The following sections of the EE/CA are PDF documents

This Final Chemical Spill-8 Coast Guard Abandoned Radio Cabinet Area Engineering Evaluation/Cost Analysis (EE/CA) supports a non-time-critical removal action at the Chemical Spill-8 Coast Guard (CS-8 CG) radio cabinet area. The Air Force Center for Environmental Excellence (AFCEE) and the regulatory agencies previously agreed that AFCEE would prepare an EE/CA for excavation and disposal of contaminated soil at this location.

The site investigation data indicate that the concentrations of polychlorinated biphenyls (PCBs) (arochlor 1254) and two metals, cadmium and manganese, found in soils underlying the radio cabinet, present an unacceptable risk to human health and ecological receptors. The soil sampling results indicate that the contamination is likely to be limited in extent and confined to the immediate area of the radio cabinet. The volume of contaminated soils is estimated to be from 20 to 80 cubic yards.

Removal action objectives (RAOs) were developed to identify response actions that are necessary to adequately address human health and ecological risks. AFCEE anticipates that this removal action will be the final action to remediate the CS-8 CG site. The RAOs developed for the site are as follows:

•Provide for the removal of contaminants from the site soils, such that unacceptable risks to human and ecological receptors are eliminated.

•Restore the site by means of backfilling the excavation with clean fill and re-grading any significant ruts. Due to the anticipated small size of the excavation and its wooded location, it is assumed that top dressing with native loam and re-seeding will not be necessary.

The contaminants to be addressed and associated action levels are: PCBs (aroclor 1254) at 1.0 milligrams per kilogram (mg/kg), cadmium at 1.8 mg/kg, and manganese at 274 mg/kg.

Based on the analysis of the nature and extent of contamination and on the removal action objectives, four alternatives were developed: no action (Alternative A), engineering controls (Alternative B), disposal at a chemical (i.e., hazardous waste) landfill (Alternative C) and soil incineration (Alternative D).

Each alternative was evaluated using the effectiveness, implementability, and cost criteria set forth in the National Contingency Plan and the U.S. Environmental Protection Agency guidance on conducting EE/CAs (EPA 1993). 

Alternative A - No Action does not meet the RAOs developed for this site and does not provide any reduction in risk to human and ecological receptors. There is no cost associated with implementing this alternative.

Alternative B – Engineering Controls, addresses protection of human health by limiting the potential for direct human contact with the soils. However, the alternative does not prevent the migration of PCB-contaminated surface soils to human receptors by means of wind transmission and subsequent human inhalation and/or ingestion of those soils. Although this alternative is not especially effective at preventing potential terrestrial wildlife exposure, the potential for such exposure is considered small given the small size of the site (approximately 140 square feet). Because the contaminated soils would remain on site, this alternative does not satisfy the statutory preference for treatment. Alternative B is the least expensive of the active-action alternatives.

Alternative C – Landfill, and Alternative D – Incineration, are similar in nature and both are protective of human health and the environment. Both also meet the RAOs developed for the site and comply with the ARARs. Only Alternative D satisfies the statutory preference for treatment, however achieving this level of compliance carries a significantly higher cost than the other Alternatives.

Alternative C (chemical landfill) is the recommended alternative for the CS-8 CG radio cabinet study area. This alternative can achieve the RAOs, would be ARAR compliant, is relatively simple to implement, and has a lower cost than soil incineration.