Long Postponed Investigation of POI 2 Comes Up Empty-Handed

In January1993, the first discovery of munitions in Spring Valley was made on 52 Court, NW, when a backhoe operator excavated part of the disposal pit, exposing munitions items.  At that location, there were circular trenches that were used for munitions testing during the World War I era ... When USACE began investigating and reestablishing the history of the American University Experiment Station (AUES), USACE noticed a very similar set of trenches existing on Sedgwick. The Sedgwick Trenches became "Point of Interest" (POI) 1 in the site conceptual model of what needed to be further investigated in Spring Valley. POI 2, 3, and 4 were areas immediately adjacent to Sedgwick Trench, where aerial photography suggested the existence of disposal features. During the remedial investigation, USACE was able to investigate POI 3 and 4, but not POI 2. After 2012, USACE reestablished communication with the property owner at 3700 Block of Fordham Road, where property POI 2 is located. USACE was able to gain access to the property to intrusively investigate POI 2 within the last few weeks. 

1986 EPIC Photo Analysis, Vol. II (fig. 2)

In 2003, two geophysical surveys were conducted at this property; an Electromagnetic (EM) survey and a Magnetic (MAG) survey. The EM survey showed two clusters of single point anomalies in the front yard. A "possible pit" feature was seen on the MAG survey, but not on the EM survey. Although there may be some error in the aerial photograph from 1918, the location of the "possible pit" feature shown in the MAG survey very closely matches the location of a "possible pit" ground scar on the 1918 map, causing this area to be of more interest to the Army Corps ... The MAG survey can be more sensitive, and can scan deeper into the ground. Anomalies do not show up on an EM survey if they are buried very deep. So there might be a disposal pit full of World War I bombs made out of metal, which could be an explanation as to why the anomalies show up in the MAG Survey but not in the EM survey ... 

Red arrow points to POI 2 (possible burial pit in backyard).

USACE went back to the property in March. The large anomaly was intrusively investigated in two locations ... Once these holes were excavated to four feet, the geophysical instruments were inserted into the holes. The instruments did not detect a signal at the bottom of either hole. When the instruments were brought up the side of the hole near the surface, the signal returned. The conclusion is that something about the soil structure in this area causes a magnetic signature. The signal happens near surface, in the first foot or two. However, there were no more magnetic signals at the bottom of the holes. USACE [now] believes that this large anomalous area, which was designated as POI 2, is due to what is referred to as “hot soil” or “hot rocks,” not buried metal.

Dan Noble, Project Manager

Spring Valley FUDS
RAB Meeting Minutes
March 8, 2016 (pgs. 6 - 8)

RAB Meeting PowerPoint (March 8, 2016, pg. 13)

Corps Releases Feasibility Study Analyzing Cleanup Alternatives

Feasibility Study report summary fact sheet

The U.S. Army Corps of Engineers, Baltimore District has released the final Feasibility Study [FS] report, stemming from the previously completed Site-Wide Remedial Investigation for the Spring Valley Formerly Used Defense Site [FUDS] ... The purpose of the FS is to develop, screen, and provide a detailed analysis of remedial alternatives to mitigate: 1) unacceptable risks posed by soil contamination resulting from chemicals of concern, and 2) potential unacceptable explosive hazards due to munitions & explosives of concern that may remain within the SV FUDS ... Based on the detailed analysis of contaminated soil remedial alternatives in the Feasibility Study, Alternative 4, “Excavation and Off-site Disposal,” is the most favorable remedial alternative to achieve the Remedial Action Objectives [RAOs] ...

 Spring Valley FUDS Feasibility Study (pg. ix)

Based on the detailed analysis of remaining explosive hazards remedial alternatives for the areas of focus, Alternative 6, “Digital Geophysical Mapping of Accessible Areas, Remove Selected Anomalies,” is the most favorable remedial alternative to achieve the RAOs, but final selection of a preferred alternative will be proposed and documented in the forthcoming Proposed Plan ... The next step in the CERCLA process now that the FS has been finalized will be for USACE to compose a draft final Proposed Plan ... A formal public comment period will be held to allow the community an opportunity to review and comment on the Proposed Plan before it is finalized.
Announcement
Spring Valley FUDS
U.S. Army Corps of Engineers
January 2016

NRDC Sues EPA to Force It to Limit Perchlorate in Drinking Water

The Natural Resources Defense Council sued the Environmental Protection Agency in federal court in New York today to force it to set limits on perchlorate.  Perchlorate is a toxic chemical that has been detected in the drinking water systems that serve up to 16.6 million Americans.  Even at low levels, it can present serious health risks to children and pregnant women ... Perchlorate has been widely used by the military and defense industries.  It is commonly used in rocket fuel, fireworks and explosives.  It is highly soluble in water, and can move quickly into ground and surface water when it contaminates soil.  Five years ago — on February 11, 2011 — after reviewing 39,000 comments, the EPA acknowledged its duty to regulate perchlorate under the Safe Water Drinking Act ... That finding by EPA triggered two deadlines under the Safe Drinking Water Act:  EPA had 2 years to propose safeguards, and another 18 months to finalize them.  EPA has missed both deadlines.
Press Release
NRDC
February 18, 2016

NRDC v. EPA Complaint

Once EPA has determined to regulate a new chemical under the Act, it must issue a proposed regulation for that chemical “not later” than twenty-four months after making the determination to regulate, and must issue a final regulation within eighteen months thereafter ...  EPA had a mandatory duty to propose perchlorate regulations no later than February 11, 2013, and a mandatory duty to finalize those regulations no later than August 11, 2014.  EPA has neither proposed nor finalized any limits on perchlorate in drinking water.  These failures violate express statutory deadlines contained in the Safe Drinking Water Act and jeopardize human health.  NRDC therefore seeks declaratory and injunctive relief against EPA for failure to fulfill the agency’s nondiscretionary duties under the Act ...

Request for Relief (pg. 12) 

Perchlorate contamination in drinking water systems poses a threat to human health.  When ingested, perchlorate impairs the uptake of iodine into the thyroid gland, which disrupts thyroid hormone production.  Thyroid hormone is critical to many aspects of growth and metabolism.  Its role in brain development during pre-natal and post-natal growth is especially vital.  As a result, fetuses, infants, and young children are particularly vulnerable to perchlorate ingestion.  Scientific studies have linked decreased thyroid function in pregnant women, infants, and children to delayed development, reduced growth, and impaired learning capabilities.  Even small reductions in thyroid hormone levels can be associated with abnormal brain development and lower cognitive function in children.
NRDC v. EPA
U.S. District Court
February 18, 2016

Army Conducts Shelter-in-Place Alert System Test on Wednesday

The U.S. Army Corps of Engineers will soon be testing its “shelter-in-place” alert system before starting work to dig up the third and final portion of 4825 Glenbrook Road NW, where the Army anticipates a “high probability” of finding dangerous World War I-era chemical contamination.  During the war the Army operated a munitions testing station at American University, and buried leftover materials in the surrounding area.  Most of the contamination has been cleaned up in recent years for $250 million.  At 4825 Glenbrook in Spring Valley, where the Army tore down a house to conduct its investigation, workers are operating under a protective tent due to the level of contamination expected there ... 

As before, if toxic fumes escape from the tent, an alert system will contact neighbors asking them to shelter in place until further notice.  Re-training about the shelter-in-place program will be available for residents of seven nearby homes and users of American University’s Watkins Building ...  Excavation of the riskiest areas at 4825 Glenbrook is expected to last through late 2016 or early 2017, followed by investigation of “low-probability” spots where the Army doesn’t expect to find contamination.   The property will then be restored to residential standards in spring and summer 2017.
Northwest Current
January 27, 2016
 

Three CAFS units (left) were activated on February 3 (USACE)

This week concluded with all snow at the site either removed or melted, and any storm damage repairs completed. The on-site team continues with preparing the site for high probability operations to begin in about 2 weeks, sometime during the week of February 15th. The Chemical Agent Filtration System (CAFS) units, with all new filters, were activated on Wednesday so that they will be ready to perform for next week's smoke test ... Next week we will begin several days of refresher training, conduct the smoke test, and complete the installation and testing of the Shelter-in-Place system sirens.  We will be briefly testing the Shelter-in-Place sirens on Monday, Feb 8th throughout the day.  We will then perform a complete Shelter-in-Place alert system test, including the ring-down and email alerts, on Wednesday, Feb 10th at 4:05pm.
Weekly Update
4825 Glenbrook Road
February 5, 2016

Shelter-in-Place zone during Tent 3 work (pg. 41)

Site-Wide Feasibility Study Favors 'Alternative 6' to Clear Munitions

Unacceptable chemical risks in soil from AUES activities

The draft-final Feasibility Study (FS) was sent to our regulatory partners (EPA and DDOE) and Dr. Peter deFur, our independent Technical Assistance for Public Participation Program (TAPP) consultant for review ... The purpose of the FS is to develop, screen, and evaluate alternatives to achieve possible remedial action objectives addressing any unacceptable human health risks in or potential unacceptable explosive hazards identified in the Final Remedial Investigation Report ... As a reminder, the locations, referred to as exposure units (EU), where unacceptable human health risks in soil were identified are the Spaulding Captain Rankin Area (SCRA), and Southern American University (AU).  The areas associated with unacceptable explosive hazards include impact areas, static test fire areas and possible munition disposal pits.  The areas cover about 100 properties in the neighborhood.

Areas with unacceptable explosive hazards

The below chart (Table 5.2 from the draft Site-Wide Feasibility Study) shows the remediation alternatives that were analyzed against the EPA’s nine screening criterion established to address CERCLA requirements and technical and policy considerations ... Alternative 6 was determined to be the most favorable alternative to achieve the Remedial Action Objectives (RAOs).  It is protective of human health and the environment, is compliant with "applicable or relevant and appropriate requirements" and will meet the RAOs in the shortest amount of time.  However, the formal selection of the preferred alternative will be proposed and documented in the Proposed Plan, and subject to acceptance from our regulatory partners and the community.
The Corps'pondent
January 2016 (pg. 3)

Chemical Cleanup on Glenbrook Road will Resume in February

The U.S. Army Corps of Engineers plans to resume removing  World War I-era debris from Spring Valley in February, upon moving a protective tent at 4825 Glenbrook Road NW to its third and final location.  The tent will be moved at the Glenbrook site above the former basement of the home that once stood there.  The Army previously demolished that home after the site was found to be contaminated by the munitions testing station formerly located on the land of present-day American University.  The Army has suspended its “shelter in place” emergency response program until the tent is moved, but the program will be tested about 30 days before the work resumes.
Northwest Current

December 23, 2015 (pg. 2) 

Efforts in early December focused on preparing the site and relocating support equipment, as we incrementally arrange the tent at its third and final location ... In mid-December, the crews leveled the driveway and placed the first section of the tent into its final position.  Additionally, crews constructed a pad area where the medical monitoring tent, one of the site's multiple layers of safety protocols, was placed behind Tent 3.  In January, the team will resume using the crane to move the final two sections of the tent into their final locations so the entire Engineering Control Structure (ECS) can be reassembled ... We will notify everyone prior to reinstating the Shelter-in-Place program, and will share further details when we have a firm date for the start of that next phase of high probability operations.

Spring Valley FUDS

Monthly Project Update

December 2015

Third tent move at 4825 Glenbrook Road

Corps Pursues "PRP" Investigation to Recoup Added Cleanup Costs

Brenda Barber, Spring Valley Project Manager: USACE is conducting an investigation regarding the post-AUES development of three properties within the Spring Valley FUDS, focusing on 4825 Glenbrook Road, 4835 Glenbrook Road, and the Public Safety Building at 4400 Massachusetts Avenue on AU’s campus.  The purpose is to identify additional potentially responsible parties (PRP) for the presence and/or extent of contamination at these sites ... Anyone who has information about this matter is encouraged to contact USACE’s PRP investigation contractor: Watermark, Inc.  Contact information and brief details can be left on the contractor’s toll free phone number (866-383-7327) and James Carney will return the call to conduct a comprehensive interview.

 

  PRP targets Glenbrook Road & Public Safety bldgs.

Linda Argo, AU Representative clarified that, to her knowledge, AU does not know which fraternity constructed the Public Safety Building ...

The ultimate purpose of the PRP search is to determine whether any of the property developers and/or their subcontractors possessed any knowledge of the contamination at the site, and whether they exacerbated the extent of contamination during their activities, thus requiring the USACE to conduct larger remedial efforts than would have been necessary had the contamination remained undisturbed ... If the developer is identified as a PRP, then USACE may be able to recoup some of the remediation costs from the developer ...

Dan Noble, Spring Valley Project Manager explained that the Spring Valley FUDS cleanup is governed by the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA), which includes a liability framework for determining a wide range of parties that are potentially liable for site contamination.  The USACE is a PRP for the Spring Valley FUDS and has spent significant time and funding on site cleanup.  D. Noble further explained that as soon as USACE has spent cleanup funding at the site, they are permitted to pursue other PRPs for the purpose of sharing cleanup costs.
Spring Valley FUDS 
RAB Meeting Minutes
January 8, 2013 (pgs. 12 - 14)

Army unearthed this 75mm shell under PSB

The Army Corps of Engineers unearthed more munitions debris next to the Public Safety building during this winter break.  On Jan. 4, workers found a single 75mm round buried four feet underneath a concrete slab that they had removed in front of the building’s lower entrance ... Although heavily corroded and empty, the projectile was still largely intact ... Kent Slowinski, a community activist and former Restoration Advisory Board member, said recent work conducted by the Army Corps indicates a likelihood that the debris field around the Public Safety building extends underneath the building, because debris from the AU Experimental Station has been found behind and in front of it.
Christopher Cottrell
The Eagle
January 21, 2010

 Shell found beneath slab 4 ft. under lower entrance