This is middle grade paper, the paper was sent to several student reviewers, whose comments follow the instructor's comments.

 

Grading

 

Mark each category 5 to 10:

10 = Yes, very well

9 = Yes

8 = Adequate

7 = Not quite adequate

6 = No

5 = Definitely no.

 

  1. Did the paper discuss a risk assessment? __8_
  2. Was the paper as a whole relevant to describing the risk assessment process?___8
  3. Did paper cover some technical issues relevant to risk assessment? ___7
  4. Was paper of sufficient length to cover the topic? ___6
  5. Was the paper “well integrated” that is, all parts of the paper relevant and adequately connected to each other? ___10
  6. Were the English “mechanics” in good order, no typos or structural problems? __9.5
  7. Were the figures and tables informative and related to the text? ___10
  8. Were facts presented properly referenced? ___8
  9. Was the overall appearance of the paper professional? ___10
  10. Would you hire this student to write a technical report for a client of yours? ___10

 

For comment:

Did the paper raise questions you would like answered?  Name some.

 

 

 

 

Other comments:

 

Safety of the hot springs water supply was not a concern of the residents until the public meeting was held.  This is an example of public meetings actually causing the concern.  Fortunately for all parties it can be addressed fairly simply. Yes and no.  Whether or not an issue is scientifically important, it can be important to people.  Therefore it is better to daylight these concerns before the risk assessment, rather than have them come up later.

 

Spent  a long time on material that is not risk assessment.  Lacked a critical review of  any risk assessment topics

 

Student Reviewer 1

 

  1. Did the paper discuss a risk assessment? _9__
  2. Was the paper as a whole relevant to describing the risk assessment process?_8__
  3. Did paper cover some technical issues relevant to risk assessment? _8__
  4. Was paper of sufficient length to cover the topic? _10__
  5. Was the paper “well integrated” that is, all parts of the paper relevant and adequately connected to each other? __9_
  6. Were the English “mechanics” in good order, no typos or structural problems? 8__
  7. Were the figures and tables informative and related to the text? _9__
  8. Were facts presented properly referenced? __9_
  9. Was the overall appearance of the paper professional? _9__
  10. Would you hire this student to write a technical report for a client of yours? 9___

 

For comment:

Did the paper raise questions you would like answered?  Name some.

 

Don’t you think inclusion of a public involvement would make the risk assessment more complete?

If there is not enough population then what action will be taken to prevent tresspassers?

 

 

Other comments:

 

 

 

 

 

 

 

 

 

 

Use of a Risk Assessment

Granite Mountain Radio Relay Station

 

Introduction

Following World War II the United States became increasingly worried about an attack from the Soviet Union.  It was felt that one of the likely scenarios was an air strike launched from across the Arctic Ocean.  The United States, in response to this perceived threat, set up a communication system to relay information about airborne aircraft that were offshore of Alaska.  Part of this system was a series of Radio Relay Stations (RRS) known as the White Alice Communication System (WACS).  As satellite communications technology became available the WACS sites were phased out of use.

 

General Site Description

The Granite Mountain RRS is located on the Alaska Seward Peninsula about 130 miles east of Nome and 12 miles north of Dime Landing.  The topography (figure 1.1-1) is a high area along the continental divide that is devoid of large vegetation.  Several small creeks have their source at Granite Mountain in the form of natural seeps and surface drainage.  The location is remote with a landing strip but no road system to connect it to villages. (UASF, 2000)

 

 

 

 

(UASF, 2000)

 

Land Use, Ownership and the Responsible Party

By 1976 the Granite Mountain RRS was no longer in use by the United States Air Force (USAF).  They  decided to lease the facilities to Alaskcom, an Alaskan communications company.  Later, during the 1980’s the Bureau of Land Management (BLM) used this site as a base of operations for fighting fires on the Seward Peninsula. (Buck, 2001) However, by 1981 the USAF had already sent a notice to relinquish the RRS at Granite Mountain to the Bureau of Land Management. (UASF, 2000) This action has proved a more difficult undertaking than was first perceived as this transfer is still incomplete. 

 

The transfer of federal land ownership or management between agencies or state government has been hampered in the past by existing contamination.  When contamination is discovered on a site the State of Alaska has a law in their statute that applies that is titled Strict Liability (Alaska Statute 46.03.822).  This law has the effect of casting a wide net to identify the Responsible Party (RP) and force them to either cleanup that property to state standards or the state can perform the cleanup and bill the RP for all the costs involved. (State of Alaska, 1996)

 

Typically the current land owner or manager is the first to be identified as the RP.  It is assumed by the State of Alaska that a potential land owner or manager would perform a due diligence search to look for contamination prior to transfer and the issues of site cleanup should have been taken into consideration by the two parties prior to transfer.  This would not be the case if the contamination was not known, hence not disclosed and was not reasonable to be found during a due diligence search.  (Lenard, 2000)

 

It is due to the existence of the Strict Liability Law that the receiving agencies are reluctant to have land transferred to them prior to a due diligence search.  The Alaska Department of Natural Resources (ADNR) has been the recipient of land where contamination was later found.  By an internal agreement made after the land transfer between ADNR and the BLM, BLM is performing the cleanup of this property.  Without this agreement the ADNR would have been held liable for cleanup.  (Buck, 2001)

 

It is unknown if the delay in this transfer of the Granite Mountain RRS from the UASF to the BLM was due to the strict liability law or the existing contamination but it is logical to conclude that they may have been a factor. 

 

Waste handling practices

Waste handling practices for remote military sites during 1950’s to the 1970’s indicated that the following options were available for field personnel:

1.      Placing liquids in 55 gallon drums for shipment back to Military Base for disposal that fit into the following classifications:  not needed and unused, used liquids such as used motor oil,  or contaminated liquids such as recovered spill materials.

2.       Pouring all of the materials mentioned above down floor drains.  This activity will be limited by the permeability of the soil and the volume of material that needs to be disposed.

3.      Burning the above mentioned liquids on site.

4.      Using the above mentioned materials on roadways as a dust suppressant.

5.      An area designated as a landfill for solid waste was also a typical for remote sites.  This also served to concentrate unsightly and unsanitary material from kitchen waste to shop materials.  (Buck, 2001)

 

Although these were the general practices for that time period, adherence to these practices was not a priority.  Dumping of waste liquids, was in many cases, a matter of convenience.  Landfills were used for liquid disposal, as were creeks, and land areas away from the main camp.  These alternative practices made finding all the of areas that needed to be sampled during the Remedial Investigation more of a challenging task.  (Buck, 2001)

 

Contaminate Removal History

In 1976 Congress enacted the Toxic Substance Control Act (TSCA) which was a legislative attempt to prevent toxic substance exposure by limiting its production and use.  This act gave EPA authority to evaluate individual substances manufactured and used in the US that presented a toxicity risk to human health and the environment.  In 1979, through the TSCA authority the EPA banned the manufacture of PCB’s in the US.  (EPA, History Index)

 

A series of removal and investigative activities have taken place on this site over the past two decades.  The investigative activities began in 1980 when transformers that had contained PCB’s were identified by the Electrical Building on the upper camp.  Their condition indicated that they had leaked their contents or had their contents emptied out on the ground by the side and doorway of the building.  During the 1980 and 1983 summer field season the transformers and some of the PCB contaminated soil was transported off site.  From 1984 through 1986 the identified remaining hazardous substances, drums and debris were removed.  In 1988 and 1993 a preliminary assessment was performed and in 1994 a Preliminary Assessment and Site Inspection (PA/SI) was completed.  It was not until 1999 that the UASF completed the Remedial Investigation (RI) and Risk Assessment (RA).  The RA was used to identify what exposure risk and the toxicity of the remaining site contaminates presented to humans and ecological receptors.  (UASF, 2000)

 

PCB’s are known for their chemical stability and fire residency. They were favored for use in electrical equipment, such as transformers, for their dielectric properties.  Due to these properties they had many different industrial applications in the US from 1927 through the late 1970’s. Unfortunately the same chemical stability that made them sought after for industrial use also created problems in when they were released to the environment.  Their persistency allowed them to remain in the environment as a source for exposure to human and ecological receptors for many years. (Fiedler, PCB)

 

Remedial Investigation

After the identification of areas that are possibly contaminated in the PA/SI.  A sampling plan was designed which utilized both field screening and sample removal for laboratory analysis of several different on site media.  The soil in areas that were suspected of containing contaminate were both field screened and sampled to not only identify the contaminate that is present but also the extent of its surface area and vertical penetration.  Containers such as drums and tanks that were left on site that had remaining unknown product were also sampled in an attempt to further define and characterize the potential site contaminates.  In addition, this sampling was a needed step prior to disposal of the liquids.  Nearby surface waters were sampled to verify that contamination was not leaving the site in the surface runoff.  (UASF, 2000)

 

When describing the site the PA/SI divided the area into the Upper Mountain, Mid Mountain and Lower Mountain.  Each had its own features and was physically separated.  The White Alice Array was on the Upper Mountain.  Mid Mountain contained the water cistern, Water Pump House, and Landfill.  And, the Lower Mountain has the Landing Strip with a road that connected all three areas.   PCB’s were discovered through field screening and laboratory analysis in all three areas.  The area of highest concentration was outside the Electrical Building on the Upper Mountain by the White Alice Array.  (UASF, 2000)

 

Most of the White Alice Communication Sites had a similar design.  A pattern of contamination has been found around the electrical buildings of other sites with such regularity that the site investigators are certain that the PCBs were poured out by the electricians rather than leaking or releasing. Interestingly the investigators feel that they can tell whether the shop workers were right or left handed by the spill pattern outside of the  door.  (Buck, 2001)

 

The sampling plan also included three background samples to be collected from areas on Granite Mountain near the Radio Relay Station but far enough away as to be considered not contaminated by activities that took place at the facility.  The purpose of these samples was to identify any potentially toxic or carcinogenic substance, and their abundance that maybe preexisting in the local soils.  This stage of sampling is an attempt to help the RP limit the potential liability, of being required by regulating agencies, to remediate substances that may have been onsite, either naturally occurring or by previous land user, prior to the activities taking place.  (UASF, 2000)

 

Public Involvement

At the initiation of the RI public meetings were held in both Koyo and Buckland, Alaska.  The meetings were held for several reasons:

1.      To satisfy ADEC guidance on the risk assessment process.  The ADEC guidance requires that public meetings be held at  two junctures in the decision process.  Following site discovery and again at site closure.  This guidance was followed during the 1994 RI but was not adopted by ADEC until 1999. (ADEC, 1999)

2.      To gain a better understanding of how this site is used by the public.  This will help the risk assessors establish an exposure level to site contaminates.

3.       To gain site history that maybe missing from the written record through discussion with the village elders.

4.      Give the residents an opportunity to express concerns that they have on the site, the proposed cleanup process and eventual closure.  (Buck, 2001)

 

There was no reported controversy at the public meetings but a better understanding of site use was gained.  It was learned that a hot springs was located about 1 mile from the site and was frequented by residence from both villages for recreation.  There was concern about the safety of this activity given the contamination at the site.  The UASF addressed this issue by evaluating the direction of ground water movement in that area.  Since the ground water does not move in that direction no water samples were taken. (Buck, 2001)

 

It was also learned that this area is used for subsistence hunting.  There did not appear to be concern from the residents for contaminate getting into the food supply or exposure to the hunters.  If there are remaining public concerns about either of these two issues it can be anticipated that they will be brought up, at site closure, with the second public meeting. (Buck, 2001)

 

The value of the public meeting was demonstrated when the people were able to describe the site use.  The risk assessors were then able to use this information in the RA to better define the exposure risk to the public.  

 

Safety of the hot springs water supply was not a concern of the residents until the public meeting was held.  This is an example of public meetings actually causing the concern.  Fortunately for all parties it can be addressed fairly simply. Yes and no.  Whether or not an issue is scientifically important, it can be important to people.  Therefore it is better to daylight these concerns before the risk assessment, rather than have them come up later.

 

 

 

Risk Assessment

Using the information from the RI, a RA was performed to better understand the potential exposures and effects of all the chemicals identified on site that were deemed to be a concern to human health or ecological sources.  During the RA it was determined that 10 separate chemicals were present on site that were ranked: A, B1 or, B2 by the United States Environmental Protection Agency (EPA) Weight –of –Evidence Carcinogenic Classification System.  It was later determined that the Aroclor 1260, a polychlorinated biphenyl (PCB) presented the single largest carcinogenic risk due to exposure and toxicity.  PCB’s are listed as B2 under this system, a probable human carcinogen.  (UASF, 2000) (EPA, 2000)

 

The risk assessors for the UASF used toxicity information on PCB’s that is available from the Integrated Risk Information System (IRIS) database through the EPA Environmental Criteria and Assessment Office in Cincinnati, Ohio. Several other sources were utilized for chemicals of concern that were not fully described by IRIS, such as the Health Effects Assessment Summary Tables (HEAST), provided by the EPA Office of Solid Waste and Emergency, and a memo from J. Dollarhide, Environmental Criteria and Assessments Office, to Carol Sweeney, Region 10 EPA, January 5, 1995. (UASF, 2000) Which means??

 

The process of hazard characterization separated the chemicals of concern that were found on site into the two broad categories of those that presented a carcinogenic risk and those that were thought to be noncarcinogenic.  In order to quantify the carcinogenic risk that the exposure to any one of these chemicals presented the risk assessors used the following formula: Risk = 1-exp^(-cdi x sf).  Where:

Risk  = Excess lifetime cancer risk (unitless probability)

CDI = Chronic daily intake average over a lifetime (mg/kg-day)

SF = Cancer Slope Factor (mg/kg-day)

The total carcinogenic risk from exposure to the multiple chemicals found on site from a single exposure source was estimated by using a summation formula. (UASF, 2000)

 

The risk assessors summarized their risk findings in the three areas of the Granite Mountain RRS as follows:

Summary of Risk Estimates for Upper Mountain

 

(UASF, 2000)

 

Cleanup levels

Federal cleanup levels for PCB’s are based upon 4 general categories of contaminated media: bulk PCB remediation waste, non-porous surfaces, porous surfaces and liquids.  Bulk PCB remediation waste has two sub categories, based upon low or high occupancy of the site.  Under the low occupancy sub category, CFR Title 40 Section 761.61(4)(B), the PCB contamination at Granite Mountain RRS  would need to be cleaned up to less than or equal to 25 mg/kg.   The high occupancy cleanup standard, CFR Title 40 Section 761.61(4)(A), is less than or equal to 1 mg/kg.  This subsection gives the RP the alternative standard of less than or equal to 10 mg/kg if they cap the site. (Stephens, 2000) 

 

State of Alaska  Regulation 18 AAC 75.340 table B1 gives several cleanup levels for  PCB contaminated soil depending on location: 

1.      Contaminated surface soil in an area deemed to be residential 1 mg/kg.

2.      Contaminated subsurface soil in an area deemed to be residential 10 mg/kg.

3.      Contaminated surface soil in an area deemed to be industrial 10 mg/kg.

4.      Contaminated subsurface soil in an area deemed to be industrial 25 mg/kg.

(State of Alaska Department of Environamental Conservation, 1999)

 

At the writing of this paper there still exists a difference of opinion concerning site use classification.  UASF has proposed the industrial standard for use at this site.  The State of Alaska Department of Environmental Conservation (ADEC) feels that a residential classification better describes site use since it is open to the public and not used for industrial purposes at the present time or planned for the future.  Also, the public does use the site for recreational and subsistence use.  The limited access, past use and lack of  year long residence in the immediate area have been listed as reasons by the USAF that industrial classification would be an appropriate listing. (Buck, 2000)

 

The UASF does not mention Federal cleanup levels in the RA.  It is evident that a standard does exist but they are applying Alaska State Regulations only in this document.  Both state and federal laws must be observed during a cleanup. If the Federal standard for low occupancy is an appropriate standard then the ADEC would provide an equal or more conservative standard to be met by the UASF.   Hence, it would be appropriate for the USAF to work with the ADEC for site cleanup and closure.  However, the ADEC would not have authority in this matter if their applied standards exceeded the federal standards and the federal standards were required to be observed. 

 

 

 

 

Conclusions and Recommendations

The PCB contamination was found primary around two areas of an electrical equipment building.  Since PCBs were used in electrical transformers during the operation of this facility.  And, disposal practices were ill defined, often resulting in dumping of the material on the ground nearby.  A logical conclusion can be reached as to how the PCBs were used and how they got to where they were found.

 

The sample analysis showed that the site had a general area of contamination that averaged somewhat higher than the ADEC cleanup standard with a smaller more heavily contaminated zone that reported 1100 mg/kg PCB.  In response to these findings the recommendations were to excavate the contaminated soil until the remaining PCB’s were below the ADEC cleanup standard.  They estimate that this will require the removal of 84 yards of soil. (UASF, 2000)

 

Through the RI and RA process the UASF had the opportunity to apply alternative cleanup levels found in method 3 and method 4 in 18 AAC 75.340 that would have created a site specific cleanup level based upon the specific site characteristics.  This request was not made. A soil removal could have been made following the RI saving the USAF the time and cost of the RA.  The final documentation required by ADEC prior to initiating the cleanup process has been submitted and is waiting for approval.   (Buck, 2001)

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

References:

Alaska Department of Environmental Conservation (ADEC), (1999) Guidance on Decision Documentation Under the Site Cleanup Rules (18 AAC 75.325 – 18 AAC 75.390)

 

Buck, Patrice, May 2001 personal communication.

 

Lenard, Cameron, November 2000 personal communication.

 

Fiedler, Heidi.  Poly Chlorinated Biphenyls (PCB): Uses and Releases. http://www.chem.unep.ch/pops/POPs_Inc/proceedings/abu-dhabi/FIEDLER1.html

 

State of Alaska, Department of Environmental Conservation.  (1999).  Oil and Hazardous Substance Pollution Control Regulations.

 

State of Alaska, (1996). Selected Oil and Hazardous Substance Pollution Control Stautes and Regulations. Section 46.03.822

 

Stephens, Tamar,  (2000).  PCB Regulations, Guidances, and Related Information. PCB Cleanup Levels.  (unpublished).

 

 

United States Air Force (UASF). (2000). Granite Moutain Radio Relay Station Remedial Investigation Report. (unpublished).

 

 

 

United States Environmental Protection Agency (EPA)  (2000).  Integrated Risk Information System. List of Substances on IRIS. http://www.epa.gov/ngispgm3/iris/index.html

 

United States Environmental Protection Agency (EPA).  History Index.  Train Sees New Toxic Substance Law as “Preventative Medicine”. http://www.epa.gov/history/topics/tsca/03.htm