.631 0.434 17000
Benzene 2 / 45 0.00251 - 0.0419 0.0222 0.00538 1.11
Benzo (a) anthracene 5 / 64 0.0071 - 0.137 0.0534 0.0158 0.151
Benzo (a) pyrene 1 / 64 0.00325 0.00325 NC 0.0151
Benzo (b) fluoranthene 1 / 64 0.0109 0.0109 NC 0.151
Chrysene 4 / 64 0.00373 - 0.196 0.0582 0.0134 151
DRO 46 / 66 5.94 – 52,400 5,432 5,750 5002
Ethylbenzene 4 / 45 0.128 - 2.36 0.987 0.194 5.41
Fluoranthene 15 / 64 0.00194 - 1.26 0.211 0.0905 23001
Fluorene 25 / 64 0.00159 - 13.2 1.491 1.013 23001
GRO 17 / 66 0.0187 - 261 29.3 14.78 1002
Naphthalene 19 / 64 0.0014 - 15.7 2.115 1.124 3.61
Phenanthrene 27 / 64 0.00178 - 25.6 1.833 1.462 10.692
Pyrene 17 / 64 0.00197 - 2.37 0.359 0.172 17001
Toluene 1 / 45 0.00123 0.00123 NC 50001
Xylenes (combined) 3 / 45 0.18 - 1.147 0.594 0.251 6301
Groundwater
Analyte Frequency Range (µg/L) Average
(µg/L)
UCL 95
(µg/L)
Screening
Criteria (µg/L)
1,2,4-Trimethylbenzene 1 / 11 0.18 0.18 NC 153
Benzene 2 / 11 0.07 - 0.16 0.115 0.0982 54
Carbon disulfide 4 / 11 1.28 - 3.56 2.255 2.076 10003
DRO 3 / 11 37.8 – 3,510 1,932.6 1,310 6402
Isopropylbenzene 1 / 11 0.46 0.46 NC -
Naphthalene 1 / 11 0.37 0.37 NC 242
n-Butylbenzene 1 / 11 0.48 0.48 NC 18003
n-Propylbenzene 1 / 11 0.53 0.53 NC -
sec-Butylbenzene 1 / 11 0.6 0.6 NC -
Tetrachloroethene 1 / 11 0.16 0.16 NC 54
Toluene 1 / 11 0.51 0.51 NC 10004
Xylenes (combined) 1 / 11 0.42 0.42 NC 100004
Notes, Acronyms and Abbreviations: 1Screening levels based on EPA residential RSLs. 2Screening levels based on GEPA ESLs (unrestricted land-use with a nonpotable water source and shallow contamination). 3 Screening levels based on EPA PRGs for tap water; since the water
source is nonpotable, this conservatively biases the results. 4Screening levels based on UES Table 3-2D.1. Analytes identified as COCs are
bolded. NC = not calculated; UCL = upper confidence limit.
Final Roi-Namur POL Yard RAM Sivuniq, Inc.
Kwajalein Atoll/Reagan Test Site 2-5 July 2012
Figure 2-1 Roi-Namur POL Yard Soil Boring Locations and Analytical Detections
Final Roi-Namur POL Yard RAM Sivuniq, Inc.
Kwajalein Atoll/Reagan Test Site 2-6 July 2012
Figure 2-2 Roi-Namur POL Yard Piezometer Locations and Analytical Detections
Final Roi-Namur POL Yard RAM Sivuniq, Inc.
Kwajalein Atoll/Reagan Test Site 2-7 July 2012
Figure 2-3 Roi-Namur POL Yard Product Thickness Map
Final Roi-Namur POL Yard RAM Sivuniq, Inc.
Kwajalein Atoll/Reagan Test Site 2-8 July 2012
Figure 2-4 Roi-Namur POL Yard DRO Plume in Groundwater
Final Roi-Namur POL Yard RAM Sivuniq, Inc.
Kwajalein Atoll/Reagan Test Site 2-9 July 2012
2.1.1 Conceptual Site Model
Based on historical information and data collected by the latest SI, Table 2-2 summarizes the
conceptual site model (CSM) for the Roi-Namur POL Yard Spill Site.
Table 2-2 Roi-Namur Plan Spill Site CSM
Model Element Input Rationale
Primary Source Petroleum separate phase hydrocarbons,
solvents Documented sources
Primary Transport
Mechanism
Direct separate phase hydrocarbons
discharge
Release from storage tanks and abandoned
pipeline, wash rack discharge ditch, and
oil/solvent pit
Secondary Source Contaminated soil Contamination from direct discharge
Secondary Transport
Mechanisms
Separate phase hydrocarbons migration
from the release point(s)
Dissolved (aqueous) transport by
groundwater
Measured and reported soil contamination at
various locations
Measured groundwater contamination in vicinity
of release locations
Exposure Media Soil
Groundwater
Contamination in soil
Contamination in groundwater
Exposure Pathways
Incidental ingestion of soil
Dermal contact with soil
Inhalation of vapors
Direct contact and use at site locations
Current Receptors On-site operations personnel
On-site (construction) workers
USAKA and contractor personnel are potentially
exposed during excavation work at site locations
Future Receptors On-site residents Unrestricted future land-use and development.
Complete/Significant
Exposure Scenarios
Incidental soil ingestion and dermal contact with contaminated soil by future on-site workers
during excavation activities.
Inhalation of soil contaminant vapors by future on-site workers and future operations
personnel.
Exposure scenarios for future residents cannot be evaluated at this time due to lack of surface
soil analytical data.
Note that although groundwater contamination was encountered, groundwater from the most
contaminated area is not within the freshwater lens and will therefore not be used as potable
water. This was based on freshwater lens maps (see Figure 2-5), and also on conductivity
measurements (more dissolved ions [i.e. salts] would give a higher conductivity reading) and
results for the amount of chloride ions present in sampled groundwater (Sivuniq, 2011). The
freshwaters lens maps indicated that freshwater was unlikely to be located south (also
downgradient) of the diesel storage ASTs, and that groundwater would flow out towards the
lagoon (effectively flushing contamination out of the tip of the freshwater lens that might be
present north of the ASTs); this is compounded by the fact that the ASTs (and surrounding area)
are located on artificial land created by coral dredging (see Figure 2-5), further making extensive
freshwater reserves in the area unlikely.
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Kwajalein Atoll/Reagan Test Site 2-10 July 2012
Therefore, the following exposure pathways were ruled out: ingestion of groundwater, contact
with groundwater, and inhalation of groundwater vapors (which would likely be the result of
water heating activities, like showers). This concurs with a prior preliminary characterization
performed in 1991, which concluded that this site is not located within the area in which usable
quantities of fresh groundwater exist, and that there is no direct human exposure pathway via
groundwater (USAHEA, 1991).
Complete/significant exposure scenarios related to each receptor are as follows:
On-site operations personnel:
o Inhalation of soil contaminant vapors from proximity to any open excavations at
the site
On-site construction workers:
o Incidental ingestion of soil and dermal contact with soil from direct exposure due
to construction activities at the site
o Inhalation of soil contaminant vapors from proximity to any open excavations at
the site
Note that residents are not included as part of the risk scenarios, because the risk from current
residents incidentally contacting contaminated material are accounted for from the
aforementioned receptors. However, screening levels used to determine contaminants to be
evaluated as part of the risk assessment have used residential or unrestricted land-use scenarios
to encompass risk due to potential residential exposure.
Additionally, future residents have been added to the CSM to account for Marshallese citizens
after the lands are turned over to the Republic of the Marshall Islands (RMI). Note that although
this pathway was not initially identified in the work plan, it has been included here for
completeness. While it is assumed that surface soil (0 to 2 feet bgs) contamination is not present
at the site due to presumed spill response activities, potential exposure cannot be definitely
excluded because no data was collected for evaluation. Collection of surface soil data is planned
as part of a supplemental mobilization for the aforementioned SI (see Section 5.0).
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Kwajalein Atoll/Reagan Test Site 2-11 July 2012
2.2 CULTURAL RESOURCE ASSESSMENT
Archaeological monitoring of soil from all sampling locations is discussed and presented in the
Roi-Namur POL Yard SI (Sivuniq, 2011). In summary, no artifacts or discrete cultural features
were uncovered during the SI.
Final Roi-Namur POL Yard RAM Sivuniq, Inc.
Kwajalein Atoll/Reagan Test Site 2-12 July 2012
Figure 2-5 Roi-Namur Island Freshwater Lens and Dredge Fill Map
Final Roi-Namur POL Yard RAM Sivuniq, Inc.
Kwajalein Atoll/Reagan Test Site 3-13 July 2012
3.0 APPLICABLE REMEDIAL TECHNOLOGIES
3.1 SCOPE AND PURPOSE OF REMOVAL ACTION
The scope of removal and remedial actions at the Roi-Namur POL Yard Spill Site includes soil
and groundwater contamination from the 1996 fuel spill, as well as contamination from
historically identified sources that exceed cleanup concentrations (as defined below). The
objection of the removal action is to remove contaminants from the soil and restore groundwater
quality so that cleanup concentrations are achieved.
After delineation of the remaining contamination in the Roi-Namur POL Yard Spill Site area, it
was determined that the highest concentration of contaminants of concern (COCs) were centered
around the tanks, with the groundwater contamination plume extending into the lagoon and
covering an area of approximately 216,500 square feet. This plume was defined by the
concentration equal to or greater than 640 µg/L of DRO (the primary COC) (which is the
environmental screening level [ESL] provided by the Guam Environmental Protection Agency
[GEPA] for a residential site with shallow contamination over a non-potable water source).
The area covering where measurable quantities of NAPL exist is approximately 150,000 square
feet (Figure 2-3). Soil contamination is primarily located in the vadose zone soils, and is
encompassed by the area covered by the groundwater contamination plume. GRO,
benzo(a)anthracene, benzo(a)pyrene, naphthalene, and phenanthrene are also COCs at this site.
The purpose of remedial actions is to lower the concentrations of these COCs to acceptable
exposure levels [per UES 3-6.5.8(l)(3)] in groundwater as identified by comparison to GEPA
ESLs, U.S. Environmental Protection Agency (EPA) Regional Screening Levels (RSLs), or
National Oceanic and Atmospheric Administration (NOAA) Screening Quick Reference Tables
(SQuiRTs), and contaminants in soil as identified by comparison to EPA RSLs or GEPA ESLs,
pursuant to UES 3-6.5.8(l)(2).
The UES regulatory framework identifies the area around the Roi-Namur POL Yard as
containing „Class III‟ groundwater. Additionally, the contamination does not extend into
adjacent „Class I‟ groundwater, and is not likely to impact the water quality of that groundwater
since it is downgradient. Therefore, according to UES 3-2.6.2, the water does not have to follow
Final Roi-Namur POL Yard RAM Sivuniq, Inc.
Kwajalein Atoll/Reagan Test Site 3-14 July 2012
the standards presented in UES Appendix 3-2D, and risk-based cleanup levels will be used as
described above; this rationale is pursuant to UES 3-6.5.8(n)(2)(ii)(D).
The practicability of any remediation option depends on factors related to the type of
contamination, site characteristics, cost, and performance. Remediation options were assessed
using the Treatment Technologies Screening Tool developed by the Federal Remediation
Technologies Roundtable (FRTR) (USACE, 2002). The FRTR is an interagency work group that
exchanges information between government agencies responsible for remediation of
environmental sites. The screening tool grades remediation technologies on criteria such as cost,
performance and logistical requirements. This information is continually updated in response to
new technology.
Technologies were selected from the FRTR Screening Matrix primarily based on the ability to
remediate DRO and GRO („Fuels‟ in the screening matrix), although secondary consideration
was given to the ability to remediate nonhalogenated semivolatile organic compounds (SVOCs)
(for benzo(a)anthracene, benzo(a)pyrene, naphthalene, and phenanthrene). Technologies that
were considered above average for these two contaminant groups were then researched further
before the final few technologies were selected for in-depth analysis (described below).
Since NAPL remains floating on the groundwater over a large area of the Roi-Namur POL Yard
Spill Site, a treatment train is necessary so that available remedial options can be implemented
after this NAPL is removed. Remedial technologies were selected with this in consideration as
well.
The affected area of this removal action is approximate, and will be more precisely defined by
additional soil and groundwater data before the removal action is implemented. These actions are
proposed and described in Section 5.0.
3.2 JUSTIFICATION FOR THE PROPOSED ACTION
Sampling of soils and groundwater during the SI and historical information show contamination
remains from multiple sources at the Roi-Namur POL Yard Spill Site. COCs identified for the
site include DRO, GRO, benzo(a)anthracene, benzo(a)pyrene, naphthalene, and phenanthrene for
soil, and DRO for groundwater; these contaminants exceed 10% of their applicable screening
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levels. Over a foot of emulsified NAPL is also present on the water table, and exceedances were
identified in soil and groundwater for DRO, and in soil for GRO, naphthalene, and phenanthrene
(Sivuniq, 2011).
Additionally, bioremediation parameters were collected from the affected area to determine if
active bioremediation (natural attenuation) was occurring at the site. Although many results were
qualified as estimated due to holding time exceedances, the data indicates that little active
bioremediation is taking place and that nutrients have been exhausted where natural attenuation
was taking place. This means that the concentrations of contaminants at the site will degrade
very slowly, and that human action is necessary for the site to return to its natural state in the
foreseeable future.
Potential remedial technologies pursuant to the scope and of this removal action are described in
the following sections.
3.3 TECHNOLOGY IDENTIFICATION AND DESCRIPTION
Preliminary technologies provided by the FRTR Screening Matrix are presented in Table 3-1.
These options were selected from all available choices based on having above average
performance for both „Fuels‟ and „Nonhalogenated SVOCs‟.
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Table 3-1 FRTR Screening Matrix Preferred Options
Black = Above Average
Gray = Average
White = Below Average
Red = Level of Effectiveness highly dependent
upon specific contaminant and its application
N/A = "Not Applicable"
I/D = "Insufficient Data"
Dev
elo
pm
ent
Sta
tus
Tre
atm
ent
Tra
in
Relative Overall Cost &
Performance
Contaminant
Groups
O&
M
Ca
pit
al
Sy
stem
Rel
iab
ilit
y
& M
ain
tain
ab
ilit
y
Rel
ati
ve
Co
sts
Tim
e
Av
ail
ab
ilit
y
No
nh
alo
gen
ate
d
SV
OC
's
Fu
els
Soil, Sediment, Bedrock and Sludge
In situ Biological Treatment
Bioventing
Enhanced Bioremediation
In situ Thermal Treatment
Thermal Treatment
Ex Situ Biological Treatment (assuming
excavation)
Landfarming
Slurry Phase Biological Treatment
Ex situ Thermal Treatment (assuming
excavation)
Incineration
Thermal Desorption
Ground Water, Surface Water, and Leachate
In situ Biological Treatment
Enhanced Bioremediation
In situ Physical/Chemical Treatment
Bioslurping
Dual Phase Extraction
Thermal Treatment
Ex situ Biological Treatment (assuming
excavation)
Bioreactors
Ex situ Physical/Chemical Treatment (assuming
pumping)
Advanced Oxidation Processes
Granulated Activated Carbon/ Liquid Phase
Adsorption
Separation
Containment
Physical Barriers
Air Emissions/ off-Gas Treatment
Oxidation N/A I/D
Vapor Phase Carbon Adsorption N/A I/D
Notes: Adapted from FRTR, 2007
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From the above options, those involving excavation were discounted as not applicable. This is
because the affected area for treatment is approximately 150,000 square feet for NAPL removal,
and 216,500 square feet for remediation of residual contamination; additionally, the affected soil
and groundwater is covered with up to approximately four feet of presumably clean overburden.
This meant that all ex situ technologies for soil were excluded (except for NAPL removal by
infiltration galleries, which would excavate a comparably small amount of soil from installation
of collection trenches), as well as groundwater treatment by bioreactors.
Similarly, those technologies involving extensive pumping were excluded due to UES
restrictions on Class I groundwater, which is adjacent to the site. Since the area of contamination
is directly downgradient of Class I groundwater, extensive groundwater pumping would likely
start to drain the aquifer used to supply potable water for much of Roi-Namur Island; Class I
groundwater cannot be affected in this manner if water quality is affected, according to UES
regulations. If the treated groundwater could be reintroduced as reclaimed water, it could be used
to resupply the freshwater lens; however, as the groundwater contains considerable
concentrations of contaminations, this option is likely not feasible and has been discounted.
Additionally, containment by physical barriers was discounted because of the size of the affected
area and also because the plume extends to the lagoon shoreline (which would complicate
containment efforts significantly). Based on the assumed hydraulic gradient, groundwater
movement is likely very slow, meaning that physical containment would not provide enough
benefit to be practical for implementation.
The following options were selected for evaluation and analysis after all options were
researched:
NAPL Removal
o Bioslurping (which would include off-gas treatment and ex situ groundwater
treatment)
o Dual phase extraction (which would include off-gas treatment and ex situ
groundwater treatment)
o Infiltration galleries (which would include ex situ soil treatment for excavated soil
and ex situ groundwater treatment)
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Kwajalein Atoll/Reagan Test Site 3-18 July 2012
Soil and Groundwater Remediation
o Enhanced bioremediation
o Thermal treatment
Note that infiltration galleries are not present in the FRTR Screening Matrix options identified
above. It is essentially an ex situ groundwater treatment, although it is still being considered
because the amount of groundwater removed is significantly less than other ex situ groundwater
treatment technologies (because its primary mode of operation is skimming).
Depending on success of NAPL removal, monitored natural attenuation may also be considered.
However, this will not be analyzed as a viable option at this time because bioremediation
parameters results indicate that natural attenuation has occurred but is now nutrient and oxygen
limited (see Section 4.2.1); if NAPL removal is adequately successful, this will be considered at
that time.
Since NAPL still remains onsite, a NAPL removal system will need to be implemented before
other remedial technologies can be utilized. All applicable technologies are described below, and
categorized by NAPL removal options and remedial options. These technologies are evaluated in
Section 4.0.
3.3.1 NAPL Removal Options
The main principle behind the removal of NAPL at the Roi-Namur POL Yard Spill Site is to
capture emulsified product floating in the upper margin of the groundwater. Four general
techniques or approaches are used to recover NAPL (EPA, 1996):
NAPL removal/skimming systems
NAPL recovery with water table depression
Vapor extraction/groundwater extraction
Dual phase (liquid and vapor) recovery
NAPL recovery with water table depression was discounted due to UES restrictions on Class I
groundwater, as described above. The technologies utilizing the other techniques were selected
primarily from the FRTR Screening Matrix, and are described below.
Final Roi-Namur POL Yard RAM Sivuniq, Inc.
Kwajalein Atoll/Reagan Test Site 3-19 July 2012
3.3.1.1 Dual Phase Extraction
Dual phase extraction (DPE), also known as multi-phase extraction or vacuum-enhanced
extraction, is a technology that uses a vacuum system to remove various combinations of
contaminated groundwater, separate-phase petroleum liquid, and hydrocarbon vapor from the
subsurface using a multi-pump system. Extracted liquids and vapor are treated and collected
separately for disposal, or re-injected to the subsurface (FRTR, 2007). It is very similar to
bioslurping, which is discussed in Section 3.3.1.2.
DPE systems can be effective in removing separate-phase liquids from the subsurface, thereby
reducing concentrations of petroleum hydrocarbons in both the saturated and unsaturated zones
of the subsurface. DPE systems are typically designed to maximize extraction rates; however, the
technology also stimulates biodegradation of petroleum constituents in the unsaturated zone by
increasing the supply of oxygen due to pore-space vapor cycling with air from the surface, and
the general system design is amenable to implementation of bioventing or biosparging (EPA,
1995).
A vacuum system is utilized to remove liquid and gas from low permeability or heterogeneous
formations. The vacuum extraction well includes a screened section in the zone of contaminated
soils and groundwater. It removes contaminants from above and below the water table. The
system lowers the water table around the well, exposing more of the formation. Contaminants in
the newly exposed vadose zone are then accessible to vapor extraction. Once above ground, the
extracted vapors or liquid-phase organics and groundwater are separated and treated. Dual phase
extraction for liquid/vapor treatment is generally combined with bioremediation, biosparging, or
bioventing when the target contaminants include long-chained hydrocarbons (FRTR, 2007).
Although the technology is generally described above, significant variations in design for DPE
systems exist. DPE systems often apply relatively high vacuums to the subsurface. Thus, the
adjective “high-vacuum” is sometimes used to describe DPE technologies, even though all DPE
systems are not high-vacuum systems. The most noteworthy system variation is the use of a
single pump or multiple pumps for extraction. Single pump designs are known as bioslurping,
while multi-pump designs are known as DPE (EPA, 1995).
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Multi-pump systems use one pump to extract liquids from the well and a surface blower (the
second pump) to extract soil vapor. An additional pump is sometimes used to specifically extract
floating product on the groundwater surface. Multi-pump systems are simply a combination of
traditional soil vapor extraction and groundwater (and/or floating product) recovery systems.
Multi-pump systems tend to be more flexible than single-pump systems, making them easier to
apply over a wider range of site conditions (e.g., fluctuating water tables, wide permeability
ranges); however, equipment costs are higher (EPA, 1995).
The target contaminant groups for dual phase extraction are volatile organic compounds (VOCs)
and fuels (e.g., light non-aqueous-phase liquids [LNAPLs]). Dual phase vacuum extraction is
more effective than soil vapor extraction for heterogeneous clays and fine sands. However, it is
not recommended for lower permeability formations due to the potential to leave isolated lenses
of un-dissolved product in the formation (FRTR, 2007).
The vacuum applied to the subsurface with DPE systems creates vapor-phase pressure gradients
toward the vacuum well. These vapor-phase pressure gradients are also transmitted directly to
the subsurface liquids present, and those liquids existing in a continuous phase will flow toward
the vacuum well in response to the imposed gradients. The higher the vacuum, the larger the
hydraulic gradients that can be achieved in both vapor and liquid phases, and thus greater vapor
and liquid recovery rates (EPA, 1995).
Dramatic enhancements in both water and petroleum product recovery rates resulting from the
large hydraulic gradients attainable with DPE systems have been reported (EPA, 1995). The
depressed groundwater table that results from theses high recovery rates serves both to
hydraulically control groundwater migration and to increase the efficiency of vapor extraction.
A flow diagram for DPE is presented in Figure 3-1.
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Figure 3-1 Flow Diagram for DPE
3.3.1.2 Bioslurping
Bioslurping utilizes vacuum-enhanced free NAPL recovery in process very similar to DPE. The
primary difference between bioslurping and DPE is that bioslurping uses a single pump design,
while DPE uses a multi-pump design. Vacuum-enhanced free-product recovery extracts
LNAPLs from the capillary fringe and the water table. Bioslurping combines elements of both
technologies to simultaneously recover NAPL and bioremediate vadose zone soils (FRTR,
2007).
The single pump system utilized by bioslurping relies on high-velocity airflow to lift suspended
liquid droplets upward by frictional drag through an extraction tube to the ground surface. This
technology can be used to extract groundwater combinations of separate-phase product and
groundwater. Bioslurping is generally better suited to low-permeability conditions than DPE,
although they are difficult to implement at sites where natural fluctuations in groundwater levels
are substantial (EPA, 1995).
Bioslurping can improve free-product recovery efficiency without extracting large quantities of
groundwater. In bioslurping, vacuum-enhanced pumping allows LNAPL to be lifted off the
Groundwater and Product Extraction
Groundwater/Product Separator
Product Storage
Groundwater Treatment
Soil Vapor Extraction Air Emission Off-Gas
Treatment
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water table and released from the capillary fringe. This minimizes changes in the water table
elevation which minimizes the creation of a smear zone. Bioventing of vadose zone soils is
achieved by drawing air into the soil due to withdrawing soil gas via the recovery well. The
system is designed to minimize environmental discharge of groundwater and soil gas. When
free-product removal activities are completed, the bioslurping system is easily converted to a
conventional bioventing or biosparging system to complete the remediation via enhanced
bioremediation. The system is otherwise similar to DPE, as described in Section 3.3.1.1.
A flow diagram for bioslurping is presented in Figure 3-2.
Figure 3-2 Bioslurping Flow Diagram
3.3.1.3 Infiltration Gallery Collection
Infiltration gallery collection is a fairly straightforward method of NAPL removal. Extraction
trenches are dug below the surface of the water table, and stabilized with porous sidewalls that
allow the upper layer of groundwater (which will include the NAPL) to collect in the trenches.
Skimmers and/or sump pumps are then used to collect groundwater and NAPL, which is treated
using an ex situ treatment technology after being separated. Further percolation of NAPL and
groundwater through the porous sidewalls due to passive diffusion and rainwater infiltration
allows further product to be recovered and treated.
Sumultaneous Gas and Liquid Extraction
Aboveground Phase Separator
Air Emission Off-Gas Treatment
Groundwater/Product Separator
Product Storage
Groundwater Treatment
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Soil removed to install the trenches will need to be segregated into clean overburden and
contaminated soil. Contaminated soil must be treated using an ex situ treatment technology,
which is typically landfarming (since it is the simplest to implement). Clean overburden will be
stockpiled near the site and used as clean fill once NAPL removal is complete. Treated soil will
also be used as fill once NAPL removal is complete.
Infiltration galleries are essentially an ex situ groundwater treatment technology, but allows a
specific strata of groundwater to be targeted for treatment. Since the NAPL present at the Roi-
Namur POL Yard Spill Site is a LNAPL, it can be skimmed or pumped off of the surface with
little residual groundwater collection, especially if hydrophobic collection materials are used to
segregate product. This will provide less drawdown from surrounding groundwater, and will also
allow the most affected groundwater to be drawn into the trenches (less mixing will occur). The
overall goal is the collection of NAPL with little recovery of groundwater.
3.3.2 Remedial Options
The main principle behind the remedial options is to reduce residual concentrations left from the
NAPL removal action to levels where no risk remains to potential receptors. Due to site-specific
constraints, only two options are presented below.
3.3.2.1 Enhanced Bioremediation
Enhanced bioremediation technologies are used to accelerate naturally occurring in situ
bioremediation of petroleum hydrocarbons, and some fuel oxygenates, primarily by indigenous
microorganisms in the subsurface. Most of these technologies work by providing a supplemental
supply of oxygen to the subsurface (although other nutrients can also be supplemented), which
becomes available to aerobic, hydrocarbon-degrading bacteria. The stoichiometric ratio of
oxygen per hydrocarbon is 3 moles oxygen gas (O2) per 1 mole of hydrocarbons. Oxygen is
considered by many to be the primary growth-limiting factor for hydrocarbon-degrading
bacteria, but it is normally depleted in zones that have been contaminated with hydrocarbons. By
using these technologies, rates of biodegradation of petroleum hydrocarbons can be increased at
least one, and sometimes several, orders of magnitude over naturally-occurring, non-stimulated
rates (EPA, 2004).
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Most enhanced bioremediation technologies primarily address petroleum hydrocarbons
(typically, mid-weight petroleum products like diesel fuel) and some oxygenates that are
dissolved in groundwater or are sorbed to soil particles in the saturated zone. The technologies
are typically employed outside heavily contaminated source areas which will usually be
addressed by more aggressive remedial approaches. It is generally not practical to use this
technology to address free mobile product or petroleum contamination in low permeability soil
(EPA, 2004).
Enhanced bioremediation may be classified as a long-term technology which may take several
years for cleanup of a plume. It is discussed for each matrix separately in the following sections.
3.3.2.1.1 Soil
The activity of naturally occurring microbes is stimulated by circulating water-based solutions
through contaminated soils to enhance in situ biological degradation of organic contaminants or
immobilization of inorganic contaminants. Nutrients, oxygen, or other amendments may be used
to enhance bioremediation and contaminant desorption from subsurface materials (FRTR, 2007).
In the presence of sufficient oxygen (aerobic conditions), and other nutrient elements,
microorganisms will ultimately convert many organic contaminants to carbon dioxide, water,
and microbial cell mass. Enhanced bioremediation of soil typically involves the percolation or
injection of groundwater or uncontaminated water mixed with nutrients and saturated with
dissolved oxygen (DO). Oxygen is typically supplied via oxygen releasing compounds, hydrogen
peroxide infiltration, pure oxygen injection, ozone injection, or bioventing. Sometimes
acclimated microorganisms (bioaugmentation) are also added. An infiltration gallery or spray
irrigation is typically used for shallow contaminated soils, and injection wells are used for deeper
contaminated soils.
Aerobic conditions in soil can be enhanced using bioventing, which uses low airflow rates to
provide only enough oxygen to sustain microbial activity. Oxygen is most commonly supplied
through direct air injection into residual contamination in soil. In addition to degradation of
adsorbed fuel residuals, volatile compounds are biodegraded as vapors move slowly through
biologically active soil.
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In the absence of oxygen (anaerobic conditions), the organic contaminants will be ultimately
metabolized to methane, limited amounts of carbon dioxide, and trace amounts of hydrogen gas.
Under sulfate-reduction conditions, sulfate is converted to sulfide or elemental sulfur, and under
nitrate-reduction conditions, nitrogen gas is ultimately produced (FRTR, 2007).
3.3.2.1.2 Groundwater
The rate of bioremediation of organic contaminants by microbes is enhanced by increasing the
concentration of electron acceptors and nutrients in groundwater. Oxygen is the main electron
acceptor for aerobic bioremediation. Nitrate and sulfate serve as alternative electron acceptors
under anaerobic conditions.
Biosparging (akin to bioventing, but below the vadose zone; also called air sparging) below the
water table increases groundwater oxygen concentration and enhances the rate of biological
degradation of organic contaminants by naturally occurring microbes. Biosparging also increases
mixing in the saturated zone, which increases the contact between groundwater and soil. The
ease and relatively low cost of installing small-diameter air injection points allows considerable
flexibility in the design and construction of a remediation system (EPA, 2004).
Oxygen releasing compounds, hydrogen peroxide infiltration, pure oxygen injection, and ozone
injection can also be used to stimulate an aerobic environment. During these activities, a dilute
solution is circulated through the contaminated groundwater zone to increase the oxygen content
of groundwater and enhance the rate of aerobic biodegradation of organic contaminants by
naturally occurring microbes.
In nitrogen-limited environments, nitrate can be circulated to increase anaerobic biodegradation.
Solubilized nitrate is circulated throughout groundwater contamination zones to provide an
alternative electron acceptor for biological activity and enhance the rate of degradation of
organic contaminants. This technology enhances the anaerobic biodegradation through the
addition of nitrate (FRTR, 2007).
3.3.2.2 Thermal Treatment
Thermal treatment is discussed for each matrix separately in the following sections.
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3.3.2.2.1 Soil
Thermally enhanced soil vapor extraction (SVE) is a full-scale technology that uses electrical
resistance/electromagnetic/fiber, optic/radio frequency heating, or hot-air/steam injection to
increase the volatilization rate of semi-volatiles and facilitate extraction. The process is
otherwise similar to standard SVE, but requires heat resistant extraction wells (FRTR, 2007).
Electrical resistance heating uses an electrical current to heat less permeable soils so that water
and contaminants trapped in these relatively conductive regions are vaporized and ready for
vacuum extraction. Electrodes are placed directly into the less permeable soil matrix and
activated so that electrical current passes through the soil, creating a resistance which then heats
the soil. The heat dries out the soil causing it to fracture. These fractures make the soil more
permeable allowing the use of SVE to remove the contaminants. The heat created by electrical
resistance heating also forces trapped liquids to vaporize and move to the steam zone for removal
by SVE (FRTR, 2007).
Radio frequency heating (RFH) is an in situ process that uses electromagnetic energy to heat soil
and enhance SVE. RFH technique heats a discrete volume of soil using rows of vertical
electrodes embedded in soil (or other media). Heated soil volumes are bounded by two rows of
ground electrodes with energy applied to a third row midway between the ground rows. The
three rows act as a buried triplate capacitor. When energy is applied to the electrode array,
heating begins at the top center and proceeds vertically downward and laterally outward through
the soil volume. The technique can heat soils to over 300 degrees Celsius (°C).
RFH enhances SVE in four ways: (1) contaminant vapor pressure and diffusivity are increased
by heating, (2) the soil permeability is increased by drying, (3) an increase in the volatility of the
contaminant from in situ steam stripping by the water vapor; and, (4) a decrease in the viscosity
which improves mobility. The technology is self limiting; as the soil heats and dries, current will
stop flowing. Extracted vapor can then be treated by a variety of existing technologies, such as
granular activated carbon or incineration.
In hot air or steam injection, hot air or steam (or water) is injected below the contaminated zone
to heat up contaminated soil. The heating enhances the release of contaminants from the soil
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matrix in the same manner as RFH. Some VOCs and SVOCs are stripped from contaminated
zone and brought to the surface through SVE.
Thermally enhanced SVE is normally a short- to medium-term technology (FRTR, 2007).
3.3.2.2.2 Groundwater
Steam is forced into an aquifer through injection wells to vaporize volatile and semivolatile
contaminants. Vaporized components rise to the unsaturated (vadose) zone where they are
removed by vacuum extraction and then treated. In situ biological treatment may follow the
displacement and is continued until ground water contaminants concentrations satisfy statutory
requirements (FRTR, 2007).
The process can be used to remove large portions of oily waste accumulations and to retard
downward and lateral migration of organic contaminants. The process is applicable to areas with
shallow and deep contamination, and readily available mobile equipment can be used.
Hot water/steam injection is typically short to medium duration, lasting a few weeks to several
months.
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4.0 ENGINEERING EVAULATION AND COST ANALYSIS OF
ALTERNATIVES
Each technology described above was analyzed for effectiveness, implementability, and cost, as
prescribed by UES 3-6.5.8(g)(1)(iii) for RAMs/FSs. Each technology was categorized into
NAPL removal options and remedial options. Technologies were evaluated according to UES 3-
6.5.8(n)(1) and (2).
For cost analysis, Remedial Action Cost Engineering and Requirements (RACER) software was
used to estimate site-specific costs. Note that these costs are only estimates and do not represent
real-world value, since cost is modeled without consideration of the unique components of the
site. However, these estimates can be used for comparative purposes for cost analysis since the
calculations are based on the same assumptions. RACER supporting documentation can be found
in Appendix B, which includes detailed cost outlines and a list of assumptions for each cost
estimate.
The detailed evaluation is presented in Appendix C. A summary is presented below, along with a
comparison of the alternatives.
4.1 NAPL REMOVAL OPTIONS
4.1.1 Dual Phase Extraction
DPE is often selected because it enhances groundwater and/or product recovery rates, especially
in layered, fine-grained soils. The application of DPE also maximizes the effectiveness of SVE
by lowering the water table and therefore increasing air-phase permeabilities in the vadose zone.
4.1.1.1 Effectiveness
The EPA recommends an initial screening for effectiveness before a more detailed analysis is
conducted (EPA, 1995). For DPE, systems, the initial screening focuses on two parameters:
permeability of the petroleum-contaminated soils, and volatility of the petroleum constituents.
Permeability affects the rates at which groundwater and soil vapors can be extracted and controls
the pore volume exchange rate; this can be generalized by soil type. Volatility determines the
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rate at and degree to which petroleum constituents will vaporize to the soil vapor state; volatility
can be estimated by boiling point. These two parameters will indicate whether the site is
amenable to DPE, as extraction efficiency is largely dependent on these generalized parameters.
The majority of the Roi-Namur POL Yard Spill Site is located on dredge fill, containing
unconsolidated fine- to coarse-grain coralline sand with some gravel and/or medium to large
coral fragments. This dredge fill is present to below the level of groundwater over most of the
site. The underlying natural geology (as determined by soil boring logs – see Appendix D),
which is present at decreasing depths over the more northern sections of the site, is also layered
coralline sand of similar composition. According to EPA guidance, silty or clean sand has an
intrinsic permeability of between approximately 10-10
and 10-5
square centimeters (cm2),
indicating that DPE will be effective or highly effective in these soils (EPA, 1995).
The main source of contamination at the Roi-Namur POL Yard Spill Site is diesel fuel, although
heavier oils and also solvents may also be present due to an oil/solvent pit that was historically
operated just south of the two storage ASTs (Figure 1-1). EPA guidance indicates that diesel fuel
is amenable for DPE systems, and will be of average effectiveness. For solvents, DPE will be
more effective, while for heavier oils, it will be less effective; however, since this would be the
first remediation step in a treatment train, the remaining constituents can be treated using other
means (described in Section 3.3.2).
Since initial screening has confirmed the DPE will potentially be effective, a more detailed
analysis of effectiveness was conducted and is presented in Appendix C. Effectiveness of the
DPE system depends on the following site characteristics and chemical properties (EPA, 1995):
Site Characteristics
Intrinsic permeability
Soil structure and stratification
Moisture content in the unsaturated zone
Depth to groundwater
Chemical Properties
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Effective volatility
Chemical sorptive capacity
Table 4-1 summarizes the effectiveness of DPE for known conditions at the site along with a
summarized explanation.
Table 4-1 DPE Effectiveness Evaluation
Parameter Effective? Reason
Site Characteristics
Intrinsic
permeability
Yes Intrinsic permeability most likely lies between 10-8
to 10-5
cm2, in the highly effective range.
Soil structure and
stratification
Yes While definite stratification exists in sections below fill
material, most layers are primarily composed of sand, with
little finer materials noted.
Moisture content
in the unsaturated
zone
No High moisture content in the soil would mean higher
amounts of groundwater would be extracted and need to be
processed.
Depth to
groundwater
No Depth to groundwater is very shallow, usually located at
approximately 6 feet bgs. This indicates a high potential for
air-flow short circuiting to the surface. Additionally,
groundwater levels fluctuate at the site due to tidal forces.
This would cause further design complexities.
Chemical Properties
Effective volatility Yes Chemical-specific parameters indicate low volatility of
contaminants. However, the system could be designed to
extract NAPL on the groundwater surface, increasing
effectiveness.
Chemical sorptive
capacity
No Chemical-specific parameters indicate that the contaminants
would adhere to the soil rather than dissolve in soil moisture,
indicating low effectiveness. However, further site-specific
data is required to estimate effectiveness.
4.1.1.2 Implementability
The applicable advantages and disadvantages of DPE systems are presented below, derived from
generalized advantages and disadvantages presented by the EPA (EPA, 1995).
Advantages:
Proven performance under a wide range of conditions; readily available equipment.
Minimal disturbance to site operations.
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Short treatment times (usually six months to two years under optimal conditions).
Flexible applications to sites with water table fluctuations or widely ranging
permeabilities.
Can be applied to sites with floating product, and can be combined with other
technologies, such as bioremediation.
Can be used under buildings and other locations that cannot be excavated.
Disadvantages:
May require costly oil/water separation and groundwater treatment.
Requires complex monitoring and control during operation.
4.1.1.3 Cost
The key cost drivers are (FRTR, 2007):
Soil Type
o Soil type determines permeability, which is the primary cost driver. DPE
extraction works best for permeable sand-silt mixtures. Impermeable (clayey) or
excessively permeable (gravel/sand) soils are more difficult to implement.
Depth to Base of Contamination
o Depth to the base of contamination is the secondary driver, as an increased
thickness and depth of contaminated groundwater increases cost.
A rough estimate for a cost of small and large sites for VOC contamination, being both easy (soil
composed of sand-silt/silty-sand mixture) and difficult (soil composed of silt/silty-clay mixture)
and using carbon adsorption for gas and liquid treatment, range from $23,460 to $54,545 per
1000 cubic yards (CYs) processed (this would not include additional shipping costs for required
materials to reach the atoll, nor difficulties encountered from inefficiencies described in the
above sections) (FTRT, 2007). This brings the total cost to somewhere between approximately
$525,000 and $1,220,000, assuming an affected area of 150,000 square feet and the affected
depth of 4 to 8 feet bgs.
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RACER software was used to estimate site-specific costs for DPE at the Roi-Namur POL Yard
Spill Site. Assuming that vapor emissions were processed using carbon adsorption filters,
product and groundwater mix were processed using an oil/water separator, and NAPL was
drummed before being burned on-site, the cost of NAPL removal was approximately $1,400,000
(including mark-up and professional labor management). Direct costs for this estimate compare
to the range of costs noted above.
4.1.2 Bioslurping
Bioslurping is very similar to DPE, but uses a single-pump design to extract contamination
groundwater, floating product, and soil gas. The system is also amenable to conversion into a
traditional bioventing system after extraction is complete. It is a cost-effective in situ remedial
technology that simultaneously accomplishes LNAPL removal and soil remediation in the
vadose zone.
4.1.2.1 Effectiveness
The discussion for effectiveness of DPE systems also applies to bioslurping systems, since the
concept behind the technologies is the same (see Section 4.1.1.1). Differences in the systems are
described in the Implementability sections.
Additionally, two case studies are noted in the FRTR technologies guidance, and are described
below.
The U.S. Navy has used bioslurping at Naval Aviation Facility in Fallon, Nevada. This system
was able to remove 6,500 gallons of JP-5 jet fuel during 1993, with operation 75% of the time
(FRTR, 2007).
The U.S. Air Force used a bioslurper on the island of Diego Garcia to pull out JP-5 at the site
where jet fuel leaked into the ground during the Persian Gulf War. The recovery rate of JP-5
averaged about 1,000 gallons per month (FRTR, 2007).
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4.1.2.2 Implementability
The applicable advantages and disadvantages of bioslurping systems are presented below,
derived from generalized advantages and disadvantages presented by the EPA (EPA, 1995).
Advantages
Proven performance in low-permeability soils. Requires no down-hole pumps.
Minimal disturbance to site operations.
Short treatment times (usually six months to two years under optimal conditions).
Can be applied at sites with floating product, and can be combined with other
technologies, such as bioremediation.
Can be used under buildings and other locations that cannot be excavated.
Disadvantages
Difficult to apply to sites where the water table fluctuates.
Treatment may be expensive for extracted vapors and for oil-water separation.
Can extract a large volume of groundwater that may require treatment.
Requires specialized equipment with sophisticated control capacity
Requires complex monitoring and control during operation.
4.1.2.3 Cost
Bioslurping of LNAPL at multiple Air Force sites had an average cost of $56 per gallon of
LNAPL recovered (FRTR, 2007). Assuming 10,000 gallons remain at the site (a conservative
estimate based on the amount of product known to have spilled and known to have been
recovered), this gives an estimated cost of $560,000; however, this cost estimate is likely low,
since conditions and the isolated location of Roi-Namur Island will drive up costs considerably,
and will likely be only slightly lower than the estimated costs for DPE presented in Section
4.1.1.3.
RACER software was used to estimate site-specific costs for bioslurping at the Roi-Namur POL
Yard Spill Site. Assuming that vapor emissions were processed using carbon adsorption filters,
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product and groundwater mix were processed using an oil/water separator, and NAPL was
drummed before being burned on-site, the cost of NAPL removal was approximately $2,000,000
(including mark-up and professional labor management).
4.1.3 Infiltration Galleries
Infiltration galleries are trenches installed to a level below the surface of groundwater, with
porous wall stabilizers that allow product and groundwater to pool in the trenches. Sump pumps
or skimmers are used to extract product and groundwater, which continues to refill into the
trenches due to passive diffusion from the hydraulic gradient and groundwater flow.
4.1.3.1 Effectiveness
Effectiveness of infiltration gallery extraction depends primarily on the ability of product to flow
into the collection trenches, and then the success of product collection from these trenches (EPA,
1996).
The fate-and-transport of liquid petroleum products in the subsurface is determined primarily by
the properties of the liquid and the characteristics of the geologic media into which the product
has been released. Properties that determine the effectiveness include (EPA, 1996):
Chemical Properties
Density
Viscosity
Interfacial tension
Soil Properties
Porosity
Permeability
Combined Properties
Chemical sorptive capacity
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Capillary pressure
Relative permeability
Wettability
Saturation
Residual Saturation
Table 4-2 summarizes the effectiveness of infiltration galleries for known conditions at the site
along with a summarized explanation.
4.1.3.2 Implementability
The advantages and disadvantages of infiltration gallery NAPL removal are described below.
Advantages
Works with and enhances natural in situ processes already at play (typically uses natural
groundwater gradient, naturally occurring biodegradation)
Can be a low-energy approach
Can have simple operation and monitoring requirements
Can be used in tandem with other remedial technologies that address small amounts of
residual soil and groundwater contamination
Short treatment times (usually six months to two years under optimal conditions)
Can be applied at sites with floating product, and can be combined with other
technologies, such as bioremediation
Can be used to control migration of contaminants (e.g., flow into the lagoon)
Disadvantages
Can extract groundwater that may require oil-water separation and treatment
Requires specialized equipment with sophisticated control capacity
Will not be able to reduce contaminants to background or very low concentrations
Must be accompanied by other technologies to address residual contamination
May require significant trenching to be effective
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Table 4-2 Infiltration Galleries Effectiveness Evaluation
Parameter Effective? Reason
Chemical Properties
Density Yes NAPL density is less than that of water, so it will
be amenable to collection in trenches.
Viscosity Yes Since diesel fuel (even when emulsified) and
water have relatively low viscosities, they can be
expected to flow through a porous medium fairly
easily.
Interfacial
tension
N/A Effectiveness due to interfacial tension is included
in the discussion of other parameters.
Soil Properties
Porosity N/A The calculated porosity is quite porous (the
material is primarily unconsolidated fill material),
indicating that large volumes of liquid can be held
in the soil.
Permeability Yes Estimated permeability values indicate that soils
are fairly permeable, meaning the soils are
amenable to fluid flow.
Combined Properties
Chemical
sorptive
capacity
No Chemical-specific parameters indicate that the
contaminants would adhere to the soil rather than
dissolve in soil moisture, indicating low
effectiveness. However, further site-specific data
is required to estimate effectiveness.
Capillary
pressure
N/A Additional measurements are required to estimate
effectiveness for infiltration galleries based on
this parameter.
Relative
permeability
No Since NAPL at the site is emulsified, there is
likely a mix of water and diesel fuel near the
water table, which means that the relative
permeability would be reduced. However,
rainwater flow through would help flush
contaminants in the pore space.
Wettability N/A A factor in other parameters
Saturation N/A A factor in other parameters
Residual
saturation
No Residual saturation levels tend to be much higher
in the saturated zone than in the unsaturated zone.
There are multiple types of NAPL removal systems that can be used to extract NAPL from
collection trenches with little collection of groundwater. Either a floating collection apparatus or
a belt skimmer would be the best options for NAPL removal. Rationale for this conclusion is
presented in Appendix C.
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4.1.3.3 Cost
Since infiltration galleries were not included in the FRTR screening matrix, RACER software
alone was used to estimate site-specific costs for this NAPL removal strategy. Assuming that 900
feet of trenching was installed, NAPL was removed with belt skimmers powered by solar panels,
clean overburden was stockpiled, contaminated soil was landfarmed, and the NAPL could be
stored in drums before being burned on-site, the total cost was estimated to be approximately
$850,000 (including mark-up and professional labor management).
4.2 REMEDIAL OPTIONS
4.2.1 Enhanced Bioremediation
Enhanced bioremediation technologies are used to accelerate naturally occurring in situ
bioremediation of contaminants by indigenous microorganisms in the subsurface. The basic
principle is to supply these microorganisms with the necessary nutrients to optimize contaminant
degradation rates.
4.2.1.1 Effectiveness
The EPA recommends an initial screening for effectiveness before a more detailed analysis is
conducted (EPA, 2004). For enhanced bioremediation systems, the initial screening focuses on
the following overall assessments for viability:
Free mobile product is present and the corrective action plan does not include plans for
its recovery.
Potentially excessive risks to human health or the environment have been identified and
the corrective action plan does not include a supplemental mitigation plan.
The target contaminant zone includes unstratified dense clay.
None of these conditions are true for the Roi-Namur POL Yard Spill Site. While free mobile
product is present, enhanced bioremediation is being considered as the step following product
removal in a treatment train. Likewise, since risk to human health has been identified at the site
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from RSL exceedances, a more rapid remedial approach is being considered for the NAPL
removal, which will mitigate these risks.
Since initial screening has confirmed enhanced bioremediation will potentially be effective, a
more detailed analysis of effectiveness was conducted. The analysis primarily focused on
enhanced aerobic bioremediation, although enhanced anaerobic bioremediation was also
mentioned. Many factors influence the effectiveness of enhanced bioremediation at a site, and
include (EPA, 2004):
Site Characteristics
Oxygen demand factors
Oxygen demand from biodegradation of organic compounds
Microbial population
Nutrients
pH
Temperature
Inorganic oxygen demand
Advective and Dispersive Transport Factors
Intrinsic permeability
Soil structure and stratification
Hydraulic gradient
Depth to groundwater
Iron and other reduced inorganic compounds dissolved in groundwater
Constituent Characteristics
Chemical class and susceptibility to bioremediation
Contaminant phase distribution
Concentration and toxicity
Bioavailability characteristics (solubility and Koc factor).
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It should also be noted that the two most important factors to consider for enhanced
bioremediation effectiveness are saturated soil permeability and chemical-specific
biodegradability, so these parameters were given higher consideration when determining overall
effectiveness of this technology. Table 4-3 summarizes the effectiveness of enhanced
bioremediation for known conditions at the site along with a summarized explanation.
4.2.1.2 Implementability
The applicable advantages and disadvantages of enhanced bioremediation systems are described
below, as derived from generalized advantages and disadvantages (EPA, 2004).
Advantages
Works with and enhances natural in situ processes already at play (typically uses natural
groundwater gradient, naturally occurring biodegradation)
Destroys the petroleum contamination in place.
Produces no significant wastes (off-gases or fluid discharges)
Can be a low-energy approach
Is relatively inexpensive
Complements more aggressive technologies (e.g., groundwater extraction) and less
aggressive approaches (e.g., intrinsic remediation) that can be integrated into site
remediation.
Causes minimal disturbance to site operations
Has simple operation and monitoring requirements
Is potentially more reliable than other, more active remedial technologies (e.g.,
groundwater extraction and treatment)
Can be used in tandem with other remedial technologies that address small amounts of
residual soil and groundwater contamination
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Table 4-3 Enhanced Bioremediation Effectiveness Evaluation
Parameter Effective? Reason
Site Characteristics
Oxygen demand
factors Yes
Dissolved oxygen readings indicate that groundwater is fairly easily
oxygenated
Oxygen demand
from
biodegradation of
organic compounds
N/A
Depending on the effectiveness of the NAPL removal technology
utilized, the residual levels of petroleum hydrocarbon contamination
remaining on site could vary substantially.
Microbial
population Yes
Studies have shown that microorganisms exist that are adapted and
able to degrade hydrocarbon contaminants (ORNL, 1991a)
Nutrients No Supplements would likely be required to ensure enhanced
bioremediation would be effective.
pH Yes Groundwater is closely centered on pH 7, meaning that it is amenable
to enhanced bioremediation.
Temperature Yes Temperatures are in the range for highly effective enhanced
bioremediation.
Inorganic oxygen
demand Yes
Analytical results indicate that inorganic oxygen demand would be
low.
Advective and Dispersive Transport Factors
Intrinsic
permeability Yes
Enhanced bioremediation is effective if the intrinsic permeability is
greater than approximately 10-9 cm2 (EPA, 2004), which estimates
indicate is the case.
Soil structure and
stratification Yes
Soil boring logs and grain size analysis indicates that the existing
geology is amenable to enhanced bioremediation.
Hydraulic gradient No Hydraulic gradient is assumed to be relatively flat.
Depth to
groundwater Yes
The shallow depth to groundwater will likely make oxygenation more
effective than for deeper water.
Iron and other
reduced inorganic
compounds
dissolved in
groundwater
No Analysis of groundwater indicates that these components are not
present in significant quantities.
Constituent Characteristics
Chemical class and
susceptibility to
bioremediation
Yes
According to the EPA, DRO (the primary COC) and GRO are
amenable to biodegradation, and are approximately in the middle of
the range for effective degradation (EPA, 2004).
Contaminant phase
distribution N/A
The success of the removal action will determine the success of
enhanced bioremediation.
Concentration and
toxicity N/A
The success of the removal action will determine the success of
enhanced bioremediation.
Bioavailability
characteristics
(solubility and Koc
factor)
No
Chemical-specific parameters indicate that the contaminants would
adhere to the soil rather than dissolve in soil moisture, indicating low
effectiveness. However, further site-specific data is required to
estimate effectiveness.
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Disadvantages
May have longer remedial time frames than more aggressive approaches
May not be able to reduce contaminants to background or very low concentrations
Typically requires long-term monitoring of residual contamination in soil and
groundwater
May not be fully effective on all petroleum hydrocarbons and product additives
Can be misapplied to remediation at some sites if the conditions for use are not fully
understood
Contamination at the Roi-Namur POL Yard Spill Site is primarily in the saturated zone, with
NAPL floating on the groundwater. Evaluation of all oxygenation techniques indicated that
oxygen releasing compounds or biosparging would be the best options to implement. Rationale
for this conclusion is presented in Appendix C.
Additional site-specific factors that may limit the implementability enhanced bioremediation at
the Roi-Namur POL Yard Spill Site include:
Inadequate removal of NAPL could retard microbial proliferation.
High contaminant concentrations have been found in groundwater close to the lagoon that
has high levels of dissolved ions; previous studies have not been performed to indicate
how salinity affects microbial degradation of hydrocarbon contamination.
4.2.1.3 Cost
Bioremediation treatment does not require heating, requires relatively inexpensive inputs, such
as nutrients, and usually does not generate residuals requiring additional treatment or disposal.
Also, when conducted in situ, it does not require excavation of contaminated media. Compared
with other technologies, such as thermally enhanced recovery (discussed in Section 4.2.2),
bioremediation may provide a cost advantage (FRTR, 2007).
Typical costs for enhanced bioremediation range from $20 to $80 per CY of soil (not including
material, equipment, and personnel transportation costs or personnel wages); total costs from
these estimates would be from approximately $650,000 to $2,500,000, assuming an affected
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volume of approximately 32,074 CY (4 to 8 feet bgs over 216,500 square feet). Factors that
affect cost include the soil type and chemistry, type and quantity of amendments used, and type
and extent of contamination. Effectiveness of developed systems increases with time.
Infrastructure used for bioventing/biosparging activities associated with bioslurping could be
used as an injection well for air or other nutrients to reduce installation costs (FRTR, 2007).
RACER software was used to calculate a site-specific estimate of the costs for enhanced
bioremediation at the Roi-Namur POL Yard Spill Site, using biosparging and injection wells.
Total costs, including mark-up and professional labor management, were approximately
$2,800,000; excluding mark-ups, this is within the cost estimates noted above.
4.2.2 Thermal Treatment
Thermal treatment uses electrical resistance/electromagnetic/fiber, optic/radio frequency heating,
or hot-air/steam/hot water injection to increase the volatilization rate of semi-volatiles and
facilitate extraction. The process is otherwise similar to standard SVE, but requires heat resistant
extraction wells.
4.2.2.1 Effectiveness
Factors that may limit the applicability and effectiveness of the process include (FRTR, 2007):
Soil type, contaminant characteristics and concentrations, geology, and hydrogeology. While the
characteristics of the site geology that contribute to effectiveness are the same for standard SVE,
heat-based in situ remediation techniques can overcome or lessen the limiting contaminant
characteristics (EPA, 1997).
Table 4-4 summarizes the effectiveness of thermal treatment for known conditions at the site
along with a summarized explanation.
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Table 4-4 Thermal Treatment Effectiveness Evaluation
Parameter Effective? Reason
Intrinsic permeability Yes
Estimated permeability values indicate that
soils are fairly permeable, and would be
effective for thermal treatment
Soil structure and stratification Yes
Soil boring logs indicate that the existing
geology is amenable to thermal treatment, as
preferential flow would not be expected to
occur.
Depth to groundwater No
Special considerations must be taken at sites
where groundwater is located at less than 10
feet bgs due to groundwater upwelling and
extraction short-circuiting (EPA, 1994).
Moisture content No
The body of contamination is in soils with a
significant amount of moisture, which would
decrease effectiveness.
Chemical properties Yes Addition of heat would make extraction of
DRO and PAHs much more effective.
4.2.2.2 Implementability
The three general methods used to apply heat during thermal treatment are: injection of hot gases
such as steam or air, electromagnetic energy heating, and hot water injection. Based on a flow
chart provided by the EPA for site-specific parameters at the Roi-Namur POL Yard Spill Site,
either steam or hot water injection are the preferred methods (EPA, 1997). After a thorough
evaluation of both injection methods (presented in Appendix C), steam injection was identified
as the preferred technology. The applicable advantages and disadvantages of steam injection are
described below.
Advantages
Does not require chemicals of any sort to be injected in the subsurface
Minimal disturbance to site operations
Excavation is not required
Short treatment times
Easily combined with other technologies
Can be used under buildings and other locations that cannot be excavated
Studies and pilot studies have proven the technology to be effective in sandy soils
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Disadvantages
Residual concentrations of contaminants will likely remain
Generally more costly than ex situ procedures, especially for shallow contamination
Shallow groundwater requires special design considerations
May require costly treatment for atmospheric discharge of extracted vapors
Requires a significant amount of energy to heat up the steam
Requires treatment of extracted mixture
Complex sampling and monitoring required
Complex modeling required to design appropriate systems
4.2.2.3 Cost
The most significant factor affecting cost is the time of treatment or treatment rate. With a
mobile system, treatment rate is influenced primarily by the soil type, waste type, and on-line
efficiency. Cost estimates for this technology are strongly dependent on the treatment rate and
range. On average, the cost ranges from $100 to $300 per CY based on a 70 percent on-line
efficiency (FRTR, 2007). This means that the total cost based on an affected area of 216,500
square feet with a treatment depth of 4 feet (4 to 8 feet bgs) would be between approximately
$3,200,000 and $9,600,000.
In depth analysis using RACER software was not conducted for thermal treatment, as the
physical parameters for the site (primarily depth to contamination) do not meet the calculation
requirements of the software.
4.3 COMPARATIVE ANALYSIS OF ALTERNATIVES
Since a treatment train is necessary for complete remediation, treatment options will be discussed
in terms of NAPL removal and residual contamination remediation. Significant factors
influencing effectiveness and implementability will be discussed for each technology, and a cost
comparison for each technology can be found for each phase of the treatment train.
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4.3.1 NAPL Removal
4.3.1.1 Dual Phase Extraction
Soil properties at the site are amenable to DPE. However, high moisture content could inhibit
airflow into the subsurface, which would mean that more groundwater would be extracted with
the NAPL. Additionally, since the body of contamination is close to the surface, extraction short-
circuiting to the surface could occur, which would substantially decrease efficiency; a cap would
likely be necessary to ensure this would not happen. Contaminant properties would likely not
affect efficiency or implementability. However, the main disadvantage of DPE is that since the
product is emulsified (meaning it is suspended in groundwater), large volumes of product and
groundwater mixed together would be extracted that would require separation before the NAPL
could be disposed of. This would likely increase costs substantially.
4.3.1.2 Bioslurping
Bioslurping is almost identical to DPE, except that it is less applicable to sites with fluctuating
groundwater depths, as is the case at the Roi-Namur POL Yard Spill Site due to tidal effects.
Therefore, while bioslurping has the potential to be less expensive than DPE, it is less applicable
to the site. Otherwise, the discussion for DPE presented above also applies to bioslurping.
4.3.1.3 Infiltration Galleries
While soil properties are amenable to product flow, the relative permeability is likely low due to
emulsification of the product at the site. The soil is generally porous and has fairly high
permeabilities, but the relative permeability of the product is reduced substantially due to the
presence of water in the pores. Additionally, since the hydraulic gradient is essentially flat, flow
rates into extraction trenches would be very low, although this may be increased by the frequent
rain showers. Due to these factors, the area of effect for each trench might be limited, which
would require installation of more trenches; also, for NAPL under buildings at the site, it might
be difficult for product to migrate out from under them (especially the ASTs and associated
secondary containment). Product would also have to be separated out in the trenches before
extraction (using hydrophobic membranes or other means), otherwise oil/water separation would
be necessary.
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4.3.1.4 Cost Comparison
Since DPE and bioslurping are essentially identical, except that bioslurping is less applicable to
conditions at the Roi-Namur POL Yard Spill Site, only DPE and infiltration galleries will have
their costs compared below.
RACER software cost estimates for DPE were $1,400,000, while cost estimates for infiltration
galleries were $850,000. Additionally, costs for DPE would increase dramatically if a cap was
required to prevent short-circuiting. This uncertainty, along with the fact that extraction trenches
were used successfully at this site during initial response activities, indicates that infiltration
galleries would be the most cost-effective option for residual remediation.
4.3.2 Remedial Technologies
4.3.2.1 Enhanced Bioremediation
The geologic features at site are amenable to enhanced bioremediation. Low groundwater flow
rates would retard oxygen and nutrient dispersion, but this could be accounted for using good
engineering practices. However, the advantages are balanced out by the nature of the COCs that
remain, as they are largely insoluble and have high Koc constants, indicating that their
bioavailability would be limited. Additionally, separate phase product remains at the site, which
would have to be removed prior to the implementation of enhanced bioremediation. This means
that the success of the NAPL removal would indicate how effective enhanced bioremediation at
the site could be.
4.3.2.2 Thermal Treatment
While the geologic features at the site are amenable to thermal treatment (moisture content is
likely a little higher than ideal values), and the contaminants would also likely be amenable to
extraction once properly heated, the shallow depth to the body of contamination invalidates this
technology as a viable option for residual remediation. This is primarily due to the fact that the
overburden pressure is provided by only a few feet of soil, which would cause a high risk of
surface fracturing. Vapor recovery could potentially be an issue as well, since constituents would
be heated up significantly before extraction.
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4.3.2.3 Cost Comparison
RACER software cost estimates for enhanced bioremediation were $2,800,000, while FRTR cost
estimates for thermal treatment ranged from $3,200,000 to $9,600,000. This, along with the fact
that thermal treatment is likely an unviable option due to risks of surface fracturing, indicates
that enhanced bioremediation would be the most cost-effective option for residual remediation.
4.4 REMEDY OF RECORD
Comparisons of effectiveness, implementability, and costs indicate that a treatment train of
infiltration galleries followed by enhanced bioremediation would be the most cost effective
strategy for NAPL removal and residual remediation at the Roi-Namur POL Yard Spill Site.
Infiltration galleries were identified as the preferred NAPL removal strategy at the site primarily
due to uncertainty in the other technologies analyzed. While this technology would likely take
longer than DPE or bioslurping due to slow product migration in the subsurface, high vacuum
extraction associated with the latter technologies might not be applicable at the site due to short
circuiting from the proximity of the contamination to the surface (which would increase costs
substantially). Extraction trenches were used as part of the initial spill response at the site, so it is
known that they are at least somewhat effective for NAPL removal. Note that although
infiltration galleries would require more extensive soil excavation than for DPE or bioslurping,
the Cultural Resource Evaluation (CRE) (included as Appendix E) has indicated that this is not a
detriment since the area is located in post-WWII dredge fill and would not require monitoring.
Enhanced bioremediation was identified as the preferred overall strategy for residual remediation
at this site for multiple reasons. First, it allows the primary contaminant (DRO) to be degraded
without excavation or ex situ treatment necessary. It is also very cost effective, since it
supplements natural processes with the need for little additional infrastructure. Finally, multiple
feasibility studies and data collected during the SI (Sivuniq, 2011) have determined that
conditions on the Kwajalein Atoll are amenable for enhanced bioremediation. Results from
bioremediation parameters, as well as water quality parameters (i.e. oxygen reduction potential),
indicate that natural attenuation has occurred at the Roi-Namur POL Yard Spill Site, but is
nutrient limited.
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Design concepts for this treatment train are provided in Section 6.0. Section 7.0 provides the
management plan for implementation, including the work plan elements required by the UES.
4.5 CULTURAL RESOURCE EVALUATION
Based on the above remedy of record, a CRE was conducted on possible effects on cultural
resources during implementation of the treatment train. The CRE concluded that future
investigational and remedial activities at Roi-Namur POL Yard Spill site have little or no
probability of effects to cultural resources. This is primarily because the portion of Roi-Namur
Island where these activities will take place was created by lagoon dredging in the immediate
aftermath of World War II. The CRE is presented in its entirety in Appendix E.
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5.0 FUTURE PRE-REMOVAL ACTION ACTIVITIES
Additional design-related investigation activities beyond those completed to date are being
conducted to support the removal and remedial action design of a treatment train of infiltration
galleries followed by enhanced bioremediation. A summary of planned tasks is provided below.
These activities are a continuation of the activities initiated as part of the 2010 and 2011 SI, and
are fully outlined in the supplemental work plan (Sivuniq, 2011). Results of these activities will
be integrated into the Data Evaluation report deliverable, as well as the removal and remedial
action work plan.
Perform a site topographic survey
Install vertical control monuments to ensure site survey control
Collect soil lithology/classification data
Verify nature of soil contamination
o Sample for PCBs near the old power plant
o Sample for solvents/PCBs near the former oil spill
o Collect surface samples to support residential receptor risk assessment
Verify extent of soil contamination
o Define extent near vicinity of former wash rack (NE of containment basin)
o Define extent near septic leach field
o Define extent of soil contamination near SB63
Verify nature of groundwater contamination
o Sample for chlorinated solvents/PCBs near former wash rack
o Sample for chlorinated solvents/PCBs near former oil pit
Verify extent of groundwater contamination
o Define extent north/west of containment basin
Install network of permanent monitoring well points
Collect accurate depths to product and groundwater
LNAPL
o Accurately measure thickness of LNAPL at groundwater interface
o Characterize composition of emulsified LNAPL layer
Remediation data
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o Accurately measure microbial population as colony forming units
o Accurately measure nutrients levels up- and downgradient within holding times
Hydrogeology
o Accurately measure groundwater flow rate through formation (conductivity)
o Accurately measure head effects on lateral groundwater flow (storativity)
o Accurately define tidal influence area and magnitude with depth
Results from previous investigations, as well as results from planned activities, will be evaluated
and interpreted during the remedial design. Interpretation of this data will be included in the
design concepts described in Section 6.0. Evaluation of data collected to date and identification
of data gaps are ongoing, so design-related investigation activities beyond those listed above may
be appropriate.
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6.0 REMOVAL ACTION SYSTEM DESIGN PROCESS
This section describes the system elements, system design concepts, and schedule for the
removal action system design. The design and construction of removal action system
components will be performed concurrently, where appropriate, to expedite the removal action
schedule and allow the treatment train system design to be flexible as contaminant
concentrations change. Design drawings and plans will be included as part of the removal and
remedial action work plan, upon completion of the supplemental data collection described in
Section 5.0.
6.1 REMOVAL AND REMEDIAL ACTION SYSTEM ELEMENTS
The primary elements of the selected technologies to be used in the treatment train described in
Section 4.4 include:
Infiltration galleries
o Trenches
Stockpile clean overburden
Landfarm contaminated soil
o Trench boxes
o Belt skimmers
o Overhead power connections
o Product storage
Landfarming cell
o Tilling machine
o Cover
o Nutrient application
Enhanced bioremediation
o Injection points/air sparging points
o Injection/air pumps
o Overhead power connections
Habitat restoration
o Landfarmed soil and clean overburden as backfill
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Institutional controls during implementation
o Rope off treatment area
Long-term operation, maintenance, and monitoring
o Hazardous waste management
o Periodic sampling
o Periodic maintenance
o System optimization
6.2 DESIGN AND PERFORMANCE CRITERIA
6.2.1 Cleanup Goals
The USAKA UES (USAKA, 2011) provide a regulatory framework for restoration activities at
this site. The UES were developed from United States Government statutes, Republic of
Marshall Islands statutes and International agreements (USAKA, 2011).
A review and comparison of chemical data against published screening criteria (EPA RSLs, and
GEPA ESLs) was used to identify chemicals of potential concern; additionally, contaminants
detected in piezometers installed in the tidal zone were screened against NOAA SQuiRTs lowest
observed effect levels (LOELs), where available, to screen for ecological risk.
For matrices where at least one screening criterion exceedance was noted, all contaminants that
had maximum or upper confidence limit (UCL) 95 concentrations within 10% of applicable
screening criteria were retained as COCs (for the purposes of the data evaluation). COCs
identified at the site include benzo(a)anthracene in soil; benzo(a)pyrene in soil; GRO in soil;
naphthalene in soil; phenanthrene in soil; and DRO in soil and groundwater. All of these
contaminants will be monitored throughout the life of the removal action, and will form the basis
of performance criteria that removal efficiency is based on. Current and target COC
concentrations are presented in Table 6-1; this table will be updated after collection of the
supplemental data described in Section 5.0. Target concentrations were derived from ARARs,
which included evaluation of residential and industrial EPA RSLs and GEPA ESLs, and EPA
risk-based SSLs if there was no other applicable criteria; these screening levels were used as
planning-level target concentrations. EPA maximum contaminant level (MCL)-based SSLs were
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not used because the groundwater in the vicinity of the site is nonpotable. Target concentrations
will be refined based on pathway-specific evaluation once supplemental data is collected, and
will be reported in the Data Evaluation report deliverable pursuant to 3-6.5.8(l)(3).
Table 6-1 Current and Target COC Concentrations
Soil
Analyte Frequency UCL 95 or Maximum
(mg/kg)
Screening Criteria / Initial Target
Concentration (mg/kg)
Benzo (a) anthracene 5 / 64 0.0158 0.151
Benzo (a) pyrene 1 / 64 0.00325 0.0151
DRO 46 / 66 5,750 5002
GRO 17 / 66 14.78 1002
Naphthalene 19 / 64 1.124 3.61
Phenanthrene 27 / 64 1.462 10.692
Groundwater
Analyte Frequency UCL 95 (µg/L) Screening Criteria / Initial Target
Concentration (µg/L)
DRO 3 / 11 1,310 6402
Notes, Acronyms and Abbreviations: 1 Screening levels based on EPA residential RSLs.
2 Screening levels based on GEPA ESLs (unrestricted land-use scenario with a nonpotable water source and shallow contamination).
UCL = upper confidence limit.
6.2.2 Performance Criteria
Requirements for measuring the effectiveness of the removal action are described in UES 3-
6.5.8(i). The overall goal of the removal action is to render a NFA determination for the site,
pursuant to UES 3-6.5.8(i)(2). All supporting data and rationale to support this determination
shall be documented in a formal report which will be made available for 30 days for public
review and comment. This report will detail evidence that removal has been completed and/or
that the associated exposure risks have been reduced to acceptable levels. An NFA designation is
an endpoint, meaning that all requisite mitigation work and evaluation has been fully
implemented.
Effectiveness will be monitored throughout the project to ensure that the endpoint will be a NFA
designation; modifications to implementation will be necessary if measured effectiveness will
not achieve this endpoint. Applicable performance criteria for each phase of the removal action
are described below, along with potential modifications to the system to improve efficiency.
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6.2.2.1 NAPL Removal
The key performance criterion for the NAPL removal phase of the removal action is the NAPL
removal rate. This criterion is determined by many factors, but will primarily be based on the
ability of the NAPL to migrate through the subsurface and the holding capacity of the soil. After
supplemental data is collected, the system design will be modified to accommodate for site
conditions. Monitoring of the amount of NAPL removed, as well as the water content, will also
determine success of the removal system.
Water content in NAPL removed will primarily be a function of the belt material. Since the
contamination is primarily DRO, the belt material will be selected to be most effective at
selectively absorbing DRO. Water content in the removed material will be monitored, and
adjustments to the belt material will be implemented if the water content is too high.
The area of effect for each infiltration gallery will also determine the success of the removal
action. This will be determined by measuring product thickness in monitoring wells throughout
the site. If the NAPL is not mobile enough to be captured by the planned trenching, the location
and length of the trenches may be modified to capture as much product as possible. Additionally,
trenches will be placed in a manner to intercept any contaminant migration towards the lagoon.
Sampling on the shoreline will indicate success of trench placement in this regard.
The latent contaminant concentration after NAPL removal levels off will primarily be
determined by the holding capacity of the soil. If concentrations are still relatively high, the
injection wells planned for the residual contamination removal phase could be installed while
trenching and extraction is still in place to try and use air sparging to push contamination through
the soil (while at the same time preparing the soil for enhanced bioremediation). The higher the
residual concentration, the longer enhanced bioremediation will take.
6.2.2.2 Enhanced Bioremediation
The first performance criterion that will be measured during the residual contamination reduction
phase will be the overall oxygenation of groundwater. This will determine when nutrients are
supplied, as well as the onset of contaminant concentration reduction. This will be accomplished
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through air sparging. Modifications to air injection rates will be implemented to ensure that a
concentration of 2 mg/L of DO is achieved.
The rate of contaminant concentration reduction is a function of the amount of hydrocarbon-
degrading bacteria, the amount of available oxygen in the soil and groundwater, and the amount
of nutrients available. These components will be monitored through the duration of the removal
action, and augmented on a schedule determined by on-site conditions encountered.
The area of effect for each injection point/sparging well will determine how effectively nutrients
and oxygen are spread throughout the soil column. Collection of data to help model movement
through the soil column will be conducted during the supplement deployment. Additionally, on-
site conditions will be evaluated to determine if this modeled spacing needs to be adjusted.
The overall effectiveness of this phase is determined by the residual concentration after reduction
levels off. Presumably, contaminant reduction will level off after cleanup goals are met;
however, if this is not the case, other remedial options will be investigated and implemented to
ensure that contaminant concentrations are reduced to cleanup goals within the acceptable
timeframe.
6.3 SYSTEM DESIGN CONCEPTS
The treatment train for this removal action will consist of infiltration galleries for NAPL
removal, and enhanced bioremediation for residual contaminant reduction. The general design
for each of these systems is described below; design drawings and plans will be included as part
of the removal and remedial action work plan, upon completion of the supplemental data
collection described in Section 5.0.
6.3.1 Infiltration Galleries
The infiltration galleries will consist of 50 or 100 foot-long trenches, with trench boxes installed
in each for structural integrity as the length is progressed. Underneath the trench box, infiltration
tile for the collection of water and NAPL will be installed; porous material (i.e., gravel) will be
packed around the tile to facilitate flow. The trench will then be backfilled to surface grade with
clean native material after the trench box is removed as the length is progressed, leaving the end
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of infiltration tile open to connect with the next section (where another trench box will have
already been inserted – segmental installation along the length). This is depicted in Figure 6-1
and Figure 6-2.
Trenches will be installed in areas of equal product thickness so contaminants are not transported
to less contaminated portions of the site. The dimensions of the trenches will be 4 feet wide by 8
feet deep, to ensure that there is adequate area for product collection and that the bottom of the
trench is well below the water table. The proposed locations of these trenches are presented in
Figure 6-3. A total of 4 100-foot and 8 50-foot trenches are tentatively scheduled for installation.
Note that placement near the secondary containment was done to draw out NAPL that is
presumed to reside underneath the tanks. Also note that placement downgradient (i.e., between
the tanks and the lagoon) was done to prevent further migration of contaminants into the lagoon.
Belt skimmers tied into the Roi-Namur Island electrical infrastructure will be used to extract
NAPL from the trenches, while leaving most water in the trenches (a hydrophobic material will
be used as the belt). Extracted NAPL will be stored in 55-gallon drums at each trench to reduce
the amount of piping and heavy equipment that will be necessary for each step of the project. A
planning-level schematic is shown in Figure 6-1 and Figure 6-2.
Soil excavated to install these trenches will be divided into clean overburden and contaminated
soil. The clean overburden will be stockpiled near the site to be used as backfill, while the
contaminated soil will be moved to an area designated for landfarming (that will use containment
to ensure the contamination does not migrate into subsurface soils). The soil will be spread out in
a 1-foot thick layer, and tilled on a regular schedule; nutrients will also be added to enhance
biodegradation. These nutrients will be the same nutrients as those described below for enhanced
bioremediation, and the landfarming will be used as a feasibility study to determine what
nutrients will be required for the residual contamination reduction phase of the treatment train.
Soils will be landfarmed until they can be used as fill, preferably to backfill infiltration galleries
if the timing is appropriate.
NAPL removal rates will be monitored, and soil and groundwater samples will be collected on a
regular schedule to ensure that the removal action is effective (see Section 6.2.2). Adjustments to
infiltration gallery installation and locations will be performed as necessary. Once contaminant
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concentrations level off, the residual contaminant phase of the treatment train will be
implemented, and the trenches will be backfilled. Modification of the enhance bioremediation
phase approach will be conducted if contaminant concentrations cannot be lowered to a point
where enhanced bioremediation will be effective over the acceptable timeframe.
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Figure 6-1 Infiltration Gallery Side View and Installation Procedure
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Figure 6-2 Infiltration Gallery Planning-Level Schematic
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Figure 6-3 Proposed Initial Locations for Infiltration Gallery Installation
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6.3.2 Enhanced Bioremediation
Once NAPL removal has been initiated, injection wells will be installed in areas where
contaminant concentrations are elevated but NAPL does not exist (the fringe of the contaminant
plume). These injections wells will have a dual purpose: to be used as nutrient injection points by
mixed recirculated water from the NAPL removal process, and also to be used as air sparging
wells. Injection wells will be installed at approximately every 25 feet in the affected area;
however, this spacing will be adjusted based on the area of effect for each well (as determined
from data collected during supplemental data collection events). Positions will be moved towards
the center of the contaminant mass as NAPL is removed. Air sparging will be conducted until
groundwater oxygen reduction potentials indicate that the subsurface has 2 mg/L of DO or
higher. At this point, a step injection of nutrients will be conducted, after which air sparging will
continue at a level to keep groundwater DO concentrations at 2 mg/L or greater. Pumps used will
be tied into the Roi-Namur Island electrical infrastructure.
Soil and groundwater contaminant concentrations will be monitored, and adjustments to nutrient
injection and sparging rates will be implemented to increase reduction rates. Enhanced
bioremediation will continue until contaminant concentrations meet the cleanup goals described
in Section 6.2.1.
6.4 SCHEDULE
After obtaining all required approvals and authorizations, Sivuniq intends to execute this
proposed removal action system design in a timely fashion. Pending approvals, the fieldwork
will commence during July 2012, with the installation of removal action system structure
concluding within three months. The removal action system will be run until contaminant
concentration reduction becomes asymptotic (approximately one year, dependent on site
conditions), with landfarming of excavated soils conducted concurrently. Data will be collected
for a verification assessment upon completion of this phase.
Concurrently, the remedial action system will be installed, which will take approximately three
months. The system will then be run for approximately five years. Long-term monitoring will be
conducted over this time. Data collection, validation, and review will lead to status reports on a
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regular schedule thereafter, with a final summary document upon conclusion of long-term
monitoring. The project schedule is presented in Appendix A.
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7.0 PROPOSED WORK SUMMARY
This section summarizes the field activities planned for the restoration activities at the Roi-
Namur POL Yard Spill site, and will outline installation of components described in Section 6.1,
as well as associated sampling and monitoring activities. The work plan elements identified in
later sections and appendices to this document include screening, sampling, and analysis
strategies, safety considerations, operating procedures, and data validation approaches. Specific
and detailed procedures for these activities were included in the work plan for the SI and will be
adapted for future work at this site; the removal and remedial action work plan will provide site-
specific details beyond the generalized discussion presented in the following sections.
The SAP, presented in Section 7.3, provides generalized procedures related to the collection and
analysis of soil and water samples as well as other field activities that will be used by the Sivuniq
field team. The QAPP, presented in Section 7.4, describes the policies, organization, functional
activities, and the data quality objectives (DQOs) and measures necessary to obtain adequate
data.
The SSHP presented in Section 7.5 examines the hazards associated with performing
investigative work and describes the practices to be implemented to ensure worker safety.
An Archaeological Monitoring Plan (AMP) is provided in Section 7.6, and addresses the
significant concerns related to protecting and preserving cultural and historical resources at the
site. The generalized approach will be refined and republished in the removal and remedial
action work plan.
7.1 GENERAL FIELD ACTIVITIES
During field activities, Sivuniq and stakeholders provide active support to the field crews. The
support ensures satisfaction of logistical, advisory, and performance needs. The Sivuniq Project
Manager monitors and fills requests for personnel, material, and equipment during daily
communications with the Field Team Leader. Communication enhancements provided by
satellite telephone, Web-based platforms (i.e., SharePoint or FTP sites), and daily
teleconferences ensure that the management team and field crew share information and
coordinate activities.
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Open communication within the office environment also provides affirmative guidance to Task
Managers and staff. Appointed Task Managers lead efforts related to data compilation,
evaluation, and validation, risk assessment, and reporting.
An office-based Data Manager organizes and analyzes information from the field to guide field-
screening efforts and achieve sampling objectives. Using Geographic Information System (GIS)
based analysis tools such as Visual Sampling Plan, dynamic data analysis identifies areas of
highest likelihood for contamination. Under the accelerated site characterization process, site
sampling focuses on the identification of the source location and contaminant extent to allow risk
assessment and remedial alternative evaluation.
After completing fieldwork, the Data Manager will organize analytical laboratory data for
evaluation, validation, and presentation. The organized data allows easy review for data
completeness. Data validation involves a comprehensive review of the laboratory data to verify
conformance with quality controls; qualifiers flag any deficient data to alert data users of
possible quality concerns. Tables organize all validated data, identifying the detected
contaminants, frequency and range of detections, and statistically representative contaminant
levels.
Data reviewers compare the maximum detected soil and groundwater contaminant levels to the
published risk-based screening criteria for each site. The EPA RSLs evaluate potential human-
health risk concerns and the NOAA SQuiRTs values identify potential ecological risk drivers.
Volatile and extractable petroleum hydrocarbons, which are not cited by either reference, are
evaluated against GEPA ESLs (Guam EPA, 2008).
7.2 RESTORATION ACTIVITIES APPROACH
Due to the intrusive nature of the removal action, the first order of business includes identifying
and locating the pipelines, valves, and associated equipment at the Roi-Namur POL Yard. Each
of the necessary steps following these activities are outlined below in the following sections.
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7.2.1 Supplemental Data Collection
All field work pertaining to the supplemental data collection described in Section 5.0 is outlined
in the work plan addendum to the 2010 Sivuniq work plan (Sivuniq, 2011).
Data collected during this supplemental mobilization, as well as that collected during the original
SI mobilization, will be used as a baseline for removal action/remediation efficiency.
7.2.2 Subsurface Modeling and Design Finalization
After collection of supplemental data, subsurface modeling of contaminant fate and transport
will be conducted, along with modeling for oxygen and nutrient dispersal for the
sparging/injection wells. Final designs will be developed based on the results of this modeling,
with revision of the remedial approach implemented if subsurface conditions indicate that the
current approach is not feasible.
7.2.3 Construction of Infiltration Galleries
Trenching will occur continuously until all infiltration tile is installed. Dig permits and utility
locates will be completed prior to initiation. Clean overburden will be stockpiled near the site, so
that it can be used as backfill once the infiltration tile has been laid in the trench. A trench box
will be used to hold up each trench, with infiltration tile installed under it. After the tile is laid
down, a porous material (gravel) will be overlain, and then clean backfill will fill the trench. As
this is happening, the trench box will be moved as the trench is extended until the trench is
completed. Contaminated soil will be moved to a landfarming cell for treatment. The entire site
area will be restricted using hard barriers against unwanted access during construction of the
infiltration galleries (as required by the UES).
Infiltration galleries will be installed based on the final designs that are developed for the
removal and remedial action work plan.
7.2.4 Installation of NAPL Extraction Equipment
After the first few trenches are excavated, the extraction equipment will be concurrently installed
to ensure system startup occurs promptly. Trenches will consist of porous material outside an
infiltration drain that is wrapped with hydrophobic material. After the trenches have been
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installed, the belt skimmer will be installed in at least the center of the length of the trench
(depending on the final design).
Once the trench is complete, the equipment used for NAPL retrieval will be connected to the belt
skimmer, and also to the 55-gallon drums used for product storage and oil/water separation.
Drums will be located within secondary containment to ensure that accidental discharge does not
occur. The system will not be connected to the on-site power grid until it is ready for startup.
7.2.5 Infiltration Galleries System Startup
Once the first infiltration gallery has been installed, it will be connected to the on-site power grid
and made ready for startup. This will be conducted concurrently with the installation of other
infiltration galleries. Once the system has stabilized, efforts will be made to optimize NAPL
extraction and ensure that the system is working in an efficient manner. Any modifications made
to the design will be implemented for the other infiltration galleries that will be concurrently
installed.
7.2.6 NAPL Removal Monitoring and Operation
Once each system has stabilized, extraction will run in pulsed waves to allow the trench to
accumulate product between each removal event. This will also facilitate waste handling, as each
of these pulses will generate waste that can then be disposed of while the trench recharges. The
amount of water in the collected waste will be monitored to ensure that the belt skimming
operation is working as designed. The interval time between pulses will be determined by on-site
conditions, and most likely correspond to rain events (that would presumably create flow into the
infiltration galleries).
7.2.7 Contaminated Soil Landfarming
While the NAPL removal system is running, active landfarming of the excavated soil that was
contaminated will be conducted. Once all of the contaminated soil has been stockpiled, it will be
spread out over a liner so that the total thickness is approximately 1 foot. Nutrients will be
supplemented during start-up, and also each time the soil is tilled. Tilling will occur on a regular
schedule twice per month. The landfarm cell will be covered unless it is being tilled, to prevent
runoff and wind erosion.
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Contaminant concentrations will be monitored using PetroFLAG test kits or other petroleum
hydrocarbon screening methods. Once screening results indicate contaminant concentrations are
low enough for the soil to be used as fill material, multi-incremental sampling will be used to
confirm the final concentration of contaminants. The soil will be used to backfill the trenches if
possible.
7.2.8 NAPL Removal Verification Assessment and Reporting
Following the NAPL removal, a verification assessment shall be conducted to evaluate whether
hazards have been adequately mitigated to support enhanced bioremediation. The verification
assessment shall include sampling and analysis in consonance with the SAP and QAPP.
Per UES 3-6.5.8(i)(2), the verification assessment and accompanying findings and
recommendations shall be provided to the appropriate agencies, which shall have a period of 30
days for review and comment. If, in conjunction with/following the agency comment period,
USAKA determines that an unacceptable risk remains, removal actions shall be continued. In
circumstances where it is determined that the immediate hazards have been mitigated, all
supporting data and rationale shall be documented in a formal report which will be made
available for 30 days for public review and comment. The report will indicate which of two
possible courses of action is proposed: 1) the mitigation efforts are deemed complete and
effective, rendering a determination of NFA/RC, or 2) potential contamination remaining may be
addressed in a non-time critical manner via the remedial actions. Since the NAPL removal is not
intended to reduce contaminant concentrations below a concentration where unacceptable risk
remains (only immediate risk), remedial actions shall be conducted as described below.
7.2.9 Installation of Injection Wells
After the infiltration galleries have been installed, injection/sparging wells will be installed after
the trenches have been backfilled. Spacing will be based on contaminant modeling and site
conditions encountered, and will cover the area where de-oxygenation of groundwater has
occurred (indicating that groundwater and soil need amendments for further biodegradation to
occur). Wells will be installed upgradient of infiltration galleries, so that water extracted during
NAPL removal can be recirculated with nutrients and oxygen to recharge the aquifer. Initial
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wells will be installed near the fringe of the contaminant plume, and additional wells installed
towards the center of the contaminant mass as NAPL is extracted by removal action activities.
7.2.10 Installation of Sparging Equipment and Pumps
After the first few wells are installed, sparging equipment and pumps will be installed on the
finished wells concurrently with the installation of the remaining wells. Nutrients will be
uniformly distributed throughout the site (in approximately 10% of the total number of wells),
and the wells used rotated through so that aeration and nutrient addition will not be found in
isolated areas.
7.2.11 Enhanced Bioremediation System Startup
Once the first injection/sparging well has been installed, it will be connected to the on-site power
grid and made ready for startup. This will be conducted concurrently with the installation of
other wells. After startup, and once the system has stabilized, efforts will be made to optimize
injection rates to ensure that the system is working in an efficient manner. Any modifications
made to the design will be implemented for the other injection wells that will be concurrently
installed. Nutrient requirements determined by contaminated soil landfarming will form the
baseline for enhanced bioremediation start-up activities.
7.2.12 Long-Term Monitoring
Air sparging will be performed continuously at flow rates necessary to keep DO concentrations
above 2 mg/L, based on site conditions encountered. Nutrients will be injected through wells on
a regular rotation schedule determined by site conditions. The objective will be to ensure that
aerobic biodegradation can occur at optimal levels.
Contaminant concentrations will be monitored in groundwater on a regular schedule throughout
the life of the removal action; soil concentrations will be monitored using soil borings on a less
frequent basis. Screening methods will be used to determine contaminant concentrations until
cleanup goals are attained. At this point, analytical confirmation samples will be collected to
verify the results of the screening. If confirmation sample results indicate that cleanup goals have
been attained, the remedial action will cease and the project will move into reporting.
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7.2.13 Project Reporting
Following contaminant concentration reduction to below cleanup goals, verification sampling
and assessment shall be conducted to evaluate whether hazards have been adequately mitigated,
pursuant to 3-6.5.8(q). This effort shall ensure:
the collection of a representative number and type of samples requisite to determine the
effectiveness of the remedial action instituted;
the appropriate cleanup or alternative standards have been achieved; and
human health, safety, and the environment have been adequately protected and restored.
A detailed SAP shall be developed and followed for this stage.
After verification sampling and assessment actions have been adequately completed, a final
project evaluation will be performed pursuant to 3-6.5.8(r). All actions and assessment
findings/rationale shall be documented and provided to the public and the Appropriate Agencies.
The remediation project manager, in consultation with the Appropriate Agencies, shall make one
of three determinations from the verification assessment performed:
Termination of remediation and a designation of NFA/response complete;
Propose modification of the selected remedy via a modification to the Document of
Environmental Protection (DEP) or completion of a new DEP for the remedial action,
modifications to the proposed remedy could include long-term monitoring and/or
institutional controls in lieu of further remedial action; or
Propose repetition of the remedial action via a modification to the DEP.
Further actions will be conducted pursuant to the determination.
7.3 SAMPLING AND ANALYSIS PLAN
Contamination at the Roi-Namur POL Yard Spill site was generally delineated during the SI and
supplemental sampling activities. However, additional soil and groundwater sampling will be
required to confirm the extent of contamination prior to completion of the remedial design and
installation of the remediation system, as well as for long-term monitoring during the
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implementation of the removal action. This section describes the sampling techniques and
methods to be used during these activities.
Visual assessments by the Field Team Leader prior to field sampling will identify surface
features, indications of contamination, or other conditions that may affect the effectiveness of the
proposed approach. Notable site features will be included in the data collection program, as
appropriate, to provide a comprehensive site investigation and support future remedial decision-
making.
Field activities include two phases of sampling – screening and confirmation. The sampling
objectives delineate the locations and extents of vapor and dissolved contaminant plumes, source
areas, and release points. Screening activities provide data to the field teams to identify
contaminant and source locations and direct field efforts. Indirect screening methods, such as
headspace vapor analysis, indicate secondary impacts from contaminants in soil and
groundwater. Direct screening measurements use infrared absorbance and turbidimetric methods
to quantify contaminants contained within the medium. Table 7-1 and Table 7-2 summarize
screening techniques for soil and groundwater, respectively. Although quality controls
procedures for screening techniques will be implemented, the data are typically qualitative or
semi quantitative in nature.
Table 7-1 Field Screening Methods for Soils
Parameter Method
Organic Headspace Vapors Physical Inspection (odor, etc.)
Photoionization Detector (PID)
Petroleum Product Sheen Screen Testing
Notes: 1 RaPIDAssay
TM Petroleum Fuels in Soil Field Test equipment provided by Strategic Diagnostics, Inc
2 PetroFLAG analyzer system provided by Dexsil Corporation
Table 7-2 Field Screening Methods for Water
Parameter Method
Organic Headspace Vapors Field Portable Gas Chromatography
Petroleum Product Sheen Screen Testing
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The second sampling phase, confirmation sampling, provides high-quality data for decision-
making purposes. Utilizing a variety of quality control in the field and at the laboratory, these
data provide the basis for definitive site characterization, risk assessment, and remedial
evaluations. The laboratory analyses that will be performed for soil and water matrices are listed
in Table 7-3 and Table 7-4.
Table 7-3 Laboratory Analytical Methods for Soils
Parameter Analytical Method
Volatile Petroleum Hydrocarbons (VPHs) EPA Method 8260B Modified
Extractable Petroleum Hydrocarbons (EPHs) EPA Method 8015B Modified
Volatile Organic Compounds (VOCs) EPA Methods 8260B
Polycyclic Aromatic Hydrocarbons (PAHs) EPA Method 8270D-SIM
Bulk Density ASTM D2937-10
Particle Size Distribution ASTM D6913-04
Total Organic Carbon (TOC) EPA Method 9060
Table 7-4 Laboratory Analytical Methods for Water
Parameter Analytical Method
Volatile Petroleum Hydrocarbons (VPHs) EPA Method 8260B Modified
Extractable Petroleum Hydrocarbons (EPHs) EPA Method 8015B Modified
Volatile Organic Compounds (VOCs) EPA Method 8260B
Ethylene dibromide (EDB) EPA Method 8011
Polycyclic Aromatic Hydrocarbons (PAHs) EPA Method 8270D-SIM
Sample collection methods vary according to the media under investigation. Soil sampling
methods include the use of direct-push equipment, hand augers, and shovels. Field crews use
manual and direct-push equipment to install groundwater sample points; permanent, pre-packed
well points will be used to provide high quality data for monitoring.
Archeological and safety concerns characterize much of Roi-Namur Island; however, this risk is
limited at the Roi-Namur POL Yard Spill site because it is located almost entirely on post-WWII
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dredge fill (since the disturbance caused by the filling operations would have likely detonated
any buried UXO). However, strict adherence to the USAKA dig permitting process will ensure
that artifacts and critical infrastructure remain protected and the worksite remains a safe
operation, even if the risk is low. Additionally, even though the proper authorities permit digging
and intrusive activities, Sivuniq field personnel must remain vigilant to the possibility of
inadvertent discoveries of artifacts, ordnance, or equipment during fieldwork.
Intrusive activities associated with soil and groundwater sampling shall be monitored by a
qualified archeological specialist implementing the AMP described in Section 7.6. Major
elements of the monitoring include GPS-positioning for all sample locations, inspection of
coring samples, and descriptive documentation of soil characteristics.
7.4 QUALITY ASSURANCE PROJECT PLAN
The QAPP addresses performance and measurement issues by identifying critical attributes and
assessment characteristics to evaluate degree of conformance to the project requirements.
Project performance characteristics generally evaluate qualitative aspects of work activities. The
measurement characteristics pertain to quantitative data and information elements.
The finalized QAPP will contain four sections to address key components of quality
management, and will be provided as part of the removal and remedial action work plan.
The Project Management section defines the project organization, roles and
responsibilities of key stakeholders, quality objectives/criteria, and recordkeeping
requirements.
The Measurement section prescribes the sampling process and methods, operating
procedures, audit schedule, and information management.
The Assessment and Oversight section details performance and technical audit systems,
data reporting, and corrective action reporting.
The Data Validation and Usability section provides scrutiny of output data to verify
appropriate uses.
The following subsections provide the planning level data quality objective parameters for the
proposed remediation projects. As the removal and remedial action work plan develops, critical
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work elements will be identified and assessment criteria developed. These criteria will then
populate the bulk of the quality assurance plan for use during project execution. Furthermore, all
analytical data obtained will have quantitation limits set below developed target concentrations
(as described in Section 6.2.1), pursuant to UES 3-5.6.8(g)(1)(iii).
7.4.1 Data Quality Objectives
After fieldwork has been completed, the Data Manager will organize analytical laboratory data
for evaluation, validation and presentation. The organized data compiled for each media and
analysis group will be reviewed to assess data for completeness. Data validation will involve a
comprehensive review of the laboratory data to verify conformance with quality controls; any
deficient data will be qualified to alert data users of possible quality concerns. Validated data
will be organized into tables to identify detected contaminants, frequency and range of
detections, and statistically representative contaminant levels. Data validation memorandums
will be developed for each data group.
The validation focuses on the DQOs specified in the QAPP in terms of Data Quality Indicators
(DQIs), which include precision, accuracy, representativeness, comparability, sensitivity, and
completeness. The quality control (QC) parameters applied to evaluating each of the DQIs are
summarized in Table 7-5.
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Table 7-5 Quality Control Parameters Corresponding to Data Quality Indicators
Data Quality Indicators QC Parameters
Precision
RPD values of:
(1) LCS/LCSD
(2) MS/MSD (or Laboratory Duplicate)
(3) Field Duplicates
Accuracy
%RPD, %R, or %D values of:
(1) Initial Calibration and Calibration Verification
(2) Surrogate Spikes
(3) Internal Standards
(4) Labeled Compounds
(5) LCS
(6) MS
Results of:
(1) Instrument and Calibration Blank
(2) Method (Preparation) Blank
(3) Trip Blank
Representativeness
(1) Results of All Blanks
(2) Sample Integrity
(3) Holding Times
Comparability
(1) Sample-specific LOQs
(2) Sample Collection Methods
(3) Laboratory Analytical Methods
Sensitivity Sample-specific LOQs
Completeness
(1) Data qualifiers
(2) Laboratory deliverables
(3) Requested/Reported valid results
Notes, Acronyms and Abbreviations:
%RSD Percent relative standard deviation
%R Percent recovery
%D Percent difference
%Df Percent drift
LCS Laboratory control sample
LCSD Laboratory control sample duplicate
MS Matrix Spike
MSD Matrix spike duplicate
PQL Practical quantitation limit
RPD Relative percent difference
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7.4.1.1 Precision
Precision is defined as the degree of mutual agreement among independent measurements as the
result of repeated application of the same process under similar conditions. Analytical precision
is evaluated by the relative percent difference (RPD) values of laboratory control
sample/laboratory control sample duplicate (LCS/LCSD) and matrix spike/matrix spike duplicate
(MS/MSD) analyses. The RPD values of field duplicate analyses represent the combined
precision of sample collection and analysis procedures, as well as sample homogeneity.
7.4.1.2 Accuracy/Bias
Accuracy is a statistical measurement of correctness and includes components of random error
(variability due to imprecision) and systemic error. It is quantified as the degree of agreement
between a measurement with a known reference. Analytical accuracy is evaluated via the
percent recovery (%R), or percent difference (%D) values of initial and continuing calibration,
internal standards, surrogate spikes, MS/MSD, and LCS/LCSD in conjunction with method
blank, calibration blank, and trip blank results. Results of blanks assist in identifying the type
and magnitude of effects contributed to the system error introduced via field and/or laboratory
procedures.
7.4.1.3 Representativeness
Representativeness is the level of confidence that the analytical data reflect the actual field
condition. Representativeness is ensured by maintaining sample integrity during collection,
preparation, and analysis. The evaluation of associated method and field blanks also assists in
identifying artifacts that may skew the representativeness of the samples.
7.4.1.4 Comparability
Comparability describes the confidence with which one data set can be compared to another data
set measuring the same property. Methods used to assess and promote comparability of data
include blanks and use of standard methods. Using standard methods throughout the data
generation processes ensures the comparability of data generated in separate sampling days or
events.
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7.4.1.5 Sensitivity
Sensitivity depicts the level of ability an analytical system (i.e., sample preparation and
instrumental analysis) of detecting a target component in a given sample matrix with a defined
level of confidence. Factors affecting the sensitivity of an analytical system include: analytical
system background (e.g., laboratory artifact or method blank contamination), sample matrix
(e.g., mass spectrometry ion ratio change, co-elution of peaks, or baseline elevation), and
instrument instability.
7.4.1.6 Completeness and Data Usability
Completeness is a measure of the amount of valid data obtained from a measurement system for
each method, analyte, and matrix. Completeness is calculated for the aggregation of data for
each analyte measured for any particular sampling event or other defined set of samples, and
reported for each method, matrix, and analyte combination. The number of valid results divided
by the number of possible individual analyte results, expressed as a percentage, determines the
completeness of the data set.
The requirement for completeness is 95% for all collected samples of a particular matrix. In the
case of samples that cannot be analyzed (because of holding time violations in which re-
sampling and analysis were not possible, samples spilled or broken, etc.), the numerator of this
calculation will be the number of valid results minus the number of possible results not reported.
7.5 SITE SAFETY AND HEALTH PLAN
The project SSHP addresses risks to personnel safety during work performance. The scope of
the SSHP includes regulatory, installation, and corporate requirements to ensure full protection
for project employees, stakeholders, and bystanders during work performance and remediation
operations.
The SSHP has two basic parts to provide general information for non-specific work hazards and
mitigation strategies to manage and control risk from specific risks derived from a job hazard
analysis. Table 7-6 provides a generalized job hazard analysis to be used as a planning-level
SSHP for the remediation projects under consideration. The SSHP is a “living document” that
grows and adapts to the project tasks as the work proceeds; routine maintenance of the document
provides job- and task specific hazard analyses and response to address new conditions. A
finalized SSHP will be delivered as an attachment to the removal and remedial action work plan.
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Table 7-6 Hazard Analyses for General Jobsite Activities
Potential Hazards Precaution
Uneven, Unstable, Slippery
Terrain Use caution when moving about excavations, berms, and soil piles.
Slip, Trip, Fall Hazards Be aware of trip hazards at the worksite, and use suitable footwear for work in rough terrain.
Maintain good housekeeping for worksite areas.
Heavy Lifting Strains/Back
Injury
Use care when lifting heavy loads.
Proper lifting techniques include bending at the knees and using leg muscles or utilizing mechanical
lifting aids.
Pinching and Drop
Hazards
Do not place hands into tight spaces.
Use care when handling heavy tools.
Wear steel-toed boots, gloves, and eye protection to avoid injury to vulnerable body parts.
Inclement Weather Stop outdoor work during storms and seek shelter.
Exposure to Heat (Air and
Water)
Utilize appropriate hot-weather PPE such as cooling vests to aid natural body ventilation; these
devices add weight, so their use should be balanced against efficiency. Use portable showers or
hose-down facilities to reduce body temperature and cool protective clothing.
Heat Stress
Drink 16 ounces of water before beginning work. Water maintained at 50°F to 60°F should be
available. Under severe conditions, drink 1 to 2 cups every 20 minutes, for a total of 1 to 2 gallons
per day. Do not use alcohol or other nonalcoholic fluids in place of water . Decrease your intake of
coffee and caffeinated soft drinks during working hours to prevent dehydration.
Acclimate yourself by slowly increasing workloads (e.g., do not begin with extremely demanding
activities).
Avoid direct sun whenever possible, as it can decrease physical efficiency and increase the
probability of heat stress. Take regular breaks in a cool, shaded area. Use a wide-brim hat or an
umbrella when working under direct sun for extended periods. Wear sunscreen (SPF30 minimum) to
prevent sunburn.
Provide adequate shelter/shade to protect personnel against radiant heat (sun, flames, hot metal).
Observe one another for signs of heat stress. Persons who experience signs of heat syncope, heat
rash, or heat cramps should consult the Site Safety Supervisor to avoid progression of a heat-related
illness.
On-site Traffic Wear high-visibility clothing.
Avoid high-traffic areas.
Low Light Conditions No field work after dark.
Working Alone Use the buddy system.
Blood-borne Pathogens
Hepatitis B, human immunodeficiency virus (HIV), and other life-threatening diseases can be
transmitted by contact with body fluids of an infected individual. When rendering first aid to another
individual, avoid contact with bodily fluids.
Noise Wear hearing protection if you have to shout to be heard by someone 3 feet away.
Heavy Equipment
Operations
Clear sites for subsurface hazards such as underground utilities and UXO.
Observe equipment operation during excavation – stay 20 feet from overhead power lines.
If UXO are suspected stop all activity, evacuate to a safe location and call Kwajalein fire
department.
Stay away from operating equipment.
Working area to be defined to exclude pedestrians.
Review equipment operation including kill switch locations.
Be aware of moving parts.
Wear hearing protection if noise levels exceed permissible exposure limits of 85 dBA.
Working Around Heavy
Equipment and Drill Rig
Operations
Stay alert.
Make sure the operator knows you are there.
Wear high-visibility vests and other required PPE.
Use hand signals to communicate with equipment operator
Wear ear protection
Trenches/Excavations
Do not enter any trenches or excavations. This plan does not cover excavation safety (OSHA
1926.650-.652), as this work will be performed by subcontractors.
Stay 4 feet from the sidewall of any exaction or trench over 4 feet deep.
Munitions and Unexploded
Ordnance
Attend orientation training to understand nature and identification of hazard
Approach all investigation activities with caution
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The finalized SSHP will provide information related to roles and responsibilities, routine and
emergency procedures, hazard classes, and generic mitigation strategies. The project manager,
field team leader, and site safety coordinator each play key roles in the plan application. All
work performers share responsibility to work safely and can shut down operations if unsafe
conditions occur. Practiced routine and emergency procedures will be enacted to ensure that
personnel know proper safety operation and response protocols. The physical, chemical, and
biological hazards for each task activity will be identified along with one or more engineering
controls or mitigation strategies.
7.6 ARCHAEOLOGICAL MONITORING PLAN
The purpose of the AMP is to define a structured plan for the identification and documentation of
potential cultural resources during the activities related to the contaminated sites investigation. A
CRE has been completed which outlines the results of the background research and previous
archaeological investigations within the areas of potential effect for the proposed construction.
The CRE has determined that some portions of the Environmental Investigations Activities as
Potential Contamination Sites at USAKA has limited potential to destroy, damage, or alter
known and hitherto previously unidentified cultural resources that would qualify for the RMI
List of Cultural and Historic Places under criteria a, d, e, and/or k as defined in the UES (2011:
3-7.6.4).
The five aspects of this project have been defined to have a potential to effect sub-surface
cultural resources, if present. These include:
1. Soil sampling
2. Groundwater sampling
3. Excavations
The area described for remediation in this RAM has little or no probability of effects to cultural
resources, because the area is located exclusively atop dredge fill material. Therefore, no
archaeological monitoring is required.
Should sampling or other excavations encounter artifacts, remains or any other archaeological
resources in locations where monitoring is not required, work will stop. The archaeologist will be
followed; these procedures will be included in the removal and remedial action work plan.
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