i sems-rm docid # 1150012 i the united …i i i ] ] ] i i ] ] i i i j i i report documentation page...

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THE UNITED STATES NAVY

INSTALLATION RESTORATION PROGRAM

FINAL

RECORD OF DECISION FOR

SITE 14 MAIN BASE OPERABLE UNIT

ANDERSEN AIR FORCE BASE, GUAM

November 2010

SEMS-RM DOCID # 1150012

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THE UNITED STATES NAVY INSTALLATION RESTORATION PROGRAM

FINAL

RECORD OF DECISION FOR

SITE 14 MAIN BASE OPERABLE UNIT

ANDERSEN AIR FORCE BASE, GUAM

November 2010

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REPORT DOCUMENTATION PAGE Form Approved 0MB No. 0704-0188

The public reporting burden for this collection of information is estimated to average 1 hour per response, including the time for reviewing instructions, searching existing data sources, gathering and maintaining the data needed, and completing and reviewing the collection of information. Send comments regarding this burden estimate or any other aspect of this collection of information, including suggestions for reducing the burden, to the Department of Defense, Executive Services and Communications Directorate (0704-0188). Respondents should be aware that notwithstanding any other provision of law, no person shall be subject to any penalty for failing to comply with a collection of information if it does not display a currently valid 0MB control number. PLEASE DO NOT RETURN YOUR FORM TO THE ABOVE ORGANIZATION. 1. REPORT DATE (DD-MM- YYYY) , 2. REPORT TYPE 3. DATES COVERED (From - To)

11-2010 Final 4. TITLE AND SUBTITLE 5a. CONTRACT NUMBER

Final Record of Decision for Site 14, F41624-03-D-8596-0057 Main Base Operable Unit, Andersen Air Force Base, Guam

5b. GRANT NUMBER

5c. PROGRAM ELEMENT NUMBER

6. AUTHOR(S) 5d. PROJECT NUMBER Phil Potter, Summer Barbina, and Scott Moncrief, P.G. AJJY20067001 S 1

5e. TASK NUMBER

Task Order 0057

5f. WORK UNIT NUMBER

7. PERFORMING ORGANIZATION NAME(S) AND ADDRESS(ES) 8. PERFORMING ORGANIZATION

EA Engineedng, Science, & Technology, Inc. REPORT NUMBER

P.O. Box 4355, Andersen AFB, Yigo, Guam 96929-4355 NIA

9. SPONSORING/MONITORING AGENCY NAME(S) AND ADDRESS(ES) 10. SPONSOR/MONITOR'S ACRONYM(S)

Air Force Center for Engineering and the Environment AFCEE 3300 Sidney Brooks Brooks City Base, TX 78235-5112 11. SPONSOR/MONITOR'S REPORT

NUMBER(S)

NIA 12. DISTRIBUTION/ AVAILABILITY STATEMENT

Approved for public release~ distribution is unlimited

13. SUPPLEMENTARY NOTES

14.ABSTRACT

This Record of Decision (ROD) presents the rationale for selection of the preferred cleanup alternative for Installation Restoration Program (IRP) Site 14, located in the Main Base Operable Unit at Andersen AFB, Guam. This ROD summarizes the history, environmental background, extent of contamination, associated human health and ecological risks, evaluation of remedial alternatives, public involvement, and rationale for selecting the preferred remedy for Site 14.

15. SUBJECT TERMS

- Andersen AFB - Public Involvement - Installation Restoration Program - Record of Decision

16. SECURITY CLASSIFICATION OF: 17. LIMITATION OF a. REPORT b.ABSTRACT c. THIS PAGE ABSTRACT

u u u uu

- Land Use Controls - Consolidation Unit

18. NUMBER OF PAGES

19a. NAME OF RESPONSIBLE PERSON

19b. TELEPHONE NUMBER (Include area code/

Standard Form 298 (Rev. 8/98) Prescribed by ANSI Std. 239. 18

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Final Record of Decision i November 2010 Site 14 Main Base OU, Andersen AFB, Guam

Table of Contents

Table of Contents ............................................................................................................................. i List of Tables ................................................................................................................................. iv List of Figures ................................................................................................................................. v List of Photographs ........................................................................................................................ vi Acronyms and Abbreviations ....................................................................................................... vii 1.0 Declaration .......................................................................................................................... 1-1

1.1 Site Name and Location ............................................................................................. 1-1 1.2 Statement of Basis and Purpose ................................................................................. 1-1 1.3 Assessment of Site ..................................................................................................... 1-2 1.4 Description of Selected Remedy ................................................................................ 1-2 1.5 Statutory Determination ............................................................................................. 1-3 1.6 Data Certification Checklist ....................................................................................... 1-4 1.7 Authorizing Signatures .............................................................................................. 1-4

2.0 Decision Summary .............................................................................................................. 2-1

2.1 Site Name, Location, and Description ....................................................................... 2-1 2.2 Site History and Enforcement Activities ................................................................... 2-1 2.3 Community Participation ........................................................................................... 2-3 2.4 Scope and Role of Operable Unit .............................................................................. 2-3 2.5 Site Characteristics ..................................................................................................... 2-5

2.5.1 Physiography and Climate ............................................................................... 2-5 2.5.2 Geology and Hydrogeology ............................................................................. 2-6 2.5.3 Surface Water Hydrology ................................................................................ 2-7 2.5.4 Ecology ............................................................................................................ 2-7 2.5.5 Previous Site Characterization Activities ........................................................ 2-7 2.5.6 Nature and Extent of Contamination ............................................................... 2-9 2.5.7 Conceptual Site Model ................................................................................... 2-10

2.6 Current and Potential Future Land and Resource Uses ........................................... 2-10

2.6.1 Land Use ........................................................................................................ 2-10 2.6.2 Ground and Surface Water Uses .................................................................... 2-10

2.7 Summary of Site Risks............................................................................................. 2-11

2.7.1 Summary of Human Health Risk Assessment ............................................... 2-11 2.7.2 Summary of Ecological Risk Assessment ..................................................... 2-17 2.7.3 Basis for Action ............................................................................................. 2-22

Final Record of Decision ii November 2010 Site 14 Main Base OU, Andersen AFB, Guam

2.8 Remedial Action Objectives .................................................................................... 2-23 2.9 Description of Alternatives ...................................................................................... 2-23

2.9.1 Description of Remedy Components ............................................................. 2-24 2.9.2 Common Elements and Distinguishing Features of Each Alternative .......... 2-28 2.9.3 Expected Outcome of Each Alternative ......................................................... 2-28

2.10 Summary of Comparative Analysis of Alternatives ................................................ 2-28

2.10.1 Overall Protection of Human Health and the Environment ........................... 2-28 2.10.2 Compliance with Applicable or Relevant and Appropriate Requirements .... 2-29 2.10.3 Long-Term Effectiveness and Permanence ................................................... 2-30 2.10.4 Reduction of Toxicity, Mobility, or Volume through Treatment .................. 2-31 2.10.5 Short-Term Effectiveness .............................................................................. 2-31 2.10.6 Implementability ............................................................................................ 2-32 2.10.7 Cost ................................................................................................................ 2-33 2.10.8 Territorial/Support Agency Acceptance ........................................................ 2-33 2.10.9 Community Acceptance ................................................................................. 2-33

2.11 Principal Threat Wastes ........................................................................................... 2-33 2.12 Selected Remedy ...................................................................................................... 2-34

2.12.1 Summary of the Rationale for the Selected Remedy ..................................... 2-34 2.12.2 Description of the Selected Remedy .............................................................. 2-35 2.12.3 Summary of Estimated Remedy Costs .......................................................... 2-40 2.12.4 Expected Outcomes of Selected Remedy ...................................................... 2-40

2.13 Statutory Determination ........................................................................................... 2-41

2.13.1 Protection of Human Health and the Environment ........................................ 2-41 2.13.2 Compliance with ARARs .............................................................................. 2-41 2.13.3 Cost Effectiveness .......................................................................................... 2-42 2.13.4 Utilization of Permanent Solutions and Alternative Treatment Technologies .................................................................................................. 2-42 2.13.5 Preference for Treatment as a Principal Element .......................................... 2-43 2.13.6 Five-Year Review Requirements ................................................................... 2-43

2.14 Documentation of Significant Changes ................................................................... 2-43

3.0 Responsiveness Summary ................................................................................................... 3-1

3.1 Stakeholder Comments and Lead Agency Responses ............................................... 3-1 3.2 Technical and Legal Issues ........................................................................................ 3-3

4.0 References ........................................................................................................................... 4-1

Final Record of Decision iii November 2010 Site 14 Main Base OU, Andersen AFB, Guam

Appendices Appendix A Federal Facility Agreement Change Letters Appendix B Notice of Public Meeting and Document Availability Appendix C Letter from Guam Environmental Protection Agency Regarding the Preferred

Remedy

Final Record of Decision iv November 2010 Site 14 Main Base OU, Andersen AFB, Guam

List of Tables

Table 1-1 Data Certification Summary. Table 2-1 Public Notification of Document Availability. Table 2-2 Public Comment Period Requirements. Table 2-3 Non-Cancer Toxicity Data – Oral/Dermal. Table 2-4 Non-Cancer Toxicity Data – Inhalation. Table 2-5 Cancer Toxicity Data – Oral/Dermal. Table 2-6 Cancer Toxicity Data – Inhalation. Table 2-7 Risk Characterization Summary – Carcinogens. Table 2-8 Risk Characterization Summary – Non-Carcinogens. Table 2-9 Common Elements and Distinguishing Features of Alternatives for Site 14. Table 2-10 Expected Outcome of Each Alternative for Site 14. Table 2-11 Cost Estimate for Alternative 3 – Excavation and Disposal of TSCA PCBs (> 50

mg/kg). Table 2-12 Cost Estimate for Alternative 3 – Excavation and On-Island Disposal in

Consolidation Unit of Soil with PBCs between 0.5 and 50 mg/kg, and/or Lead > 400mg/kg, and/or ACM.

Table 2-13 Cost Estimate for Alternative 3 – Fish Monitoring. Table 2-14 Cost Estimate for Alternative 3 – Land Use Controls. Table 2-15 Description of ARARs and TBCs for the Selected Remedy for Site 14.

Final Record of Decision v November 2010 Site 14 Main Base OU, Andersen AFB, Guam

List of Figures

Figure 1-1 Vicinity Map – Andersen Air Force Base, Guam. Figure 2-1 Location Map of Site 14, Main Base, Andersen Air Force Base, Guam. Figure 2-2 Topographic Survey at Site 14, Andersen AFB, Guam. Figure 2-3 Surface Soil Sample Locations and Results Exceeding Action Levels at Site 14,

Andersen AFB, Guam. Figure 2-4 Subsurface Soil Sample Locations and Results Exceeding Action Levels at Site

14, Andersen AFB, Guam. Figure 2-5 Human Health Conceptual Site Model for Site 14, Andersen AFB, Guam. Figure 2-6 Ecological Conceptual Site Model for Site 14, Andersen AFB, Guam. Figure 2-7 Alternative 3: Excavation with Disposal and Land Use Controls at Site 14,

Andersen AFB, Guam.

Final Record of Decision vi November 2010 Site 14 Main Base OU, Andersen AFB, Guam

List of Photographs

Photo 2-1 View east across site from the end of the access road at Site 14, Andersen AFB, Guam

Photo 2-2 View north from top of the access point at Site 14, Andersen AFB, Guam. Photo 2-3 View south from top of the access point at Site 14, Andersen AFB, Guam. Photo 2-4 View upslope at the end of 12-inch diameter pipe at Site 14, Andersen AFB,

Guam. Photo 2-5 View of the wave-cut toe of the wedge-shaped prism of debris and fill material at

Site 14, Andersen AFB, Guam. Photo 2-6 View south during seawater sampling at Site 14, Andersen AFB, Guam. Photo 2-7 View down from the top of the wedge-shaped prism of debris and fill material at

Site 14, Andersen AFB, Guam. Photo 2-8 View from offshore of Site 14, Andersen AFB, Guam.

Final Record of Decision vii November 2010 Site 14 Main Base OU, Andersen AFB, Guam

Acronyms and Abbreviations

36 CES/CEOQC 36th CES Customer Service 36 CES/CEC 36th Civil Engineer Squadron Engineering Flight 36 CES/CECB 36th Civil Engineer Squadron Engineering Flight GeoBase Section 36 CES/CEVR 36th Civil Engineer Squadron Environmental Flight

ACM asbestos-containing material AFB Air Force Base AOC Area of Concern AR Administrative Record ARAR applicable or relevant and appropriate requirement Battelle Battelle Columbus Division BGP Base General Plan bgs below ground surface BTV Background Threshold Value CERCLA Comprehensive Environmental Response, Compensation, and Liability Act of

1980 CERCLIS Comprehensive Environmental Response, Compensation, and Liability

Information System CES Civil Engineer Squadron CFR Code of Federal Regulations COC contaminant of concern COPC contaminant of potential concern CSM conceptual site model CU Consolidation Unit cy cubic yard DERP Defense Environmental Restoration Program EA EA Engineering, Science, and Technology, Inc. EE/CA Engineering Evaluation / Cost Analysis EPC exposure point concentration ERA ecological risk assessment ESE Environmental Science and Engineering, Inc. F degrees Fahrenheit FFA Federal Facility Agreement FS Feasibility Study Guam EPA Guam Environmental Protection Agency

Final Record of Decision viii November 2010 Site 14 Main Base OU, Andersen AFB, Guam

HDR|e2M HDR Engineering, Inc. | Engineering Environmental Management, Inc. HHRA human health risk assessment HI hazard index ICF ICF Technology, Inc. ID identification IRIS Integrated Risk Information Systems IRP Installation Restoration Program

lcy loose cubic yards LTGM Long-term Groundwater Monitoring LUC Land Use Control LUCMP Land Use Control Management Plan g/dl micrograms per deciliter µg/kg micrograms per kilogram MARBO Marianas/Bonins Command MEC munitions and explosives of concern MCL Maximum Contaminant Level mg/kg milligrams per kilogram MMRP Military Munitions Response Program msl mean sea level NCP National Oil and Hazardous Substances Pollution Contingency Plan of 1990 NEPA National Environmental Policy Act OU Operable Unit PCB polychlorinated biphenyl PCE tetrachloroethene PRG Preliminary Remediation Goal RAO remedial action objective RCRA Resource Conservation and Recovery Act RFA RCRA Facility Assessment RGO remedial goal objective RI Remedial Investigation RI/FS Remedial Investigation/Feasibility Study RME reasonable maximum exposure ROC receptor of concern ROD Record of Decision RSL Regional Screening Level SAIC Science Applications International Corporation SARA Superfund Amendments and Reauthorization Act of 1986

Final Record of Decision ix November 2010 Site 14 Main Base OU, Andersen AFB, Guam

Shaw Shaw Environmental, Inc. SWMU Solid Waste Management Unit TCE trichloroethene TMV toxicity, mobility, volume TRV toxicity reference value TSCA Toxic Substances Control Act UCL upper confidence limit of the mean USAF United States Air Force USEPA United States Environmental Protection Agency USN United States Navy

Final Record of Decision x November 2010 Site 14 Main Base OU, Andersen AFB, Guam

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Final Record of Decision 1-1 November 2010 Site 14 Main Base OU, Andersen AFB, Guam

1.0 Declaration

1.1 Site Name and Location

Facility Name: Andersen Air Force Base (AFB), Guam

Site Location: Yigo, Guam

Comprehensive Environmental Response, Compensation, and Liability Information System (CERCLIS) Identification (ID) Number: GU6571999519

Operable Unit/Site: Installation Restoration Program (IRP) Site 14 / Landfill 19 (Site 14), located in the Main Base Operable Unit (OU)

1.2 Statement of Basis and Purpose

This decision document presents the selected remedy for IRP Site 14, located at Andersen AFB, Yigo, Guam (Figure 1-1). The selected remedy was chosen in accordance with the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) of 1980, as amended by the Superfund Amendments and Reauthorization Act (SARA) of 1986, and to the extent practicable, the National Oil and Hazardous Substances Pollution Contingency Plan of 1990 (NCP). This decision is based on the Administrative Record (AR) for the site, including pertinent IRP documents, correspondence, and material related to the CERCLA investigation and cleanup.

This document is issued by the United States Navy (USN) 1, as the lead agency. The USN is managing remediation of contamination at Site 14 in accordance with CERCLA as required by the Defense Environmental Restoration Program (DERP). The USN and the United States Environmental Protection Agency (USEPA) have jointly selected the remedy and the Guam Environmental Protection Agency (Guam EPA) has concurred with the decision, under the guidelines established in the Federal Facility Agreement (FFA) signed in February 1993 by

1 The Department of Defense is in the process of realigning installation management functions at Andersen AFB. On October 1, 2009, pursuant to the 2005 Defense Base Closure and Realignment Commission Report, administrative custody of all real property on Andersen AFB and responsibility for installation support functions, including Environmental Restoration Program responsibilities, transferred within the Department of Defense from the Department of the Air Force to the Department of the Navy. Title to Andersen AFB real property will remain with the United States and the Air Force will continue to utilize the Base. The Navy will also utilize portions of the Base. In accordance with the April 15 2008, Department of Defense Environmental Supplemental Guidance for Implementing and Operating a Joint Base, at the time of property transfer the Navy, as the new property manager at the Base, assumed responsibility "for all existing and future environmental permits, requirements, plans, and agreements" at the Base (Ch. 1.1.2) and was required to “honor all existing, previously negotiated Federal Facility Agreements in place." (Ch. 2.17.5 of the Guidance). In January 2009, the Navy and the Air Force entered into a separate Memorandum of Agreement, which delegated installation support and authority back to the Air Force General who is the Andersen Base Commanding Officer under the authority, control, and direction of the Joint Region Commander, who is a Navy Admiral. This delegation includes the authority to sign Records of Decision. The Andersen Base Commanding Officer and Andersen environmental staff continue to administer the FFA under Navy direction. Both the Air Force and the Navy notified USEPA of the change of administrative responsibility under the FFA (See Appendix A).


representatives of the USEPA Region 9, Guam EPA, and United States Air Force (USAF) (USEPA et al., 1993).

1.3 Assessment of Site

The response actions selected in this Record of Decision (ROD) are necessary to protect public health and the environment from actual or threatened releases of pollutants or contaminants from Site 14.

Areas within Site 14 cannot support unrestricted use due to pollutants or contaminants remaining in place after implementation of the selected remedy. Land use restrictions are required as part of this response action and will be achieved through imposition of land use controls (LUCs) that limit the use and/or exposure to those areas of the property that are contaminated.

The USN is committed to implementing, monitoring, maintaining, reporting on, and enforcing all components of the selected remedy to ensure that it remains protective of human health and the environment.

1.4 Description of Selected Remedy

The USN has determined that remedial actions are required for Site 14, based on the results of a previously conducted Engineering Evaluation / Cost Analysis (EE/CA) (URS-Dames & Moore, 2002), Remedial Investigation (RI) (HDR Engineering, Inc. | Engineering Environmental Management, Inc. [HDR|e2M], 2009a), and Feasibility Study (FS) (HDR|e2M, 2009b).

The proposed remedial alternatives were developed and evaluated for Site 14 through the FS (HDR|e2M, 2009b). Based on the results of the FS, the USN selected a combination of soil removal and land use controls (referred to in the FS and hereinafter as Alternative 3) as the preferred remedial alternative for Site 14. The major components of the selected response action are presented in the following table.


Selected Remedial Action Performance Standard Above the Cliff Line

Excavation and removal of soil containing PCBs ≥ 50 mg/kg and shipment of the soil to an off-island facility

TSCA hazardous waste level for PCBs of 50 mg/kg.

Excavation and removal of soil containing PCBs between 0.5 mg/kg and 50 mg/kg, and/or lead ≥ 400 mg/kg, and/or ACM and movement of the soil to the CU

Excavation and disposal of soil containing PCBs between 0.5 mg/kg and 50 mg/kg, with a cleanup goal of an average of 0.5 mg/kg (RGO at 10-6), not to exceed 5.0 mg/kg

Excavation and disposal of soil containing lead at concentrations greater than 400 mg/kg (USEPA 2009 residential RSL)

Excavation and disposal of ACM Below the Cliff Line

Land Use Controls Prevent future residential use of the land Monitoring Conduct fish monitoring in the ocean water adjacent to the site Notes: ACM = asbestos-containing material mg/kg = milligram(s) per kilogram PCB = polychlorinated biphenyl RGO = remedial goal objective

RSL = Regional Screening Level TSCA = Toxic Substances Control Act (60 Code of Federal

Regulations [CFR] Part 761)

1.5 Statutory Determination

This section describes how the selected remedy satisfies the statutory requirements of CERCLA, §121 and the regulatory requirements of the NCP.

The selected remedy for Site 14 is protective of human health and the environment, complies with promulgated requirements that are applicable or relevant and appropriate to the remedial action, and is cost effective.

The selected remedy represents the maximum extent to which permanent solutions can be used in a practicable manner at the site. It provides the best balance or trade-offs in terms of balancing criteria, while also considering the bias against offsite treatment and disposal and considering territorial and community acceptance.

The NCP establishes the expectation that treatment will be used to address the principal threats posed by a site whenever practicable (40 CFR 300.430[a] [1] [iii] [A]). The selected remedy for Site 14 does not satisfy the statutory preference for treatment as a principal element of the remedy because treatment of the COC-impacted soil at Site 14 is not practicable and will not be performed. However, excavation and offsite disposal of the majority of the COC-impacted soil will significantly reduce the mobility and volume of COCs on site. If necessary, based upon the waste characterization sampling, the excavated soil at Site 14 may be treated (e.g., stabilized) to meet disposal requirements of the receiving facility.

Because this remedy will result in hazardous substances, pollutants, or contaminants remaining on-site above levels that allow for unlimited use and unrestricted exposure, a statutory review will be conducted for Site 14 within five years after initiation of the remedial action to ensure that the remedy is, or will be, protective of human health and the environment.


1.6 Data Certification Checklist

The information included in the Decision Summary section (Section 2) of this ROD is summarized in Table 1-1. Additional information can be found in the AR file for Andersen AFB, which is available for public review at the Information Repositories located at the Robert F. Kennedy Library, on the University of Guam campus, and the Nieves M. Flores Memorial Library in Hagåtña.

1.7 Authorizing Signatures

The following signature sheets document the decision by USN and USEPA Region 9 to select Alternative 3 as the remedy for Site 14, Main Base OU, Andersen AFB, Guam, and the concurrence of Guam EPA in that decision.

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This signature sheet documents the USN and Andersen AFB co-selection of Alternative 3 as the remedial action for Site 14, Main Base OU, Andersen AFB, Guam.

Brigadier General, USAF Base Commanding Officer2

2 Under Delegation of Authority from Commander Joint Region Marianas. See Footnote l. Final Record of Decision l-5 Site 14 Main Base OU, Andersen AFB, Guam

November 2010

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This signature sheet documents the USEPA Region 9 co-:selection of Alternative 3 as the remedial action for Site 14, Main Base OU, Andersen AFB, Guam.

Ml~- MONTGOMERY Assistant Director, Federal Facilities and Site Cleanup Branch U.S. Environmental Protection Agency, Region 9

Final Record of Decisio11 Site /4 Main Base OU, A,rdersen AFB, Guam

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Date

NOYember 2010

'This signature sheet documents the Guam EPA concurrence in the selection of Alternative 3 as the remedial action for Site 14, Main Base OU, Andersen AFB, Guam.

- -----<--~fl_ ; /_[ ______ tJ_.__3/(_94_1/-3 ___ , - ·- ----BRIC Administrator Guam Environmental Protection Agency

F ,nal Record of Decision Sr te 14 Jrain Base OU. Andersen AFB, Guam

Date

1-9 November 2010


2.0 Decision Summary

The Decision Summary identifies the selected remedy for Site 14, explains how the selected remedy fulfills statutory and regulatory requirements, and provides a substantive summary of the AR file that supports the remedy selection decision.

2.1 Site Name, Location, and Description

The following section presents a description of Site 14 and its location.

Full Site Name: Site 14 CERCLIS ID Number: GU6571999519 Site Location: Yigo, Guam Site Type: Former Waste Disposal Area

Site 14 is located on the eastern boundary of the Main Base area of Andersen AFB, between Anao Point and Lafac Point (Figures 1-1 and 2-1). The site is approximately 13.75 acres in area, of which 5.4 acres lies above a limestone cliff line and 8.35 acres are below the cliff line. The elevation above the cliff line is approximately 360 feet above mean sea level (msl).

The upper portion of the site is surrounded by limestone forest and consists of broad mounds and accumulations of waste debris and fill material that are covered by small shrubs and herbs commonly associated with fill material. The lower portion of the site is below the cliff line and includes a wedge-shaped accumulation of debris and fill material located at the base of the cliff, near sea level. A very steep escarpment separates the two portions of the site (Shaw Environmental, Inc. [Shaw], 2006). Site conditions were photographed in July 2008 and are presented in Photos 2-1 through 2-8.

2.2 Site History and Enforcement Activities

This section provides background information and summarizes the series of investigations that led to the ROD. It describes the CERCLA response actions undertaken at Site 14, Main Base OU.

Due to its primary mission in national defense, Andersen AFB has long been engaged in a wide variety of operations that involve the use, storage, and disposal of hazardous materials. On 14 October 1992, Andersen AFB was formally listed on the National Priorities List by the USEPA to investigate abandoned sites that may have been impacted by the use, storage, and disposal of hazardous materials.

Site 14 was used for disposal of asphalt drums and roofing material from housing construction in 1955 (ICF, 1995). The USN and USAF have conducted environmental investigations at the Main Base OU, Site 14, in accordance with CERCLA under the DERP, which was established by Section 211 of SARA.

As the support agencies, the USEPA Region 9 and Guam EPA provide primary oversight of the environmental restoration actions, in accordance with the FFA. The enforcement activities for


Andersen AFB were initiated when the USAF entered into an FFA with the USEPA Region 9 and Guam EPA. The FFA, finalized on 30 March 1993, established procedures for involving federal and territorial regulatory agencies, as well as the public, in the environmental restoration process at Andersen AFB. The FFA was based on applicable environmental laws including CERCLA, Hazardous and Solid Waste Act of 1982, SARA, and the NCP.

Funding is provided by the Defense Environmental Restoration Account; a funding source approved by Congress to clean up contaminated sites on U.S. Department of Defense installations.

In accordance with USN policy, to the extent practicable, National Environmental Policy Act (NEPA) values have been incorporated throughout the CERCLA process culminating in this ROD. Separate NEPA documentation will not be issued.

Site 14 has been evaluated in the following eleven environmental reports:

Installation Restoration Program Phase I: Records Search, Andersen Air Force Base, Guam (Environmental Science and Engineering, Inc. [ESE], 1985)

Resource Conservation and Recovery Act (RCRA) Facility Assessment of Solid Waste Management Units at Andersen AFB, Guam, USA (Science Applications International Corporation [SAIC] and A.T. Kearney, Inc., 1986)

Installation Restoration Program Phase II, Stage 1-Confirmation/Quantification, Andersen AFB, Guam. Final Report (Battelle Columbus Division [Battelle], 1989)

Work Plan Addendum to Operable Unit 6 for Operable Unit 5, Andersen Air Force Base, Guam, Final (USAF, 1994)

Operable Unit 6 Basewide Work Plan for Andersen Air Force Base Guam, Final, Revision 1 January 1995 (ICF Technology, Inc. [ICF], 1995)

Installation Restoration Program, Final Records Search for Andersen Air Force Base, Guam (ICF, 1996)

Final Engineering Evaluation / Cost Analysis for IRP Site 14, Landfill 19 Andersen Air Force Base, Guam (URS-Dames & Moore, 2002)

Environmental Cleanup Plan, Interim Remedial Action, Installation Restoration Program Site 14 / Landfill 19, Andersen Air Force Base, Guam (Shaw, 2006)

Interim Remediation Verification Report, Interim Remedial Action, Installation Restoration Program Site 14 / Landfill 19, Andersen Air Force Base, Guam (Shaw, 2007)

Final Remedial Investigation, IRP Site 14, Andersen Air Force Base, Guam (HDR|e2M, 2009a)

Final Feasibility Study, IRP Site 14, Andersen Air Force Base, Guam (HDR|e2M, 2009b).


2.3 Community Participation

NCP Section 300.430(f)(3) establishes a number of public participation activities that the lead agency must conduct following preparation of the Proposed Plan and review by the support agency. Components of these items and documentation of how each component was satisfied for Site 14, Andersen AFB, Guam, are described in Tables 2-1 and 2-2.

Responses to comments received during the public comment period are included in the Responsiveness Summary, which is provided as Section 3 of the ROD.

2.4 Scope and Role of Operable Unit

As with many large sites, the environmental issues at Andersen AFB are complex. Due to past practices and activities at Andersen AFB, such as post-typhoon emergency debris disposal, potentially harmful materials have been disposed of in an uncontrolled manner at some locations. The Andersen AFB IRP has conducted numerous environmental investigations to locate past disposal areas and to determine if disposed materials have caused soil or groundwater contamination. As an aid in managing the overall environmental program, the USAF, with concurrence from USEPA Region 9 and Guam EPA, organized the environmental restoration work at Andersen AFB into six OUs as described below. The site addressed by this ROD has been bolded.

Main Base OU (Sites 2, 3, 4, 5, 6, 8, 9, 10, 11, 12, 13, 14, 15, 25, 26, 27, 28, 29, 34, and 35)—The RODs addressing the Main Base OU are either completed or in the process of completion. The sites were grouped in the following separate ROD documents:

Sites 6, 9, and 12 (Group 1) Sites 5 and 8 (Group 2) Sites 4, 11, 25, 28, and 34 (Group 3) Sites 3, 10, 13, 15, 21, 26, and 27 (Group 4) Site 2 Sites 29 and 35 Site 14

The final RODs for Groups 1, 2, and 3 were signed in September 2007, July 2008, and February 2008, respectively, and the RODs for the remaining sites are currently under development.

Northwest Field OU (Sites 7, 16, 17, 21, 30, 31, and 36)—A final ROD addressing Sites 7, 16, 17, 31, and 36 was signed in February 2008. The ROD for Site 21 is currently under development.

Due to the presence of munitions and explosives of concern (MEC), Site 30 was transferred to Andersen AFB’s Military Munitions Response Program (MMRP). Under the MMRP, a ROD will be completed for Site 30 after further investigation and a feasibility study (FS), with respect to the MEC, is completed.


Marianas/Bonins Command (MARBO) Annex OU (Sites 20, 22, 23, 24, 37, and 38)—A final ROD addressing the MARBO Annex OU was signed in August 1998. Five-year ROD reviews were completed in July 2004 and July 2009. A ROD Amendment for MARBO Annex groundwater is currently under development.

Harmon Annex OU (Sites 18, 19, and 39)—A final ROD addressing the Harmon Annex OU was signed in July 2005.

Urunao OU (Site 40)—A final ROD addressing the Urunao OU was signed in July 2005.

Site-Wide OU (Sites 41 through 78, Areas of Concern [AOCs], and Solid Waste Management Units [SWMUs])—The Site-Wide OU consists of the IRP sites that have been added to the program in recent years as well as the AOCs and SWMUs at Andersen AFB, and is distributed geographically across the Main Base, Northwest Field, MARBO Annex, and Tumon Tank Farm. The sites, AOCs, and SWMUs are proposed to be addressed in separate ROD documents as follows:

Sites 45, 49, 59, 61, 67, 68, and 69 (Group A) Sites 48, 56, 58, 70, and 73 (Group B) Sites 47, 50, 51, 53, and 55 (Group C) Sites 63, 64, 65, 66, 72, and 77 (Group D) Sites 57, 71, 74, 75, and 76 (Group E) Sites 44 and 46 (Group F) Sites 41, 42, and 43 (Group G) Site 78 Site 54 SWMU-4, SWMU-8B, SWMU-17, SWMU-33, SWMU-35C, and SWMU-44 SWMU-6, SWMU-9, SWMU-10, SWMU-13A, SWMU-20D, SWMU-22C, and

SWMU-29A SWMU-8A, SWMU-8C, SWMU-11, SWMU-12, SWMU-18, SWMU-34A,

SWMU-37A, SWMU-42E, SWMU-46A, SWMU-46B, SWMU-47C, SWMU-53B, and SWMU-57

SWMU-16C, SWMU-20E, SWMU-22B, SWMU-29B, SWMU-31B, SWMU-32E, SWMU-32F, SWMU-42D, and SWMU-53D

AOC-4, AOC-7B, AOC-7C, AOC-7D, AOC-9, SWMU-22A, SWMU-23B, SWMU-32G, SWMU-35A, and SWMU-41

SWMU-29C, SWMU-42F, SWMU-43, SWMU-53C, and SWMU-53F SWMU-15 SWMU-30C SWMU-40C

The final ROD for Group G was signed in December 2009. The final RODs for Groups A, B, and F were signed in March 2010. The RODs for the remaining sites, AOCs, and SWMUs are currently under development. Due to the presence of MEC, Sites 52, 60, 62, and the MEC Area at Site 65 were transferred to Andersen AFB’s MMRP. Under the MMRP, RODs will be


completed for these sites after further investigations and FSs are completed with respect to the MEC.

2.5 Site Characteristics

This section describes the physical characteristics of Site 14. Guam is the largest, most populated, and southernmost island in the Mariana Islands, located in the western Pacific Ocean (Figure 1-1). Relative to Guam, Hawaii is located 3,700 miles to the east-northeast and Japan is located 1,560 miles to the north. Guam is approximately 30 miles long, varies in width from 4 to 12 miles, and has a total land area covering approximately 209 square miles.

2.5.1 Physiography and Climate

Physiographically, the island of Guam may be divided into northern and southern regions, which are separated by the Adelup Fault. The northern region is a limestone plateau consisting of rolling hills and cliff lines ranging from 200 to 600 feet above msl.

Andersen AFB consists of multiple parcels of land located on the northern half of Guam (Figure 1-1), and is situated on an undulating limestone plateau with surficial karst features. The Base property includes the Main Base (formerly North Field) and Northwest Field. Andersen AFB is approximately 8 miles wide by 2 to 4 miles long, and covers approximately 24.5 square miles.

Guam is located at 13º 27’ north latitude (approximately 900 miles north of the equator), creating a year-round warm and humid climate. The mean annual temperature is 81 degrees Fahrenheit (ºF). Daily temperatures range from the lower 70s to the upper 80s ºF. Relative humidity ranges from 65 to 80 percent in the afternoon and 85 to 100 percent in the evening. Guam has two distinct seasons, a wet and a dry season. The dry season is typically from December to June, and the wet season occurs from July through November. Approximately 65 percent of the annual precipitation falls during these five rainy months, and the annual rainfall on northern Guam averages between 80 and 100 inches.

The dominant winds are the trade winds, blowing from the east or northeast with velocities between 4 and 12 miles per hour throughout the year. Storms may occur at any time during the year, although tropical storms and typhoons are more frequent during the rainy season. Large rainfall events associated with typhoons are common, with as much as 25 inches of rain in a 24-hour period (Ward et al., 1965). These climatic conditions hold true for Site 14.

Site 14 is located in the northern region of Guam (Figure 2-1), on the east side of the Main Base along the eastern edge of a limestone plateau. The site comprises two distinct areas, as it is situated along the coastline and divided in two by a limestone cliff. Approximately 60 percent of the site is below the cliff line and 40 percent is above the cliff line. The site is approximately 12,800 feet south-southwest of Pati Point between Anao Point and Lafac Point on the northeast coast of Guam, where the limestone cliffs are approximately 355 to 385 feet above msl. The elevation of the site ranges from approximately 25 feet above msl near the shoreline to 360 feet above msl at the top of the cliff line, and up to approximately 385 feet above msl in some of the fill areas above the cliff line (Figure 2-2).


2.5.2 Geology and Hydrogeology

Site 14 is underlain by the Mariana Limestone, which is underlain by the Barrigada Limestone. The soils on the Main Base consist predominately of the following three series of upland limestone soils: Guam, Guam-Urban land-Pulantat, and Ritidian Series. These soils are generally very shallow to shallow, well-drained, and range from flat to gently sloping on the interior to extremely steep along the cliff lines (Young, 1988).

The typical soil observed at Site 14 consists of Ritidian - Rock outcrop complex, 3 to 15 percent slopes, and the Rock outcrop - Ritidian complex, 60 to 99 percent slopes. The Ritidian - Rock outcrop complex, 3 to 15 percent slopes, is composed of 45 percent Ritidian extremely cobbly clay loam and 35 percent Rock outcrop (Young, 1988). The soil is made up of dark reddish brown, extremely cobbly, clay loam at the surface, in which 60 to 90 percent is covered with gravel, cobbles, and stones. This soil has a moderately high permeability and is mildly to moderately alkaline. The surface layer is composed of six to nine percent organic matter. The Rock outcrop - Ritidian complex, 60 to 99 percent slopes, is on limestone escarpments. Vertical limestone cliffs with occasional ledges and benches characterize this soil. It is comprised of 50 percent Rock outcrop and 45 percent Ritidian extremely cobbly clay loam. The soil is made up of dark reddish brown, extremely cobbly, clay loam at the surface layer, in which 60 to 90 percent is covered with gravel, cobbles, and stones. This soil has a moderately high permeability and is mildly to moderately alkaline. The surface layer is composed of six to nine percent organic matter (Young, 1988).

Surface soils and bedrock are very porous and permeable and as a result, no rivers or streams are present in the northern portion of the island. Precipitation, except that portion lost to evapotranspiration, contributes to the groundwater lens.

Site 14 is characterized by highly permeable reef limestone and the water table is presumed to be between 2.5 to 3.5 feet above msl (or ranging from approximately 20 feet below ground surface [bgs] at the eastern boundary and base of slope near the coast to 380 feet bgs at the upper western boundary). The important factors governing the volume of freshwater in the lens are: the effects of mixing freshwater and marine water, the permeability of the limestone formations, and the rate of recharge. Faults, fractures, brecciated zones, joints, dissolution channels, or cavities can affect flow.

The limestone aquifers of northern Guam have an average gradient of 0.0005 feet per foot, a hydraulic conductivity of approximately 2,000 feet per day, and a porosity of ten to 15 percent (Branch et al., 1982). As there are no monitoring wells installed on site, there is no data available that characterizes the basal groundwater lens beneath the site. However, it is postulated that the basal lens in the general vicinity of Site 14 is relatively thin (presumed to be less than 100 to 120 feet thick) and becomes brackish to saline near the coastline.

The following is a tabular summary of the geology and hydrogeology at Site 14.


Limestone Formation Soil Depth to

Groundwater (approximate)

Proximity to Cliff Line

Detrital and reefal facies of the Mariana

Limestone

Ritidian - Rock outcrop complex, 3 to 15 percent

slopes, and Rock outcrop - Ritidian complex, 60 to 99

percent slopes

20 to 380 feet bgs 60 percent of site area is below the cliff line,

and 40 percent is above

2.5.3 Surface Water Hydrology

No wetlands or surface water resources are located in the Northwest Field, the Main Base, or in the vicinity of Site 14. The geology in the region is dominated by highly porous limestone bedrock underlying very thin soils with moderately rapid permeability. As a result precipitation readily infiltrates into the vadose zone, preventing the formation of surface streams, rivers, and lakes.

2.5.4 Ecology

This section provides site-specific information related to the ecology at Site 14. The ecological receptor populations for the site are discussed in Section 2.7.

Based on a comprehensive site reconnaissance, mixed shrub and limestone forest habitats were identified at Site 14. Site 14 is a coastal site located along the cliff line southeast of the active runways, adjacent to the Andersen AFB golf course. The major habitat type located within Site 14 is mixed shrub (approximately 90 percent), and a small portion of the site consists of limestone forest habitat. Some notable tree species found in this habitat are ufa-halomtano (Heritiera longipetiolata), which appears on the Guam Endangered Species List and Tabernaemontana rotensis, a rare, native tree proposed for Guam Endangered Species listing (HDR|e2M, 2009a). Animals are prevalent across the habitat, including Sambar deer (Gervus mariannus) and feral pigs (Sus scrofa). There are several nearby areas within the Main Base, including the cliff line areas that are proposed as critical habitats for the Mariana crow and the Mariana fruit bat (endangered species) (URS-Dames & Moore, 2002).

Presently, Site 14 and the surrounding area are relatively unused, though the site lies near the base golf course. Potential receptors at the site include occasional users/trespassers. This includes hunters or trespassers who may walk through the area as well as maintenance workers who may work at the site on a limited basis. There is limited hunting of deer and wild pigs in this area of Andersen AFB. There are no nearby wetland communities (HDR|e2M, 2009a).

2.5.5 Previous Site Characterization Activities

A complete list of previous investigations conducted at Site 14 is presented in Section 2.2.

Site 14 was initially identified during the Phase I Records Search (ESE, 1985). The report described the site as consisting of two small disposal areas with a combined size of about 1 acre, located at the foot of a cliff, approximately 2,500 feet east of Building 25016. Approximately 50 to 70 drums were disposed of at this site; however, field verification was not performed due to


the remote location at the foot of the cliff and heavy vegetation. The Phase II, Stage 1 Investigation reiterated this site description; however, no field verification was performed (Battelle, 1989).

The RFA described Site 14 as a cliff-side dump site located on a rise behind the beach, 30 to 75 feet above msl, and confirmed the reported historical use of the site (SAIC and A.T. Kearney, Inc., 1986). Heavy vegetation and poor beach access prevented visual confirmation of Site 14 during the RFA, which reported that there was insufficient information to determine the potential for past or ongoing releases of hazardous materials from the site.

An EE/CA was conducted between 2000 and 2002 that included a records search, review of aerial photographs, visual site reconnaissance, detailed site inventory, geophysical survey, topographic survey, and surface and subsurface soil sampling (URS-Dames & Moore, 2002). A total of 77 surface soil samples (0-1.0 feet bgs) and 31 subsurface soil samples (2.0 to 5.0 feet bgs), including field duplicates, were collected during two sampling events. The EE/CA indicated that the most suitable remedy for Site 14 was soil removal for the area above the cliff line and land use controls for the area below the cliff line.

In March 2006, an interim removal action began on the area above the cliff line to remove and dispose of contaminated soil at Site 14 (Shaw, 2006; 2007). A total of 98 surface soil samples (0-0.5 feet bgs) and 59 subsurface soil samples (1.5 to 2.5 feet bgs), including field duplicates, were collected to delineate the lateral and vertical extent of contaminated soil. Before excavation of contaminated soils began, the Guam EPA advised that soil contaminated with polychlorinated biphenyls (PCBs) in concentrations in excess of one milligram per kilogram (mg/kg) would not be allowed in the Consolidation Unit (CU) located within the Andersen AFB landfill complex, which conflicted with the cleanup plan3. At this point remediation activities were stopped and a fence and gate were constructed at the entrance to the site.

In July 2008, RI field activities were conducted below the cliff line to determine if PCB contaminated soil on the slope had impacted aquatic receptors and the shoreline environment (HDR|e2M, 2009a). The scope of work included surface and subsurface soil, sediment, seawater, and marine biota sampling and analysis for PCBs. However, no sediment was present in the intertidal zone; therefore, no sediment samples were collected. A total of eighteen surface soil samples (0-0.5 feet bgs) and eighteen collocated subsurface soil samples (2.5 to 3.0 feet bgs), including field duplicates, were collected below the cliff line to delineate the PCB contamination. Three seawater samples were collected from along the shore adjacent to Site 14. Forty fish were collected from within the Pati Point Marine Preserve in the ocean waters adjacent to the site. Protected and rare species were not sampled. Two fish from each grid were filleted prior to analysis, and the remaining 24 fish were analyzed as whole organisms. Eleven marine invertebrate samples were also collected from the shoreline in the vicinity of the site.

Details on the nature and extent of contamination can be found in Section 2.5.6.

3 The Guam EPA has since granted a one-time approval of disposal of soil contaminated with PCBs at concentrations less than 50 mg/kg in the CU. The letter granting this approval can be found in Appendix C.


2.5.6 Nature and Extent of Contamination

Based upon the results of the human health risk assessment (HHRA) and the FS, PCB and lead concentrations in surface soil pose potentially unacceptable risks to future residents (Figure 2-3). The ecological risk assessment (ERA) concluded that there was a potentially significant risk to the yellow bittern posed by surface soil concentrations of PCBs as well.

Based upon the results of the HHRA and the FS, PCB concentrations in subsurface soil pose potentially unacceptable risks to future residents (Figure 2-4).

Large amounts of asbestos-containing material (ACM) were also observed above the cliff line at depths of up to one foot bgs, located mostly within broad, low-lying mounds. ACM locations are identified on Figures 2-3 and 2-4 to show proximity to the PCB- and lead-contaminated soil at Site 14.

The PCB-, lead-, and ACM-contaminated soil above the cliff line covers an area of approximately two acres. PCBs contribute to the majority of surface soil contamination above the cliff line, with many samples exceeding the cleanup level of 0.5 mg/kg with concentrations ranging from 0.51 mg/kg to 109.5 mg/kg (Figure 2-3). PCBs also contribute to the majority of subsurface soil contamination above the cliff line, with four samples exceeding the cleanup level with concentrations ranging from 3.791 mg/kg to 380 mg/kg (Figure 2-4). Lead concentrations in surface soil greatly exceed the residential RSL of 400 mg/kg in several areas above the cliff line, with concentrations ranging from 400 mg/kg to 8,100 mg/kg (Figure 2-3). Lead did not pose any significant risk in subsurface soil.

The volume of Toxic Substances Control Act (TSCA) hazardous waste was calculated using a vertical and lateral dimension of PCB-contaminated soil based on the nearest sample location at which the PCB concentration is less than 50 mg/kg and a bulking factor for soil of 20 percent. An additional 15 loose cubic yards (lcy) of soil was added to the calculated soil volume, to account for “step-out” excavating that may be required based on confirmation sampling. This totals approximately 40 lcy of soil containing PCBs at concentrations greater than or equal to the TSCA hazardous waste level of 50 mg/kg, covering a surface area of 36 square feet, located above the cliff line.

Approximately 9,600 lcy of soil located above the cliff line contains PCBs at concentrations between 0.5 mg/kg and 50 mg/kg, lead at concentrations greater than or equal to 400 mg/kg, and/or ACM. The volume was calculated using a two acre surface area, an excavation depth of 2.5 feet, and a bulking factor for soil of 20 percent.

The lateral extent of contamination of the soil below the cliff line is significantly less than that of the soil above the cliff line. Lead contributes to the majority of surface soil contamination below the cliff line, with five samples exceeding the residential RSL with concentrations ranging from 478 mg/kg to 905 mg/kg (Figure 2-3). PCBs contribute to the majority of subsurface soil contamination below the cliff line, with five samples exceeding the cleanup level with concentrations ranging from 1.707 mg/kg to 7.770 mg/kg (Figure 2-4).


The source for the COCs in surface and subsurface soils at Site 14 is most likely attributable to former use of the land as a dump site for asphalt drums and roofing material. The downhill extent of debris and fill material below the cliff line was attributed to the significantly steep slope of the site.

2.5.7 Conceptual Site Model

Conceptual site models (CSMs) were developed for Site 14 to depict the potential relationship or exposure pathway between chemical sources and receptors. An exposure pathway describes the means by which a receptor can be exposed to contaminants in environmental media. The CSMs developed for the HHRA and ERA are presented in Figures 2-5 and 2-6, respectively, and are based upon current and reasonably likely future land uses at Site 14.

Although future residential land use is considered unlikely at Site 14, resident adult and child receptors were evaluated in the HHRA as a conservative measure to determine whether the site would be suitable for unlimited use or unrestricted exposure, as described within this ROD.

2.6 Current and Potential Future Land and Resource Uses

2.6.1 Land Use

The following is a summary of current land use conditions at and around Site 14.

Site Current Land Use Surrounding Land Use Site 14 Open Space (USAF, 2006) Site 14 is located along the cliff line on the eastern boundary of the

Main Base. It is adjacent to an area zoned for accompanied military housing. At present, the nearest residential area is located approximately 2,600 feet west of Site 14 (USAF, 2006).

Current users of the land at Site 14 are occasional users/trespassers. Land use for the site, as well as adjacent and surrounding land, is expected to remain the same for the foreseeable future.

2.6.2 Ground and Surface Water Uses

Site 14 is located above the Northern Guam Lens aquifer, which is designated by the USEPA as a sole source aquifer, and supplies Guam with approximately 80 percent of its drinking water (Barrett, 1982). The groundwater at the Main Base has been monitored regularly as part of the Long-term Groundwater Monitoring (LTGM) Program at Andersen AFB (EA, 2009). The initial round of groundwater sampling was performed at all existing Main Base monitoring wells in November 1995 (Round 1) and on a semiannual basis (twice a year) thereafter.

The historical groundwater data set for the Main Base has established that there is no connection between the COCs observed in the surface and subsurface soils at Site 14 and any groundwater contamination. Trichloroethene (TCE) and tetrachloroethene (PCE) have been observed in groundwater samples collected from Main Base monitoring wells at concentrations exceeding the respective Federal Safe Drinking Water Act’s Maximum Contaminant Levels (MCLs).


However, the groundwater contamination has been attributed to a likely TCE/PCE source(s) in the vicinity of Building 18006.

The LTGM data collected at Andersen AFB strongly support the CSM, which indicates that most of the contaminants observed in surface and subsurface soil samples (i.e., polycyclic aromatic hydrocarbons, pesticides, PCBs, and metals) are relatively immobile and are rarely observed in groundwater at concentrations exceeding drinking water standards (MCLs) (EA, 2009). Groundwater and surface water were not identified as media of concern at Site 14; therefore, these media were not assessed in the HHRA or ERA.

Four groundwater wells are located in proximity to Site 14. Production well USGS-128 (used for irrigation purposes), located 3,200 feet west (upgradient) of Site 14, was removed from the LTGM Program in 2003 because no COCs had been detected in any groundwater samples during 15 rounds of sampling (collected from Fall 1995 to Spring 2003). Monitoring well IRP-50, located 2,700 feet north of Site 14, has been sampled on a semiannual basis since October 1996. Detectable concentrations of TCE and chromium were observed over the course of 19 rounds of sampling; in the latest round of sampling, no analytes were observed at concentrations exceeding screening criteria. Monitoring wells USGS-150 and IRP-51 are a paired set of shallow and deep wells located within IRP Site 8 (Landfill 10), approximately 3,000 feet northeast of Site 14. Both wells are currently sampled as part of the LTGM Program at the Main Base OU. Between Fall 1996 and Fall 2008, detectable concentrations of TCE, naphthalene, and benzo(a)pyrene were observed in samples from USGS-150; in the latest round of sampling, only benzo(a)pyrene was observed at a concentration slightly exceeding its screening criteria. Between Fall 1996 and Fall 2008, detectable concentrations of TCE, bis(2-ethylhexyl)phthalate, beryllium, cadmium, and chromium were observed in samples from IRP-51; in the latest round of sampling, only TCE was observed at a concentration of twice the screening criteria, showing a slight decrease in concentration over time (EA, 2009). Because none of the identified COCs were observed in the historical groundwater data set for these adjacent wells, it can be concluded that contaminants at Site 14 have not negatively impacted the aquifer.

2.7 Summary of Site Risks

This section summarizes the human health and ecological risk assessments that have been performed at Site 14. The COCs associated with unacceptable site risk are identified, as well as the potentially exposed populations and exposure pathways of primary concern. A summary of the findings of the ecological risk assessment is also presented. Based on the presence of unacceptable risks to potential future residents, remedial action is being recommended to reduce the risks.

2.7.1 Summary of Human Health Risk Assessment

An HHRA was initially performed as a component of the 2002 EE/CA to evaluate potential human health risks associated with exposure to contamination at Site 14 (URS-Dames & Moore, 2002). An additional HHRA was performed in support of the 2009 RI to evaluate potential human health effects associated specifically with PCB contamination (HDR|e2M, 2009a). The RI HHRA was based closely on the HHRA performed as part of the EE/CA, updated when necessary to adhere to recent risk assessment guidance. The RI HHRA included analyses of


PCBs in soil performed in support of the EE/CA and the Interim Remediation Verification Report, as well as analyses of PCBs in soil and marine biota conducted during the RI field investigation. Because no PCBs were detected in seawater at concentrations exceeding the MCL, seawater was not evaluated in the HHRA.

The baseline risk assessment estimates what risks the site poses if no action were taken. It provides the basis for taking action and identifies the contaminants and exposure pathways that need to be addressed by the remedial action. This section of the ROD summarizes the approaches used and the results of the baseline risk assessment for this site. The HHRA is divided into the following sections: identification of COCs (hazard assessment), exposure assessment, toxicity assessment, and risk characterization. Potential risks for both current and potential future site occupants are discussed. Key assumptions and uncertainties associated with the HHRA are also identified. The COCs, exposure pathways, and populations associated with unacceptable risk are highlighted, as they serve as the primary basis for remedial action.

2.7.1.1 Identification of Contaminants of Concern

This section identifies those chemicals associated with unacceptable risk at the site and that are the basis for the proposed remedial action. Although other chemicals were detected at the site, these COCs are the primary risk-driving chemicals. The data used in this risk assessment was deemed to be of sufficient quality and quantity for its intended use. The detection frequency, range of detected concentrations, and the exposure point concentrations (EPCs) for COCs and media of concern are presented in the table below.

Media Contaminant

of Concern

Concentration Detected (mg/kg) BTV

USEPA Regional Screening Level

(mg/kg)

Frequency of

Detection EPC

Statistical Measure

Minimum Maximum Residential Industrial

Soil On-Site -Direct Contact - Surface Soil

Lead 5.3 8,100 166 400 800 62/62 270 95%

UCL-T

Total PCBs 0.0031 109.5 NA 0.220 0.740 118/158 7.02 97.5%

KM UCL

Soil On-Site -Direct Contact - Subsurface Soil

Lead 7.6 742 166 400 800 25/25 225 95%

UCL-T

Total PCBs 0.0026 380 NA 0.220 0.740 49/68 20.1 97.5%

KM UCL

Statistics: 95% UCL-T is the 95 percent upper confidence limit of log-transformed data; 97.5% KM UCL indicates the Kaplan-Meier Method UCL of the mean, as calculated using USEPA's ProUCL software.

Notes: BTV = Background Threshold Value NA = not applicable UCL = upper confidence limit of the mean

2.7.1.2 Exposure Assessment

This section documents the populations and exposure pathways that were quantitatively evaluated in the risk assessment. A CSM was developed to aid in determining reasonable exposure scenarios and pathways of concern; this CSM is shown in Figure 2-5. As described in this section, both current and future populations have been evaluated based on current and

I I I I I I I I I I I


reasonably anticipated future land use. The contaminated media to which people may be exposed is also discussed.

The HHRA identified surface soil, subsurface soil, air exposures (which could result from dispersion of surface and subsurface soil into air), and fish tissue4 as the media of concern. Risks were estimated for the following receptors and exposure pathways5:

Incidental ingestion of, dermal contact with, and inhalation of airborne particulates of surface soil by current and future trespassers (and other occasional users) on the site

Incidental ingestion of, dermal contact with, and inhalation of subsurface soil particles by hypothetical future resident adults and children

Incidental soil ingestion, dermal exposure to surface soil, and inhalation of air emissions from surface soil by hypothetical future resident adults and children

Individuals consuming fish caught immediately offshore from Site 14.4

2.7.1.3 Toxicity Assessment

This section describes the cancer and non-cancer toxicity criteria used to calculate the potential risk for each COC. When available, these toxicity criteria are separated into ingestion, inhalation, and dermal routes of exposure. Also included is the source of the toxicity criteria and the primary health endpoint and organ of concern for each COC. Toxicity data for noncarcinogens are presented in Tables 2-3 and 2-4 and for carcinogens in Tables 2-5 and 2-6. When available, values were taken from the Integrated Risk Information Systems (IRIS) database (USEPA, 2000). IRIS chronic reference doses, reference concentrations, and cancer slope factors are developed by USEPA and undergo an extensive process of scientific peer review. Therefore, IRIS values are judged as adequately verified.

2.7.1.4 Risk Characterization

This section of the risk assessment combines the results of the exposure assessment with the toxicity criteria identified for the COCs. Cancer risks and non-cancer impacts for each COC are presented for all populations and media of interest, including both current and future land use settings. Cumulative risks for all relevant pathways and populations are also described. These risk estimates are summarized in Tables 2-7 and 2-8.

During completion of the HHRAs, the risks for cancer contaminants of potential concern (COPCs) and non-cancer COPCs were calculated separately and the risks for each were then summed to determine cumulative risks. For cumulative cancer risks, the USEPA has established an acceptable risk level of 10-6, which represents a one-in-a-million increase in the lifetime cancer risk for the evaluated receptor (e.g., a resident or a site worker) if exposed to the site

4 Fish tissue was identified as a medium of concern only during the RI HHRA, which estimated risks due to PCBs. 5 As indicated in the CSM, there is limited hunting of deer and wild pigs in this area of Andersen AFB. Therefore, adults and children who consume deer and pig meat are considered receptors at the site. However, risks associated with ingestion of deer and wild pig meat have been addressed on a Basewide basis and are presented in two separate reports (EA, 1995 and Agency for Toxic Substances and Disease Registry, 2006)


COPCs. The USEPA has determined increased cancer risk in excess of 10-4 (one-in-ten-thousand) is unacceptable. The risk range of 10-6 to 10-4 may be evaluated in the risk management context to determine whether risk is acceptable for future site conditions (such as land use and potential users). For cumulative non-cancer risks, the USEPA has established a hazard index (HI) of less than 1.0 as acceptable.

More detailed descriptions of the HHRA process are presented in the EE/CA and RI documents.

Following the completion of the risk-based screening process, calculation of medium-specific exposure point concentrations, and assessment of cumulative risks for receptors and media of concern, the following risks due to PCBs were identified under reasonable maximum exposure (RME) assumptions:

Surface Soil Cancer Risks – Excess cancer risk estimates for the resident adult and child (combined) and occasional user/trespasser receptors (3.2 × 10-5 and 1.7 × 10-6, respectively) were within the risk range of 10-6 to 10-4.

Surface Soil Non-Cancer Risks – Cumulative non-cancer risks across all pathways exceed an HI of 1.0 only for future resident children (HI=6.25) for exposure to PCBs in surface soil at the site. This indicates the potential for adverse health effects in a hypothetical future residential scenario.

Subsurface Soil Cancer Risks – The excess cancer risk estimate for the resident adult and child (combined) (9.1 × 10-5) was within the risk range of 10-6 to 10-4.

Subsurface Soil Non-Cancer Risks – Cumulative non-cancer risks across all pathways exceeded an HI of 1.0 for future potential resident adults (HI=2.2) and children (HI=18) for exposure to PCBs in subsurface soil at the site. This indicates the potential for adverse health effects in a hypothetical future residential scenario.

Fish Ingestion Cancer Risks – The excess cancer risk estimate for the fisher adult and child (combined) (4.1 × 10-6) was within the risk range of 10-6 to 10-4. The risk assessment assumes that 100 percent of fish consumed are from the site, an unlikely scenario given the relatively small size of the site relative to the size of Guam. Based on the current and expected future land use at the site, a risk management decision was made that determined this risk to be acceptable. Therefore, no unacceptable cancer risks were identified for receptors ingesting fish caught in the ocean adjacent to the site.

Fish Ingestion Non-Cancer Risks – Cumulative non-cancer risks due to fish ingestion were found to be acceptable as they did not exceed an HI of 1.

For resident children, the risks associated with lead in surface and subsurface soil were estimated using the USEPA Integrated Exposure Uptake Biokinetic Model:

Surface Soil Lead Risks – Lead was detected in surface soil at concentrations greater than the screening level of 400 mg/kg. The mean lead concentration in surface soil was 270 mg/kg and the maximum detected concentration was 3,970 mg/kg. Based on LEAD99D model outputs (USEPA, 1994), children exposed to lead in surface soil under residential exposure conditions are predicted to have a mean blood lead level of 4.6 micrograms per


deciliter (g/dl), with approximately 95 percent of the exposed children’s blood lead levels below the 10 g/dl level of concern. Although the predicted mean blood lead concentration for children is below the level of concern, there are several areas throughout the site where lead concentrations greatly exceed the residential RSL of 400 mg/kg (Figure 2-3). Therefore, a risk management decision was made to retain lead as a COC.

Subsurface Soil Lead Risks – Lead was detected in subsurface soil at concentrations greater than the screening level of 400 mg/kg. The mean lead concentration in subsurface soil was 127 mg/kg and the maximum detected concentration was 742 mg/kg. Based on the LEAD99D model outputs, children exposed to lead in subsurface soil under residential exposure conditions are predicted to have a mean blood lead level of 3.0 g/dl, with more than 99 percent of the exposed children’s blood lead levels below the 10 g/dl level of concern. Therefore, under future potential conditions whereby children could be exposed to Site 14 subsurface soil under residential conditions, there are no concerns for potential adverse health effects.

2.7.1.5 Uncertainties in the HHRA

Numerous uncertainties are involved in the HHRA process. These are discussed briefly below.

Sampling and Analysis Uncertainties

The sampling plan can have a significant impact on the results obtained in calculating human health risks at a site. When samples are taken in areas which are expected to be contaminated (biased sampling), the EPC used to calculate risk is more likely to overestimate the average concentration of contaminants at the site than data collected randomly during a sampling event. This sampling bias will generally result in an overestimate of exposures and risks at a site. The soil sampling at Site 14 incorporated a combination of random and biased samples. As the majority of soil samples collected at Site 14 are biased toward potentially contaminated areas, the measured concentrations and calculated health risks may be overestimated.

The data from soil samples collected from the entire Site 14 area (above and below the cliff line) were combined for the HHRA. To verify that this did not result in underestimated risk estimates, an analysis was conducted to evaluate the potential risks for these COPCs using RME values calculated for data sets for the areas above and below the cliff line. The analysis concluded that the calculated risks do not underestimate the risks to future residents if future residential exposures were limited to above or below the cliff line (URS-Dames & Moore, 2002).

Forty fish samples were analyzed using USEPA Method 8082. The ten samples in which PCBs were detected were also analyzed using USEPA Method 1668. If the Method 1668 data were used in place of the Method 8082 data in the risk assessment, the results of the risk assessment would not change significantly.


Chemical Fate and Transport Modeling Uncertainties

The models used to estimate chemical concentrations associated with particulates in air at Andersen AFB are consistent with those recommended by USEPA (1996). However, due to uncertainties in modeling methodologies, USEPA-recommended models are likely to overestimate actual concentrations at the site. Thus, use of models is likely to result in overestimates of health risks at Andersen AFB.

Uncertainties of Toxicity Assessment

Numerous uncertainties are associated with the toxicity assessment. These are generally due to the unavailability of data to evaluate the toxicity of COPCs.

Uncertainties Analysis of Exposure Assessment

Soil Ingestion Rate – Soil ingestion rates for children are based on studies performed by Binder et al. (1986) and Clausing et al. (1987). Methods used in both studies involve the measurement of non-metabolized tracer elements in the feces of children and in the soil with which the child is in contact with. Both were short-term studies, and as they were not based on average long-term exposures, they represent an overestimate of exposure. More recent published data have shown that average soil ingestion rates for two-year-olds is less than 100 mg/day (Calabrese et al., 1989; Davis et al., 1990). Furthermore, USEPA soil ingestion rates for children ages 1 to 6 are based on ingestion rates for children at age 18 months and are applied through age 6 years (USEPA, 1989). This soil ingestion rate is very unlikely because children over 2 years old do not ingest at the same rate as an 18-month-old. Additionally, a conservative estimate was used for the fraction ingested (value of 1.0), which assumes that all soil ingested (for residential exposures) is ingested at the residence. This assumes that no activities take place elsewhere. Taken together, these suggest that intakes for this pathway are overestimated.

Exposure Duration – USEPA assumes residential exposure duration for adults is 30 years, which represents the USEPA-derived 90th percentile upper limit for time spent at one residence. The average (50th percentile) time spent at one residence is seven years. These values are recommended in the Risk Assessment Guidance for Superfund (USEPA, 1989). Soil ingestion for children age 1 to 6 is assumed to continue for the entire 6-year time frame.

Exposure Frequency – Although an assumption was made that occasional users/trespassers on the island of Guam will be exposed to subsurface soils containing hazardous waste for 40 days/year for 25 years, this is very unlikely. It does not seem feasible that there are enough housing developments built on land above landfills to make it possible for occasional users/trespassers to be exposed to this extent. Therefore, it is highly likely that the RME risk estimates presented in this report significantly overestimate the potential human health risks.


Uncertainties in Risk Characterization

Uncertainties in the risk characterization can stem from the inherent uncertainties in the data evaluation, the exposure assessment process, including any modeling of EPCs in secondary media from primary media, and the toxicity assessment process. The individual uncertainties in these respective processes were addressed in the previous sections.

2.7.2 Summary of Ecological Risk Assessment

This section summarizes the approaches and findings of the ERAs that have been performed at Site 14. The COCs associated with unacceptable site risk (if any) are identified, as well as the receptors and exposure pathways of primary concern.

An ERA was initially performed as a component of the 2002 EE/CA to evaluate potential ecological risks associated with exposure to contamination at Site 14 (URS-Dames & Moore, 2002). In support of the 2009 RI for Site 14, an additional ERA was performed to evaluate the likelihood that adverse ecological effects may occur or are already occurring as a result of exposure to PCBs at Site 14 (HDR|e2M, 2009a). The RI ERA was based closely on the ERA performed as part of the EE/CA, updated when necessary to adhere to recent risk assessment guidance. The RI ERA included analyses of PCBs in soil performed in support of the EE/CA and the Interim Remediation Verification Report, as well as analyses of PCBs in soil and marine biota conducted during the RI field investigation.

2.7.2.1 Identification of Contaminants of Concern

This section identifies those chemicals associated with unacceptable risk at the site and that are the basis for the proposed remedial action. Although other chemicals were detected at the site, these COCs are the primary risk-driving chemicals. The detection frequency, range of detected concentrations, and the EPCs for COCs and media of concern are identified.

Media Contaminant

of Concern

Concentration Detected (mg/kg)

Frequency of

Detection EPC

Statistical Measure

Minimum Maximum Soil On-Site - Direct Contact - Surface Soil

Total PCBs 0.0031 109.5 118/158 7.02 97.5%

KM UCL

Statistics: 97.5% KM UCL indicates the Kaplan-Meier Method UCL of the mean, as calculated using USEPA's ProUCL software.

Notes: UCL = upper confidence limit of the mean

2.7.2.2 Exposure Assessment

This section describes the ecological setting on and near the site and types of habitat present, including any ecologically sensitive areas that have been identified. The key species at the site


are identified, including any Federal or State designated rare, endangered, or threatened species. Complete exposure pathways and chemical-specific exposure point concentrations for each receptor of interest are also presented. The results of any field studies that have been conducted, as well as the assumptions, approaches, and results of any exposure modeling are presented.

Site 14 is a coastal site located along a cliff line and contains both mixed shrub and limestone forest habitats (Photos 2-1 through 2-8). Ecological receptors of concern (ROCs) included the endangered Mariana crow, the endangered Mariana fruit bat, the yellow bittern, terrestrial plants, and terrestrial invertebrates, and the marine community, including fish and piscivorous (fish-eating) wildlife.6 Surface soil was identified as the only media of concern. A CSM was developed to aid in determining reasonable exposure scenarios and pathways of concern; this CSM is shown in Figure 2-5.

2.7.2.3 Ecological Effects Assessment

This section summarizes the results of any toxicity tests or field studies conducted to evaluate adverse ecological effects. In addition, the assessment and measurement endpoints developed for this site are presented.

To assess ecological risks, analysis must focus on one or more endpoints, or explicit expressions of the environmental values that are to be protected. Measurement endpoints are quantifiable ecological characteristics that are related to the assessment endpoints, since the latter may be difficult to measure directly. The assessment endpoint characteristics that are not measurable may be inferred from measurement endpoint data. A summary of the assessment and measurement endpoints for Site 14 is summarized in the following table.

6 Marine receptors were identified as ROCs only for the RI ERA, which estimated risks due to PCBs.


Assessment Endpoint Measurement Endpoint Specifics of Assessment

Ecological health of terrestrial plant community

Measured soil concentrations of PCBs

Comparison of site-averaged soil concentrations to screening level protective of plants.

Ecological health of terrestrial invertebrate community

Measured soil concentrations of PCBs

No screening level protective of soil invertebrates is available for PCBs; this endpoint could not be assessed.

Ecological health of herbivorous terrestrial animal community (Mariana fruit bat)

Evaluation of dose in food items based on food web modeling and soil concentrations

Calculated dose to be compared to PCBs TRVs for surrogate species.

Ecological health of omnivorous terrestrial animal community (Mariana crow)


Calculated dose to be compared to TRVs for PCBs for surrogate species. Diet assumed to consist of equal fractions of plant matter and invertebrates.

Ecological health of carnivorous terrestrial animal community (yellow bittern)


Calculated dose to be compared to TRVs for PCBs for surrogate species. Diet assumed to consist of equal fractions of invertebrates and omnivorous prey animals.

Ecological health of marine community, including piscivorous wildlife(1)

Measured marine biota concentrations of PCBs (maximum fish level)

Comparison of maximum measured concentration of total PCBs in fish to screening level protective of piscivorous wildlife

Notes: 1. Marine receptors were identified as ROCs only for the RI ERA, which estimated risks due to PCBs. TRV = toxicity reference value

2.7.2.4 Ecological Risk Characterization

Risks to ecological ROCs were found to be acceptable, with the exception of soil invertebrates and the yellow bittern. No toxicity information for soil invertebrate exposure to PCBs was available, which precluded evaluation of this endpoint.

A potentially significant risk to the yellow bittern population was found, as the lowest observed adverse effects level-based hazard quotient was calculated as 1.2. The yellow bittern, as a terrestrial carnivore high on the food chain, is most vulnerable to bioconcentration of PCBs. Several assumptions could lead to these risks being overestimated. As a highly mobile predator, the yellow bittern population is not expected to forage exclusively on Site 14. It also prefers to nest in wetland areas with reeds and shrubs, and not in the open, cleared environment characteristic of the site. Additionally, as the highest trophic level receptor, the yellow bittern endpoint is prone to the most uncertainties regarding parameters used in the food web analysis. However, the assumption that 1/2 of the yellow bittern’s diet is invertebrates rather than omnivores may lead to underestimation of risk, as the modeled tissue concentrations in omnivores were 6.5 times higher than those in invertebrates. Overall, although the modeled risks to the yellow bittern are highly uncertain and likely overstated, the potential for significant risk cannot be ruled out.

Based on the presence of unacceptable risks to the yellow bittern, remedial action is being recommended to reduce the risks.


2.7.2.5 Uncertainties in the ERA

Numerous uncertainties are involved in the ERA process. These are discussed briefly below.

Non-Random Sampling

While ecological receptors are likely to be found anywhere about Site 14, environmental media at known or suspected waste sites are typically sampled in a non-random fashion. Peripheral and nearby areas are under-sampled, if at all, and thus the average exposure of ecological receptors is biased high and exposure concentrations used in the risk assessment are conservative.

COPC Selection

COPCs for the ERA were selected by comparison of maximum concentrations for the measured analytes with conservative, toxicologically based concentrations expected to represent no adverse effect levels. In addition, because the geology of Andersen AFB is unique (represented by highly weathered limestone), reference background concentrations of metals were also used to identify COPCs. The use of conservative toxicity values relative to maximum concentrations represents a very conservative screening process. Because plants and animals on Andersen AFB have acclimated to high metal concentrations such as lead or nickel, the use of representative background concentrations represents a more realistic COPC selection mechanism.

Receptor of Concern Selection

Selection of appropriate ROCs in the Site 14 ERA was performed using different criteria than are typically used. Because of the concern for the extirpation of native animals and plants on the island, any species that were introduced to the island and are thus not native species were not considered to be ROCs. Alternatively, native species found at the site were identified as ROCs. The native blue-tailed skink, while observed on the site, was not selected as an ROC due to the lack of appropriate toxicological values. It is expected that in the event of acceptable risk being found for identified ROCs, the insectivorous blue-tailed skink would also have acceptable risk; however, this is an assumption with unknown uncertainty.

Exposure Pathways

Inhalation and dermal exposure to terrestrial receptors were not quantified because doses from these pathways are very small relative to food and incidental soil ingestion. While this may underestimate the total dose to the ROC, the underestimate would be in the fraction of a percent of total dose, and is thus not of importance. In addition, ingestion of surface water was not considered in this risk assessment. There are very few, if any, natural surface water bodies at Andersen AFB because the ground is very porous, and any water that falls on the surface is rapidly infiltrated into the ground. Groundwater at Site 14 is moderately deep, from 20 to 380 feet bgs, and is thus not accessible to ecological receptors. The ecological receptors on Guam have adapted to this characteristic by obtaining most of their water from the food that they consume, which accounts for the large number of fruit eaters on Guam.


Exposure Assumptions

A number of assumptions were made to estimate metal doses to the terrestrial ROC. Some of these assumptions were conservative, adding to the potential overestimate of risk, while some exposure assumptions have an unknown effect on the uncertainty of this risk assessment.

Because there is little information available for the bird receptors, certain food-web model components are uncertain. For example, the assignment of feeding fractions for the yellow bittern (100 percent of reptile) and the 2 percent incidental soil ingestion are based on best professional judgment, in the absence of species- and site-specific data. Similarly, the use of the available tissue concentration data for monitor lizard and papaya as a surrogate for the various food items eaten by the ROC adds uncertainty. These food items were collected or hunted at Andersen AFB, but not at Site 14. It has been assumed that concentrations of these food items at Site 14 are the same as those found at the base. How this assumption relates to uncertainty is not known, as risks may be either over- or under-estimated.

COPCs were assumed to be 100 percent bioavailable. The assumption that COPCs are 100 percent bioavailable is highly unlikely based on soil chemistry.

A conservative assumption made for the Mariana fruit bat, Mariana crow, and the yellow bittern was that the foraging range for them was 100 percent at Site 14 with respect to incidental soil exposure, and over the entire Andersen AFB for tissue concentrations. The assumption of

100 percent soil exposure from the site is very conservative, as all of these receptors have a wide foraging range.

Exposure and subsequent risk to worms and plants were represented by mean values instead of upper level exposures such as the maximum concentration or UCLM. Consequently, the use of mean concentrations rather than upper limit estimates is more representative of population exposure than individual exposure.

Toxicity Reference Values

Numerous uncertainties are associated with the toxicological data used in the risk characterization. These are generally due to the unavailability of data to thoroughly calculate the toxicity of COPCs. In several instances, there were missing toxicity reference values for various ROCs. Given the absence of appropriate toxicity reference values, it is not possible to eliminate the potential risk from these COPCs; however, the finding of acceptable risk levels for other ROCs indicates that these receptors may also not be at risk.

Cumulative Hazard Indices

While not evaluated for this ERA, it is known that two or more chemicals can interact with each other, resulting in skewed toxicity. No real guidance exists for this type of assessment within the ERA process, and the state-of-the-science does not suggest that cumulative hazard indices be calculated.


Population Level Effects

The goal of an ERA is to protect the populations of organisms living on or near the site of concern. When the potential or observed presence of threatened and endangered species is found, these receptors deserve a special level of protection, protecting each individual organism. However, for most organisms, the protection of the populations remains the goal. Toxic endpoints used for plants tend to be individual, such as reduced weight or shoot length. Toxic endpoints for earthworms, mammals, and birds are those that could have an impact on the population, such as reproduction. In addition, for this ERA, concentrations of metals in soil were represented by lognormal means, which are more reflective of what the populations of organisms are likely to be exposed to at the site.

Analytical Methods for PCB Measurement

The most detailed and theoretically accurate available method for PCB analysis, USEPA Method 1668, identifies individual compounds and determines total PCBs by summing over the compounds. The original method, USEPA Method 8082, attempts to identify Aroclor mixtures. Complete compound-specific methods have comparatively recently become available and remain as much as an order of magnitude more expensive than Aroclor-based methods. However, particularly for estimation of total PCBs, Method 1668 may in some cases be technically preferable. Aroclor mixtures may contain overlapping sets of compounds, and so determining total PCBs by summing over Aroclors may partially double-count the actual PCBs present. Moreover, Method 8082 may be unable to quantify weathered products whose compound profile is no longer consistent with any Aroclor mixture, which would lead to incorrect estimates of total PCBs.

Method 8082 was used to analyze soil samples for Site 14, and marine biota samples were analyzed with both Method 8082 and Method 1668. For marine biota, the results of Method 1668 were used in the risk assessment. However, there were inconsistencies between the results of the two methods on the same biota samples, most notably in one analysis of a flagtail grouper, in which Method 8082 detected total PCBs at a concentration of 3.5 micrograms per kilogram (µg/kg) while Method 1668 detected total PCBs at a concentration of 23.68 µg/kg. Since only Method 8082 was used on the soil samples, it is possible that the measurements of total PCBs in soil are inaccurate, which casts some uncertainty on the risk assessments for the terrestrial endpoints.

2.7.3 Basis for Action

The response action selected in this ROD is necessary to protect public health or welfare or the environment from actual or threatened releases of pollutants or contaminants from surface and subsurface soil at Site 14, which may present an imminent and substantial endangerment to public health or welfare.

A response action at Site 14 is warranted to mitigate unacceptable cancer and non-cancer risks present in surface and subsurface soil at the site.


2.8 Remedial Action Objectives

Remedial action objectives (RAOs) provide a general description of what the cleanup will accomplish. These goals typically serve as the design basis for the remedial alternative. Generally applicable RAOs include the following:

Protect human health and the environment by reducing the potential for exposure to contaminants.

Expedite site cleanup and restoration.

Use permanent solutions to the maximum extent possible.

Use solutions that support existing and proposed land uses.

Achieve compliance with applicable or relevant and appropriate requirements (ARARs).

Specific RAOs were developed to protect against exposure to contaminated media that present an unacceptable risk to human health. Based on the results of the EE/CA and RI HHRAs, PCBs, lead, and ACM are the risk drivers at Site 14. The following concentrations are used as site-specific PRGs protective of human health and the environment:

PCBs – 0.5 mg/kg, the risk-based RGO based upon 10-6 excess cancer risk developed in the risk assessment (URS-Dames & Moore, 2002).

Lead – 400 mg/kg, the USEPA 2009 residential RSL.

Ecological-based remedial goals were developed to address potentially unacceptable ecological risks to the yellow bittern related to PCBs. However, due to the highly conservative nature of the ERA models, it is likely that risks to the yellow bittern are overstated. Therefore, a risk management decision was made to develop remedial action alternatives based on achieving site-specific PRGs that are protective of potential human receptors at the site rather than ecological receptors. This risk management decision is consistent with the remedial action selection process employed for other sites at Andersen AFB under the IRP.

These are considered immediate objectives, which are possible to achieve using a variety of readily implementable technical approaches.

2.9 Description of Alternatives

This section presents descriptions of those remedial alternatives that were retained for Site 14 and carried through to the Comparative Analysis of Alternatives in Section 2.10. Each alternative evaluated is described in detail, including remedy components, common elements and distinguishing features, and expected outcomes, in the following subsections.


2.9.1 Description of Remedy Components

Above the Cliff Line Alternatives

Four alternatives for addressing contamination above the cliff line were retained through the screening process, as described below (HDR|e2M, 2009b).

Alternative 1 – No Action

The No Action alternative is required by the NCP so that a baseline set of conditions can be established against which other remedial actions may be compared. This no cost alternative allows the site to remain in its current state with no remedial actions being implemented. No treatment technologies are implemented, no containment or mitigation of contaminants is performed, no LUCs are enacted, and there are no operations, maintenance, or monitoring requirements.

Alternative 2 - Excavation of PCBs ≥ 50 mg/kg with Off-Island Disposal, Soil Cover, and LUCs

For the area above the cliff line, this remedial action alternative combines excavation with off-island disposal of soil containing PCBs at concentrations of 50 mg/kg or greater, soil cover, and LUCs to limit exposure pathways for PCBs, lead, and ACM contamination at Site 14.

Excavation with Off-Island Disposal – Excavation of a total of 40 lcy of soil, covering a surface area of 36 square feet, containing PCB concentrations greater than or equal to 50 mg/kg and disposal at a TSCA-approved off-island treatment, storage, and disposal facility. Confirmation sampling would be employed to ensure that all soils with PCBs in excess of 50 mg/kg were properly excavated and disposed.

Soil Cover – Following the removal of soil containing PCB concentrations greater than or equal to 50 mg/kg, the ACM and lead-containing soil located north of the cover area will be excavated and placed in the PCB excavations. An area of approximately 86,000 square feet, or 2 acres, will be covered with a 24-inch layer of crushed coral topped with a 4-inch thick layer of clean soil to provide containment of the following contaminants:

o PCBs at concentrations greater than 0.5 mg/kg (RGO 10-6 cancer risk)

o Lead at concentrations greater than 400 mg/kg (USEPA residential soil RSL)

o ACM

Prior to placement of the soil cover, grubbing operations would be used to clear the area of underbrush. The removed vegetation would be piled in a location onsite and allowed to decompose naturally. The cover would be designed to minimize erosion and to divert surface runoff away from cliff edge at the site. Soil would be pulled back approximately ten feet from the cliff edge along the cover area, and a retaining wall would be constructed to prevent contaminated soil from raveling over the cliff. The site would then be revegetated. The existing access gate and heavily forested area on the western side of Site 14 would further minimize any potential damage to the soil cover from


unrestricted vehicle access. Periodic inspections of the soil cover would be required to ensure long-term protectiveness.

LUCs – Implementation of administrative and/or legal measures would prohibit future residential use of Site 14 above the cliff line. For active military bases, the local authority for regulating and enforcing LUCs is the Base Commander. LUCs should be incorporated into the Base Master Plan and provide details on the subject property and the restrictions that apply. This low-cost control would be used in unison with limited excavation and disposal and a soil cover to help reduce exposure to COCs left at the site.

Following successful implementation of the above actions, the site would be suitable for continued use as open space, but would not be suitable for unlimited use and unrestricted exposure (e.g., residential). Therefore, the USN, in conjunction with the USEPA and Guam EPA, would conduct five-year reviews to ensure that the land use restrictions are effective in the future in protecting human health and the environment. The reviews would focus on the site conditions, the current and planned future site use, the results of nearby monitoring programs (e.g., the Basewide LTGM Program), and the LUC-compliance reports. Five-year reviews would be conducted until the concentrations of hazardous substances in the soil are at such levels to allow for unrestricted use and exposure.

Alternative 3 – Excavation and Removal of Soil Containing PCBs ≥ 50 mg/kg and Shipment of the Soil to an Off-Island Facility, and Excavation and Removal of Soil Containing PCBs < 50 mg/kg, and/or Lead ≥ 400 mg/kg, and/or ACM and Movement of the Soil to the CU (resulting in unrestricted use)

To achieve unrestricted use for the area above the cliff line, this remedial alternative includes the excavation and disposal of PCB-, lead-, and ACM-contaminated soil above the cliff line at Site 14:

Excavation with Off-Island Disposal – Excavation of a total of 40 lcy of soil containing PCBs at concentrations greater than or equal to 50 mg/kg and disposal at a TSCA-approved off-island treatment, storage, and disposal facility. Confirmation sampling would be employed to ensure that all soils with PCBs in excess of 50 mg/kg were properly excavated and disposed.

Excavation with On-Island Disposal in the CU – Excavation and disposal of approximately 9,600 cubic yards of soil containing PCBs at concentrations between 0.5 mg/kg and 50 mg/kg, lead at concentrations greater than or equal to 400 mg/kg, and ACM at the on-island CU. Confirmation sampling would be employed to ensure that PCB concentrations remaining in onsite soils averaged 0.5 mg/kg or less, not to exceed 5.0 mg/kg. A new cell would be constructed at the CU to contain the contaminated soils from Site 14. The excavated limestone from the CU cell would be segregated by size (2-inch minus [2 inches and less] and 4-inch minus [4 inches and less]) and stockpiled for later use as the final earth cover. The remedial wastes would be buried below ground surface with a synthetic impervious liner installed over top, prior to installing the final earth cover, to provide added protection against migration of COCs. The final earth


cover would consist of a one-foot layer of 2-inch minus fill material over a one-foot layer of 4-inch minus fill material.

If necessary, based upon the waste characterization sampling, the excavated soil at Site 14 may be treated (e.g., stabilized) to meet disposal requirements of the receiving facility. Confirmation sampling would be employed to ensure that all soils exceeding remedial goals were properly excavated and disposed.

Alternative 4 – Excavation of Contaminated Soil with Off-Island Disposal (resulting in unrestricted use)

To achieve unrestricted use for the area above the cliff line, this remedial alternative combines the use of excavation with off-island disposal of approximately 9,640 lcy of soil containing PCBs at concentrations greater than or equal to 0.5 mg/kg, and/or lead at concentrations greater than or equal to 400 mg/kg, and/or ACM above the cliff line at Site 14.

If necessary, based upon the waste characterization sampling, the excavated soil at Site 14 may be treated (e.g., stabilized) to meet disposal requirements of the receiving facility. Confirmation sampling would be employed to ensure that all soils exceeding remedial goals were properly excavated and disposed.

Below the Cliff Line Alternatives

Two alternatives for addressing contamination below the cliff line were retained through the screening process: 1) No Action and 2) LUCs and Monitoring. Other common remedies such as excavation or capping were screened out in the FS. The primary source of contamination is above the cliff line and the contaminants below the cliff line pose a relatively low risk. In conjunction with the very low implementability for work access to the areas below the cliff, only LUCs and monitoring were carried forward.

Alternative 1 – No Action

The No Action alternative is required by the NCP so that a baseline set of conditions can be established against which other remedial actions may be compared. This no cost alternative allows the site to remain in its current state with no remedial actions being implemented. No treatment technologies are implemented, no containment or mitigation of contaminants is performed, no LUCs are enacted, and there are no operations, maintenance, or monitoring requirements.


Alternative 2 – LUCs and Monitoring

Implementation of LUCs below the cliff line at Site 14 will aid in prevention of future development or use of the property not in line with its current land use designation. For active military bases, the local authority for regulating and enforcing LUCs is the Base Commander. LUCs should be incorporated into the Base Master Plan and provide details on the subject property and the restrictions that apply. This low-cost control will be used to help reduce exposure to COCs left at the site by prohibiting future residential use of Site 14 below the cliff line. The LUCs would remain in effect for as long as the site conditions are not suitable for unrestricted use and unlimited exposure. A length of 30 years was used for the purpose of cost analysis.

Fish monitoring conducted during the RI showed no unacceptable risks to marine receptors. The remedy would include follow-up fish monitoring as a conservative measure to confirm that there were no impacts to marine receptors from PCBs below the cliff line. At least one round of samples would be collected prior to the five-year review and the need for additional rounds would be evaluated during the five-year review.

Following successful implementation of LUCs and fish monitoring, the site would be suitable for continued use as open space, but would not be suitable for unlimited use and unrestricted exposure (e.g., residential). Therefore, the USN, in conjunction with the USEPA and Guam EPA, would conduct five-year reviews to ensure that the land use restrictions are effective in the future in protecting human health and the environment. The reviews would focus on the site conditions, the current and planned future site use, the results of the fish monitoring, and the LUC-compliance reports. Five-year reviews would be conducted until the concentrations of hazardous substances in the soil are at such levels to allow for unrestricted use and exposure.

Combination of Alternatives for Above and Below the Cliff Line

As described above, separate sets of alternatives were developed to address contamination above the cliff line and below the cliff line. As the only feasible alternative for below the cliff line is LUCs and Monitoring, the alternatives have been combined as follows to simplify the discussion presented in the remainder of this document:

Alternative Designation

Description

1 No action

2 Above the Cliff Line: Excavation of PCBs ≥ 50 mg/kg with Off-Island Disposal, Soil Cover, and LUCs. Below the Cliff Line: LUCs and Monitoring.

3

Above the Cliff Line: Excavation and Removal of Soil Containing PCBs ≥ 50 mg/kg and Shipment of the Soil to an Off-Island Facility, and Excavation and Removal of Soil Containing PCBs between 0.5 mg/kg and 50 mg/kg, and/or Lead ≥ 400 mg/kg, and/or ACM and Movement of the Soil to the CU (resulting in unrestricted use). Below the Cliff Line: LUCs and Monitoring.

4 Above the Cliff Line: Excavation of Contaminated Soil with Off-Island Disposal (resulting in unrestricted use). Below the Cliff Line: LUCs and Monitoring.


2.9.2 Common Elements and Distinguishing Features of Each Alternative

Table 2-9 provides a summary of elements common to each alternative and features that distinguish one alternative from another.

2.9.3 Expected Outcome of Each Alternative

Table 2-10 provides a summary of the expected outcomes of each alternative.

2.10 Summary of Comparative Analysis of Alternatives

In accordance with the NCP, the alternatives for Site 14 were evaluated using the nine criteria described in Section 121(b) of CERCLA and the NCP §300.430(f)(5)(i). These criteria are classified as threshold criteria, balancing criteria, and modifying criteria.

Threshold criteria are standards that an alternative must meet to be eligible for selection as a remedial action. There is little flexibility in meeting the threshold criteria—the alternative must meet them or it is unacceptable. The following are classified as threshold criteria:

Overall protection of human health and the environment

Compliance with ARARs

Balancing criteria weigh the tradeoffs between alternatives. These criteria represent the standards upon which the detailed evaluation and comparative analysis of alternatives are based. In general, a high rating on one criterion can offset a low rating on another balancing criterion. Five of the nine criteria are considered balancing criteria:

Long-term effectiveness and permanence

Reduction of toxicity, mobility, and volume through treatment

Short-term effectiveness

Implementability

Cost

Modifying criteria are as follows:

Community acceptance

Territorial/support agency acceptance

This section summarizes how well each alternative satisfies each evaluation criterion and indicates how it compares to the other alternatives under consideration.

2.10.1 Overall Protection of Human Health and the Environment

Overall protection of human health and the environment addresses whether each alternative provides adequate protection of human health and the environment and describes how risks


posed through each exposure pathway are eliminated, reduced, or controlled, through treatment, engineering controls, and/or land use controls.

The excavation process options in Alternatives 3 and 4 would provide a very high degree of protection to human health and the environment from COCs, as soil above the cliff line containing PCBs at concentrations greater than or equal to 0.5 mg/kg, lead at concentrations greater than or equal to 400 mg/kg, and ACM would be excavated and disposed. In the areas where this process option would be implemented, potential pathways to human and ecological exposure at the site and the potential for migration of COCs to underlying soil and groundwater would be eliminated. In Alternative 3, only soil containing PCBs greater than or equal to 50 mg/kg would be disposed of off-island. The remainder of contaminated soil would be disposed on-island in the CU. In Alternative 4, all contaminated soil would be excavated and disposed off-island.

The excavation process option in Alternative 2 would provide a high degree of protection to human health and the environment from COCs in surface and subsurface soils as PCBs at concentrations greater than or equal to 50 mg/kg would be removed. Although the soil cover on the remaining non-hazardous portion of the site would not physically remove COCs from soil, the 2.3-foot thick soil cover (two feet of crushed coral topped with four inches of compacted soil with reseeding) would significantly reduce the likelihood of direct contact with contaminated soil in Site 14. Because this is the primary route of human and ecological exposure to COCs, this process option would be moderately protective of human health and the environment. Potential migration of COCs to underlying soil and groundwater may also be slightly reduced as a result of a compacted soil cover. Through maintenance of a vegetative cover and periodic inspections for erosion, this alternative would minimize the potential for future exposure. Additionally, LUCs, including the existing access gate to Site 14, would help reduce the number of human receptors potentially exposed to COCs in soil.

The LUCs component of Alternatives 2, 3, and 4 would be equally protective of human health and the environment, as residential use of the site would be prohibited through amendments to the Base General Plan (BGP) that effectively act as deed restrictions on the real property. The fish monitoring component of Alternatives 2, 3, and 4 would also be equally protective of human health and the environment by providing at least one round of follow-up sampling to confirm that there are no impacts to marine receptors from PCBs below the cliff line.

Alternative 1 would not mitigate short-term and long-term human health or ecological risks associated with the exposure pathways at Site 14 and therefore would not be protective of human health and the environment.

2.10.2 Compliance with Applicable or Relevant and Appropriate Requirements

Section 121(d) of CERCLA and NCP §300.430(f)(1)(ii)(B) require that remedial actions at CERCLA sites at least attain legally applicable or relevant and appropriate Federal and Territorial requirements, standards, criteria, and limitations which are collectively referred to as “ARARs,” unless such ARARs are waived under CERCLA section 121(d)(4).


Applicable requirements are those cleanup standards, standards of control, and other substantive requirements, criteria, or limitations promulgated under Federal environmental or Territorial environmental or facility citing laws that specifically address a hazardous substance, pollutant, contaminant, remedial action, location, or other circumstance found at a CERCLA site. Territorial standards that are identified by a territory in a timely manner and that are more stringent than Federal requirements may be applicable.

Relevant and appropriate requirements are those cleanup standards, standards of control, and other substantive requirements, criteria, or limitations promulgated under Federal environmental or Territory environmental or facility citing laws that, while not “applicable” to a hazardous substance, pollutant, contaminant, remedial action, location, or other circumstance at a CERCLA site address problems or situations sufficiently similar to those encountered at the CERCLA site (relevant) that their use is well-suited (appropriate) to the particular site. Only those Territorial standards that are identified in a timely manner and are more stringent than Federal requirements may be relevant and appropriate.

Compliance with ARARs addresses whether a remedy will meet all of the applicable or relevant and appropriate requirements of other Federal and Territorial environmental statutes or provides a basis for invoking a waiver.

All alternatives, except the no action alternative, had common ARARs associated with hazardous waste transportation and disposal, water pollution, endangered species, and historical sites. All alternatives would attain their respective Federal and State ARARs.

2.10.3 Long-Term Effectiveness and Permanence

Long-term effectiveness and permanence refers to expected residual risk and the ability of a remedy to maintain reliable protection of human health and the environment over time, once cleanup levels have been met. This criterion includes the consideration of residual risk that would remain on site following remediation and the adequacy and reliability of controls.

Each alternative, except the No Action alternative, would provide some degree of long-term protection. Alternatives 3 and 4 would provide the highest level of long-term effectiveness and permanence because the contaminated soils containing PCBs, lead, and ACM above the cliff line would be physically removed from the site. Alternative 2 would provide a moderate level of long-term effectiveness and permanence because the most highly contaminated soils containing PCBs would be physically removed from the site. This would effectively eliminate risks related to direct contact in this remediation zone. The soil cover is considered adequate and reliable in eliminating exposure risks and preventing migration of COCs via erosion. To remain effective, this process would require periodic surface inspections and implementation of corrective actions such as maintenance and/or repair of the cover surface to address erosion or damage that may occur over time.

The LUC component below the cliff line for Alternatives 2, 3, and 4 would be moderately effective and permanent, as residential use would be prohibited; however, migration of COCs via erosion could potentially occur. Fish monitoring would be conducted as a conservative measure to confirm that there are no impacts to marine receptors from PCBs below the cliff line.


Reviews at least every five years, as required, would be necessary to evaluate the effectiveness of any of these alternatives because hazardous substances would remain on-site in concentrations above health-based levels.

2.10.4 Reduction of Toxicity, Mobility, or Volume through Treatment

Reduction of toxicity, mobility, or volume through treatment refers to the anticipated performance of the treatment technologies that may be included as part of a remedy.

The greatest reduction in the mobility of contaminants would be achieved through the implementation of Alternative 3 or Alternative 4 because the contaminated soils above the cliff line would be physically removed from the site. Alternatives 3 and 4 also provide a low degree of treatment by including the stabilization of the lead-contaminated soil above the cliff line, if required by the disposal facility. Stabilization would reduce the mobility of lead while potentially increasing the volume of stabilized material by 10 percent.

Alternative 2 would reduce only the mobility of the most highly contaminated soil at Site 14 by physically transferring contaminated soil containing PCBs at concentrations greater than the TSCA hazardous waste level to an off-island approved disposal site. Alternative 2 would not reduce the toxicity or volume of contamination at the site.

The LUC and monitoring components below the cliff line for Alternatives 2, 3, and 4 do not include treatment; therefore, they would not reduce the toxicity, mobility, or volume of contamination at the site.

Alternative 1 does not include treatment as a component of the remedy; therefore, this alternative would not reduce the toxicity, mobility, or volume of contamination at the site.

2.10.5 Short-Term Effectiveness

Short-term effectiveness addresses the period of time needed to implement the remedy and any adverse impacts that may be posed to workers, the community, and the environment during construction and operation of the remedy until cleanup levels are achieved. This evaluation criterion is two-fold. One aspect addresses the time until remedial action objectives are met and the other addresses the effects of the alternative during the construction and implementation phase of the alternative.

Alternatives 2, 3, and 4 are effective in the short term because they would begin reducing PCBs soil concentrations upon alternative implementation. There would be some short-term risks to site workers and the environment from the potential impact of fugitive dust emissions generated during grubbing, soil excavating, and soil cover placement operations. Dust emissions could be mitigated through engineering controls (dust suppression), air monitoring, and personal protective equipment.

The time estimated to implement Alternative 2 is approximately one month. The excavation and disposal process in Alternative 3 would take approximately six months to complete, as it would involve construction of a new cell in the CU to contain the contaminated soils from Site 14. The


excavation and disposal process in Alternative 4 would take approximately one month to complete.

The LUC component below the cliff line for Alternatives 2, 3, and 4 would be effective in the short-term as LUCs would be quickly implemented (e.g., within 1 year) to achieve RAOs and no new risks to the community, site workers, or the environment would result. The fish monitoring component would also be effective in the short-term, as the first round of samples would be collected prior to the five-year review and the need for additional rounds would be evaluated during the five-year review.

Alternative 1, No Action, would not be an effective alternative because current risks from direct contact would continue to exist; occasional users/trespassers would potentially be exposed to high concentrations of PCBs and lead in soil, as well as ACM.

2.10.6 Implementability

Implementability addresses the technical and administrative feasibility of a remedy from design through construction and operation. Factors such as availability of services and materials, administrative feasibility, and coordination with other governmental entities are also considered.

Alternative 2 would be the simplest alternative to implement from an administrative and technical viewpoint. Manifesting and off-island disposal of 40 lcy of contaminated soil would be required under this alternative. Technically, engineering services and materials would be readily available in Guam for providing excavation services and constructing a soil cover. Soil cover operations in Alternative 2 would be relatively simple to implement both technically and administratively through use of the following planning measures: dust suppression, scheduling of truck traffic flow into and out the site, and staging of earth moving equipment. Several health and safety risks would need to be addressed with regard to truck traffic and the general hazards associated with earth moving activities.

Alternative 3 would be the next simplest alternative to implement. Administratively, Alternative 3 requires a similar level of effort as Alternative 2. Technically, Alternative 3 would require more effort than Alternative 2, as it would include excavation of the fill material in the cell at the CU, as well as installation of an impervious synthetic top liner over the contaminated soil deposited in the cell.

Alternative 4 would require the most administrative effort because of permit requirements to allow for the disposal of contaminated soil off-island. The technical effort required for loading and transporting 9,640 lcy of contaminated soil for disposal off-island under Alternative 4 would also be much greater than Alternatives 2 and 3.

The LUC component below the cliff line for Alternatives 2, 3, and 4 is a proven and accepted remedial alternative under the appropriate site conditions. The administrative feasibility of implementing the LUCs would be relatively simple, as there would be very little coordination of resources and materials. Annual inspections and periodic site reviews, to be conducted in conjunction with the five-year review process, would be implementable with the existing Andersen AFB personnel to ensure that LUCs are protective of human health and the


environment. The fish monitoring component below the cliff line for Alternatives 2, 3, and 4 would be relatively simple to implement both technically and administratively, as it would be based upon the previous fish sampling event conducted for Site 14.

Alternative 1 would require no implementation effort.

2.10.7 Cost

The estimated total present worth costs and cost summaries for the alternatives are presented in the following table. There are no costs associated with Alternative 1.

Alternative

Total Present

Worth Cost Short-Term and Long-Term Costs Considered Alternative 2 $1,769,508 This alternative includes $452,017 for excavation and disposal of soil

containing PCBs > 50 mg/kg, $1,165,523 for soil cover, $144,705 for fish monitoring, and $7,263 for LUCs.

Alternative 3 $2,711,366 This alternative includes $452,017 for excavation and disposal of soil containing PCBs > 50 mg/kg, $2,107,381 for excavation and on-island disposal in the CU of soil containing PCBs between 0.5 and 50 mg/kg and/or lead > 400 mg/kg, and/or ACM, $144,705 for fish monitoring, and $7,263 for LUCs.

Alternative 4 $78,614,244 This alternative includes $78,462,276 for excavation of contaminated soil with off-island disposal, $144,705 for fish monitoring, and $7,263 for LUCs.

2.10.8 Territorial/Support Agency Acceptance

The Government of Guam has expressed its support for Alternatives 2, 3, and 4. The Government of Guam does not support Alternative 1 because the identified unacceptable risks to human health would not be mitigated.

2.10.9 Community Acceptance

During the public comment period, the community expressed its support for Alternative 3. The community does not support Alternative 1 because the identified unacceptable risks to human health would not be mitigated.

2.11 Principal Threat Wastes

The NCP expects that treatment that reduces the toxicity, mobility, or volume of the principal threat wastes will be used to the extent practicable. The principal threat concept refers to the source materials at a CERCLA site considered to be highly toxic or highly mobile that generally cannot be reliably controlled in place or present a significant risk to human health or the environment should exposure occur. A source material is material that contains hazardous substances, pollutants, or contaminants that act as a reservoir for migration of contamination to groundwater or air, or that acts as a source for direct exposure. This section lists the principal threat waste at Site 14 and discusses how each remedial alternative would address it.


Approximately 40 lcy of soil contaminated with PCBs above the TSCA hazardous waste level of 50 mg/kg may be considered a principal threat waste at Site 14. Alternatives 2, 3, and 4 all provide equal reduction in risk posed by the principal threat waste, as the soils would be excavated and disposed off-island at a TSCA-approved facility. Alternative 1 does not provide any reduction in risk from the principal threat waste as no action would be taken.

2.12 Selected Remedy

The primary indicator of remedial action performance will be satisfying the RAOs for Site 14 and protecting human health and the environment. Performance measures are defined herein as the RAOs (see Section 2.8) plus the required actions to achieve the objectives, as defined in this section. It is anticipated that successful implementation, operation, maintenance, and completion of the performance measures will achieve a protective and legally compliant remedy for Site 14.

The remedy for Site 14, Alternative 3, was selected based upon the ability to protect human health and the environment, and cost effectiveness. This section describes the selected remedy and also provides specific performance measures for the selected remedy.

Remedy selection is based on the detailed evaluation of remedial alternatives presented in the FS (HDR|e2M, 2009b). It is expected that the remedy will remain in effect and be protective of human health and the environment until such time as the concentrations of COCs decrease to, or below, applicable cleanup levels.

The USN is responsible for implementing, monitoring, maintaining, reporting on, and enforcing the remedial action identified herein for the duration of the remedy selected in this ROD. The USN will exercise this responsibility in accordance with CERCLA and the NCP.

2.12.1 Summary of the Rationale for the Selected Remedy

The selected remedy for Site 14 is Alternative 3. The USN and USEPA believe that the selected remedy is the alternative that best meets the nine criteria described in Section 300.430(e)(9)(iii) of the NCP. Pursuant to Section 300.430(f)(i) of the NCP, these criteria are grouped into the three categories set forth below.

Threshold criteria

- Protection of human health and the environment

- Compliance with ARARs

Balancing criteria

- Long-term effectiveness and permanence

- Toxicity, mobility or volume reduction through treatment

- Short-term effectiveness

- Implementability

- Cost


Modifying criteria

- Territorial agency acceptance

- Community acceptance

The USN and USEPA have selected Alternative 3 as the remedy on the basis of the criteria above. Alternative 3 meets the threshold criteria and provides the best balance of tradeoffs among the other alternatives with respect to the balancing and modifying criteria, and provides the greatest potential return on investment when compared to the other alternatives.

Alternative 1 was not selected because it is not protective human health and the environment. Alternative 2 was not selected because it provides a less permanent remedy when considering potential return on investment. Alternative 4 was not selected because it is not cost-effective.

2.12.2 Description of the Selected Remedy

The selected remedy, Alternative 3, combines the use of excavation with disposal above the cliff line and LUCs and fish monitoring below the cliff line to eliminate exposure pathways for PCBs, lead, and ACM contamination at Site 14 (Figure 2-7).

2.12.2.1 Excavation with Off-Island Disposal

This component of the remedy involves excavating a total of 40 lcy of contaminated soil containing PCBs at concentrations greater than or equal to 50 mg/kg from four locations above the cliff line (Figure 2-7). The excavated soil will be segregated, placed in disposal bags, and transported to an approved off-island disposal facility. Confirmation sampling would be employed to ensure that all soils exceeding the TSCA hazardous waste level for PCBs were properly excavated and disposed.

2.12.2.2 Excavation with On-Island Disposal in the Consolidation Unit

Following the excavation of impacted soil containing PCB concentrations greater than or equal to 50 mg/kg, approximately 9,600 lcy of soil above the cliff line will be excavated and disposed at the on-island CU. This component of the remedy focuses on the areas of impacted soil above the cliff line containing PCBs, lead, and metals at the concentrations defined below:

PCBs at concentrations between 0.5 mg/kg and 50 mg/kg, with a cleanup goal of an average of 0.5 mg/kg (RGO at 10-6), not to exceed 5.0 mg/kg.

Lead at concentrations greater than or equal to 400 mg/kg (residential USEPA RSL)

ACM

This component will require the development of a remedial design. A new cell with a depth of at least 10 feet will be constructed at the CU to contain the contaminated soils from Site 14. The excavated limestone from the CU cell will be segregated by size (2-inch minus and 4-inch minus) and stockpiled for later use as the final earth cover. Soils would be emplaced in the CU in accordance with the specifications outlined in the Consolidation Unit Management Plan for


Andersen AFB (EA, 2007). The remedial wastes would be buried below ground surface with a synthetic impervious liner installed over top, prior to installing the final earth cover. The final earth cover would consist of a one-foot layer of 2-inch minus fill material over a one-foot layer of 4-inch minus fill material.

Soil will be tested on-site using the Toxicity Characteristic Leaching Procedure and may be treated (e.g., stabilized), if necessary, to meet disposal requirements of the CU. Based on the sample results shown in Figures 2-3 and 2-4, an estimated 10 percent of the lead-contaminated soils (960 lcy) may require onsite treatment with triple superphosphate to stabilize the soil prior to removal from the site. Confirmation sampling would be employed to ensure that all soils exceeding remedial goals were properly excavated and disposed.

An estimated 1,600 lcy of clean soil will be required to cover the Site 14 excavation area, shown on Figure 2-7. The site will be hydroseeded to help restore the vegetative cover.

2.12.2.3 Land Use Controls

In support of the selected remedy, the USN will implement the following actions to ensure that current and future land use activities remain compatible with the land use restrictions that are imposed by the ROD, and that they remain protective of human health and the environment. LUCs will be maintained until the concentrations of hazardous substances in the soil are at such levels to allow for unrestricted use and exposure.

The components necessary for implementation of the LUCs are as follows:

Phase 1Development of a Land Use Control Management Plan (LUCMP) and implementation of LUCs.

Phase 2Periodic reviews (LUCs inspections and five-year reviews).

Site Constraints

The site is located on the Main Base and site access is limited to personnel with access to the Base. An existing chain-link fence and gate constructed at the entrance to the project site limit access to the site. The LUCs will prohibit residential use of the site below the cliff line. The LUCs will be implemented through amendments to the BGP that will effectively act as deed restrictions on the real property. The BGP will be amended to include LUCs upon ROD approval. The USN will amend the BGP with one of the following sections: (1) a new section entitled “Prohibited and Permitted Uses at Environmental Restoration Sites,” or (2) text to an existing section of the BGP that addresses LUC restrictions at Andersen AFB. The USN will utilize its BGP as an administrative LUC to prevent uses that are inconsistent with the approved ROD. The boundaries of the LUCs are presented in Figure 2-7.

Future Land Use Restrictions

The designated LUC area is prohibited from residential use as long as the site conditions are not suitable for unrestricted use and unlimited exposure.


Land Use Control Performance Objectives

Prevent future residential exposures to soil located below the cliff line containing PCBs and lead at concentrations greater than their respective RGOs.

Prohibit the development and use of property below the cliff line for residential housing, elementary and secondary schools, child care facilities and playgrounds.

Limit and control any future excavation activities at the site (e.g., worker requirements, soil management, and waste disposal).

Implementation and Management of Land Use Controls

The LUCs will be implemented through amendments to the BGP that will effectively act as deed restrictions on the real property. The LUCMP will be used as a reference document for Andersen AFB planning, environmental restoration, and real property to show restoration sites with LUCs. The USN is responsible for implementing, maintaining, monitoring, reporting on, and enforcing the LUCs established in approved decision documents for IRP sites within Andersen AFB.

BGP - The BGP will be amended upon ROD approval to identify the designated LUC area as prohibited from further residential development as long as the site conditions are not suitable for unrestricted use and unlimited exposure. AFI 32-7062 (Air Force Comprehensive Planning) requires that installations develop and maintain a BGP as a central repository for information deemed essential for planning and managing the installation’s physical assets, including environmental planning constraints such as the LUCs. AFI 32-1021 (Planning and Programming Military Construction Projects) requires installations to comply with their BGP to ensure that there are no conflicts with land-use constraints stemming from the LUCs of the Environmental Restoration Program that would impact facility planning and construction. Any requests for invasive activities (i.e., utility or construction work) through excavation permits, such as AF Form 103, or the construction review process, as per AFI 32-1001 (Operations Management), will be denied, unless the procedures for proposed land use changes described in the approved ROD, and amended to the BGP, are followed. The LUCs amended to the BGP will be monitored, maintained, enforced, and reported on through existing land-use management programs, such as the BCE Work Clearance Form (AF Form 103) (Digging Permit) and the construction review process (AFI 32-1001). The USN shall notify USEPA and Guam EPA in writing in advance of any changes to the internal procedures that would affect the LUCs.

The USN shall not modify or terminate LUCs, implementation actions, or modify land use without approval by USEPA and the Guam EPA. The USN shall seek prior concurrence before any anticipated action that may disrupt the effectiveness of the LUCs or any action that may alter or negate the need for LUCs.

This requirement shall be reviewed as part of the regular five-year ROD review (planned for 2012) and remain in effect as long as hazardous substances in soil remain at concentrations that prevent unrestricted use and unlimited exposure.


The office on Andersen AFB responsible for implementing these actions is the 36th Civil Engineer Squadron (CES) Engineering Flight (36 CES/CEC) and the GeoBase section within 36 CES/CEC (36 CES/CECB).

Dig and Construction Permits - No intrusive activities shall occur within the designated LUC area without prior approval of the USN in the form of a dig and/or construction permit. If intrusive activities are conducted within the designated LUC area, the work would require an approved health and safety plan and procedures for the proper handling and disposal of displaced wastes and/or soils. Dig and construction permits shall be maintained as part of the LUCMP for Site 14. This permit requirement shall be subject to an annual review (see below section for reporting requirements) and will remain in effect as long as hazardous substances in soils below the cliff line remain at concentrations that prevent unrestricted use and unlimited exposure.

The office on Andersen AFB responsible for processing dig and construction permits is the 36th CES Customer Service (36 CES/CEOQC).

LUCMP - The LUCMP shall serve as the operational “road map” for defining, implementing, maintaining, monitoring, reporting on, and enforcing LUCs at Site 14. The USN is responsible for maintaining the LUCMP to assure that activities within the designated LUC area are in accordance with the remedy selected in the approved ROD and other pertinent decision documents.

The LUCMP includes protocols or a “process” for: (1) daily management of the LUCMP process; (2) annual inspections of Site 14 to ensure compliance with the LUCs; (3) specifications for annual LUC-compliance reporting requirements; (4) property lease or transfer (note: currently, there are no plans for property lease or transfer); (5) LUC modification or termination; and (6) notification process and relevant corrective actions for LUC non-compliant events.

Any activity that is inconsistent with the LUC objectives or use restrictions, or any other action that may interfere with the effectiveness of the LUCs will be addressed by the USN as soon as practicable, but in no case will the process be initiated later than 15 days after the USN becomes aware of the breach.

The USN will notify USEPA and Guam EPA as soon as practicable but no longer than 10 days after discovery of any activity that is inconsistent with the LUC objectives or use restrictions, or any other action that may interfere with the effectiveness of the LUCs. The USN will notify USEPA and Guam EPA regarding how the USN has addressed or will address the breach within 10 days of sending USEPA and Guam EPA notification of the breach.

The USN shall notify USEPA and Guam EPA 45 days in advance of any proposed land use changes that are inconsistent with land use control objectives or the selected remedy.

The office on Andersen AFB responsible for implementing these actions is the 36th CES Environmental Flight (36 CES/CEVR).

Monitoring and Reporting - Monitoring of the environmental use restrictions and controls will be conducted annually by the USN. The monitoring results will be included in a separate report or


as a section of another environmental report, if appropriate, and provided to the USEPA and the Guam EPA. The annual monitoring reports will be used in preparation of the five-year review to evaluate the effectiveness of the remedy.

The annual monitoring report, submitted to the regulatory agencies by the USN, will evaluate the status of the LUCs and how any deficiencies or inconsistent uses have been addressed. The annual evaluation will address whether the use restrictions and controls referenced above were communicated in the deed(s), whether the owners and state and local agencies were notified of the use restrictions and controls affecting the property, and whether use of the property has conformed with such restrictions and controls.

The office on Andersen AFB responsible for implementing these actions is the 36 CES/CEVR.

Post Signage - Signs will be posted around the perimeter of the site and will meet the following requirements:

Lettering shall be legible from a distance of at least 25 feet.

Signs shall contain contact information for Andersen AFB personnel for long-term oversight.

Signs shall be visible from surrounding areas and at potential routes of entry.

The warning signs shall contain language similar to the following:

WARNING Soil Contains Potentially Hazardous Substances

Digging or Excavating is Prohibited Contact Environmental Management at

(671) 366-0000, Ext 4692

These requirements shall be fulfilled as soon as practical, and shall be monitored annually as part of the operation and maintenance activities.

Operation and Maintenance - Warning signs shall be posted by the LUC-restricted area to prevent intrusive activities without USN approval. Annual site inspections shall be conducted to: (1) confirm that signage is intact; (2) determine that no unapproved structures have been constructed or intrusive activities have been performed; and (3) ensure that the LUCMP is properly maintained and all activities relevant to the designated LUC area (i.e., proper documentation of digging permits, etc.) are properly documented. The USN will be responsible for summarizing the findings of the previous calendar year in an annual LUC Compliance Summary Report. The LUCs shall remain in effect as long as hazardous substances in subsurface soil remain at concentrations that prevent unrestricted use and unlimited exposure.

Lease or Transfer of Property - Site 14 is located on the Main Base, and there are no current plans to lease or transfer the property. Although the USN may later transfer these procedural responsibilities to another party by contract, property transfer agreement, or through other means, the USN shall retain ultimate responsibility for remedy integrity.


The USN will provide notice to USEPA and Guam EPA at least six (6) months prior to any transfer or sale of Site 14 so that USEPA and Guam EPA can be involved in discussions to ensure that appropriate provisions are included in the transfer terms or conveyance documents to maintain effective LUCs. If it is not possible for the facility to notify USEPA and Guam EPA at least six months prior to any transfer or sale, then the facility will notify USEPA and Guam EPA as soon as possible but no later than 60 days prior to the transfer or sale of any property subject to LUCs. In addition to the land transfer notice and discussion provisions above, the USN further agrees to provide USEPA and Guam EPA with similar notice, within the same time frames, as to federal-to-federal transfer of property. The USN shall provide a copy of executed deed or transfer assembly to EPA and Guam EPA.

The office on Andersen AFB responsible for implementing these actions is the 36th CES Real Property Office (36 CES/CERR).

2.12.2.4 Monitoring

Fish monitoring will be conducted in the ocean water adjacent to Site 14 as a conservative measure to confirm that there are no impacts to marine receptors from PCBs below the cliff line. The monitoring event will be based upon the previous fish sampling event conducted during the RI for Site 14 (HDR|e2M, 2009b). At least one round of samples will be collected prior to the five-year review. The results will be used to conduct a supplemental risk analysis for fisher adults and children. The findings of the risk analysis will be addressed during the five-year review and used as a decision point as to whether or not continued fish monitoring is required at the site.

2.12.3 Summary of Estimated Remedy Costs

A cost estimate for Alternative 3 is presented in Tables 2-11 through 2-14, broken down by remedy component. The information in the cost estimate table is based on the available information regarding the anticipated scope of the remedial alternative.

Changes in the cost elements are likely to occur as a result of new information and data collected during the remedial design of the preferred remedy. Major changes may be documented in the form of a memorandum in the AR file, an Explanation of Significant Differences, or a ROD amendment. This is an order-of-magnitude engineering cost estimate that is expected to be within +50 to -30 percent of the actual project cost.

2.12.4 Expected Outcomes of Selected Remedy

The selected remedy, Alternative 3, would effectively eliminate the potential for human exposures to soil containing COCs above RGOs by excavating and disposing of contaminated soils above the cliff line and by prohibiting residential use of the land below the cliff line. The land above the cliff line would be suitable for unlimited use and unrestricted exposure upon completion of the removal activities. The land below the cliff line would remain suitable for continued use as open space, but would not be suitable for unlimited use and unrestricted exposure (e.g., residential). Land above the cliff line would be available for unrestricted use immediately upon completion of the removal action. Land below the cliff line is already


appropriate for use as open space. Groundwater is unaffected by contaminants on site and use of the groundwater would remain unchanged.

2.13 Statutory Determination

Under CERCLA §121, the lead agency must select a remedy that is protective of human health and the environment, complies with ARARs, is cost-effective, and uses permanent solutions and alternative treatment technologies or resource recovery technologies to the maximum extent practicable. In addition, CERCLA includes: 1) a preference for remedies that employ treatment which permanently and significantly reduces the volume, toxicity, or mobility of hazardous wastes as a principal element; and 2) a bias against offsite disposal of untreated wastes. The following sections discuss how the selected remedy meets these statutory requirements.

2.13.1 Protection of Human Health and the Environment

The excavation components of Alternative 3 will provide a very high degree of protection to human health and the environment from COCs in surface and subsurface soils. Soil above the cliff line containing PCBs at concentrations greater than or equal to 0.5 mg/kg, lead at concentrations greater than or equal to 400 mg/kg, and ACM will be excavated and disposed. Because direct contact is the primary route of human and ecological exposure to COCs, this alternative will be highly protective of human health and the environment. The potential for migration of COCs located above the cliff line to areas below the cliff line and nearby ocean waters will also be eliminated. As an additional measure for protection of human health and the environment, the cell in the CU containing the contaminated soils from Site 14 will be covered with a synthetic impervious top liner to prevent migration of COCs to the underlying soils and groundwater.

The LUC component of Alternative 3 will be protective of human health and the environment below the cliff line, as residential use of the land will be prohibited. Additionally, the fish monitoring component will be conducted as a conservative measure to confirm that there are no impacts to marine receptors from PCBs below the cliff line.

2.13.2 Compliance with ARARs

Remedial actions must comply with both Federal and Territorial ARARs. ARARs are legally applicable or relevant and appropriate requirements, standards, criteria, or limitations of Federal and Territorial environmental laws and regulations.

ARARs fall into three categories: chemical-specific, location-specific, and action-specific. Chemical-specific ARARs are health-based or risk-management-based numbers that provide concentration limits for the occurrence of a chemical in the environment. Location-specific ARARs restrict activities in certain sensitive environments. Action-specific ARARs are activity-based or technology-based (such as with those covered under the RCRA of 1976). Criteria to be considered, or TBCs, are non-promulgated advisories or guidance issued by federal or territorial government that are not legally binding and do not have the status of potential ARARs.


However, in many circumstances, TBCs are considered along with ARARs and may be used in determining the necessary level of cleanup for protection of health or the environment.

Table 2-15 summarizes the ARARs and TBCs for the selected remedy at Site 14 and describes how the selected remedy addresses each one.

The selected remedy complies with the action- and location-specific ARARs and TBCs. There are no chemical-specific ARARs. The implementation of a remedy is required to meet the substantive portions of these requirements and is exempt from administrative requirements, such as permitting and notifications.

2.13.3 Cost Effectiveness

The selected remedy is cost-effective and represents a reasonable value for the money to be spent. In making this determination, the following definition was used: “A remedy shall be cost-effective if its costs are proportional to its overall effectiveness” (40 CFR 300.430[f][1][ii][D]). This determination was accomplished by evaluating the “overall effectiveness” of those alternatives that satisfy the threshold criteria (that is, is protective of human health and the environment and ARAR-compliant).

Overall effectiveness was evaluated by assessing three of the five balancing criteria in combination: long-term effectiveness and permanence; reduction in toxicity, mobility, and volume through treatment; and short-term effectiveness. Overall effectiveness was then compared to costs to determine cost-effectiveness. The overall effectiveness of the selected remedy for Site 14 was demonstrated in the comparative analysis of alternatives (Section 2.10 – Summary of Comparative Analysis of Alternatives) and is summarized below.

Remedy

Total Present-Worth

Cost

Incremental Cost

(if applicable)

Long-Term Effectiveness and

Permanence

Reduction of TMV Through

Treatment Short-Term Effectiveness

Alternative 1 $0 $0 No No No Alternative 2 $1,769,508 $0 Yes No Yes Alternative 3 $2,711,366 $0 Yes Yes Yes Alternative 4 $78,614,244 $0 Yes Yes Yes Note: TMV = toxicity, mobility, and volume Cost Effectiveness Summary: • Alternative 4 is not considered to be cost effective. • While Alternative 2 is considered to be cost effective, Alternative 3 provides a potentially greater return on

investment.

2.13.4 Utilization of Permanent Solutions and Alternative Treatment Technologies

The selected remedy of Alternative 3 represents the maximum extent to which permanent solutions and treatment technologies can be used in a practicable manner at the site. Of those alternatives that are protective of human health and the environment and comply with ARARs, the selected remedy provides the best balance of trade-offs in terms of the five balancing criteria,

I I I I I I I

I I I I I I I


while also considering the statutory preference for treatment as a principal element and bias against offsite treatment and disposal and considering territorial and community acceptance.

The selected remedy manages the potential risks to human health and the environment by removing and disposing contaminated soils above the cliff line and prohibiting residential use of the land below the cliff line; therefore, effectively eliminating unacceptable human and ecological exposures to soil containing COCs at Site 14.

2.13.5 Preference for Treatment as a Principal Element

Section 121(b) of CERCLA establishes the preference that treatment will be used to address the principal threats posed by a site wherever practicable. Alternative 3 does not satisfy the statutory preference for treatment as a principal element of the remedy because treatment of the COC-impacted soil at Site 14 is not practicable and will not be performed as a principal element of the remedy. However, based upon the waste characterization sampling, the excavated soil at Site 14 may be treated (e.g., stabilized) to meet disposal requirements of the receiving facility. Additionally, excavation and offsite disposal of the majority of the COC-impacted soil will significantly reduce the mobility and volume of COCs on site.

2.13.6 Five-Year Review Requirements

Pursuant to CERCLA §121(c) and NCP §300.430(f)(5)(iii)(C), because the selected remedy for Site 14 will result in hazardous substances, pollutants, or contaminants remaining onsite above levels that allow for unlimited use and unrestricted exposure, a statutory review will be required within five years after initiation of the remedial action to verify that the remedy is, or will be, protective of human health and the environment.

Five-year reviews will be conducted until concentrations of hazardous substances, pollutants, or contaminants remaining onsite are reduced to levels that allow for unlimited use and unrestricted exposure.

2.14 Documentation of Significant Changes

The Proposed Plan for Site 14 was released for public comment on 18 August 2010. The Proposed Plan identified Alternative 3 as the preferred remedy for Site 14. Andersen AFB reviewed the comments received during the public comment period, 18 August 2010 to 17 September 2010. It was determined that no significant changes to the remedy, as originally identified in the Proposed Plan, were necessary or appropriate.


3.0 Responsiveness Summary

This section provides a summary of the public comments regarding the Proposed Plan for the planned remedial action at Site 14, at Andersen AFB, Yigo, Guam. At the time of the public review period, Andersen AFB had identified Alternative 3 as the preferred remedy for Site 14. Based upon the comments received, the Proposed Plan was accepted by the public.

3.1 Stakeholder Comments and Lead Agency Responses

A public meeting was held on 01 September 2010 at the Guam Marriot Hotel in Tumon, Guam. The meeting officially began at 6:50 PM and concluded at 7:33 PM, according to the transcript. The meeting was attended by six members of the community. Mr. Gregg Ikehara, 36 CES/CEVR, provided an opening statement. Mr. Danny Agar, 36 CES/CEVR, gave a PowerPoint presentation discussing the proposed plan for Site 14. The presentation provided a brief site history, summary of past investigative studies and related analytical results, and a summary of human health and ecological risk assessments. The preferred remedial alternative was also presented. The complete transcript is available in the AR file for Andersen AFB, which is available for public review at the Information Repositories located at the Robert F. Kennedy Library, on the University of Guam campus, and the Nieves M. Flores Memorial Library in Hagåtña.

Public Meeting Questions

After the presentation, four members of the community spoke. The questions and comments received were primarily focused on clarifying details of the presented material and were adequately answered during the meeting. A brief summary of individual questions and comments are included below.

Mr. John Jocson asked if the Base explored the possibility of incinerating the PCB-contaminated soil onsite as an alternative. Mr. Ikehara responded that the Base considered using the thermal desorption unit at Navy Base Guam, but that transporting the soils over public highways was unacceptable to the Guam EPA. The Base also considered establishing a treatment location onsite, but three were issues with where to dispose of the treated soil. Additionally, thermal desorption would not address the issue of ACM in the soil. The soil would need to be separated in order to safely dispose of the asbestos. Thermal desorption would only address PCBs.

Mr. Mike Gawal, Dededo resident, asked how long it would take to complete the preferred alternative. Mr. Agar responded that the Base is currently preparing a Remedial Design for the work, and that it normally takes about one year to complete.

Ms. Joanne Brown, RAB Member, noted that the issue regarding PCB contamination in fish in Guam’s coastal areas is a major community concern, and gave the examples of Agana swamp and Orote Point. She continued by inquiring if the Base has received any input from the rest of Guam’s agencies, like Marine Lab or Aquatic and Wildlife, Department of Agriculture; professional experts within the community, that reside in the community, that have an investment in ensuring that this really is not a concern for the public. Mr. Ikehara responded that the Base had to consult with the Department of Aquatic and Wildlife Resources in order to conduct the


fish sampling, to find out 1) is it acceptable to them for the Base to take fish within a preserve area, and 2) what species should the Base go after for territorial sampling regarding the fish in that area. At the same time, this made them aware that the Base was conducting this sort of survey to be protective of people who would be illegally fishing in a preserve. Mr. Ikehara explained that it was his understanding that the folks at the Department of Agriculture talk frequently with the Marine Lab to get an idea as to what the species distribution is in that area.

Ms. Brown then inquired if the contamination found in the fish is related to the contamination coming from the cliff line. Mr. Ikehara responded that the Base did the best they could to sample territorial species that hung around in that area and were representative of the fish types that would be most affected by any contaminant coming off of the cliff. He went on to say that it raises the question of an ambient PCB concentration in all fish. Mr. Ikehara explained that the Base did not go into a full-blown, island-wide background survey to see how the results compared overall, but that the concentrations from the fish tissue sampling were significantly lower than what was seen on the western side of the island. That dampened a lot of the concern regarding overall distribution.

Ms. Brown requested that in the future the Base provide the community with comments from the respective government entities that the Base works with. She then stressed that there is a need for community comfort with this issue, even if for someone who is illegally fishing in the preserve, to make sure that they are not going to become ill as a result. Mr. Ikehara responded “absolutely”, and stated that once the remedial action is completed and the source removed, the primary source of the PCBs will no longer be available for transport down to the coastline. By doing a source removal and moving soils to a location where the contaminants can be properly managed, this removes the possibility of a catastrophic release into the ocean (e.g. earthquake, typhoon, flooding). This is a major step in reducing the risk to both biota and humans.

Mr. Larry Kasperbauer, RAB Member, first asked for clarification on the site size and extent of contamination located below the cliff line. Mr. Agar described the dimensions of the site and told Mr. Kasperbauer that he had additional slides of the coastline from with they did the invertebrate sampling that he could show him later. Mr. Ikehara added that the majority of the material is situated up on top of the cliff, where the Base will be conducting the source removal. He added that the Base did evaluate surface and subsurface soil samples below the cliff line for distribution of PCBs along the slope, which would be the pathway that the PCBs would take to get down to the marine biota and coastline.

Mr. Kasperbauer inquired as to how the contaminants got into the water, if it was from leaching or runoff. Mr. Ikehara explained that PCBs generally do not leach at the concentrations they have seen; that they adhere to particulate matter like rock or soil. The real method of transport to the coast is over land, which is why the Base is trying to remove the source.

Mr. Kasperbauer asked about other wildlife in the area, such as deer, pig, and fruit bat, which might be consumed by humans in addition to the fish. Mr. Agar stated that the Base looked at all of the other species that were in the area, and that the yellow bittern was the only species that had concern from PCBs at the site. Mr. Ikehara explained that the early on in the restoration program, both ungulate deer and pig were evaluated for all contaminants related to the cleanups that are being conducted for the Base, and they were shown to be unaffected by the types of


contaminants; not just PCBs, but other types of metal contaminants and potential organic contaminants that they had cleaned up at other locations. In this particular instance, he explained that they have fairly good evidence that pigs do not go into the area. Not so much evidence for the deer. He went on to explain that there is not much vegetative material along the slopes and that most of the food sources were up above the cliff line.

Mr. Kasperbauer then asked if sea grapes are in the area and if they were tested. Mr. Ikehara expressed his understanding that the grapes that are collected for consumption are usually from the southern part of Guam, along the inside. Sea grapes tend not to be as prolific in the high-energy environment. He then stated that the Base did not test sea grapes. He went on to explain that they are generally filter feeders, taking in and filtering the sea water, so the mechanism for them to absorb particles with PCBs is probably less significant. Mr. Ikehara then stated that they cannot say for certain that sea grapes are not in the area, but that if they cannot get a good sample set it is very difficult to analyze.

3.2 Technical and Legal Issues

No technical or legal issues were identified during the public review period of the Proposed Plan.


4.0 References

Andersen Air Force Base, 2001. Technical Memorandum on the Recalculation of Background Threshold Value for Manganese in Soil, Installation Restoration Program Sites, Andersen Air Force Base, Guam. November.

Agency for Toxic Substances and Disease Registry, 2006. Public Health Assessment, Andersen Air Force Base, Yigo, Guam. http://www.atsdr.cdc.gov/HAC/PHA/anderson/and_p1.html. Accessed March, 2007.

Barrett, Harris & Associates, 1982. Summary Report Northern Guam Lens Study. December.

Battelle Columbus Division, 1989. Installation Restoration Program Phase II, Stage 1-Confirmation/Quantification, Andersen AFB, Guam. Final Report. January.

Binder, S., D. Sokal, and D. Maughan, 1986. Estimating soil ingestion: The use of tracer elements in estimating the amount of the soil ingested by young children. Arch. Environ. Health 41:341-345.

Branch, J. B., Mink, J. F., and Worlund, J., 1982. Summary Report Northern Guam Lens Study. Guam Environmental Protection Agency. 52p.

Calabrese, E.J., R. Barnes, E.J. Stanek III, H. Pastides, C.E. Gilbert, P. Veneman, X. Wang, A. Lasztity, and P.T. Kostecki, 1989. How much soil do young children ingest: An epidemiologic study. Reg. Toxicol. Pharmacol. 10:123-137.

Clausing, P., B. Brunekreef, and J.H. van Wijnen, 1987. A method for estimating soil ingestion by children. Int. Arch. Occup. Environ. Health 59:73-82.

Davis, S., P. Waller, R. Buschbom, J. Ballou, and P. White, 1990. Quantitative estimates of soil ingestion in normal children between the ages of 2 and 7 years: Population-based estimates using aluminum, silicon, and titanium as soil tracer elements. Arch. Environ. Health 45: 112-122.

EA Engineering, Science, and Technology, 1995. Exposure Pathway Analysis for Human Health and Ecology at Andersen Air Force Base.

------, 2007. Consolidation Unit Management Plan at Site 2/Landfill 2, Andersen Air Force Base, Guam. November.

------, 2009. Fall 2008 Groundwater Monitoring Report, Andersen Air Force Base, Guam. April.

HDR Engineering, Inc. | Engineering Environmental Management, Inc., 2009a. Final Remedial Investigation, IRP Site 14, Andersen Air Force Base, Guam. October.

------, 2009b. Final Feasibility Study, IRP Site 14, Andersen Air Force Base, Guam. October.


Environmental Science and Engineering, Inc., 1985. Installation Restoration Program Phase I: Records Search, Andersen Air Force Base, Guam. March.

ICF Technology, Inc., 1994. Work Plan Addendum to Operable Unit 6 for Operable Unit 5, Andersen Air Force Base, Guam, Final, Revision 1. October

------, 1995. Operable Unit 6, Basewide Work Plan for Andersen Air Force Base, Guam, Final, Revision 1. January.

------, 1996. Installation Restoration Program, Final Records Search for Andersen Air Force Base, Guam. February.

SAIC and A.T. Kearney, Inc., 1986. RCRA Facility Assessment of Solid Waste Management Units at Andersen AFB, Guam, USA. December.

Shaw Environmental, Inc., 2006. Environmental Cleanup Plan, Interim Remedial Action, IRP Site 14 / Landfill 19, Andersen Air Force Base, Guam. Revision 1. January.

------, 2007. Interim Remediation Verification Report, Interim Remedial Action, IRP Site 14 / Landfill 19, Andersen Air Force Base, Guam. March.

URS-Dames & Moore, 2002. Final Engineering Evaluation / Cost Analysis for IRP Site 14, Landfill 19, Andersen Air Force Base, Guam. June.

United States Air Force, 1994. Work Plan Addendum to Operable Unit 6 for Operable Unit 5, Andersen Air Force Base, Guam, Final. Prepared by ICF Technology, Inc. May.

------, 2006. Environmental Assessment, Beddown of Training and Support Initiatives at Northwest Field, Andersen Air Force Base, Guam. June.

U.S. Environmental Protection Agency, Guam Environmental Protection Agency, and the U. S. Air Force, 1993. Federal Facility Agreement Under CERCLA Section 120.

U.S. Environmental Protection Agency, 1989. Risk Assessment Guidance for Superfund, Volume I: Human Health Evaluation Manual (Part A) (Interim Final). Report No. EPA/540/1-89002. Office of Emergency and Remedial Response, Washington, D.C.

------, 1996. Exposure Factors Handbook, Volumes I, II, and III. Report No. EPA/600/P-95/002Ba,b,c. Exposure Assessment Group, Office of Health and Environmental Assessment, Office of Research and Development, Washington, D.C. August.

------, 1997. Health Effects Assessment Summary Tables: Annual Update, FY 1997. Report No. EPA/540/R-97/036. EPA Office of Solid Waste and Emergency Response, Washington, D.C. July.

------, 2000. Integrated Risk Information System. Environmental Criteria and Assessment Office, Cincinnati, OH.


------, 2008. Integrated Risk Information System. Environmental Criteria and Assessment Office, Cincinnati, OH.

Ward, P. E., Hoffman, S.H., and Davis, D. A., 1965. Hydrology of Guam: U.S. Geological Survey Professional Paper 403-H. 28 p.

Young, F.J., 1988. 1988 Soil Survey of Territory of Guam. United States Department of Agriculture, Soil Conservation Service in Cooperation with Guam Department of Commerce and University of Guam. May. 33 p.

TABLES

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Table 1-1 Data Certification Summary.

Decision Summary Sections Site 14

List of COCs and their respective concentrations Section 2.5.6, Page 2-9 and

Figures 2-3 and 2-4

Baseline risk represented by the COCs Section 2.7.1.4, Page 2-14 and

Section 2.7.2.4, Page 2-19

Cleanup levels established for COCs and the basis for these levels

Section 2.8, Page 2-22

How source materials constituting principal threats will be addressed


Current and reasonably anticipated future land use assumptions and current and potential future beneficial uses of groundwater used in the baseline risk assessment and ROD


Potential land and groundwater use that will be available at the site as a result of the selected remedies

Section 2.12.4, Page 2-39 and

Table 2-10

Estimated capital, annual operation and maintenance, and total present worth costs, discount rate, and the number of years over which the remedy cost estimates are projected

Section 2.10.7, Page 2-32 and

Table 2-9

Key factor(s) that led to selecting the remedy (i.e., describe how the selected remedy provides the best balance of tradeoffs with respect to the balancing and modifying criteria, highlighting criteria key to the decision)

Section 2.12.1, Page 2-33

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Table 2-1 Public Notification of Document Availability.

Requirement: Satisfied by:

Notice of availability of the Proposed Plan and RI/FS must be made in a widely-read section of a major local newspaper.

Notice of availability of the Proposed Plan was published in the Guam Pacific Daily News on 18 August 2010.

Notice of availability should occur at least two weeks prior to the beginning of the public comment period.

The public comment period began on 18 August 2010.

Notice of availability must include a brief abstract of the proposed plan which describes the alternatives evaluated and identifies the preferred alternative (NCP Section 300.430(f)(3)(i)(A).

Notice of availability included all of these components and is included in Appendix B of this ROD.

Notice of availability should consist of the following information: Site name and location Date and location of public meeting Identification of lead and support agencies Alternatives evaluated in the detailed analysis Identification of preferred alternative Request for public comments Public participation opportunities including:

o Location of information repositories and AR file o Methods by which the public may submit written and

oral comments, including a contact person o Dates of public comment period o Contact person for the Restoration Advisory Board

See notice in Appendix B.

Notes: AR = Administrative Record NCP = National Oil and Hazardous Substances Pollution Contingency Plan of 1990 RI = Remedial Investigation/Feasibility Study ROD = Record of Decision

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Table 2-2 Public Comment Period Requirements.

Requirement: Satisfied by:

Lead agency (USN) should make document available to public for review on same date as newspaper notification.

Document was made available to the public on 18 August 2010. The notification of availability was made on 18 August 2010.

Lead agency (USN) must ensure that all information that forms the basis for selecting the response action is included as part of the AR file and made available to the public during the public comment period.

The USN maintains information repositories for the Andersen AFB AR file at the Robert F. Kennedy Library at the University of Guam and the Nieves M. Flores Memorial Library in Hagåtña. Data and supporting CERCLA primary documents produced for Andersen AFB are maintained as part of these files and are available to the public.

CERCLA Section 177(a)(2) and NCP Section 300.430(f)(3)(i) requires the lead agency (USAF) to provide the public with a reasonable opportunity (30 days) to submit written and oral comments on the Proposed Plan.

The USAF provided a public comment period for the Proposed Plan from 18 August 2010 to 17 September 2010.

The lead agency (USN) must extend the public comment period by at least 30 additional days upon timely request.

The USN received no requests to extend the public comment period.

The lead agency (USN) must provide a public meeting to be held at or near the site during the public comment period. A transcript of this meeting must be made available to the public and be maintained in the AR for the site (pursuant to NCP Section 300.430(f)(3)(i)(E)).

A public meeting was held on 01 September 2010 at the Guam Marriott Resort and Spa. A transcript of this meeting has been added to the AR file.

Notes: AFB = Air Force Base AR = Administrative Record CERCLA = Comprehensive Environmental Response, Compensation, and Liability Act of 1980 NCP = National Oil and Hazardous Substances Pollution Contingency Plan of 1990 RI = Remedial Investigation/Feasibility Study USN = United States Navy

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Table 2-3 Non-Cancer Toxicity Data – Oral/Dermal.

Contaminant of Concern Chronic/

Subchronic

Oral RfD Value

(mg/kg/day)

Oral to Dermal Adjustment

Factor

Adjusted Dermal RfD

(mg/kg/day)

Primary Target Organ

Combined Uncertainty/ Modifying

Factors

Sources of RfD: Target Organ

Dates of RfD: Target Organ (1)

(mm/dd/yy)

METALS

Lead chronic NA NA NA NA NA NA NA

POLYCHLORINATED BIPHENYLS

PCBs(2) chronic 2.00E-05 1 2.00E-05 NA 300 IRIS 2008 11/1/96

Notes: 1. For IRIS values, the date IRIS was searched is provided. 2. The data listed for PCBs in the table is that for Aroclor-1254. IRIS has not derived RfDs for other Aroclors or for total PCBs. IRIS = Integrated Risk Information System mg/kg/day = milligram(s) per kilogram per day NA = not applicable PCB = polychlorinated biphenyl RfD = reference dose

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Table 2-4 Non-Cancer Toxicity Data – Inhalation.

Contaminant of Concern Chronic/

Subchronic

Value Inhalation

(RfC) (mg/m3)

Adjusted Inhalation

(RfD) (mg/kg/day)


Combined Uncertainty/ Modifying

Factors

Sources of RfD: Target Organ

Dates (mm/dd/yy)

METALS

Lead chronic NA NA NA NA NA NA


PCBs(1) chronic NA NA NA NA NA NA

Notes: 1. No inhalation non-cancer toxicity data are available for PCBs. To be conservative, the oral/dermal RFD is used for inhalation exposures. mg/kg/day = milligram(s) per kilogram per day mg/m3 = milligram(s) per square meter NA = not applicable PCB = polychlorinated biphenyl RfC = reference concentration RfD = reference dose

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Table 2-5 Cancer Toxicity Data – Oral/Dermal.

Contaminant of Concern Oral Cancer Slope Factor

Oral Absorption Efficiency for Dermal

Absorbed Cancer Slope Factor for

Dermal Units

Weight of Evidence / Cancer Guideline Description

Source Date (1)

(mm/dd/yy)

METALS

Lead NA NA NA NA NA NA NA


PCBs(2) 2 1 2 kg-d/mg B2 IRIS 2008 6/1/97

Notes: 1. For IRIS values, the date IRIS was searched is provided. 2. The data provided for PCBs are those derived for high risk and persistence PCBs. Slope factors for lower risk and persistence PCBs are lower. IRIS = Integrated Risk Information System Weight of Evidence: kg-d/mg = kilograms per day per milligram B2 - Probable human carcinogen - indicates sufficient evidence in animals and inadequate NA = not applicable or no evidence in humans PCB = polychlorinated biphenyl

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Table 2-6 Cancer Toxicity Data – Inhalation.

Contaminant of Concern Unit Risk Inhalation Cancer Slope Factor

Weight of Evidence/Cancer Guideline Description

Unit Risk - Inhalation Cancer Slope Factor

Value Units Value Units Source Date

(mm/dd/yy)

METALS

Lead NA NA NA NA NA NA NA


PCBs(1) NA NA NA NA NA NA NA

Notes: 1. IRIS has not derived an inhalation slope factor for high risk and persistence PCBs. To be conservative the oral/dermal slope factor is used for inhalation exposures. IRIS = Integrated Risk Information System mg/kg/d = milligram(s) per kilogram per day NA = not applicable

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Table 2-7 Risk Characterization Summary – Carcinogens.

Scenario Timeframe: Future Receptor Population: Resident Receptor Age: Adult and Child (Combined)

Medium Exposure

Point Contaminant of

Concern Carcinogenic Risk

Ingestion Inhalation Dermal Cumulative Risk Surface Soil

Site 14 PCBs 2.20E-05 1.82E-09 9.71E-06 3.17E-05

Total Risk = 3.17E-05

Scenario Timeframe: Current / Future Receptor Population: Trespasser / Occasional User Receptor Age: Adult

Medium Exposure



Ingestion Inhalation Dermal Cumulative Risk Surface Soil

Site 14 PCBs 6.12E-07 1.50E-11 1.13E-06 1.74E-06


Scenario Timeframe: Future Receptor Population: Resident Receptor Age: Adult and Child (Combined)

Medium Exposure



Ingestion Inhalation Dermal Cumulative Risk Subsurface Soil

Site 14 PCBs 6.29E-05 5.21E-09 2.78E-05 9.08-05


Scenario Timeframe: Current / Future Receptor Population: Fisher Receptor Age: Adult and Child (Combined) Exposure Medium

Exposure Point

Contaminant of Concern

Carcinogenic Risk Fish Ingestion Cumulative Risk

Fish Site 14 PCBs 4.06E-06 4.06E-06


Notes: NA = not applicable

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Table 2-8 Risk Characterization Summary – Non-Carcinogens.

Scenario Timeframe: Future Receptor Population: Resident Receptor Age: Adult

Medium Exposure


Concern Primary

Target Organ

Non-Carcinogenic Hazard Quotient

Ingestion Inhalation Dermal Cumulative

Hazard QuotientSurface Soil

Site 14 PCBs None 4.81E-01 7.07E-05 2.69E-01 7.49E-01

Receptor Hazard Index Total = 7.49E-01

Scenario Timeframe: Future Receptor Population: Resident Receptor Age: Child

Medium Exposure


Concern Primary

Target Organ




Site 14 PCBs None 4.49E+00 2.47E-04 1.76E+00 6.25E+00

Receptor Hazard Index Total = 6.25E+00

Scenario Timeframe: Current / Future Receptor Population: Trespasser / Occasional User Receptor Age: Adult

Medium Exposure


Concern Primary

Target Organ




Site 14 PCBs None 3.57E-02 8.75E-07 6.60E-02 1.02E-01


Scenario Timeframe: Future Receptor Population: Resident Receptor Age: Adult

Medium Exposure


Concern Primary Target

Organ



Hazard QuotientSubsurface Soil

Site 14 PCBs None 1.38E+00 2.02E-04 7.69E-01 2.15E+00

Receptor Hazard Index Total = 2.15E+00

Scenario Timeframe: Future Receptor Population: Resident Receptor Age: Child

Medium Exposure


Concern Primary Target

Organ



Hazard QuotientSubsurface Soil

Site 14 PCBs None 1.28E+01 7.09E-04 5.04E+00 1.79E +01

Receptor Hazard Index Total = 1.79E +01

Table 2-8 (Continued) Risk Characterization Summary – Non-Carcinogens.

Page 2 of 2

Scenario Timeframe: Current / Future Receptor Population: Fisher Receptor Age: Adult

Exposure Medium

Exposure Point




Fish Ingestion Cumulative

Hazard QuotientFish Site 14 PCBs None 1.72E-01 1.72E-01


Scenario Timeframe: Current / Future Receptor Population: Fisher Receptor Age: Child

Exposure Medium

Exposure Point




Fish Ingestion Cumulative

Hazard QuotientFish Site 14 PCBs None 4.97E-01 4.97E-01


Notes: PCB = polychlorinated biphenyl

Table 2-9 Common Elements and Distinguishing Features of Alternatives for Site 14.

Page 1 of 1

Alternative 1 Alternative 2 Alternative 3 Alternative 4

Summary of Key ARARs NA ARARs would be met. ARARs would be met. ARARs would be met. Long-term reliability of remedy None Moderate to High High High Estimated time for completion of

implementation Immediate Short Short Short

Estimated time to reach remediation goals

Indefinite Indefinite Above the cliff line: Short

Below the cliff line: Indefinite Above the cliff line: Short

Below the cliff line: Indefinite Estimated annual O&M costs $0 $21,875 $0 $0

Estimated periodic costs $0 $32,297 (yrs 5, 10, 15, 20, 25, 30) $2,301 (yrs 5, 10, 15, 20, 25, 30) $2,301 (yrs 5, 10, 15, 20, 25, 30) Discount rate NA 7% 7% 7%

Number of years over which cost is projected

0 30 30 30

Use of presumptive remedies and/or innovative technologies

None None None None

Quantity of untreated waste and treatment residuals to be

disposed of off-site or managed on-site in a containment system

and the degree of hazard remaining in such material

None

Approximately 40 lcy of PCB-contaminated soil with concentrations exceeding the TSCA hazardous waste

level (50 mg/kg) will be excavated and disposed at an approved off-

island disposal facility. Approximately 9,600 lcy of PCB-, lead-, and ACM-contaminated soil with a low to moderate degree of

hazard will remain onsite capped with a soil cover.



island disposal facility. Approximately 9,600 lcy of PCB-, lead-, and ACM-contaminated soil with a low to moderate degree of

hazard will be excavated and disposed at the on-island

Consolidation Unit.



island disposal facility. Approximately 9,600 lcy of PCB-, lead-, and ACM-contaminated soil

with low to moderate degree of hazard will be excavated and

disposed at an off-island disposal facility.

Estimated capital cost $0 $1,428,428 $2,706,404 $78,609,282 Estimated total present worth $0 $1,769,508 $2,711,366 $78,614,244

Notes: ACM – asbestos-containing material ARAR – applicable or relevant and appropriate requirement lcy – loose cubic yard mg/kg – milligrams per kilogram

NA – not applicable O&M – Operations and Management PCB – polychlorinated biphenyl TSCA – Toxic Substances Control Act

Table 2-10 Expected Outcome of Each Alternative for Site 14.

Page 1 of 1

Alternative 1 Alternative 2 Alternative 3 Alternative 4 Available uses of land upon achieving cleanup levels

Land would remain available for open space use.

Land would remain available for open space use.

Land above the cliff line would be available for unlimited and unrestricted use, including residential. Land below the cliff line would remain available for open space.

Land above the cliff line would be available for unlimited and unrestricted use, including residential. Land below the cliff line would remain available for open space.

Time frame to achieve available land use

Land is already appropriate for open space use.

Land is already appropriate for open space use.

Land above the cliff line would be available for unrestricted use immediately upon completion of the removal action. Land below the cliff line is already appropriate for use as open space.

Land above the cliff line would be available for unrestricted use immediately upon completion of the removal action. Land below the cliff line is already appropriate for use as open space.

Available uses of groundwater upon achieving cleanup levels

Groundwater is unaffected by contaminants on site and use of groundwater would remain unchanged.




Time frame to achieve available groundwater use

NA NA NA NA

Other impacts or benefits associated with alternative

No mitigation of onsite contaminants or reduction in site exposure risks.

Mitigation of onsite contaminants through soil removal, soil cover, and land use controls. Exposures to site users would be controlled by prohibiting residential use of the site.

Exposure risks above the cliff line would be eliminated by removing contaminated soils from the site, resulting in unlimited and unrestricted access. Exposure risks below the cliff line would be mitigated by prohibiting residential use of the land.

Exposure risks above the cliff line would be eliminated by removing contaminated soils from the site, resulting in unlimited and unrestricted access. Exposure risks below the cliff line would be mitigated by prohibiting residential use of the land.

Notes: NA – not applicable

l l

Table 2-11 Cost Estimate for Alternative 3 • Excavation and Removal of Soil Containing PCBs ~ 50 mg/kg

Shipped to an Off-Island Facility.

l'/VOrk Statement. EllCavate and dispose of soil containing 2. 50 mg,Kg PCBs. An estimated 40 CY of contaminated soil wm be excavated and disposed at an approved on-island kiisposal site. Excavation pits will be backfilled with clean replacement soil. Dust suppression to be provided by water trucks. Confirmation sampling for PCBs will be conducted to determine the full ex!ent of required excavation. ~pital Costa:

DESCRIPTION

Plana and Reports Work Plan Post Remediation Report SUBTOTAL

Excavation Mob/Demob exca>, ator Rent backhoe/loader, 45 to 60 HP 3/4 CY Rent dump truck, 20 CY Rent water truck, DH highway, 6000 gallon Rent truck pickup 'J/4 ton, 4WD Rent toilet portabl9 chemical Subcontractor lab!> rer Fill soil for earthwo rk Dirt, Rubble & Trash bags SUBTOTAL

Decontamination Pad Decontamination pad

Hazardous waste disposal SUBTOTAL

Transport and Diap-al Soil transport and disposal SUBTOTAL

Confirmation Samplkl g and Analyaia Hach Pocket Colorimeter II (PCBs) PCBs (USEPA Method 10050, reagent refill kit) PCBs (USEPA Method 8082) SUBTOTAL

SUBTOTAL

Contingency

SUBTOTAL

Project Management Technical Support SUBTOTAL

!TOTAL CAPITAL COST

~nual Costa: DESCRIPTION

~eriodlc Costa: DESCRIPTION

Preaant Value Analyaia: CoatType Capital Cost • year o

Notes: 1· estimate based on experience 2- estimate based on RSMeans

QUANTITY

, ,

1 1 , , 1 ,

80 40 40

1

0.5

40

, 2

100

25%

5% 10%

QUANTITY

QUANTITY

Total Coat

$ 452,017.06

3- estimated based on q4.1oted pries from supplier or contractor CY = cubic yard 4WD = four-wheel drive HAP = Heallh and Safer,, Plan HP = horsepower PCB= polychlorinated btphenyl QAPP = Quality Assurance Project Plan SAP = Sampling and Analysis Plan TSCA = Toxic Subslanoes Conlrol Act USEPA = United States Environmental Protection Agency

UNIT

ea ea

ea wk day wk wk wk hr CY ea

ea

ea

CY

ea ea 88

UNIT

UNIT

UNIT COST TOTAL NOTES

$ 16,500.00 $ 16,500.00 SAP, HSP, QAPP; assume drah, draft final, and final $ 23,000.00 $ 231000.00 Assume draft, draft final, and final

$ 39,500.00

$ 500.00 $ 500.00 $ 8,943.00 $ 8,943.00 Operator cost included $ 337.48 $ 337.48 Operator cost included $ 8,948.50 $ 8,948.50 Operator cost included; used for dust suppression $ 1,042.00 $ 1,042.00 $ 109.67 $ 109.67 $ 45.00 $ 3,600.00 $ 18.00 $ 720.00 $ 100.00 $ 4 000.00 Containerize excavated soil

$ 28,200.85

$ 14,381.00 $ 14,381.00 Consists of clean water supply tank, trash tank, steamer, pump and generator, and pad liner

$ 5,500.00 $ 2i75o.oo Decon water and sludge transport and disposal $ 17,111.00

$ 5,550.00 $ 2221000.00 Off-island disposal $ 222,000.00

$1,209.00 $1,209.00 $213.00 $426.00

$ 60.00 $ 6 000.00 $7,635.00

$ 314,446.65

$ 78,611.66

$ 393,058.31

$ 19,652.92 $ 391305.83 Includes site management and field staff $ 58,958.75

I! 45210,1.os I


11 . !No annual costs for excavation and disposal


11 . !No periodic coste for excavation and disposal

Total Cost/Yr Present Value $ 452,011.oe I $ 452.017 ,061

Page 1 of 4

SOURCE

1 1

2 2 2 2 2 2 1 3 3

3

3

3

3

, ,

SOURCE

SOURCE

Table 2-12 Cost Estimate for Alternative 3 - Excavation and Removal of Soil ContaininJ PCBs between 0.5 mg/kg

and SO mg/kg, and/or Lead:::: 400 mg/kg, and/or ACM Move to the CU.

ork tatement - Excavallon and on-Island disposal rn on ldation Unit of sol contaminate w s etween 0.5 and 50 mg/kg, and/or lea > 400 mg/kg, an or AC (resuting In unrestricted use). Confirmation sampling will be conducted to determine the full extent of requirad excavation. Dust suppression to be provided by water trucks. Excavation area wm be opped with 4• of compacted clean soil and reseeded. Task will require a Remedial Design, Work Plan, and Remedial Action Closure Plan. Consolldallon Unit cell will be constructed to a 1 0 loot depth to contain 9,600 CY of contaminated soil; excavated coral will be reused as cover material.

apllal Costs: DESCRIPTION QUANTITY UNIT UNIT COST TOTAL NOTES SOURCE

Remedial o..lgn Remedial Design ea $ 214,000.00 $ 214,000.00 SUBTOTAL $ 214,000.00

Plans and Reports Work Plan ea $ 65,000.00 $ 65,000.00 SAP, HSP, QAPP; assume draft, draft final, and final Remedial Action Closure Report ea $ 60,000.00 $ so,000.00 Assume draft, draft final, and final SUBTOTAL $ 125,000.00

I' Excavation at Site 14 Mobt'Demob dozer, loader, excavator, grader 2 ea $ 3,780.00 5 7,560.00 1 Rent bull dozer, 105 HP 2 wk $ 4,885.00 $ 9,770.00 Operator cost included 2 Rent front end loader, 4WD, 1. 75 - 2 CY 130 HP 1 mo $ 11,887.50 $ 11,687.50 Operator cost included 2 Rent excavator crawler 2.5 CY w/bucket tumbs 3 wk $ 12,156.45 $ 36,469.35 Operalor cost included 2 Rent grader, self-propelled, 40,000 lb 2 wk $ 8,591.00 $ 17,182.00 Operator cost Included 2 Rent dump truck, 20 CY 68 day $ 337.48 $ 22,948.64 Operator cost Included 2 Rent water truck, off highway, 6000 gallon 3 wk $ 8,948.50 $ 26,845.50 Operator cost included; used tor dust suppression 2 Rent truck pickup 3/4 ton, 4WD 8 wk $ 1,042.00 $ 8,336.00 2 Rent toilet portable chemical 8 wk $ 109.67 $ 877.38 2 Fill soil for earthwork 1,600 CY $ 18.00 s 28,800.00 3 Bluegrass sod replacement (golf course) 5,000 SF $ 0.66 $ 3,300.00 Replacement sod for golf course access for trucks 2 Seeding, mechanical or air, w/ lime & tertmzer 9,600 CY $ 1.58 $ 15,168.00 2 Erosion control, synthetic 1,500 LF $ 1.44 $ 2,160.00 Synthetic sllt lence, polypropylene, adverse conditions, 2

1,500 feet long x 3 feet high I. Erosion control, hay bales 16 ea $ 16.00 $ 256.00 Staked hay bells al runoff points 2 TCLP testing of lead-contaminated soil 20 ea $ 100.00 $ 2,000.00 Test before and altar TSP treatment, 1 per 100 CY 3 High density polyethylene liner, 40 mil 12,960 SF $ 2.21 $ 28,641.60 Liner for mixing of lead-contaminated soil, TSP, water 3 TSP treatment of lead-contaminated soil 20 ton $ 760.00 $ 15,200.00 Mixed on-site with excavator, 10% of soil requires

treatment (960 CY) w/ 2% TSP by volume l Soil cycle hauling 400 trip $ 10.37 $ 4,148.00 Cycle hauling (wait, load,trevel, unload or dump & 2 return)

Surveyor 10 day $ 1,200.00 $ 12,000.00 3-man survey crew, tum-key service Subcontractor Laborer 2,000 hr $ 45.00 $ 90,000.00 Includes faying of liner and preparing TSP SUBTOTAL $ 343,349.95

I . Decontamination Ped Decontamination pad ea $ 14,361.00 $ 14,361.00 Consists of clean water supply tank, trash tank., steamer, 3

pump and generator, and pad liner Hazardous waste disposal 0.5 ea $ 5,500.00 ! 2r75o.oo Decon water and sludge transport and disposal 3 SUBTOTAL $ 17,111.00

Confirmation Sampling and Analysis Hach Pocket Colorimeter II (PCBs) 1 ea $1,209.00 $1,209.00 PCBs (USE PA Method 10050, reagent refill ktt) 2 ea $213.00 $426.00 Hach Pocket Colo~meter (lead) 1 ea $509.00 $509.00

- Lead reagent set 2 ea $173.00 $346.00 Metals (USE PA Method 601 OB) 100 ea $ 100.00 $10,000.00 PCBs (USEPA Method 8082) 100 ea $ 60.00 ! 61000.00 SUBTOTAL $18,490.00

I . onsoUdaUon Unit Call Mob/Demob dozer, loader, excavator, compactor 2 ea $ 3,780.00 $ 7,560.00 1 Rent bull dozer, 105 HP 4 mo $ 14,246.00 $ 56,984.00 Operator cost included 2 Rent front end loader, 4WD, 1. 75 • 2 CY 130 HP 4 mo $ 11,687.50 $ 46,750.00 Operator cost Included 2 Rent excavator crawler 2.5 CY w/bucket tumbs 8 wk $ 12,156.45 $ 97,251.60 Operator cost Included 2 Rent roller/compactor 2 mo $ 11,000.00 $ 22,000.00 Operator cost included 2 Rent dump truck, 20 CY 150 day $ 337.48 $ 50,622.00 Operator cost included 2 Rent water truck, olt highway, 6000 gallon 16 wk $ 8,948.50 $ 143,176.00 Operator cost included; used for dust suppression 2 Rent truck pickup 3/4 ton, 4WD 16 wk $ 1,042.00 $ 16,672.00 2 Rent toilet portable chemical 16 wk $ 109.67 $ 1,754.72 2 High density polyethylene liner, 40 mil 25,920 SF $ 2.21 $ 57,283.20 Impermeable synthetic liner to cover contamlna1ed soil 3

Erosion control, synthetic 1,500 LF $ 1.44 $ 2,160.00 Synthetic slit fence, polypropylene, adverse con<litions, 2 1,500 feet long x 3 feet high

Erosion control, hay bales 16 ea $ 16.00 $ 256.00 Staked hay bells at runoff points 2 Surveyor 10 day $ 1,200.00 $ 12,000.00 3-man survey crew, turn-key service 1 Subeontractor laborer 2,500 hr $ 45.00 $ 1121500.00 Includes compacUon testing, laying of top liner 1 SUBTOTAL $ 628,969.52

L Page 2 of 4

Table2-12 Cost Estimate for Alternative 3 - Excavation and Removal of Soil Containing PCBs between 0.5 mg/kg

and 50 mg/kg, and/or Lead;?. 400 mg/kg, and/or ACM Move<f to the CU.

$UBTOTAL

Conllngency 25%

SUBTOTAL

Scoping 1 Project Management 10% Technical Support 10% SUBTOTAL

TOTAL CAPITAL COST

Annual Coats: DESCRIPTION QUANTITY

Periodic Coats: DESCRIPTION QUANTITY

Present Value Analyals: Cost Type Total Coat Capital Cost • year O $ 2,107,380.71

Noles: 1 • estimate based on experience 2- estimate based on RSMeans 3· esllmaled based on quoted price from supplier or contractor ACM = asbestos-containing material CY = cubic yard 4WD = lour-wheel drive HAP = Health and Safety Plan HP= hoisepower LF = linear loot mg/kg = mllllgrems per kilogram PCB = polychlorlnated bipheny1 QAPP = Quality Assurance Project Plan SAP = Sampling and Analysis Plan SF = square loot SY = square yard TSP= triple superphosphale USEPA = United States Environmental Protection Agency

ea

UNIT

UNIT

$ 1,344,920.47

$ 336.230.12

$ 1,681,150.59

$ 90,000.00 $ 90,000.00 1 $ 168,115.06 1 $ 1681115.06 Includes site management and field staff 1 $ 426,230.12

Is 211011380.11 I

UNIT COST TOTAL NOTES SOURCE

Is . !No annual costs for excavation and disposal

UNIT COST TOTAL NOTES SOURCE

I! I No periodic costs for excavation and disposal

Total CoaVYr Present Value $ 2.101.380.11 I s 211011380.11 I

Page 3 of 4

Table 2-13 Cost Estimate for Alternative 3 - Fish Monitoring.

~ork statement • Collect fish tissue samples In the ocean adjacent to the site via spear and hook and line methods. All whole fish and fillets samples will be analyzed for PCBs by USEPA Method 8082. Samples with detects will be reanalyzed by USEPA Method 1668A. Human health and ecologlc:al risk assessments will be completed and summari~ In an Informal Technical Information Paper. tapltal Costa:

DESCRIPTION QUANTITY

Plans and Reporta Work Plan 1 Informal Technical Information Paper 1

SUBTOTAL

Collect and Analyze Fish Tissue Samples Subcontractor for sample collection 100 Analyze PCBs (USEPA Method 8082) 40 Analyze PCBs (USEPA Method 1668A) 10 Data valldation 1 ERPIMS data management 1 SUBTOTAL

SUBTOTAL

Contingency 25%

SUBTOTAL

Project Management 5% Technical Support 15% SUBTOTAL

TOTAL CAPITAL COST

Annual Coste: DESCRIPTION QUANTITY

Periodic Costa: DESCRIPTION QUANTITY

Preasnt Value Analysts: Coat Type Total Cosl Capltat Cost • year o $ 144,705.00

Notes. 1- estimate based on experience 3- estimated based on quoted price from suppller or contractor ERPIMS = Environmental Restoration Program Information Management HAP = Health and Safety Plan PCB= polychlorlnated blphenyl QAPP = Quality Assurance Project Plan SAP= Sampling and Analysis Plan USEPA = United States Environmental Protection Agency

UNIT

ea ea

hr ea ea ea ea

UNIT

UNIT


$ 16,500.00 $ 16,500.00 SAP, HSP, QAPP; assume drell, drell final, and final $ 60,000.00 $ 60,000.00 Includes risk assessments; assume drell, drett final, final

$ 60,000.00

$ 100.00 $ 10,000.00 Boat, captain, and species collection included $ 125.00 $ 5,000.00 Assume 40 samples $ 825.00 $ 8,250.00 Assume 25% ol samples will have detects by 8082 $ 3,220.00 $ 3,220.00 $ 10,000.00 $ 10.000.00

$ 36,470.00

$ 96,470.00

$ 24,117.50

$ 120,687.60

$ 6,029.38 $ 181088.13 Includes site management and llekf staff $ 24,117.50

I$ 1~1os.oo I


Is INo annual costs for fish monitoring


I! !No periodic costs for llsh monitoring

Total Cost/Yr Present Value $ 144, 1os.oo I ! 1~10s.oo I

Page 4 of 4

SOURCE

1 1

3 3 3 3 1

1 1

SOURCE

SOURCE l .

l _

L

L

1 Table 2-14

Cost Estimate for Alternative 3 - Land Use Controls. Work Statement - Develop and submit land use restrictions to be incorporated as part of the Base Master Plan. Defines the allowable future use Site 14 and restrictions to land use as applicable.

DESCRIPTION QUANTITY Evaluate property transactions from territorial records, 16 Base records, review available data/maps, develop and submit restriction documentation Attorney review 1 DocumenVmap preparation 4 Reproduction and mailing 1

TOTAL CAPITAL COST

Annual Coate: DESCRIPTION QUANTITY

Periodic Coats: DESCRIPTION QUANTITY

Five-Year Review (Yr 5) 1

SUBTOTAL

Present Value Analysis: Cost Type Total Cost

Capilal Cost - year O $ 2,301 .36 Periodic Cost - year 5 $ 2,301 .36 Periodic Cost - year 1 O $ 2,301 .36 Periodic Cost - year 15 $ 2,301 .36 Periodic Cost • year 20 $ 2,301 .36 Periodic Cost • year 25 $ 2,301.36 Periodic Cost - year 30 $ 2,301.36 SUBTOTAL $ 16,109.52

TOTAL PRESENT VALUE OF LAND USE RESTRICTIONS

Notes: OF= Discount Factor at 7 percent 1- estimate based on experience

UNIT hr

hr hr ea

UNIT

UNIT ea

OF 1.00

0.713 0.508 0.362 0.258 0.184 0.131

UNIT COST TOTAL NOTES $ 101.43 $ 1,622.88

$ 300.00 $ 300.00 $ 69.62 $ 278.48 $ 100.00 $ 100.00

Is 21301.361


Is . INo annual costs for Land Use Controls

UNIT COST TOTAL NOTES $ 2,301.36 $ 2 301.36 Update land use restrictions every 5-yrs for 30 yrs

Is 21301.36 lsix times during 30-yr period

Total Cost/Yr PreNnt Value Notes: $ 2,301 .36 $ 2,301.36 $ 2,301.36 $ 1,640.87 $ 2,301 .36 $ 1,169.09 $ 2,301.36 $ 833.09 $ 2,301.36 $ 593.75 $ 2,301.36 $ 423.45 $ 2,301.36 $ 301 .48

$ 7,263.09

Is 11263.oo I

Page 1 of 1

SOURCE 1

1 1 1

SOURCE

SOURCE 1

Table 2-15 Description of ARARs and TBCs for the Selected Remedy for Site 14.

Page 1 of 3

Authority Medium Requirement Status Synopsis of Requirement Action to be Taken to Attain Requirement

Chemical-Specific ARARs None.

Location-Specific ARARs

Federal Regulatory

Requirement Critical Habitat

Endangered Species Act of 1973 (16 USC 1531) 50 CFR Section 200, 50 CFR Section 402

Fish and Wildlife Coordination Act (16 USC 661) 33 CFR 320 to 330

Applicable

Action to conserve endangered species or threatened species if action may be critical or threatens the habitat upon which species depend. Promotes actions to conserve endangered species or habitats.

The selected remedy will comply with this requirement by assessing the soil removal and soil cover plans to ensure that no adverse impact to potential roosting, nesting, or foraging habitat of endangered species occurs. Listed species have been identified as receptors of concern at the sites.

Federal Regulatory

Requirement

Historical Artifacts

National Historic Preservation Act (16 USC Section 469)

36 CFR 65, 40 CFR 6.301(b)

Applicable

Action to recover and preserve artifacts if in an area where action may cause irreparable harm, loss, or destruction of significant artifacts.

Will consult with Guam and National Register of Historic Places if necessary.

Territorial Regulatory

Requirement

Endangered and Threatened

Species

Endangered Species Act of Guam

5 GCA Chapter 63 Applicable

Lists endangered and threatened species; regulates wild game and fish.

The selected remedy will comply with this requirement by assessing the soil removal and soil cover plans to ensure that no adverse impact to potential roosting, nesting, or foraging habitat of endangered species occurs. Listed species have been identified as receptors of concern at the sites.


Requirement

Historical Objects and

Sites

Conservation of Archaeological Resources, 21 GCA Chapter 76

Applicable Provides for the historic preservation, restoration, and presentation of historic objects and sites.

Will consult with Guam and National Register of Historic Places if necessary.

Action-Specific ARARs

Federal Regulatory

Requirement

Hazardous Waste

Definition and Identification of Hazardous Waste

40 CFR 261 Applicable

Establishes basic definitions of solid and hazardous waste.

Excavated soil would be tested for hazardous waste characteristics using the Toxicity Characteristic Leaching Procedure. All hazardous waste materials will be handled, stored, transported, and disposed in accordance with RCRA.

Federal Regulatory

Requirement

Hazardous Waste

Standards for Generators of Hazardous Waste


Establishes regulations covering activities of generators of hazardous waste. Generator requirements include identifying waste generation activity, obtaining an EPA ID number, record keeping, and use of a uniform national manifest.

The selected remedy will comply with this requirement by completing all applicable hazardous waste generator requirements.

Table 2-15 (Continued) Description of ARARs and TBCs for the Selected Remedy for Site 14.

Page 2 of 3


Federal Regulatory

Requirement

Hazardous Waste

Standards for Transport of Hazardous Waste


Establishes regulations covering the transport of hazardous waste. The transport of hazardous waste is subject to requirements including DOT regulations, manifesting, record keeping, and discharge cleanup.

The selected remedy will comply with this requirement by properly transporting any identified hazardous wastes.

Federal Regulatory

Requirement

Hazardous Waste

Land Disposal Restrictions (“Land Ban”) 40 CFR 268

Applicable

Treatment standards require that contaminated soils that will be land disposed be treated to reduce concentrations of hazardous constituents by 90 percent or meet hazardous constituent concentrations that are ten times the universal treatment standards.

The selected remedy will comply with this requirement by treating, as necessary, any soil classified as a hazardous waste which is to be disposed in the Consolidation Unit to meet the established Land Disposal Restriction treatment standards.

Federal Regulatory

Requirement

Hazardous Waste

TSCA 40 CFR 761

Applicable Regulates wastes containing PCB constituents and asbestos materials.

The selected remedy will comply with this requirement by characterizing all wastes upon excavation and disposing off-island at an approved treatment, disposal, and storage facility. Notifications will be made as appropriate.

Federal Regulatory

Requirement

Hazardous Waste

HMTA 49 CFR 100 to 199

Applicable

Applies to the transport of hazardous materials. These standards consist of specific DOT requirements for labeling; packaging; shipping papers/ manifesting; and transport by rail, aircraft, vessel, and highway.

The transportation of wastes as conducted under the selected remedy will be consistent with DOT regulations.

Federal Regulatory

Requirement

Intergovernmental Review of Federal Programs Executive

Order 12372 40 CFR 29

Applicable

Requires State and local governmental coordination and review of proposed EPA-assisted projects. The EPA administrator is required to communicate with State and local officials to explain the project, consult with other involved Federal agencies, and provide a comment period for State review.

The Guam EPA will be provided a 60-day review period of this Record of Decision.

Federal Regulatory

Requirement Water

Coastal Zone Management Act PL 92-583,

16 USC 1451-1456 Applicable

Regulates surface water bodies or watershed basins near coastal zones.

The selected remedy will comply with this requirement by conducting removal activities in a manner that prevents surface erosion of soil to nearby streams and marine waters.

Table 2-15 (Continued) Description of ARARs and TBCs for the Selected Remedy for Site 14.

Page 3 of 3


Federal Regulatory

Requirement Air

CAA Section 109 and National Ambient Air Quality Standards

40 CFR 50

Relevant and Appropriate

National ambient air quality standards to attain and maintain primary and secondary standards to protect public health and the environment.

Remedial actions may result in air emissions as a result of excavation activities. CERCLA 121(E) exempts onsite activities from obtaining air permits. However, the selected remedy will comply with this requirement by establishing an air monitoring plan and implementing dust control measures, as necessary, to mitigate fugitive dust generation during excavation activities.


Requirement Air

Air Pollution Control Act 10 GCA Chapter 49

Applicable

Establishes air quality criteria, sampling, testing, monitoring, record keeping requirements, source permitting system, and specific control requests.

The selected remedy will comply with this requirement by establishing an air monitoring plan and implementing dust control measures, as necessary, to mitigate fugitive dust generation during excavation activities.


Requirement

Solid and Hazardous

Waste

Solid Waste Management 10 GCA Chapter 51

Applicable Regulates solid waste collection and disposal.

The selected remedy will comply with this requirement by conducting disposal of non-hazardous waste to the Andersen AFB consolidation unit in accordance with Guam’s solid waste management regulation.


Requirement Water

Water Pollution Control Act 10 GCA Chapter 47

Applicable Regulates streams and marine waters from soil erosion and sediment control.

The selected remedy will comply with this requirement by conducting removal activities in a manner that prevents surface erosion of soil to nearby marine waters.

To Be Considered Guidance Federal

Regulatory Requirement

Soil USEPA Regional Screening

Levels TBC

Screens and establishes Risk-based Cleanup Goals for chemicals in soil, air, and water

The selected remedy will comply with this requirement by removing and properly disposing of soils with contaminant concentrations above Remedial Goals.

Notes: AFB – Air Force Base ARAR – applicable or relevant and appropriate requirement CAA – Clean Air Act CERCLA – Comprehensive Environmental Response, Compensation, and Liability Act CFR – Code of Federal Regulations CWA – Clean Water Act DOT – Department of Transportation FR – Federal Register GCA – Guam Code Annotated Guam EPA – Guam Environmental Protection Agency

HMTA – Hazardous Materials Transportation Act LDRs – Land Disposal Restrictions PCB – polychlorinated biphenyl PL – Public Law RCRA – Resource Conservation and Recovery Act TBC – To Be Considered TSCA – Toxic Substances Control Act USC – United States Code USEPA – United States Environmental Protection Agency

FIGURES

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MT. SANTA ROSACOMMUNICATIONS

ANNEX

ANDERSEN AIRFORCE BASE

Main Base

ANDERSEN AIRFORCE BASE

Northwest Field

POTTS JUNCTIONTANK FARM

BARRIGADA TRANSMITTER SITE

P A C I F I CO C E A N

P H I L I P P I N ES E A

APRAHARBOR

ROTA CHANNEL

FENA RESERVOIR

MT. LAMLAMELEV. 1,332

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URUNOPOINT

HAPUTO BEACH

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AGATBAY

FACPIPOINT

CETTI BAY

UMATECBAY

COCOSLAGOON

MALILOGPOINT

INARAJANBAY

TALOFOFOBAY

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PAGOBAY

TAGUANPOINT

PAGATPOINT

ANAOPOINT

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GUAMINTERNATIONAL

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µ0 6,0003,000

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Installation Boundary

Minor Roads

Major Roads

Coral Reef Limit

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AREAENLARGED

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Indian Ocean

Phillipine Sea

Pacific Ocean

Figure 1-1.Vicinity Map - Andersen Air Force Base, Guam

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Figure 2-1. Location Map of Site 14, Andersen Air Force Base, Guam

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Andersen Air Force Base, GuamMain Base OU

Area Enlarged

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Site 14 Project Boundary

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Figure 2-2. Topographic Survey atSite 14, Andersen AFB, Guam

0 250125Feet I

December 2009


Area Enlarged

Andersen AFB

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Figure 2-3. Surface Soil Sample Locations and Results Exceeding Action Levels

at Site 14, Andersen AFB, Guam

August 2010


Area Enlarged

Andersen AFB

(

( (

(

(

((

(

(

(

(

(

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Pb = 750 mg/kgPCB = 46 mg/kg

PCB = 7 mg/kg

Pb = 970 mg/kgPCB = 10.5 mg/kg

PCB = 5.2 mg/kg


Pb = 670 mg/kgPCB = 8 mg/kg

PCB = 1.33 mg/kg

Pb = 1800 mg/kgPCB = 0.86 mg/kgPb = 750 mg/kg

PCB = 1.12 mg/kg



PCB = 0.74 mg/kg

Pb = 592 mg/kg


PCB = 1.516 mg/kg

PCB = 4.623 mg/kg

PCB = 9 mg/kg

PCB = 21 mg/kg

PCB = 3.12 mg/kg

PCB = 0.7 mg/kg

PCB = 5.6 mg/kg

PCB = 0.78 mg/kg

PCB = 1.08 mg/kg

PCB = 2.23 mg/kg

PCB = 2.11 mg/kg

PCB = 0.51 mg/kg

PCB = 3.3 mg/kg

PCB = 0.74 mg/kg

PCB = 1.19 mg/kg

PCB = 0.52 mg/kg

PCB = 0.77 mg/kg

PCB = 54 mg/kg

PCB = 3.752 mg/kg

PCB = 1.004 mg/kg

PCB = 0.9854 mg/kgPCB = 2.329 mg/kg

Pb = 2500 mg/kg

PCB = 4.59 mg/kg

PCB = 0.5701 mg/kg

PCB = 0.5383 mg/kg

Pb = 797 mg/kg

Pb = 704 mg/kg

Pb = 881 mg/kg

Pb = 478 mg/kg

Pb = 905 mg/kg

( Lead ≥ 400 mg/kgPCBs ≥ 50 mg/kgPCBs > 0.5 mg/kg, < 50 mg/kgACM LocationsCliff LineSite Boundary

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Figure 2-4. Subsurface Soil Sample Locations and Results Exceeding Action Levels at

Site 14, Andersen AFB, Guam

August2010


Area Enlarged

Andersen AFB(

(

PCB = 7.667 mg/kg

PCB = 380 mg/kg

PCB = 3.791 mg/kg

PCB = 184 mg/kg

PCB = 2.357 mg/kg

PCB = 2.186 mg/kg

PCB = 2.055 mg/kg

PCB = 7.770 mg/kg

PCB = 1.707 mg/kg

Pb = 742 mg/kg

Pb = 425 mg/kg


I0 350175 Feet

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Contaminated Soil and Debris at Site 14

Figure 2-5. Conceptual Site Model for the 2009 Remedial Investigation Human Health Risk Assessment.

PrimarySource

PrimaryRelease

Mechanism

SecondarySource

SecondaryRelease

Mechanism

TertiarySource

PotentialExposure

Routes

Specific Receptors of Concern

,. Air Particulate -• Matter

Occasional Future Residents

Usersffrespassers Hunters

(Adults, children) (Adults, children) (Adults, children)

Surface Soil Ingestion X X

~ Soil - Dermal Contact X with Soils

X

~ Vegetation -• Wild Pigs

Deer Inhalation of

X Air Particulates

X

Ingestion of Deer, Pig

X

Seawater -,. I-

Infiltration/ Groundwater Fish -----• Adso1vtion

,__~ - • Sediment ,~

~ ~


Usersffrespassers Fishers

( Adults, children) (Adults, children) (Adults, children)

I Ingestion of Fish X

Air Particulate ,. -• Matter


Usersffrespassers Hunters

(Adults, children) (Adults, children) (Adults, children)

Subsurface Soil Ingestion X

~ Soil - Dermal Contact with Soils

X

~ Vegetation -• Wild Pigs

Deer Inhalation of

Air Particulates X

Ingestion of Deer, Pig

Figure 2-6. Ecological Conceptual Site Model for Site 14, Andersen AFB, Guam.

PotentialSource

SecondaryRelease

Mechanisms

Potential Pointsof Contact

PotentialExposure

Routes

Specific Receptors of ConcernSecondarySource

Contaminated Soil and Debris

at Site 14Surface

SoilSurface

Soil

SubsurfaceSoil

Ground Water

Uptake byBiota

Plant orPrey Tissues

Infiltration

Direct Contact WithChemicals in Soil

Incidental Ingestionof Chemicals in Soil

TerrestrialPlants

YellowBittern

MarianaCrow

MarianaFruitBat

Invertebrates(Earthworms)

X X X X

X X

X

X

XX

X

Ingestion of Plantsor Prey

No CompleteExposure Routes

No CompleteExposure Routes

ErosionRunoff

....___....___H...____

Figure 2-7. Alternative 3: Excavation withDisposal and Land Use Controlsat Site 14, Andersen AFB, Guam

August 2010


Area Enlarged

Andersen AFB

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PHOTOGRAPHS

of 4

Photo 2-1. View east across Site 14, Andersen AFB, Guam,

from the end of the access road.

Photo 2-2. View north from top of the access point at Site 14,

Andersen AFB, Guam.

of 4

Photo 2-3. View south from top of the access point at Site 14,

Andersen AFB, Guam.

Photo 2-4. View up at the end of 12” pipe at Site 14,

Andersen AFB, Guam.

12’’ Pipe

of 4

Photo 2-5. View of the wave-cut toe of the wedge-shaped prism of debris and

fill material at Site 14, Andersen AFB, Guam.

Photo 2-6. View south during seawater sampling at Site 14,

Andersen AFB, Guam.

of 4

Photo 2-7. View down from the top of the wedge-shaped prism of debris and

fill material at Site 14, Andersen AFB, Guam.

Photo 2-8. View from offshore of Site 14, Andersen AFB, Guam.

Access Point

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APPENDIX A

FEDERAL FACILITY AGREEMENT CHANGE LETTERS

36 CBS/CEVR Unit 14007 APO AP 96543•4007

Mr. Mark Ripperda Project Manager

DEPARTMENT OF THE AJR FORCE HEADQUARTERS, 36TH WING (P ACAF)

UN1T 14007, APO AP 96543•4007

U.S. Environmental Protection Agency 75 Hawthome St., H-9-4 San Francisco, CA 94105-3901

Dear Mr. Ripperda

06 November 2009

This letter provides notice of a change in administrative responsibility pursuant to paragraph 28 of Federal Fac ility Agreement (FFA) Docket Number 93-117 (FFA).

As you are aware, Andersen Air Force Base is in the process of realigning installation management functions to a newly established Joint Region Marianas pursuant to the 2005 Defense Base Closure and Realignment Commission Final and Approved Recommendations. Title to Andersen Air Force Base real property will remain in the United States and the property will continue to be utilized by the Air Force. As of October I, 2009, however, administrative custody and responsibility for managing real property assets will transfer fi-om the Air Force to the Navy. The Air Force wil I become a supported component of the Joint Region Marianas and the Navy will become the supporting component.

,I

In accordance with the April 2008 Department of Defense Environmental Supplemental Guidance for Implementing and Operating a Joint Base, the Navy, as the supporting component, "will be re.lponsible for all existing and future environmental permits, requirements, plans, and agreements at the installations to become the Joint Base. " (Ch. 1.1.2). As the supporting component, the Navy will be requ ired to "honor all existing, previously negotiated Federal Facility Agreements in place at the installations to become the Joint Base at the time of tran.lfer. "(Ch. 2.17.5). The Navy is being supplied with an Environmental Condition of Property Repo1t and with access to current environmental files including the FFA. No change to the FFA will be necessary in order for the Navy to assume responsibility for implementation of the FFA and the transfer of responsibility will not change the rights of the parties under the FFA or impede any action under the FFA. The Environmental staff will remain located at Andersen Air Force Base following 01 October 2009 and will be available to assist with any issues related to the FFA. However, the civilian environmental staff will become Navy employees and, likewise, funding responsibi lity will reside with the Navy.

Please contact Mr. Russell Littlejohn, Environmental Flight Chief, at (671) 366-2556 if you have any questions or concerns or would like to discuss possible changes/addendums to the FFA to further document the substitution of the United States Navy for the United States Air Force as the entity responsible for implementation of the FF A.

cc: Ms. Lorilee Crisostomo, GEPA Mr. Rich Howard, Tech Law Inc.

Sincerely

~~ GREGG IKEHARA Chief, Installation Restoration Program

Mr. Mark Ripperda

DEPARTMENT OF THE NAVY COMMANDER, JOINT REGION MARIANAS

PSC 455. BOX 152 FPO AP 96540-1000

US Environmental Protection Agency 75 Hawthorne St. H-9-4 San Francisco, CA 94105-3901

Dear Mr. Ripperda,

.'N 111::?LY Rf"ffol< TO

9510 Ser J4/1235 November 23, 2009

SUBJECT: NOTIFICATION OF TRANSFER OF ENVIRONMENTAL RESTORATION PROGRAM RESPONSIBILITY

This letter serves as notification that all Environmental Restoration Program responsibilities for Andersen Air Force Base (AAFB), a property listed on the National Priorities List, will be officially transferred to the United States Navy under the Commander, Joint Region Marianas (CJRM), effective October 1, 2009, pursuant to chapter 2.17 of the April 2008 Department of Defense Environmental Supplemental Guidance (EVSG) for [mplemenling and Operating a Joint Base. This action is being taken to implement the 2005 Defense Base Realignment and Closure (BRAC) Act which requires the transfer of all installation support functions and administrative custody of real property from AAFB to the U.S. Navy.

In accordance with the EVSG, the Navy, as the supporting component, "will assume responsibility for environmental restoration data reporting, budgeting, record keeping, and financial liability" (Ch. 2.17.6), "will assume responsibility for all Restoration Advisory Boards" (Ch . 2.17.8), and will be required to "honor all existing, previously negotiated Federal Facility Agreements in place at the installations to become the Joint Base [Region] at the time of transfer." (Ch. 2.17.5).

[f you have any questions, please contact Mr. Richard Raines, P.E., at telephone (671) 339-8420 or at ri~hard.raines(c"i;fo.navy.mil.

Copy to: Guam En\<iromncntal Protection Agency CNIC (N45) NA VFAC Pacific (EV ) 36CES

Qii · r . S.LYNCH ~

Captain, CEC, U.S. NAVY Regional Engineer By direction of the Commander

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APPENDIXB

NOTICE OF PUBLIC MEETING AND DOCUMENT AVAILABILITY

ANDERSEN AIR FORCE BASE INSTALIATION RESTORATION PROGRAM ·

Public Meeting September 1, 2010 at 6:30pm

Guam Marriott Resort&. Spa, 1'he View 627 Pale San Vitores Rd., Tum.on, Guam 96ro

The .Andmcn AFB lmllllation Ramntion Program will hold 11. public: meeting S rembcr 1, 2010 IX> disCJJ&S the P:ropoeed Plan for Site 14 of the Main Base

le Unit of Andcm:n AFB, Guam. the Propa,ed Plan di8CUSICS the poteutial ~ bythe &.iti: ID hwnan mid emlagical~ and pmmll the evaluation

of n:medw altuna.!MI. Four Ia11edw a.ltematma were coneidaed i>r the Bite:

. .Alamiadft 1-No Action Altmaatin 2 - Ahm the CllifLlpc; Excaw.tion and Off-Island D~ of PCB& a SO mg/kg, Soil Cover, and Land Use Controls: Below the rnHLinc: Land Use Controls . Altmll1Dft3-Ahgye the CllifLine: Excavation and ~movalofSoil Contllining PCB11 a SO mg/kg Shi~ to an Off-Island Facility and Soil Containing PCBs bctwten 03 m and SO mg/kg, and/or Lead a 400 mg/kg, and/or Asbestos-Containing Ma • M~d to the Consolidation Unit; Bdmt the CliffLinc: Land Use Controls . -Altrmmve-4-Abqy; the CliffLine: F.xcavation $d Off-~ Dispoal of Conwninatcd Soil; Bclqw,the CliffLcjnc: Land Use Controls

The ptc.6:md mnedy lbr Site 14 is Alremati:Ye 3. The .6nal remedy will be Rlemd a&r public~ m Rtdvcd The Propoted Pim ll!ld aupporting documcnti ~ Vlilable for puhlic fC'Mf at the iJ1bring Joationr.

P~ nity ofG,wn (lJOG) N~ M. Fton:s Memorial.Libruy GCMl'Ollltltt Document! Dq,arlmcut 245 Martyr Stttet Robert F. Kennedy Li'bruy, UOG Sairion Hagltia, Guam 96910 Mangila.o, Guam 96932 (671) 475-4751, -4153, or -4754 (671) ?lS-2315 or -2316 Moo-ThlllS &:00am-6;00pm • Mon-ThWJ1 8:00am-5:00pm Sat 8:0llam-S:OOpm Fri 9:00am-5:00pm Contact Teresita Kennimer Contact Walfrid Bcnaialte

Public commcnll will be aca:p~!rom August 18, 2010 to Sepcembcr 17, 2010. Written comments muat be posmwlicci on or bcfwe Sq,tmibei 17,2010 and mailed ID:

Mi:. _Q___~ lkwra 36 CES/CEVR, UNIT 14007

APO AP 96543-4007 •

For .further ~rpu.tjon, please contact the Andcnca }.jz Force Bue Public, • : .. ~ .~~(-671~a6~~~02pr ·S~O,~ ... : •• .. ,'~:-•.

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ANDERSENAJRFORCEBASE · INSTAILATIONRF.STORATIONPROGRAM

Publlc Meetiag Septeml,er 1, 2010 at 6:30pm

Guam Marriott Resort & Spa, The VICIW . 627 Pale San Vitorea Rd., Tum.on, Guam 96913

The Andcncn AFB lmtal1ation Rmotation Progmn will hold I public~ S her 1, 2010 to dlsC1.1&1 the ProJ,o1cd PJjo fui; Sim 14 a(ttu, fi«ain Ba,e

Unit of Andmca AFB, Guam. ThePmposedPian ~ 1he ~ -...l bythcaie tD human aid~ recep and II the ewluAtiol1

of~ altemativa. Four remedial~~ for the aim: Alta...m,c 1-No Action .Abmmiftl-Abm di; Oif[Ljne: Emmtion and Otr-Islmd ~ of PCBs ~50 mg/kg. Soil Cover, tnd Land U1111: Contmlat Bdcm:thc Qift'Ljne; Land Use Control& . Altrmatm 3 - Ahoye the Clif[Ljge; 11.xta.fftion and Rtmowl of Soil CC>nnuniag PCBs ~ 50 mg/kg ~!ed to an Off-Island Facility and Soil · .' Conmining PCB1 bctw=n 03 m and 50 mg/kg, and/or Lc:adi. 400 mg/kg, 8;!1d/or Asliestos--Containiog ' Mowd to the Consolldatio.11 Unit; .&km th& ClifFLlm;: Land Use Controls · . Almoudm:-4-i\hon the ClifILioc: Excaviuinn and oe:-hland DkpOl&l of Contaminated Soil; Bclczw th; Cllf[Ljne: Larul Use Contmhi The prm:rmi remedy for Site 14 ii Altcmative 3. The final mm:dy will be ~ after public tommen11 are r=wd. The Propoecd Plan and 11apporting documenta m awilable .fnr pub1ic review at the fnllowing loc:atiom: Unm:rsity of Gutm (tJOG) Nie"'8M. F1mu Memorial Library Govl:nunent Documeu111 Dg,artmcnt 245 Martyr Street . Robert F. Kennedy Library, UOG Sm.tion HagAtfia, Gwn 96910 Mangilao, Guam 96932 . (671) 475-4751,-4753, Ill' -4754 (67lf735-2315 or-2316 Mon-Thun 8:00am-6100pm Mon-Thun 8:00am-S:llOpm S1.t B:OOam-5:00pin · Fri 9:00am-5:00pm Contact: Tm:sita Kemwni:r Contact: WilfiiJ Beua.vanm 1ahlic commcnta-will be 11CCq,tm mun &pt 18, 2010 ID Scptmabcr 17, 2010. Writtm commentl mlllt be pOltmatbd on orb~ Septauber 17, 20101111d llllilalto:

35•;

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APPENDIXC

LETTER FROM GUAM ENVIRONMENTAL PROTECTION AGENCY REGARDING THE

PREFERRED REMEDY

GUAM ENVIRONMENTAL PROTECTION AGENCY

AHENSIAN PRUTEKSION LINA'LA GUAHAN

FELIX P. CAMACHO GOVERNOR OF GUAM

Mr. Gregg N. Ikehara Project Manager 36CES/CEVR Unit 14007 APO AP 96543-4007

Dear Mr. Ikehara:

P,O, Box 22439 GMF • BARRIGADA, GUAM 96921 TEL: 475-1658/9 • FAX: 477-9402

nAY O 5 2010

MICHAEL W. CRUZ LT. GOVERNOR OF GUAM

Hafa Adai! This letter is in response to your request to dispose of approximately 9,600 cubic yards of soil comingled with less than 50 mg/kg PCB and asbestos from IRP Site 14, at the Andersen Air Foree Base (AAFB) Consolidation Unit (CU).

After having exhausted your on-island options to remediate the subject soil, please be informed that the disposal of this soil at the AAFB CU is approved under the following conditions:

That a synthetic impervious liner be installed over the disposed contaminated soil prior to installing the final earth cover; That the U.S. Navy shall continue to perform fish monitoring in the marine waters around Site 14 in coordination with Guam EPA' s Monitoring and Surveillance Program staff (Jesse Cruz and/or Walter Leon Guenero); and,

- That this disposal approval is for a "One-Time Only" event.

Should you have any questions or require clarification, please feel free to contact Michael S. Cruz at 475-1658/59. Dangkolo na Si Yu'os Ma'i\se'.

CC: Mark Ripperda, U.S. EPA Region IX

Sincerely,

~--~~~ LORILEE T. C~OMO Administrator

"ALL LIVING THINGS OF THE EARTH ARE ONE"

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