Apr 7, 2017

'Unknown Black Substance' Stops Excavation Behind Retaining Wall

Five years after the house at 4825 Glenbrook Rd. NW, was removed, in the Spring Valley neighborhood, the U.S. Army Corps of Engineers tells WTOP the final stages of the cleanup of toxic munitions is in the midst of a brief pause, after crews found an unknown black substance mixed with soil on the property.  “We don’t know what it is, but it has low levels of mustard,” said Chris Gardner, spokesman with the Corps’ Baltimore District.  In functioning weapons, mustard gas can cause large blisters on skin and in lungs.  After the April discovery of the substance, the Army Corps, Environmental Protection Agency and [DC's] Department of Energy & Environment performed additional soil sampling, and decided to pause the cleanup, to factor-in plans for handling the soil.
The project partners determined the low risk of the soil did not require enlarging the fenced-in safety zone ... The Spring Valley project began in 1993, when a contractor unearthed buried military ordinance on nearby 52nd Court NW. During World War I the U.S. government researched and tested chemical agents, equipment, and munitions at the American University Experiment Station Since 2000, more than 500 munition items, 400 pounds of laboratory glassware, and 100 tons of contaminated soil have been removed from the site, according to the Corps ... Gardner said the project will likely resume by the end of May or beginning of June. 
Neal Augenstein

During our efforts [along the shared property line between 4825 and 4835 Glenbrook Road] we encountered small amounts of broken glassware and an unknown solid black substance in the soil.  Samples of the solid black substance recovered this week are being sent for analysis.  The first small sample of this substance was recovered and taken for analysis toward the end of February, and the results returned this week showed a small amount of mustard and agent breakdown products within the substance.  Our air monitors did not detect any chemicals present in the air during excavation operations associated with the unknown black solid ... We will continue to follow all safety protocol as we continue to hand dig and sift through the soil behind the retaining wall.
Glenbrook Road Update
On Wednesday, during low probability operations along the shared property, the crew encountered additional amounts of the unknown black substance mixed with the soil behind the retaining wall.  The area was quickly mitigated by covering it with plastic sheeting and a layer of soil.  The team decided to perform additional sampling of the soils and materials behind the former curved retaining wall area along the shared property line.  We had a small crew come in this morning to take soil samples adjacent to the unknown black substance, plus additional samples of the unknown substance.  As safety is our priority, we have decided to shift our area of operations within the site.  We plan to resume our efforts in the backyard area of the property while awaiting the sampling results. 
Glenbrook Road Update
April 7, 2017

Mar 18, 2017

Pilot Project Evaluated Three Different Geophysical Instruments

In November, our team completed the Pilot Project at three selected residential properties.  The collected data is currently being used to evaluate the suitability of using two newly developed “Advanced Classification” geophysical instruments [the Time domain Electromagnetic Multi-sensor Towed Array Detection System (TEMTADS) and Man Portable Vector (MPV)] within the Spring Valley residential area to detect and correctly identify buried munitions and explosives of concern related items during upcoming cleanup activities outlined in Site-Wide Decision Document being finalized ... For the purposes of the Pilot Project, all detected anomalies were intrusively investigated (dug up and removed from the ground).  About 200 anomalies on average were removed from each property.  The purpose of this effort was to verify if the new instruments were characterizing the anomalies correctly.  The majority of the items were innocuous non-military related cultural debris, such as nails, wire, bottle caps, and wire baskets.  Four pieces of munitions debris were also removed from the site: three fragments of munitions debris and one three inch Stokes mortar, which was determined to be an unfused practice round and did not contain any explosive or chemicals.  The TEMTADS and MPV both identified the Stokes mortar correctly.
Spring Valley USACE
The Corps'pondent
February 2017 (pg. 2)
[Project Manager Dan] Noble added that what is also interesting about the new technology is that it is the same technology as the EM-61 instrument that missed the target in previous investigations ... because the target was too close to the house.  These new instruments, because they are very focused on the ground immediately underneath the instruments, have very good resolution for what is directly underneath them.  The new instruments were able to clearly see that there was an anomalous area using the exact same EM (electromagnetic) technology that formerly was blind in the same area ... The previous instrument was the size of a lawnmower and recorded GPS coordinates of targets for later review.  The new technique includes the same dynamic scan, and when a target is located the team will go back and perform a cued investigation.  The cued investigation is the second part of the survey in which the instrument is parked directly over the target for approximately 30 to 60 seconds.  A tremendous amount of data calculations are created concerning decay constants of the target.  This allows the precision of location and identification of the target, leading to a better excavation decision.
Restoration Advisory Board
Meeting Minutes
January 10, 2017 (pg. 6)

The summary of the Pilot Project results did confirm that Advanced Geophysical Classification (AGC) is more effective at munitions detection than the current conventional EM-61 digital geophysical mapping methods used, but that there were some challenges.  It was also concluded that AGC should be used with the G-858 magnetometer in order to detect large items at deeper depths.  The report concluded that TEMTADS and the MPV each have their own advantages and disadvantages, but that either instrument could be efficiently used for the full scale munitions remediation throughout Spring Valley.  The AGC method would provide the highest level of confidence in the geophysical surveys.  USACE expects the AGC method will provide less anomaly investigation throughout the remedial action for the Spring Valley FUDS.
Spring Valley FUDS Partners
Meeting Minutes
February 9, 2017 (pg. 4)

Mar 1, 2017

Novel Strategy to Deal with Toxic Contamination: Do Nothing

At toxic cleanup sites across the country, environmental agencies have allowed groundwater contamination to go untreated and slowly diminish over time — a strategy that saves money for polluters but could cost taxpayers dearly and jeopardize drinking water supplies.  The strategy is called monitored natural attenuation, or MNA ... It basically means keeping a watchful eye while natural processes purge groundwater of chemical pollution.  According to Environmental Protection Agency guidelines, it’s an acceptable approach under some circumstances.  That includes when contaminants are expected to degrade in years rather than centuries, and where there is no risk of polluted water seeping into, and spoiling, fresh water supplies ... 
Some advocates and experts say MNA sometimes has been approved in violation of EPA guidelines.  Because it is usually much simpler and cheaper than active cleanup methods — such as pumping water out of the ground and treating it — they say that MNA is being aggressively pushed by polluters at many contaminated sites, often with too little pushback from regulator ... According to data from the EPA, MNA is in use at 85 of 141 U.S. military sites that are classified as Superfund sites ... A separate assessment shows that in 2011, the most recent year tracked, 31 percent of EPA groundwater cleanup decisions involved some use of MNA ... Why can’t the EPA and state environmental regulators simply demand an active cleanup when they think MNA is the wrong choice? 
 
It largely comes down to money.  The cleanup of Defense and Energy department sites depends on Congressional appropriations, and the amount of available funding is limited ...  Officials at an array of agencies, however, struggled to figure out how to regulate MNA, prompting the Environmental Protection Agency to issue an MNA directive in 1999.  That directive, and the EPA's updated guidelines, state that MNA shouldn’t be applied when, among other things, the source of pollutants isn’t yet under control, when the tainted groundwater is still spreading and when the contaminants won’t break down to safe levels within a “reasonable” period.   
Dan Ross
Fair Warning
February 28, 2017

Feb 13, 2017

Southern California Pioneers Microbe Perchlorate Treatment

RIALTO -- A defense industry contractor has agreed to pay $700,000 or more annually for the operations and maintenance costs of a perchlorate removal system which uses microbes to break down the harmful chemical.  West Valley Water District made environmental cleanup history late last year by shipping water directly to customers from a $23 million specialized treatment plant at its headquarters.  The agreement with Goodrich Corp. authorizes funding for 100 percent of operations and maintenance costs for up to $700,000 annually for the first year and no cap for subsequent years in the life of the project, West Valley said in a statement.  Negotiations have been going on since 2014.  The talks were the result of a judicial consent decree which requires Goodrich, under the EPA’s oversight, to fund clean-up facilities, said Matthew H. Litchfield, WVWD general manager.  Perchlorate has polluted portions of the Rialto-Colton water basin, the result of past military, industrial and agricultural activities above it ... 
Following the discovery of perchlorate in portions of the Rialto-Colton groundwater basin in 1997, WVWD and the city of Rialto shut down wells in the impacted area.  Following years of testing and review by regulatory agencies, WVWD began, in September 2016, using bio-remediation to remove perchlorate and restore water for potable use.  The plant has the capacity to provide the water needs for about 16,000 of West Valley’s 66,000 customers.  WVWD has begun working on perchlorate destroying plant number two, called a fixed-bed biotreatment plant, which takes a slightly different approach to treatment with the same naturally occurring microbes.  The second plant is expected to deliver water sometime in 2019, Litchfield said.  The operational costs of this second treatment technology will also be paid for by Goodrich, he said.
Jim Steinberg  
San Bernardino County Sun
February 13, 2017

Jan 20, 2017

Partners Signal Preference for Groundwater Remediation

Currently the [Spring Valley FUDS] Groundwater Remedial Investigation is in the preliminary draft and internal Baltimore District review phase of the Feasibility Study (FS).  USACE plans to submit the draft FS to USACE Environmental and Munitions Center of Expertise (EM/CX) for review before the holidays.  Response to CX comments and revising the document will likely take a month or two before the draft final FS can be submitted it to the Partners.  The draft final should be completed by April 2017.  At that time, USACE will submit the draft final to the Partners.  USACE has been following EPA guidance for evaluation of the various alternatives. 
After screening all alternatives, the selected alternatives are as follows: no action alternative, land use control and long term monitoring alternative, in-situ alternative, and a pump-and-treat alternative.  The details will be in the Groundwater FS.  EPA noted that the regulators do not prefer the land use controls with monitoring alternative because of the monitoring aspect.  If there is something unacceptable in the groundwater, the regulators prefer to have a plan for that to be remediated over time.  USACE understands that the Partners’ position is the main issue with the Groundwater RI.  USACE will receive those comments when the Groundwater FS is submitted for Partner review.
Spring Valley FUDS 
Partnering Meeting Minutes
December 6, 2016 (pgs. 2 - 3)

Dec 27, 2016

EPA Agrees to Promulgate Perchlorate Regs by 2019

US EPA recently agreed in federal court to engage in a rulemaking process over the next three-plus years which would culminate in the promulgation of final perchlorate regulations by December 19, 2019. Perchlorate remains the only unregulated contaminant for which EPA has made a final determination to regulate since the Safe Drinking Water Act (SDWA) was amended in 1996. Perchlorate is a highly soluble chemical in water and can move quickly from soil contamination into groundwater. It has been used by the US Department of Defense as an oxidizer in munitions and missiles since the 1940s, and 90 percent of its manufacturing is for the defense and aerospace industries. In a February 2011 declaration, EPA determined that it should regulate perchlorate in drinking water — giving itself 24 months from that date to propose regulations and another 18 months thereafter to finalize them under the SDWA. However, due in part to the Scientific Advisory Board’s rejection of the model EPA submitted for perchlorate regulation, these self-imposed deadlines were missed. As a result of the delay, the Natural Resources Defense Council (NRDC) filed a complaint in the US District Court for the Southern District of New York against EPA in February 2016 to enforce the deadline for proposed perchlorate regulations for public comment. 
In the NRDC case, the Agency acknowledged that it failed its legal obligations to propose and promulgate a maximum contaminant level (MCL) and maximum contaminant level goal (MCLG) as a national primary drinking water standard for perchlorate ... Under the proposed agreement, EPA will: complete an “external peer review process” by October 18, 2017; propose limits by October 31, 2018; and finalize a rule by December 19, 2019. Given the amount of delay that has already occurred in promulgating federal regulations, it is somewhat surprising that NRDC accepted the length of the proposed schedule ... It is noteworthy that, in likely response to national attention paid to the Flint Michigan crisis, two US House of Representatives resolutions (H.R. 6116 and H.R. 6140 ) were introduced on September 22, 2016 that, if passed, would require the EPA Administrator to publish an MCLG and promulgate a national primary drinking water regulation for perchlorate no later than 12 months following the law’s date of enactment. This proposed legislation amending the federal SDWA has the potential to expedite the rulemaking process outlined in the settlement agreement reached between EPA and NRDC.
Jonathan S. King
National Law Review
December 26, 2016

Oct 7, 2016

Army Recommends "Feasibility Study" to Remediate Groundwater

During World War I, the U.S. Government established the American University Experiment Station (AUES) to investigate the testing, production, and effects of noxious gases, antidotes, and protective masks.  The AUES, located on the current grounds of AU, used additional property in the vicinity to conduct this research and develop chemical warfare materiel (CWM), including mustard (HD) and lewisite (L) agents, as well as adamsite, irritants, and smokes.  After the war, these activities were transferred to other locations and the AUES property was returned to the owners ...
Early in the SVFUDS groundwater study, much of the SVFUDS groundwater was noted to flow westward toward the natural valley currently occupied by the Dalecarlia Reservoir.  The reservoir water elevation (typically about 150 feet mean sea level (ft msl) was also noted to be similar to the water table elevation along the eastern reservoir shoreline, indicating the potential for groundwater seepage into the reservoir along the eastern reservoir boundary ... The maximum arsenic and perchlorate concentrations ever measured in groundwater proximate to the eastern reservoir shoreline are orders of magnitude less than the threshold concentration (3,906 part per billion) that would increase the reservoir concentration by 1 ppb.  Thus, the reservoir water quality is not threatened by possible groundwater seepage into the reservoir ...
Chemical releases from historical AUES activities have impacted groundwater and surface water proximate to the Lot 18 Debris Area and Glenbrook Road Disposal Areas.  The impacts are due to arsenic and perchlorate in groundwater ... The perchlorate detected in groundwater along Glenbrook Road and in East Creek could partially, or in total, originate from the nearby upgradient area proximate to AU’s Kreeger Hall where perchlorate-impacted shallow and deep groundwater has been confirmed.  The source of the groundwater perchlorate contamination on AU near Kreeger Hall, originally evidenced by groundwater perchlorate monitoring data for several locations (PZ-4S, PZ-4D, and PZ-5) is not known precisely ...
For the future scenarios, the arsenic cancer risk is 1E-04, and the perchlorate non-cancer target organ-specific HI [Hazard Index] exceeds the non-cancer threshold of 1.  Arsenic and perchlorate are groundwater EU2 [Exposure Unit 2] chemicals of concern.  Actions to control exposure to arsenic and perchlorate in groundwater EU2 would warrant consideration, if groundwater is to be used for potable water ... Chemical releases from historical AUES activities have impacted groundwater and surface water proximate to the Lot 18 Debris Area and Glenbrook Road Disposal Areas.  The impacts are due to arsenic and perchlorate in groundwater ... A Feasibility Study is recommended to determine the best alternative to remediate the groundwater risk to future residential users.
Spring Valley FUDS
Groundwater Remedial Investigation Report
September 2016
 
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