Technical Memorandum:
Camp Adair Areas of Potential Concern (AOPC) Status Update and Recommendations Report
Multiple Sites at the Former Camp Adair
City of Adair Village, Oregon
PREPARED BY
U.S. Army Corps of Engineers
Seattle District
April 2015
1. Introduction ...... 6 2. Site Activities and Investigations ...... 7 2.1. 1990 Boise-Cascade Preliminary Assessment III ...... 7 2.2. 1995 UST Decommissioning Report ...... 7 2.3. 2003 USEPA Targeted Brownfield Assessment ...... 8 2.4. 2007 Draft Preliminary Assessment Report ...... 8 2.5. 2012 Site Investigation ...... 9 2.6. 2014 Technical Memo: Background Desktop Exercise ...... 9 3. Evaluation of AOPCs ...... 10 3.1. AOPC 1 – Bomarc Missile Site ...... 10 3.2. AOPC 2 – Coal Storage Yard ...... 10 3.3. AOPC 3 – Camp Adair Sewage Treatment Plant ...... 10 3.4. AOPC 4 – Morgue ...... 10 3.5. AOPC 5 – SAGE Facility ...... 10 3.5.1. 5A ...... 11 3.5.2. 5B ...... 11 3.5.3. 5C ...... 15 3.5.4. 5D ...... 16 3.6. AOPC 6 – Salvage Yard ...... 18 3.7. AOPC 7 – Shops ...... 18 3.8. AOPC 8 – Vehicle Fueling Areas ...... 18 3.8.1. 8A1 to 8A7 Cantonment Vehicle Fueling Areas ...... 18 3.8.2. 8B1 to 8B2 Adair Village Fueling Areas ...... 19 3.9. AOPC 9 – Vehicle Maintenance Areas ...... 26 3.9.1. 9A1, 9A2, 9A4, 9A5, 9A11, 9A13 ...... 26 3.9.2. 9A3 ...... 26 3.9.3. 9A6 ...... 26 3.9.4. 9A7 ...... 26 3.9.5. 9A8 ...... 27 3.9.6. 9A9 ...... 27 3.9.7. 9A10 ...... 27 3.9.8. 9A12 ...... 27 3.9.9. 9A13 ...... 27 3.9.10. 9B1 ...... 28
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3.9.11. 9C ...... 28 3.10. AOPC 10 – Adair AFS Sewage Treatment Plant ...... 28 3.11. AOPC 11 – Boiler Houses ...... 29 3.12. AOPC 12 – Electrical Substations ...... 29 3.13. AOPC 13 Landfill ...... 30 3.14. AOPC 14 Laundry Facility and Steam Plant ...... 30 3.15. AOPC 15 Non-Military Industrial Process Areas ...... 30 3.16. Summary and Conclusions ...... 30 3.16.1. AOPCs that may warrant no further action by DoD ...... 30 3.16.2. AOPCs that may warrant continued investigation under the FUDS program ...... 31 4. References ...... 31 Tables 34 Figures 37
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Abbreviations
AOPC Area of Potential Concern Ba barium BD/BR Building Demolition/Building Removal bgs below ground surface BTEX benzene, toluene, ethylbenze, and xylenes CON/HTRW Containerized Hazardous, Toxic, or Radioactive Waste COPC Contaminant of Potential Concern COPEC Contaminant of Potential Ecological Concern Cu copper DERP-FUDS Defense Environmental Restoration Program for Formerly Used Defense Sites DRO diesel-range organics EPJCE E. P. Johnson Construction and Environmental, Inc. GRO gasoline-range organics HTRW Hazardous, Toxic, or Radioactive Waste LSE Lambier Stevenson Engineers LUST Leaking Underground Storage Tank mg/kg milligrams per kilogram MMRP Military Munitions Response Program Mn manganese NDAI No Department of Defense Action Indicated NFDA No Further Department of Defense Action NLETTF Northwest Laborers-Employers Training Trust Fund Ni nickel ODEQ Oregon Department of Environmental Quality OSILETT Oregon & Southern Idaho Laborers-Employers Training Trust OTPH Oregon Total Petroleum Hydrocarbons OWS oil-water separator PA Preliminary Assessment PAH polycyclic aromatic hydrocarbon Pb lead ppm parts per million RBC risk-based concentration RI Remedial Investigation SI Site Investigation TAL target analyte list TBA Targeted Brownfields Assessment TCLP toxicity characteristic leaching procedure TM Technical Memorandum TPH total petroleum hydrocarbons UPL upper prediction limit USACE United States Army Corps of Engineers USEPA United States Environmental Protection Agency UST Underground Storage Tank UTL upper tolerance limit VFA vehicle fueling area VMA vehicle maintenance area Zn zinc
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1. Introduction The United States Army Corps of Engineers (USACE) is conducting investigation and remediation activities at the Former Camp Adair /Adair Air Force Station (Camp Adair), located approximately nine miles north of Corvallis, Oregon under the authorities of the Defense Environmental Restoration Program for Formerly Used Defense Sites (DERP-FUDS).
Under the DERP-FUDS program, USACE has the following existing or former projects for Camp Adair (Site No. F10OR002900):
• Containerized Hazardous, Toxic, or Radioactive Waste (CON/HTRW) – Project No. F10OR002901 was approved in 1992. Ten Underground Storage Tanks (USTs) were removed in 1994 (EPJCE, 1995), although No [further] Department of Defense Action Indicated (NDAI) status was not achieved. This project was closed in 2006. • Building Demolition/Debris Removal (BD/DR) – Project No. F10OR002902 was approved in 1992. One high brick chimney was demolished and disposed, one partially completed mobile missile facility was filled, 10 man-holes in the Camp Adair cantonment area were filled, and 33 manhole covers were replaced in the Camp Adair cantonment area. No additional work was identified. This project is currently closed. • Military Munitions Response Program (MMRP) – Project No. F10OR002903 was approved in 2000. An MMRP Site Inspection Report for Camp Adair was completed in 2007 (USACE, 2007b). This project is currently in progress. • Hazardous, Toxic, or Radioactive Waste (HTRW) – Project No. F10OR002904 was approved in 2007. A Site Investigation Report was completed in 2012 followed by a Background Desktop Exercise Technical Memorandum in 2014. This project is currently in progress.
Under the HTRW and CON/HTRW projects, USACE has performed multiple investigation and cleanup actions. These activities have included underground storage tank (UST) decommissioning activities, a draft Preliminary Assessment (PA; USACE, 2007a), an HTRW Site Investigation (SI; USACE, 2011a), and a Background Desktop Exercise Technical Memorandum (USACE, 2014). Munitions response is handled separately under the MMRP project and is not addressed in this document.
The 2007 draft PA identified 15 main categories of Areas of Potential Concern (AOPCs) not related to the MMRP and recommended each AOPC for NDAI or further investigation. Table 1 lists all AOPCs identified in the draft PA. Figure 1 shows the locations of all AOPCs.
On the basis of the PA, the subsequent SI, and background re-evaluations, the Oregon Department of Environmental Quality (ODEQ) has concurred with NDAI recommedations for a subset of the AOPCs defined in the PA. Recently, in reviewing ODEQ comments on the draft RI Work Plan for Camp Adair (ODEQ, 2014a), the USACE discovered that some AOPCs proposed for investigation may be ready for NDAI recommendation without further sample collection. Furthermore, the USACE discovered that some AOPCs remain without NDAI concurrence from ODEQ, but are not currently being addressed in the draft RI Work Plan. These discoveries prompted the USACE to conduct a review of all AOPCs and relevant past decisions.
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The purpose of this Technical Memorandum (TM) is to review and provide a status update on all of the AOPCs identified in the PA, and, as appropriate, recommend further investigation or NDAI on the basis of new information. With ODEQ concurrence, the outcome of this evaluation will influence subsequent development of the Remedial Investigation (RI) Work Plan and ensure that no AOPCs are omitted without a mutual understanding between ODEQ and the USACE as to their disposition.
2. Site Activities and Investigations This section provides a brief summary of investigations and cleanup activities at Camp Adair relevant to the AOPCs defined for the site.
2.1. 1990 Boise-Cascade Preliminary Assessment III The Preliminary Assessment III (PAIII) was prepared by Boise-Cascade to document environmental investigations and remediation activities conducted at the former Boise-Cascade (BC) property in the northeast corner of the cantonment area (LSE, 1990). The investigation included soil and groundwater sampling at what are now known as AOPC 8A7 and 9A7. Contaminated soils were removed from four areas of the site, including AOPC 8A7. Subsequent confirmation testing was performed to ensure residual soil contamination did not exceed the cleanup levels established for the site at that time (500 mg/kg for petroleum hydrocarbons and 1.0 mg/kg for pentachlorophenol).
Although AOPC 2 was within the area formerly used by BC, the PAIII investigation did not include sampling at AOPC 2.
The report concludes that no further action is warranted for the site given that PAII accomplished soil removal to below the agreed upon action levels. ODEQ responded in a letter dated 11 March 1991and determined that the soil removal activities performed by BC are complete (ODEQ, 1991). ODEQ stated that no further action is required at the site, unless additional information becomes available which warrants further investigation.
2.2. 1995 UST Decommissioning Report The Underground Storage Tank Decommissioning Report describes work completed in two areas. In the Adair Village, ten tanks were removed, contaminated soil was excavated, and soil and water sampled at Tank Sites 1, 2, and 3, which correspond to AOPCs 8B1, 5B/D, and 8B2, respectively (EPJCE, 1995). The activity completed at each AOPC is summarized below:
• 5B & 5D (“Tank Site No. 2”) – Five fuel oil tanks, one diesel tank, and one oil-water separator removed at the SAGE powerhouse facility. • 8B1 (“Tank Site No. 1”) – Two gasoline tanks, one waste oil tank removed from the former gas station. • 8B2 (“Tank Site No. 3”) - one gasoline tank removed from the former auto maintenance shop.
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Tanks were removed as part of the decommissioning, but underground piping was not removed beyond the tank excavation. During tank removal, contaminated soil was discovered and excavated at AOPCs 5B and 8B1.
The decommissioning report also documents soil sampling in test pits at six former fuel distribution areas (now referred to as AOPCs 8A1 – 8A6). The USTs had been removed several years prior, but not by the USACE. The pits were left open and had become heavily overgrown. No soil removal or other remedial action occurred; no analytes were detected in the test pits. The fuel distribution piping between the former tank locations and distribution islands was not characterized.
In response to the discovery of contaminated soil at 5B and 8B1 during the UST decommissioning, ODEQ established two new Leaking Underground Storage Tank (LUST) project numbers 02-94- 4143 (“Tank Site No. 2”) and 02-94-4159 (“Tank Site No. 1”). The LUST project numbers correlate to AOPCs 5B/D and 8B1, respectively.
In a letter dated April 29, 2003, ODEQ responded to the 1995 Decommissioning Report requesting additional information (ODEQ, 2003). Several communications regarding the Camp Adair LUST sites occurred subsequently between ODEQ and USACE, including two follow-up letters from ODEQ dated September 21, 2005 (ODEQ, 2005a) and November 28, 2005 (ODEQ, 2005b) that also addressed a previously identified LUST project number 02-91-4077 (AOPC 5C) that was established in 1991. Primary concerns raised by ODEQ included lack of UST piping characterization and groundwater considerations.
2.3. 2003 USEPA Targeted Brownfield Assessment In 2002, URS Corporation, on behalf of USEPA, conducted a Targeted Brownfields Assessment (TBA) at a portion of the former Camp Adair cantonment area (URS, 2003). The TBA focused on parcels currently owned by the City of Adair Village that were transferred to the city from Boise- Cascade. A portion of AOPC 8A7 was included in the TBA investigation.
2.4. 2007 Draft Preliminary Assessment Report In May 2007, USACE completed a draft Preliminary Assessment (draft PA) under the HTRW program to review and update the current understanding of all potential Deparment of Defense (DoD)-contaminated sites not related to munitions. The current AOPC numbering assignments were made in this document, and this nomenclature continues to be utilized.
ODEQ reviewed the draft PA in two separate response letters. In a letter dated 4 September 2007 prepared by Cathy Rodda, ODEQ addressed the following AOPCs discussed in the draft PA:
• AOPCs 5B & 5D (LUST #02-94-4143); • AOPC 5C (LUST #02-91-4077); and • AOPC 8B1 (LUST #02-94-4159).
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ODEQ denied the USACE request for NDAI concurrence for the above listed AOPCs and requested additional information and/or investigation (ODEQ, 2007a).
In a letter dated 13 December 2007 prepared by Norman Read, ODEQ addressed the remaining AOPCs not covered in the previous ODEQ letter. ODEQ concurred with some of the PA’s recommendations, but denied some NDAI requests (ODEQ, 2007b).
The decisions recorded in the 4 September 2007 and 13 December 2007 letters are summarized in Table 1.
2.5. 2012 Site Investigation In 2012, USACE completed the SI Report for multiple HTRW sites at Camp Adair. The SI Report identified the following AOPCs with selected chemicals for further investigation:
• AOPC 2 (copper); • AOPC 5 (barium, copper, and nickel); • AOPC 8B1 (copper, manganese, and nickel); • AOPC 8B2 (copper, nickel); • AOPC 9A3 (nickel); • AOPC 9A6 (lead, nickel, zinc); • AOPC 9A8 (nickel); • AOPC 9A9 (barium, copper); and • AOPC 9A10 (nickel).
An additional subset of AOPCs was recommended for NDAI. In a letter dated April 12, 2013, ODEQ concurred with the SI Report’s recommendations. The decisions are summarized in Table 1.
2.6. 2014 Technical Memo: Background Desktop Exercise Following completion of the SI Report in March 2013, ODEQ published revised data tables specifying new regional default background concentrations of various metals in Oregon soils (ODEQ, 2013). USACE re-evaluated AOPC inorganic concentrations recommended for further investigation in the SI against these new 2013 Oregon background values to identify whether additional chemicals or entire AOPCs should be removed from further consideration. The results of the study were presented in the Background Desktop Exercise TM that included NDAI recommendations for the following subset of AOPCs/inorganics (USACE, 2014):
• AOPC 5 (barium) • AOPC 9A3 in entirety (nickel) • AOPC 9A6 (nickel, zinc) • AOPC 9A9 in entirety (barium, copper) • AOPC 9A10 in entirety (nickel).
The Background Desktop Exercise TM also recommended expanding the site-specific background dataset and the data sets associated with the remaining AOPCs and chemical pairs to evaluate
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wither observed metal concentrations at the AOPCs represent contamination or are indicative of site-specific conditions.
In a letter dated 22 May 2014, ODEQ concurred with the recommendations presented in the Background Desktop Exercise TM (ODEQ, 2014b). The decisions are summarized in Table 1.
3. Evaluation of AOPCs This section provides a status update, including all known ODEQ decisions, for every AOPC identified at Camp Adair.
3.1. AOPC 1 – Bomarc Missile Site The SI Report recommended the Bomarc Missile Site for NDAI for all analytes. ODEQ concurred with this recommendation in their 12 April 2012 letter (ODEQ, 2012a).
3.2. AOPC 2 – Coal Storage Yard The coal storage yard was investigated during the SI; the SI Report recommended NDAI for all analytes except copper in soil. ODEQ concurred with this recommendation in their 12 April 2012 letter (ODEQ 2012a). Copper will be investigated during the HTRW Remedial Investigation.
3.3. AOPC 3 – Camp Adair Sewage Treatment Plant The former sewage treatment plant was investigated during the SI; the SI Report recommended NDAI for all analytes. ODEQ concurred with this recommendation in their 12 April 2012 letter (ODEQ, 2012a).
3.4. AOPC 4 – Morgue The SI Report recommended the former morgue for NDAI. ODEQ concurred with this recommendation in their 12 April 2012 letter (ODEQ, 2012a).
3.5. AOPC 5 – SAGE Facility The Semi-Automatic Ground Environment Facility (SAGE Facility) consisted of a three-story technical building with equipment powered by an adjoining powerhouse. AOPC 5 (the SAGE Facility) is subdivided into four sub-areas: 5A, 5B, 5C, and 5D. AOPCs 5A, 5B, and 5D are located on or immediately adjacent to the former SAGE Facility. The property containing AOPCs 5A, 5B, and 5D is privately owned and zoned as Limited Industrial (USACE, 2012). AOPC 5C is located approximately 400 ft southeast from the other AOPCs. The future land use for AOPCs 5A, 5B, and 5D will remain commercial as the site owner plans to maintain the property for commercial purposes.
The site is flat and open with concrete/asphalt paving and lawn covering the majority of the ground around the SAGE building. There are no surface water features nearby and surface runoff is managed in the Adair Village stormwater collection system. Because AOPC 5 is paved and located
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within the central Adair Village and there is no habitat available at or near this site, impacts to ecological receptors are unlikely. Land use to the north of the property is residential, and the land to the east and south is zoned for educational facilities. Public lands lie to the west. The property to the east is owned and operated by the Samian Christian School, and the property to the south is owned and operated by the Oregon & Southern Idaho Laborers Employers Training Trust (OSILETT) for the training of laborers. Current and future receptors include industrial or commercial workers, and the primary exposure pathway of concern is direct contact with soil. Much of the area is surrounded by residential receptors. Consequently, the ODEQ residential risk- based concentrations (RBCs; ODEQ, 2012b) were selected as the most appropriate, health protective screening criteria.
AOPC 5B encompassed six former USTs (five fuel oil tanks and one diesel tank); AOPC 5D is the site of a former oil-water separator (OWS) and associated piping. AOPCs 5B and 5D were previously the sites of Underground Storage Tank (UST) decommissioning activities performed in 1994 that removed the six tanks and the oil-water separator (EPJCE, 1995). As noted in Section 2.2, the area that included 5B and 5D was referred to as “Tank Site No. 2” during UST decommissioning activities.
Each AOPC 5 sub-area is discussed in more detail in the following sub-sections.
3.5.1. 5A AOPC 5A refers to the actual SAGE process facility (main building). The draft PA recommended that additional information be gathered and reviewed to determine if the operation of the SAGE facility required use of substances with hazardous constituents, and if so, what the likelihood of a release having occurred is. In their letter dated 13 December 2007, ODEQ agreed with this assessment.
Subsequently, the lack of an access agreement with the current property owner prevented visual reconnaissance during the SI Workplan development. No sampling was proposed or conducted during the SI (USACE, 2012).
The former SAGE facility building is currently under private ownership and has been converted into a distillery.
AOPC 5A is recommended for further evaluation. Pending access agreements, a site walk-through is recommended as a first step to determine what, if any, HTRW-producing processes may have been used at the site. Since site access cannot be obtained through the current owner, AOPC 5A will be placed in an interim risk management phase upon such time as a right of entry can be acquired.
3.5.2. 5B AOPC 5B consists of the SAGE Facility Generator Tank Site which contained fuel oils for boiler operations. The USTs consisted of four 30,000-gallon diesel oil #6 tanks (Tanks No. 4 through 7), one 15,000-gallon fuel diesel oil #6 tank (Tank No. 8), and one 2,000-gallon boiler ignition oil, diesel #2 tank (Tank No. 9). The site also contained approximately 150 linear feet of aboveground
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fill and distribution piping. Tanks No. 4, 5, 6, 8 and 9 were in contiguous concrete vaults but Tank No. 7 was not in a vault.
UST removal and decommissioning activities
Tank Nos. 4, 5, 6, 7, and 8 were removed in 1994. Above ground piping was removed prior to excavation in order to access the tank pits. In total, approximately 1,200 cubic yards of petroleum contaminated soils were removed from the two primary excavation locations (Tanks 4, 5, 6, 8 and Tank 7), and the final dimensions of the UST excavation were approximately 70 ft x 83 ft x 18 ft. Most of the contaminated soils were associated with Tank No. 7. Contaminated soils were also discovered at a storm sewer line adjacent to the southern edge of the excavation of Tank No. 4. Portions of the storm sewer line found to contain diesel contamination were also replaced.
A release report was made to the ODEQ on 29 September 1994; ODEQ currently has a record for a USTcleanup site at the SAGE facility identified as USTC #02-94-4143, Camp Adair Site No. 2 in their online UST cleanup database.
The tank excavation revealed that the tanks were installed in a dished, concrete structure approximately 18 ft bgs which covered the entire floor of the excavation. The exception was tank No. 9, which was mounted on three individual raised concrete saddles. Some water was encountered within the bottom area of the tank excavations, but according to EPJCE (1995), the water appeared to be either perched within the dished areas of the concrete hold-down pad assembly or trapped along the sides of the concrete hold-down pad assembly. A small collection pit was excavated between the main tank excavation and the adjacent Tank No. 7 excavation to remove the trapped water from a single point and to determine if there was an apparent groundwater table.
The depth of the collection pit was approximately 6 feet beneath the elevation of the concrete hold- down pad. No groundwater was reported at the base of the collection pit and the sand, silt, clay mixed soils at the base of the pit were very densely packed. The water that had been perched atop the concrete pad and tank saddles was subsequently allowed to drain into the collection pit for 24 hours. Approximately 1,550 gallons of water were subsequently disposed. A water sample (CPAD0017) taken from the collection pit prior to pumping was analyzed for benzene, toluene, ethylbenzene, xylenes (BTEX) and total petroleum hydrocarbons (TPH). The BTEX results were non-detect, but heavy oils were detected at a concentration 16 mg/L. Gasoline-range organics (GRO) and diesel-range organics (DRO) were not measured.
Following pumping from the tank pit, the collection pit remained open overnight and a “minimal amount of water” collected at the bottom of the pit (EPJCE, 1995). The source of this water was believed to be remaining water from the drainage of the area surrounding the concrete hold-down pads and not representative of an apparent water table (EPJCE, 1995). A second water sample could not collected due to a reported lack of groundwater infiltration.
Following removal of the trapped water, thirty two confirmation soil samples were collected from the tank excavation floor and sidewalls and storm sewer excavation trench (Table 2 and Figure 3). Since the floor of the excavation was primarily solid concrete, the bottom samples were obtained from the excavations along the sides of the concrete hold-down pads for the former USTs. This plan
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was developed on-site with the concurrence of Mr. Jim Parr of ODEQ (EPJCE, 1995). All soil confirmation samples were analyzed for total petroleum hydrocarbons (TPH) via Oregon Total Petroleum Hydrocarbons (OTPH) 418.1. No hydrocarbon detections were reported in any of the samples. Five of the confirmation soil samples were also analyzed for total metals (arsenic, cadmium, chromium, and lead). A single background soil sample (CPAD0081) was collected at a depth of 15 ft bgs in a test pit near the staging area for stockpiling clean overburden soil. EPJCE (1995) concluded that “no distinct increases of metals were found in excess of the apparent background levels.”
Soil samples were also obtained along the storm sewer line between the tank excavation and the east man-hole (CPAD0039 and CPAD0048). These samples were analyzed for petroleum hydrocarbons; all target analytes (gasoline, diesel, and heavy oils) were non-detect.
Prior to backfilling of the storm sewer excavation, a small amount of water accumulated in the storm sewer line trench. EPJCE (1995) attributed this water to drainage through the soils from discharges of the upstream storm sewer. A water sample (CPAD0046) was collected from the trench and analyzed for BTEX, heavy oils, and polycyclic aromatic hydrocarbons (PAHs); no target analytes were detected.
As the water in the storm sewer trench was suspected to have originated from the storm sewer, a sample of the upstream water was collected from the east man-hole located at the southeast corner of AOPC 5. This sample (CPAD0047) was also non-detect for heavy oils and BTEX, but the sample did contain low levels of carcinogenic PAHs. The cPAHs results in sample CPAD0047 exceeded the basic groundwater cleanup levels of OAR 340-122-242(4)(a) available at the time of the decommissioning activities1. Consequently, the water from the man-hole was removed using a submersible pump. EPJCE (1995) attributed this contamination to the oil/water separator (AOPC 5D). As the source of contamination was removed, no further actions were taken regarding the results of the PAH analyses (EPJCE, 1995).
The tank excavations were backfilled with approximately 1,800 cubic yards of imported backfill after laboratory analyses of the soils and remaining water indicated that the contaminated media had been removed (EPJCE, 1995).
ODEQ and USACE responses
ODEQ responded to the 1995 EPJCE report in a series of letters to USACE between 2003 and 2005 requesting clarifications and additional information (ODEQ, 2003, 2005a, 2005b). In particular, ODEQ was concerned about possible groundwater contamination and requested groundwater samples at Tank Site No. 2 (AOPCs 5B and 5D, collectively) to verify that groundwater was not impacted.
In the 2007 draft PA, USACE recommended that AOPC 5B for NDAI on the basis that groundwater (other than water trapped in the concrete hold-down assembly) was not encountered and soil
1 OAR 340-122-242 is no longer promulgated; ODEQ currently recommends risk-based concentrations (OAR 340- 122-0244) for evaluating UST cleanups.
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concentrations in all confirmation samples were either non-detect or slightly above background for all target analytes.
In their letter dated September 21, 2007, ODEQ disagreed with the USACE recommendation and again requested an assessment of groundwater conditions at Tank Site No. 2 (AOPCs 5B and 5D, collectively) on the basis that the decommissioning report indicated that water returned to the bottom of the tank pit in AOPC 5B following excavation and the source of the water had not been clearly identified (ODEQ, 2007a).
Prior to approval of the SI work plan, consensus was reached that for those AOPCs with UST removals, if the site reconnaissance indicated potential sources of groundwater contamination (such as utilities, floor drains, disposal pits, large stockpiles or soil or debris, or stressed vegetation) or if a contaminant of concern was detected above leaching-based screening values, then groundwater sampling would be performed (March 16, 2011 via teleconference; April 13, 2011 Technical Project Planning meeting). The approved SI work plan did not include groundwater sampling at AOPC 5B.
During the SI site reconnaissance, no areas of stained soil or stressed vegetation or any other adverse environmental conditions were noted during the site walk. As all USTs and contaminated soils were removed and no petroleum hydrocarbon detections were observed in the confirmatory soil samples, no further sampling was conducted at AOPC 5B during the SI. The SI recommended supplemental sampling for barium, copper, and nickel at AOPC 5 in the vicinity of AOPC 5D. The results and recommendations based on the sample findings at AOPC 5D are discussed in Section 3.5.4.
To address any remaining concerns about potential groundwater contamination related to UST petroleum releases at AOPC 5B, USACE reviewed the 1995 decommissioning report and UST removal soil confirmation samples were compared to the ODEQ leaching-to-groundwater’s RBCs.
The decommissioning report clearly states that little to no moisture was encountered during the excavation of the collection pit to approximately 24 ft bgs. The trapped water surrounding the concrete hold-down pads was then allowed to drain into the collection pit for 24 hours prior to removal. After pumping out the collection pit, the pit remained open overnight. By the next day, a minimal amount of water had collected in the bottom of the pit, which was attributed to residual drainage of water surrounding the concrete hold-down pads and not representative of an apparent water table (EPJCE, 1995).
The UST removal soil confirmation samples were non-detect for petroleum hydrocarbons. Five samples were analyzed for totalmetals (arsenic, cadmium, chromium, and lead). The concentrations of lead were below the ODEQ leaching-to-groundwater RBC. Arsenic, cadmium, and chromium do not have ODEQ leaching-to-groundwater RBCs. Arsenic was detected in one soil confirmation sample (CPAD0026) at a concentration of 27 mg/kg, which exceeds the regional background value of 18 mg/kg (95% UPL for Willamette Valley) but is below the maximum concentration of arsenic reported in the regional background dataset (59 mg/kg). As with all soil confirmation samples at AOPC 5B, petroleum hydrocarbons were non-detect in sample CPAD0026. Given the depth of the
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single sample (18 ft bgs) with the arsenic exceedance, the likelihood of human or ecological exposure is very low.
On the basis of the above information, USACE therefore recommends AOPC 5B for NDAI.
3.5.3. 5C In March 1991, petroleum contamination was encountered northwest of the intersection of Third Street and Vandenberg Avenue during a sewer excavation. The leak was discovered by a sewer repair crew and reported to ODEQ, leading to the creation of LUST Project #02-91-4077. The online LUST entry indicates that the soil contamination was diesel, and that soil and groundwater had been impacted.
In their April 29, 2003 letter, ODEQ requested an evaluation to determine if the source of the contamination at AOPC 5C is linked to the contamination from Tank Site No. 2 (AOPC 5B) on the basis that significant contamination was observed along the storm sewer line during the 1994 UST decommissioning activities at AOPC 5B.
Subsequently, in 2005, ODEQ revised their position and suggested that the contamination at AOPC 5C may have originated from former Tank Site No. 3 (AOPC 8B2) (ODEQ, 2005a and 2005b). Additional assessment was requested at AOPC 5C to determine the source and extent of the release.
The draft PA conducted a thorough review of possible sources and the current status of AOPC 5C and concluded that, while USACE was unable to determine the source of contamination leading to the identification of LUST #02-91-4077, the SAGE Facility tank site (AOPC 5B) was not a contributor (USACE, 2007a). USACE requested that ODEQ remove the DOD for the PRP list for this AOPC; ODEQ denied the USACE request and requested assessment activities to provide documentation to prove that the former Camp Adair operations did not contribute to the identified release (ODEQ, 2007a).
The approved SI Workplan did not include investigation activities at AOPC 5C; a soil or groundwater investigation was not conducted in the SI (USACE, 2012).
Current Status
LUST #02-91-4077 is still active with ODEQ, as no action has been taken by any party to address the discovered contamination. USACE has reviewed the 1995 UST decommissioning report and the 2007 PA and believes that the conclusions and recommendations contained in the 2007 PA remain valid. Per the PA, the SAGE Facility tank site (AOPC 5B) is an unlikely contributor to the AOPC 5C contamination because:
1. The extent of diesel contamination from the SAGE Facility tank site did not reach the waste water system, 2. The contamination that infiltrated the storm water system adjacent to AOPC 5B was limited to that system because the waste and storm water systems are not connected. (The repair work conducted at AOPC 5C occurred on the waste wate system.)
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AOPC 8B2 (Tank Site No. 3) is also an unlikely source of contamination because no contaminated soils were encountered during the 1994 decommissioning activities. Furthermore, AOPC 8B2 was the site of a former gasoline tank, whereas the contamination reported at AOPC 5C was diesel.
The 2007 PA identified two potential sources of the AOPC 5C contamination, including a diesel release that occurred at the Adair Rural Fire and Rescue (ARFR) (LUST #02-93-4165) and possible heavy equipment diesel releases related to training on the NLETTF training facility adjacent to AOPC 5C. The 2007 PA noted that “heavy equipment training was terminated because of frequent diesel spills related to refueling the equipment.” Both the ARFR site and heavy equipment storage area are shown on Figure 2.
USACE recommends AOPC 5C for NDAI.
3.5.4. 5D AOPC 5D is the site of a former oil-water separator (OWS) and associated piping. During excavation and decommissioning activities associated with the SAGE Facility USTs, the OWS at AOPC 5D was discovered and subsequently removed, but the associated underground piping was not removed. A north-south oriented piping run connected to the southern stormwater system and an east-west oriented piping run thought to connect to the eastern storm sewer line on the property were discovered during decommissioning activities. However, the OWS connection to the southern line was not found. Since the tank excavation at AOPC 5B did not extend far enough to the north to intercept the OWS connecting line and did not extend east to the storm sewer, the PA recommended additional sampling of the eastern side of the property where both sewer lines run in order to locate and characterize any possible contamination from the abandoned OWS line. The ODEQ concurred with the determination that further investigation was warranted (ODEQ, 2007b). Consequently, subsurface soil samples were collected during the SI from depths between 3 and 11 feet below ground surface (bgs) at five locations beneath the two identified piping runs and below the suspected location of the former piping (Figure 3). One field duplicate sample was also collected. Samples were analyzed for metals and petroleum hydrocarbons. Analytical results for the collected samples are included in Table 2.
The SI decision framework included a comparison of soil sampling results to various human health and ecological risk-based screening criteria, Oregon regional default background metals values that were available at that time (ODEQ, 2010), and a limited local (site-specific) background dataset. The SI analysis concluded that barium, copper, nickel, and zinc were the only analytes detected in the local soil samples above the 95% upper tolerance limit (UTL) local background values and project screening values. Zinc concentrations were less than the Oregon regional background levels. The results for petroleum hydrocarbons were all below the SI screening levels. Consequently, the SI recommended further sampling for barium, copper, and nickel at AOPC 5. The ODEQ concurred with this recommendation (ODEQ, 2012a).
Subsequent to the preparation of the SI, ODEQ published new regional default background concentrations of various metals in Oregon soils in 2013 (ODEQ, 2013). As the new regional Oregon default background values were believed to be more appropriate for background comparisons at
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Camp Adair, the SI data were re-evaluated using the South Willamette Region default background values (ODEQ, 2013). The results of this re-evaluation were summarized in the Background Desktop Exercise Technical Memorandum (USACE, 2014). As the maximum detected concentration of barium at AOPC 5D2 was below the updated Oregon regional default background upper prediction limit (UPL) value, barium was recommended for NDAI. The Background Desktop Exercise Technical Memorandum also recommended copper and nickel for further consideration at AOPC 5 as their maximum detected concentrations exceeded their respective 2013 updated Oregon regional default background UPL values and were judged to be present in the soil at concentrations statistically greater than background concentrations. The ODEQ concurred with the recommendations for AOPC 5D (ODEQ, 2014).
The draft RI Work Plan (USACE, 2014) noted that copper and nickel were recommended for further investigation because they exceed ecologically based screening criteria. Specifically, the maximum detected concentration of copper exceeded the ODEQ ecological screening criteria (ODEQ, 1998) of 50 mg/kg which is based on invertebrates (in this case, earthworms) and the maximum detected concentration of nickel exceeded the ecological screening criteria of 30 mg/kg which is associated with ecological risk to plants. As noted in Section 3.5, most of this AOPC is paved and there is no ecological habitat near the site. Furthermore, according to ODEQ’s Risk Based Decision Making Guidance (ODEQ, 2003), if contaminated soils are present only at depths greater than three feet below ground surface, screening for potential ecological affects will generally not be required. Given that all copper and nickel detections occurred at depth greater than or equal to three feet, ecological screening criteria are therefore considered not applicable. As such, the ODEQ residential soil RBCs for the protection of human health are recommended as the most appropriate risk-based screening criteria for application at AOPC 5D.
As shown below, the maximum detected concentrations of copper and nickel are well below their respective ODEQ residential RBCs. The 2014 USACE Technical Memo noted that copper appears to be locally elevated.
COPPER NICKEL SAMPLE ID DATE (mg/kg) (mg/kg)
2013 ODEQ South Willamette Valley 95% UPL 140 50 SI Site-Specific Background Range 14 - 130 14 - 37 SI Site-Specific Background 95% UTL 162 40 Residential 3,100 1,500 Urban Residential 6,200 3,100 ODEQ Soil Risk Based Concentrations Occupational 41,000 20,000 Construction Worker 12,000 6,100 Excavation Worker 340,000 170,000
2 The Background Desktop Exercise Technical Memorandum references AOPC 5; however, subsequent review of the location of the dataset used in that document indicates that the more accurate nomenclature should have been “5D.”
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Leaching-to-Groundwater NA NA AOPC5-SL-01 8/22/2011 89 50 AOPC5-SL-02 8/22/2011 -- -- AOPC5-SL-02A 8/22/2011 200 100 AOPC5-SL-03 8/22/2011 170 99 AOPC5-SL-04 8/22/2011 220 93 AOPC5-SL-05 8/22/2011 37 27 Notes: Results reported in mg/kg (ppm) dry weight. Sample AOPC-SL-05 is a duplicate of Sample AOPC-SL-02. Values in italics exceed regional background 95% UPL.
To further address concerns about potential groundwater contamination related to UST petroleum releases, the SI soil samples at AOPC 5D were compared to the ODEQ leaching-to-groundwater RBCs (shown above and also in Table 2). The SI soil samples were below ODEQ leaching-to- groundwater RBCs for lead, diesel/heating oil, gasoline and mineral/insulating (heavy) oil. All other analytes do not have ODEQ leaching-to-groundwater RBCs.
Surface soil sampling has not been conducted at AOPC 5D, but it is unlikely that surface soils would be more impacted than subsurface soils as the piping runs were below grade.
In summary, although copper and nickel were detected in subsurface samples in excess of regional and site-specific background concentrations, the observed concentrations are below appropriate human-health risk-based screening criteria. On the basis of the above information, USACE recommends AOPC 5D for NDAI.
3.6. AOPC 6 – Salvage Yard The SI Report recommended the former salvage yard for NDAI. ODEQ concurred with this recommendation in their 12 April 2012 letter (ODEQ, 2012a).
3.7. AOPC 7 – Shops The SI Report recommended the four shop areas 7A, 7B, 7C, and 7D for NDAI. ODEQ concurred with this recommendation in their 12 April 2012 letter (ODEQ, 2012a).
3.8. AOPC 8 – Vehicle Fueling Areas
3.8.1. 8A1 to 8A7 Cantonment Vehicle Fueling Areas Camp Adair had seven former fuel distribution sites in the cantonment area (8A1 to 8A7). Each of these facilities consisted of several gasoline USTs, a pump house, and eight to ten distribution islands on concrete foundations. A site investigation in November 1993 located six of the seven sites (EPJCE, 1995). The seventh site (8A7) is located on lands formerly owned by Boise Cascade that were transferred to the City of Adair Village. The two areas are discussed separately below.
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3.8.1.1 8A1 to 8A6 All USTs were removed from 8A1 through 8A6 by parties other than the DoD likely sometime in the 1970s, although not as part of an official UST decommissioning procedure (USACE, 2007a). Sampling in 1995 found no contamination (EPJCE, 1995). However, no sampling was done in the former tank pits or along the distribution piping. Soil samples in these areas were subsequently collected for the SI; no contamination was found above local background (USACE, 2012). NDAI for all six sites (8A1 to 8A6) was recorded in ODEQ’s 12 April 2012 letter.
3.8.1.2 8A7 AOPC 8A7 was sampled during the Boise Cascade (BC) Preliminary Assessments (LSE, 1990). The BC PA showed contamination in tank pits, and excavation was performed to remove petroleum contaminated soil (PCS). In a letter dated 11 March 1991, ODEQ determined that the soil removal activities are complete and stated no further action (NFA) is required at the site3.
The 2003 TBA collected samples from within the foundation area; no chemicals were detected above existing regulatory screening criteria. ODEQ residential soil RBCs were primarily used for comparison of soil data; where unavailable, Region 9 industrial soil PRGs were used for chemicals without an established Oregon screening value. Industrial PRG concentrations were selected on the assumption at the time that the site would not be re-used for residential purposes. Ecological screening levels were not considered. On the basis of this comparison, no exceedances were detected in the area of AOPC 8A7; no further investigation was recommended (URS, 2003).
According to the 1994 Remedial Design Study for the CON/HTRW study, a November 1993 site survey confirmed that the 8A7 fuel distribution site had been removed; the area was noted as having been excavated, leveled, seeded, and fenced for security by the new occupant. At that time, Hewlett Packard was identified as the occupant (USACE, 1994).
Subsequently, the draft 2007 draft PA reviewed AOPC 8A7. Without knowledge of the prior 1991 ODEQ letter, the draft PA recommended the site for NDAI on the basis that 8A7 had been beneficially used since DoD use. In their December 2007 response to the draft PA, ODEQ denied the USACE request for an NDAI, and suggested that further work be done by USACE to close this AOPC on the basis that the original source does seem to stem from DoD use of the area (ODEQ, 2007b).
At this time, USACE would like to renew attention to the 1991 ODEQ letter that issued a NFA for the BC sites that underwent investigation and removal activities, which included 8A7. Furthermore, due to FUDS policy, USACE is unable to conduct further investigation at 8A7 due to beneficial use post-DoD use. Therefore, USACE recommends AOPC 8A7 for NDAI.
3.8.2. 8B1 to 8B2 Adair Village Fueling Areas There are two former general cantonment vehicle fueling areas at the former Camp Adair Site (AOPC 8B1 and AOPC 8B2). AOPC 8B1 is the site of the former Adair AFS general fueling facility,
3 The 1991 ODEQ letter is available on ODEQ’s online ECSI database (ECSI Site ID 941). This letter only addressed those areas investigated by BC; thus, although AOPC 2 (coal storage yard) lies within the area formerly owned by BC, the letter does not appear to apply to AOPC 2 since it was not included in BC’s field work.
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and AOPC 8B2 is the site of the former Vehicle Maintenance Building fueling station. Both AOPCs were used for fuel dispensing, oil changing, and light maintenance. In 1994, the USTs at these sites were removed as part of the UST decommissioning, but the underground piping was left in place.
AOPC 8B1 is located within the commercial area of Adair Village. The property is currently owned by Benton County, but leased to the Corvallis Society of Model Engineers. One building remains on site. The site is zoned as public lands, and site use is recreational (indoor) typically during daylight hours. The future land use is anticipated to remain commercial. Current and future receptors include industrial or commercial workers. Adjacent zoning is commercial, exclusive farm use, and educational facilities. Although there are small lawn areas on site, there are no surface water features nearby and surface runoff is managed in the stormwater collection system of Adair Village. Therefore impacts to ecological receptors are unlikely as there is little to no habitat available at or near this AOPC.
AOPC 8B2 is within the commercial area of Adair Village and is located on property owned by the OSILETT. The site is located on the west side of the Former Maintenance Center building. There are no buildings present on site and the site is covered with asphalt. Surface runoff is managed in the stormwater collection system of Adair Village. Therefore, impacts to ecological receptors are unlikely as there is no habitat available at or near this AOPC.
As both AOPC 8B1 and 8B2 are located within the commercial area of Adair Village, the ODEQ occupational RBCs (ODEQ, 2012b) were selected as the most appropriate, health protective screening criteria.
3.8.2.1 8B1 AOPC 8B1 consists of the former Adair AFS gas station. It was used for fuel dispensing, oil changing, and light repair. Site features included a maintenance building surrounded by asphalt and concrete paved areas. AOPC 8B1 encompassed four former USTs: a 12,000-gallon gasoline UST (Tank No. 1), a 10,000-gallon gasoline UST (Tank No. 2), a 750-gallon waste oil UST (Tank No. 3), and one heating oil UST. Tanks No. 1 and 2 were located side by side on the east of the building. Tank No. 3 was located on the south side of the building and waste oil was pumped to it by a sump pump located inside the station repair bay. The gasoline and waste oil USTs were decommissioned by the USACE in 1994, and the heating oil UST was decommissioned by a post-military owner in the 1990s. The dispenser island pumps were also removed during decommissioning, but the island and underground piping were left in place. The heating oil tank was not removed in 1994 due to ineligibility under USACE program funding.
During tank excavation, petroleum contaminated soils were encountered and removed from between the western half of Tank Nos. 1 and 2 and the northwest area of Tank No. 2. The suspected source of contamination was the loose piping connections to the tanks. A release report was made to the ODEQ on 14 November 1994 and the ODEQ has a record for a USTC site at AOPC 8B1 identified as USTC #02-94-4159, Camp Adair Site No. 1. After removal of the two tanks, water was observed in the excavation pit. As there had been several days of precipitation, the water in the pit was attributed to local infiltration originating from the upper three feet to four feet of soil
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consisting of a sand, silt, and clay mixture. A relatively impermeable conglomerate of hard packed gravel clay was observed beneath this surficial layer from approximately three to nine feet bgs. A water sample (CPAD0054) was collected from the pit and analyzed for gasoline, heavy oils, BTEX, and PAHs. The results indicated the presence of gasoline contamination above cleanup guidelines available at that time. A second water sample was collected after sufficient accumulation of water into the pit (24-36 hours); all analytest were non-detect except for xylene (3.8 ug/L), which is well below residential groundwater RBC of 200 ug/L. The UST report attributed the water accumulation in the pit to local precipitation and not to groundwater.
After the water was pumped from the excavation and contaminated soils were removed, the excavation was terminated when gasoline soil contamination was no longer detected through field screening. Four floor (CPAD0061 through CPAD0064) and six sidewall samples (CPAD0065 through CPAD0070) were obtained from the Tank Nos. 1 and 2 excavation and were analyzedfor TPH. The locations of these samples are shown in Figure 4. As shown in Table 2, no hydrocarbon detections were reported in any of the samples. Selected composites of the confirmation soil samples were analyzed for total metals (arsenic, cadmium, chromium, and lead). The observed concentrations did not warrant continued remedial actions (EPJCE, 1995). The excavation was backfilled, the contaminated soil and water were properly disposed of, and no further remedial actions were performed.
Contaminated soils were also encountered in the excavation and removal of Tank No. 3 along the south side of the building. The release is suspected to have occurred from the overfilling of the used oil tank, allowing the contents to escape into the soils at the vent line separation as the vent pipe of the tank was found to be physically disjointed from the tank (EPJCE, 1995). The excavation was terminated when field screening indicated that the target cleanup level had been achieved. Water did not accumulate in this excavation. One floor sample (CPAD0059) and four side wall samples (CPAD0055 through CPAD0058) were obtained from the excavation and were analyzed for TPH, total metals (arsenic, cadmium, chromium, and lead), chlorinated solvents, and PCBs. As shown in Table 2, no hydrocarbon detections were reported. Chlorinated solvents and PCBs were not detected, and the observed concentrations of metals were consistent with the background sample (CPAD0081 BKGD) (EPJCE, 1995). Therefore, the 1995 UST Decommissioning Report recommended no further remedial actions at Tank Site No. 1.
In 2005, the ODEQ requested an assessment of groundwater conditions at Tank Site No. 1 due to the presence of naphthalene in the pit water sample (ODEQ, 2005b).
The draft PA recommended further action at AOPC 8B1 with respect to the automotive fuel and waste oil tanks, specifically sampling along the pipe runs because they were not characterized during the decommissioning. ODEQ concurred with this recommendation and requested an assessment of groundwater conditions at this location because the decommissioning report indicated that water was observed in the bottom of the tank pit following excavation and initial water sample results identified benzene and naphthalene above regulatory standards in place at the time (ODEQ, 2007a).
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Prior to finalization of the SI Workplan, ODEQ concurred that subsurface soil sampling at a depth that approaches the water table, or at a minimum from a depth below the level of the structure in question, should be evaluated to determine if groundwater monitoring wells are warranted (April 13, 2011 Technical Project Planning Meeting).
The SI Work Plan, therefore included targeted sampling at the approximate location of the piping at a depth of 9.5 feet bgs (approximately 0.5 to 1 foot below the depth of the UST piping). These samples were analyzed for petroleum hydrocarbons, BTEX, and total metals (arsenic, barium, cadmium, chromium, copper, lead, manganese, and nickel).
The SI decision framework included a comparison of soil sampling result to various human health and ecological risk-based screening criteria, background metals values that were available at that time, and limited local (site-specific) background data. The SI analysis concluded that copper, manganese and nickel were the only analytes detected in the SI soil samples above the project screening values. BTEX and #2 Diesel were not detected. The results for gasoline, motor oil and the other metals were all below the SI screening values. Consequently, the SI recommended further RI sampling for copper, manganese and nickel at AOPC 8B1. The ODEQ concurred with this recommendation (ODEQ, 2012a).
Subsequent to the preparation of the SI, ODEQ published new regional default background concentrations of various metals in Oregon soils in 2013 (ODEQ, 2013). The SI data were re- evaluated using the South Willamette Region default background values and the results were summarized in the Background Desktop Exercise Technical Memorandum (USACE, 2014). The Background Desktop Exercise Technical Memorandum also recommended copper, nickel, and manganese for further consideration at AOPC 8B1 as their maximum detected concentrations exceeded their respective 2013 updated Oregon regional default background UPL. ODEQ concurred with the recommendation that copper, manganese, and nickel be further evaluated (ODEQ, 2014).
The maximum observed site concentrations of copper, nickel, and manganese are less than their respective maximum concentrations reported in the 2013 ODEQ regional background dataset. This information suggests that a more representative (i.e., random and unbiased) AOPC data set may not be significantly different from regional background for nickel and manganese. Evidence exists that naturally occurring copper is locally-elevated (USACE, 2014); therefore, further comparison of additional AOPC copper data to a site-specific background data set may demonstrate that the elevated copper concentrations at 8B1 are not statistically significant.
The SI Report recommended copper, manganese and nickel for further investigation in part because they exceeded ecologically based screening criteria4. As noted previously, most of this AOPC is paved and there is no ecological habitat at or near the site. In addition to the absence of
4 The maximum detected concentration of copper at 8B1 exceeded the ODEQ ecological screening criteria (ODEQ, 1998) of 50 mg/kg, which is based on invertebrates (in this case, earthworms); the maximum detected concentration of manganese exceeded the ODEQ ecological screening criteria of 0.1 mg/kg, which is based on invertebrates; and the maximum detected concentration of nickel exceeded the ecological screening criteria of 30 mg/kg which is associated with ecological risk to plants.
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ecological habitat, contaminated soils are at depths greater than three feet bgs. Therefore, ecological screening criteria are not recommended as appropriate risk screening criteria.
Based on current and projected future site use, the ODEQ occupational soil RBCs for the protection of human health are the most appropriate risk-based screening criteria for application at AOPC 8B1. As shown below, the maximum detected concentrations of copper, manganese, and nickel are below their respective ODEQ occupational RBCs. It should be noted that the 2013 updated Oregon regional default background UPLs for copper, manganese and nickel also exceed the ecological screening criteria and that copper appears to be locally elevated (USACE, 2014).
COPPER MANGANESE NICKEL SAMPLE ID DATE (mg/kg) (mg/kg) (mg/kg)
2013 ODEQ South Willamette Valley 95% UPL 140 2,900 50 SI Site-Specific Background Range 14 - 130 200 – 2,700 14 - 37 SI Site-Specific Background 95% UTL 162 3200 40 Residential 3,100 1,800 1,500 Residential Urban 6,200 3,600 3,100 ODEQ Soil Risk Based Occupational 41,000 23,000 20,000 Concentrations Construction Worker 12,000 7,200 6,100 Excavation Worker 340,000 200,000 170,000 Leaching-to-Groundwater NA NA NA AOPC8B1-SL-01 8/15/2011 170 J+ 3,900 J 60 AOPC8B1-SL-02 8/15/2011 190 5,200 70 Notes: Results reported in mg/kg (ppm) dry weight. Sample AOPC8B1-SL-02 is a field duplicate of AOPC8B1-SL-01. Values in bold and italics exceed regional background 95% UPL, site-specific background 95% UTL, and non-residential RBCs. Values in bold exceed the ODEQ Direct Contact RBC for industrial/commercial receptors (occupational, construction, or excavation). Values in italics exceed regional background 95% UPL.
To address concerns about potential groundwater contamination related to UST petroleum releases, the UST removal confirmatory samples and SI soil samples at 8B1 were compared to the ODEQ leaching-to-groundwater RBCs.
Although the concentrations of lead in some of the UST removal soil confirmation samples (which ranged from 2.2 to 52 mg/kg) exceed the ODEQ leaching-to-groundwater RBC (30 mg/kg), they are comparable to the range observed in the 2013 ODEQ South Willamette Valley data set (1.918 to 60.7 mg/kg) and the site-specific background data collected during the SI (1.6 to 90 mg/kg) (Table 2). It should be noted that the SI site-specific 95% UTL for lead (104.8 mg/kg) exceeds the leaching- to-groundwater RBC. The concentrations of lead observed in the AOPC 8B1 SI samples (1.3 to 1.5 mg/kg) were well below the ODEQ leaching-to-groundwater RBC.
There are no ODEQ leaching-to-groundwater RBCs for copper, manganese, and nickel.
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The draft RI Work Plan included additional soil sampling for copper, nickel, and manganese. Based on further evaluation, additional sampling is believed unnecessary. Although only limited data is available for copper, manganese, and nickel at AOPC 8B1, the observed concentrations are below their respective ODEQ non-residential RBCs. Therefore, USACE recommends copper, manganese, and nickel at AOPC 8B1 for NDAI.
3.8.2.2 8B2 Historical documents for the Adair AFS indicate that there were two tanks located at the Adair AFS Vehicle Maintenance Building Vehicle Fueling site, but the 1994 - 1995 decommissioning project only found one 2,800-gallon gasoline tank (Tank No. 10) located west of the former maintenance center, which was subsequently removed. The dispenser island and underground piping associated with the site were left in place, but the tank pit was filled in during the decommissioning project. The dispenser island was later removed by the current property owners. No contaminated soil or groundwater was found during the decommissioning.
No petroleum hydrocarbon contamination was detected at this site during tank removal (EPJCE, 1995). Soil samples were collected from the bottom and sidewalls of the excavation (CPAD0049 through 0053). All five soil confirmation samples were analyzed for total petroleum hydrocarbons (GRO, DRO, and oils); all results were non-detect. Results are listed in Table 2; sample locations are shown in Figure 5.
In 2005, the ODEQ requested additional assessment to determine if Tank Site No. 3 (AOPC 8B2) could be a source of petroleum contamination at LUST # 02-91-4077 (AOPC 5C) that was identified during road construction in 1991 (ODEQ, 2005b). The draft PA included a detailed discussion of more plausible sources of the petroleum contamination observed at AOPC 5C.
Although no contaminated soils were found during tank excavation, the draft PA recommended additional sampling along the distribution piping in order to fulfil ODEQ UST closure requirements. ODEQ concurred with this recommendation (ODEQ, 2007b).
Two samples were collected at AOPC 8B2 during the SI. One subsurface sample and a duplicate sample were collected during the SI at a depth of approximately 8 feet bgs. No surface soil samples were collected at AOPC 8B2 during the SI. The samples were analyzed for petroleum hydrocarbons, BTEX, and total metals (arsenic, barium, cadmium, chromium, copper, lead, manganese, and nickel). Diesel and BTEX were not detected. The observed concentrations of gasoline and heavy oil were well below SI screening levels. The SI concluded that copper and nickel may be present at concentrations slightly above background levels and above their respective ecological risk-based screening criteria and recommended copper and nickel for further consideration. ODEQ concurred with this recommendation (ODEQ, 2012a).
Subsequently, the SI data were re-evaluated using the South Willamette Region default background values in the Background Desktop Exercise Technical Memorandum (USACE, 2014). The Background Desktop Exercise Technical Memorandum also recommended copper and nickel for further consideration at AOPC 8B2. ODEQ concurred with this recommendation in their 22 May 2014 letter (ODEQ, 2014b).
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Subsequent evaluation noted that copper and nickel were recommended in the SI for further investigation because sample concentrations exceeded ecologically based screening criteria5. However, all of this AOPC is paved and there is no ecological habitat near the site. Soil contamination within three feet of ground surface due to a UST petroleum release is unlikely, not only because the tank was underground, but also because clean imported material was used as backfill. Screening for ecological risks is generally not required per ODEQ’s 2003 Risk-Based Decision Making guidance when ecological habitat is not present or if contaminated soils are only present a depth greater than three feet (ODEQ, 2003). As such, the ecological screening criteria are not recommended for use at AOPC 8B2. ODEQ occupational soil RBCs for the protection of human health are recommended as most appropriate risk-based screening criteria at AOPC 8B2.
As shown below, the maximum detected concentrations of copper and nickel at AOPC 8B2 are well below their respective ODEQ RBCs.
COPPER NICKEL SAMPLE ID DATE (mg/kg) (mg/kg)
2013 ODEQ South Willamette Valley 95% UPL 140 50 SI Site-Specific Background Range 14 - 130 14 - 37 SI Site-Specific Background 95% UTL 162 40 Residential 3,100 1,500 Urban Residential 6,200 3,100 ODEQ Soil Risk Based Occupational 41,000 20,000 Concentrations Construction Worker 12,000 6,100 Excavation Worker 340,000 170,000 Leaching-to-Groundwater NA NA AOPC8B2-SL-01 8/15/2011 170 56 AOPC8B2-SL-02 8/15/2011 160 78
Notes: Results reported in mg/kg (ppm) dry weight. Sample AOPC8B2-SL-02 is a field duplicate of AOPC8B2-SL-01. Values in bold and italics exceed regional 95% UPL, site-specific background 95% UTL, and non-residential RBCs. Values in bold exceed the ODEQ Direct Contact RBCs for industrial/commercial receptors (occupational, construction, or excavation scenarios). Values in italics exceed regional background 95% UPL.
To address concerns about potential groundwater contamination related to UST petroleum releases, the 1994 UST removal soil confirmation samples and SI soil samples were compared to the ODEQ leaching-to-groundwater RBCs. The UST removal soil confirmation samples were non-
5 The maximum detected SI concentration of copper exceeded the ODEQ ecological screening criteria (ODEQ, 1998) of 50 mg/kg which is based on invertebrates (in this case, earthworms and the maximum detected SI concentration of nickel exceeded the ecological screening criteria of 30 mg/kg which is associated with ecological risk to plants.
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detect for petroleum hydrocarbons and were not analyzed for metals. The SI soil samples were below ODEQ leaching-to-groundwater RBCs for lead, gasoline and mineral/insulating oil. All other analytes were either not detected or do not have ODEQ leaching-to-groundwater RBCs.
Furthermore, neither copper nor nickel were historically used as fuel additives and are unlikely to be related to historical site use.
On the basis of the above information, USACE recommends copper and nickel at AOPC 8B2 for NDAI.
3.9. AOPC 9 – Vehicle Maintenance Areas
3.9.1. 9A1, 9A2, 9A4, 9A5, 9A11, 9A13 The SI Report recommended NDAI for AOPCs 9A1, 9A2, 9A4, 9A5, 9A11, and 9A13. ODEQ concurred with this recommendation in their 12 April 2012 letter (ODEQ, 2012a). No further investigation is proposed.
3.9.2. 9A3 The SI Report recommended NDAI for all analytes except nickel. ODEQ concurred with this recommendation in their 12 April 2012 letter (ODEQ, 2012a). Subsequently, the Background Desktop Exercise TM recommended AOPC 9A3 for NDAI for nickel. ODEQ concurred with this recommendation in their 22 May 2014 letter (ODEQ, 2014b). No further investigation is proposed.
3.9.3. 9A6 The SI Report recommended NDAI for all analytes except lead, nickel, and zinc. ODEQ concurred with this recommendation in their 12 April 2012 letter (ODEQ, 2012a). Subsequently, the Background Desktop Exercise TM recommended nickel and zinc for NDAI. ODEQ concurred with this recommendation in their 22 May 2014 letter (ODEQ, 2014b). USACE plans to investigate lead in the RI.
3.9.4. 9A7 Four soil borings with interval sampling at 2.5, 5, 7.5, and 10ft bgs and groundwater grab samples were collected outside of the four oil houses at AOPC 9A7 as part of the PAIII investigation performed by BC. Samples were analyzed for petroleum hydrocarbons, VOCs, SVOCs, and metals; all results were below the reporting limit, with the exception of lead (16 ug/L) in one groundwater sample taken from 10-15 ft bgs. On the basis of this information, the PAIII concluded that cleanup levels (500 mg/kg for petroleum hydrocarbons) had not been exceeded. In their letter dated 11 March 1991, ODEQ responded that no further action is required (ODEQ, 1991).
The oil houses sampled during the PAIII represent only the southernmost portion of AOPC 9A7; no samples were taken from the other associated maintenance areas of AOPC 9A7.
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The draft PA recommended that AOPC 9A7 not be included in the subsequent HTRW project on the basis of non-military industrial operations that have occurred since military use. ODEQ responded in their 13 December 2007 letter that post-military beneficial use did not seem likely to obscure the former military use and recommended that further investigation be conducted. The SI did not include AOPC 9A7 in its sampling investigation on the basis of FUDS ineligibility.
AOPC 9A7 is recommended for NDAI based on PAIII investigation results. Furthermore, since the site has been utilized for industrial activities after DoD occupation, an investigation cannot be initiated by DoD alone. All other potential contributors must be involved through the FUDS potentially responsible party (PRP) process. Fiscal law restraints prevent the FUDS program from expending funds to remediate non-DoD contamination.
3.9.5. 9A8 The SI Report recommended NDAI for all analytes except nickel. ODEQ concurred with this recommendation in their 12 April 2012 letter (ODEQ, 2012a). USACE plans to investigate nickel in the RI.
3.9.6. 9A9 The SI Report recommended NDAI for all analytes except barium and copper. ODEQ concurred with this recommendation in their 12 April 2012 letter (ODEQ, 2012a). Subsequently, the Background Desktop Exercise TM recommended barium and copper for NDAI. ODEQ concurred with this recommendation in their 22 May 2014 letter (ODEQ, 2014b). No further investigation is proposed.
3.9.7. 9A10 The SI Report recommended NDAI for all analytes except nickel. ODEQ concurred with this recommendation in their 12 April 2012 letter (ODEQ, 2012a). Subsequently, the Background Desktop Exercise TM recommended nickel for NDAI. ODEQ concurred with this recommendation in their 22 May 2014 letter (ODEQ, 2014b). No further investigation is proposed.
3.9.8. 9A12 The draft PA recommended AOPC 9A12 for NDAI due to subsequent beneficial non-DoD use. ODEQ did not specifically address 9A12 in their 13 December 2007 letter. The SI Workplan states that AOPC 9A12 was not included in the investigation due FUDS ineligibility (post-DoD beneficial use).
According to the draft PA Figure 7, AOPC 9A12 lies within the footprint of AOPC 9A11. AOPC 9A11 was investigated during the SI, and ODEQ concurred with an NDAI recommendation for this AOPC. On this basis, USACE also recommends AOPC 9A12 for NDAI.
3.9.9. 9A13 The SI determined that the PA misidentified AOPC 9A13; 9A13 is actually part of AOPC 7B. An NDAI for AOPC 7B was recorded in ODEQ’s 12 April 2012 letter (ODEQ, 2012a). No further investigation is proposed.
Camp Adair AOPC Status and Recommendations 27 Draft April 2015
3.9.10. 9B1 The draft PA recommended AOPC 9B1 for SI activities and stated that only limited field information would be needed to determine if 9B1 required remedial investigation (USACE, 2007a). A visual site inspection of 9B1 was conducted on January 25 – 27, 2011 as part of the SI kick-off meeting, and a site walk was conducted on June 13 – 17, 2011 (USACE, 2011b). During the visits, floor drains were not identified, and there were no areas of stained soils or stressed vegetation, mounds, depressions, or other man-made features that could be a source of contamination. Based on this information, the approved SI Work Plan states that there is no indication of environmental impacts from past practices and, therefore, environmental samples will not be collected at 9B1 and the site will be recommended for no further Department of Defense action (NFDA) in the SI Report. The draft SI Report reiterates that there is no indication of environmental impacts from past practices at 9B1, and states that no samples were collected from the site (USACE, 2011a).
However, the draft SI Report mistakenly omitted the NDAI recommendation for AOPC 9B1. ODEQ reviewed the draft SI Report and concurred with the Report’s recommendations (ODEQ, 2012b). The SI Report was subsequently finalized without NDAI concurrence for 9B1 (USACE, 2012). Thus, ODEQ has not officially provided NDAI concurrence for AOPC 9B1.
Therefore, USACE recommends AOPC 9B1 for NDAI and seeks official ODEQ concurrence.
3.9.11. 9C The draft PA recommended NDAI due to subsequent non-military beneficial use (USACE, 2007a). In their 13 Dec 2007 letter, ODEQ denied the NDAI request and recommended further investigation (ODEQ, 2007b). AOPC 9C was not investigated in the SI.
AOPC 9C is the former Air Force auto maintenance facility and is located on property currently zoned Education Facility. The property is currently owned by the Oregon & Southern Idaho Laborers-Employers Training Trust (OSILETT) and is used as an educational facility for vocational training in commercial/industrial labors.
Since the site has been utilized for industrial activities after DoD occupation, an investigation cannot be intiated by DoD alone. All other potential contributors must be involved through the FUDS PRP process. Fiscal law restraints prevent the FUDS program from expending funds to remediate non-DoD contamination.
3.10. AOPC 10 – Adair AFS Sewage Treatment Plant The draft PA recommended the former sewage treatment plant for NDAI (USACE, 2007a). ODEQ concurred with this recommendation in their 13 December 2007 letter (ODEQ, 2007b). No further investigation is proposed.
Camp Adair AOPC Status and Recommendations 28 Draft April 2015
3.11. AOPC 11 – Boiler Houses The draft PA recommended the three AOPCs 11A, 11B, and 11C for NDAI (USACE, 2007a). ODEQ concurred with this recommendation in their 13 December 2007 letter (ODEQ, 2007b). No further investigation is proposed.
3.12. AOPC 12 – Electrical Substations The draft PA identified three electrical substations. One is associated with the Bomarc Missile site and is included in AOPC 1. Descriptions of the other two (12A and 12B) are described below.
3.12.1. 12A The AOPC 12A substation supplied power to the Camp Adair cantonment area and possibly the hospital. During 1985, site visits by Portland District USACE discovered “abandoned” transformers. The transformers were tested and found to contain less than 50 parts per million (ppm) PCBs. The transformers were then disposed of as non-PCB transformers.
The draft PA recommended AOPC 12A for NDAI (USACE, 2007a). ODEQ responded to AOPC 12 in its entirety in their 13 December 2007 letter (ODEQ, 2007b), requesting evidence that would show that the transformers disposed of in the 1980s were the original transformers. ODEQ suggested that further investigation may be warranted if no evidence exists.
Archived documents available at the Seattle District office were reviewed in early 2015; no additional documentation regarding transformers at AOPC 12A was located. Likewise, no historical information exists to suggest that the transformers leaked. Due to the lack of available information, USACE recommends AOPC 12A for further investigation in the RI.
3.12.2. 12B
The AOPC 12B substation is located at the Supply Water Pumping Plant approximately 3.25 mile southeast of Adair Village near the intersection of Highway 20 and Rondo Street. In the 1980s, USACE personnel visited the site to look for any abandoned transformers; documentation did not show a discovery of any transformers. The absence of abandoned transformers was subsequently confirmed with the plant operator. As of March 2015, the plant is currently being used for water supply to Adair Village.
The draft PA recommended AOPCs 12B for NDAI (USACE, 2007a). ODEQ responded to AOPC 12 in its entirety in their 13 December 2007 letter (ODEQ, 2007b), requesting evidence that would show that the transformers disposed of in the 1980s were the original transformers. ODEQ suggested that further investigation may be warranted if no evidence exists.
Because no transformers were discovered or disposed of in the 1980s at AOPC 12B, USACE believes that ODEQ’s comment regarding AOPC 12 was directed primarily at 12A.
Camp Adair AOPC Status and Recommendations 29 Draft April 2015
Archived documents available at the Seattle District office were reviewed in early 2015; no additional documentation regarding transformers at AOPC 12B was located. Likewise, no historical information exists to suggest that the transformers leaked.
AOPC 12B is recommended for further evaluation; however, since AOPC 12B has been utilized for industrial activities after DoD occupation, an investigation cannot be intiated by DoD alone. All other potential contributors must be involved through the FUDS PRP process. Fiscal law restraints prevent the FUDS program from expending funds to remediate non-DoD contamination.
3.13. AOPC 13 - Landfill The PA recommended the former landfill for NDAI. ODEQ concurred with this recommendation in their 13 December 2007 letter (ODEQ, 2007b). No further investigation is proposed.
3.14. AOPC 14 - Laundry Facility and Steam Plant The PA recommended the former laundry facility and steam plant for NDAI on the basis that the likelihood of a dry cleaning operation at Camp Adair was low. According to the PA, less than eight percent of bases with laundries also had dry cleaning plants; during World War II, private cleaners were expected to serve the camp’s needs if another military base could not support the laundry needs. Additionally, soldiers were expected to be responsible for their own dry cleaning.
In their 13 Dec 2007 letter, ODEQ denied the USACE request for NDAI and requested further investigation, stating that “it seems possible that the base had some sort of dry cleaning facility” (ODEQ, 2007b).
Given the close proximity to Corvallis approximately 7 miles to the south, which was incorporated as a city in 1857, the availability of a local dry cleaner seems likely during the historical DoD operations at Camp Adair. Lacking further historical documentation that a dry cleaner was present at the former Camp Adair, USACE recommends AOPC 14 for NDAI.
3.15. AOPC 15 - Non-Military Industrial Process Areas The PA recommended the non-military industrial process areas for NDAI. ODEQ concurred with this recommendation in their 13 December 2007 letter (ODEQ, 2007b). No further investigation is proposed.
3.16. Summary and Conclusions On the basis of the information described in this memo, recommendations for the disposition of each AOPC are summarized in Table 1 and listed below.
3.16.1. AOPCs that may warrant no further action by DoD In addition to the AOPCs for which ODEQ previously provided NDAI concurrence, the following AOPCs are recommended for NDAI:
Camp Adair AOPC Status and Recommendations 30 Draft April 2015
• AOPC 5B • AOPC 5C • AOPC 5D • AOPC 8A7 • AOPC 8B1 • AOPC 8B2 • AOPC 9A7 • AOPC 9A12 • AOPC 9B1 • AOPC 14
3.16.2. AOPCs that may warrant continued investigation under the FUDS program The following AOPCs are recommended for further consideration in the RI:
• AOPC 2 – Investigate copper • AOPC 9A6 – Investigate lead • AOPC 9A8 – Investigate nickel • AOPC 12A – Evaluate further for potential HTRW
The following AOPCs are recommended for further consideration, but cannot be investigated by DoD alone. Investigation at these sites may not occur without involving all other potential contributors through the FUDS PRP process:
• AOPC 5A • AOPC 9C • AOPC 12B
4. AOPC 14 References E.P. Johnson Construction and Environmental, Inc. (EPJCE), 1995. Underground Storage Tank Decommissioning Report. Seattle, WA; file #A000143751. Portland District USACE. April 1995.
Lambier Stevenson Engineers (LSE), 1990. Preliminary Assessment III of the Camp Adair Property, Prepared for Boise Cascade Corporation, December 18, 1990.
Oregon Department of Environmental Quality (ODEQ), 1998. Guidance for Ecological Risk Assessment: Levels I, II, III, IV, Final. Waste Management & Cleanup Division. April.
ODEQ, 1991. Letter by Marilyn M. Daniel Re: Camp Adair Site ID. No 941. Letter dated March 11, 1991.
ODEQ, 2003. Risk-Based Decision Making for the Remediation of Petroleum-Contaminated Sites, Land Quality Division, Environmental Cleanup and Tanks Program, September 22, 2003.
Camp Adair AOPC Status and Recommendations 31 Draft April 2015
ODEQ, 2003. Letter by Karen White-Fallon Re: UST Facility ID# 8170; LUST #02-94-4159 Camp Adair Site No. 1; LUST #02-94-4143, Camp Adair Site No. 2; LUST #02-91-4077; Adair Village Former Camp Adair/Adair Air Force Station; Corvallis, Oregon; Underground Storage Tank Closure Reviews. Letter dated April 29, 2003.
ODEQ, 2005a. Letter by Cathy Rodda Re: LUST # 02-94-4159. Camp Adair Site No. 1; LUST #02-94- 4143, Camp Adair Site No. 2; LUST #02-91-4077, Adair Village; Former Camp Adair and Air Force Station; Corvallis, Oregon, Site Review and Recommendations. Letter dated September 21, 2005.
ODEQ, 2005b. Letter by Cathy Rodda Re: LUST #02-94-4159, Camp Adair Site No. 1; LUST #02-94- 4143, Camp Adair Site No. 2; LUST #02-91-4077, Adair Village; Former Camp Adair and Adair Air Force Station; Corvallis, Oregon; Site Review. Letter dated November 28, 2005.
ODEQ, 2007a. Letter by Cathy Rodda Re: Draft Preliminary Assessment Report. Letter dated September 4, 2007.
ODEQ, 2007b. Letter by Norman Read Re: May 2007 Draft PA Comments. Letter dated December 13, 2007.
ODEQ, 2010. Human Health Risk Assessment Guidance. Oregon Department of Environmental Quality, Environmental Cleanup Program, October 2010.
ODEQ, 2012a. Letter by Norman Read Re: DEQ Review of Revision Draft Final Site Inspection Report; ECSI 1044. Letter dated April 12, 2012.
ODEQ, 2012b. Risk-Based Concentrations for Individual Chemicals. Environmental Cleanup and Tanks Program, Revision: June 7, 2012.
ODEQ, 2013. Background Levels of Metals in Soils in Cleanups. Fact Sheet. Oregon Department of Environmental Quality, Environmental Cleanup Program, March 2013.
ODEQ, 2014a. Letter by Norman Read Re: DEQ Review the Draft Final Remedial Investigation Work Plan for Multiple Sites at the Former Camp Adair, Oregon, dated September 26, 2014. Letter dated November 3, 2014.
ODEQ, 2014b. Letter by Norman Read Re: DEQ Review of Background Desktop Exercise Technical Memorandum; ESCI 1044. Letter dated May 22, 2014.
URS Consultants, Inc. (URS), 2003. Targeted Brownfields Assessment Report for Camp Adair, Adair Village, Benton County, OR. USEPA Region 10. May 2003.
U.S. Army Corps of Engineers, 1994. Remedial Design Study, Former Camp Adair/Adair Air Force Station, Project NO. F10OR002901 (CON/HTRW), March 1994.
USACE, 2007a. Draft Preliminary Assessment Report, Camp Adair/Adair Air Force Station, FUDS property #F10OR0029, May 2007.
Camp Adair AOPC Status and Recommendations 32 Draft April 2015
USACE, 2007b. Final Site Inspection Report, Camp Adair/Adair Air Force Station, FUDS Property No. 10OR0029, Military Munitions Response Program.
U.S. Army Corps of Engineers (USACE), 2011a. Draft Site Inspection Report, Multiple Sites at the Former Camp Adair, Oregon. FUDS Project No. F10OR002904. November 30, 2011.
USACE, 2011b. Final Site Inspection Work Plan, Multiple Sites at the Former Camp Adair, Oregon. FUDS Project No. F10OR002904. July 29, 2011.
USACE, 2012. Final Site Inspection Report, Multiple Sites at the Former Camp Adair, Oregon. FUDS Project No. F10OR002904. May 16, 2012.
USACE, 2014 Draft Final Remedial Investigation Work Plan Multiple Sites at the Former Camp Adair, Oregon Contract No. W912DQ-12-D-3001 Task Order No. 0003. September 26, 2014
USACE, 2014. Technical Memorandum, Background Desktop Exercise: Re-evaluation of Camp Adair AOPC/Metal Chemical Pairs to the 2013 Oregon Regional Default Background Metals Concentrations, Multiple Sites at the Former Camp Adair, May 6, 2014.
Camp Adair AOPC Status and Recommendations 33
Tables
Table 1. AOPC Summary AOPC Description NDAI Current Status Recommended Action 1 Bomarc Missile Site NDAI recorded in ODEQ April 12, 2012 letter in response to draft final 1A Fuel USTs Y SI rpt None. NDAI recorded in ODEQ April 12, 2012 letter in response to draft final 1B Bomarc Missile Site Y SI rpt None. 2 Coal Storage Yard N NDAI recorded for all analytes except copper in 12 April 2012 letter. Investigate in RI. NDAI recorded in ODEQ April 12, 2012 letter in response to draft final 3 Camp Adair Sewage Tx Plant Y SI rpt None. NDAI recorded in ODEQ April 12, 2012 letter in response to draft final 3A Camp Adair cantonment Y SI rpt None. NDAI recorded in ODEQ April 12, 2012 letter in response to draft final 3B Incinerators and Wash Rack Y SI rpt None. 4 Morgue Y NDAI recorded in 12 April 2012 letter. None. 5 SAGE Facility PA recommended further evaluation. The 13 Dec 2007 ODEQ letter concurred with need for further investigation. Site was not 5A SAGE Facility Process Areas N addressed in SI due to inability to gain access to site. Evaluate further. SAGE Facility Generator Tanks ("Camp PA recommended NDAI. 04 Sept 2007 ODEQ letter by Cathy Rodda 5B Adair Tank Site No. 2 - LUST #02-94-4143) N requested additional groundwater investigation. Recommend for NDAI. PA recommended NDAI. The 9/4/2007 ODEQ letter by Cathy Rodda 5C Leaking UST Site (LUST #02-91-4077) N requested additional investigation. Recommend for NDAI. PA recommended additional investigation of former/current pipe runs associated with OWS. NDAI recorded for all analytes except barium, copper, nickel in 12 April 2012 ODEQ letter. NDAI recorded Recommend for NDAI for remaining 5D Oil/Water Separator N for barium in 22 May 2014 letter. analytes (copper, nickel). NDAI recorded in ODEQ April 12, 2012 letter in response to draft final 6 Salvage Yard Y SI rpt None. 7 Shops NDAI recorded in ODEQ April 12, 2012 letter in response to draft final 7A Cantonment Y SI rpt None. NDAI recorded in ODEQ April 12, 2012 letter in response to draft final 7B Ordnance Repair Shop Y SI rpt None. NDAI recorded in ODEQ April 12, 2012 letter in response to draft final 7C Hospital Y SI rpt None.
Camp Adair Background Desktop Exercise 34 Draft April 2015
AOPC Description NDAI Current Status Recommended Action NDAI recorded in ODEQ April 12, 2012 letter in response to draft final 7D Installation Engineer Y SI rpt None. 8 Vehicle Fueling Areas NDAI recorded in ODEQ April 12, 2012 letter in response to draft final 8A1 Camp Adair cantonment VFA 1 Y SI rpt None. NDAI recorded in ODEQ April 12, 2012 letter in response to draft final 8A2 Camp Adair cantonment VFA 2 Y SI rpt None. NDAI recorded in ODEQ April 12, 2012 letter in response to draft final 8A3 Camp Adair cantonment VFA 3 Y SI rpt None. NDAI recorded in ODEQ April 12, 2012 letter in response to draft final 8A4 Camp Adair cantonment VFA 4 Y SI rpt None. NDAI recorded in ODEQ April 12, 2012 letter in response to draft final 8A5 Camp Adair cantonment VFA 5 Y SI rpt None. NDAI recorded in ODEQ April 12, 2012 letter in response to draft final 8A6 Camp Adair cantonment VFA 6 Y SI rpt None. NFA recorded for 8A7 in 11 March 1991 ODEQ letter. Subsequently, draft PA recommended site for NDAI due to beneficial use since DoD 8A7 Camp Adair cantonment VFA 8 N use. ODEQ denied NDAI request in Dec 2007 letter. Recommend for NDAI. Adair AFS gas Station (LUST Proj # 02-94- May 22, 2014 ODEQ letter recommended copper, nickel, and 8B1 4159) N manganese for further consideration.. Recommend for NDAI. ODEQ May 22, 2014 ODEQ letter recommended copper and nickel for 8B2 Adair AFS/Village Auto Maintenance Bldg N further consideration. Recommend for NDAI. 9 Vehicle Maintenance Areas NDAI recorded in ODEQ April 12, 2012 letter in response to draft final 9A1 Camp Adair cantonment VMA 1 Y SI rpt None. NDAI recorded in ODEQ April 12, 2012 letter in response to draft final 9A2 Camp Adair cantonment VMA 2 Y SI rpt None. NDAI recorded for all anlaytes except nickel in 12 April 2012 letter. NDAI recorded for nickel in ODEQ May 22, 2014 letter in response to 9A3 Camp Adair cantonment VMA 3 Y Background Desktop Exercise None. NDAI recorded in ODEQ April 12, 2012 letter in response to draft final 9A4 Camp Adair cantonment VMA 4 Y SI rpt None. NDAI recorded in ODEQ April 12, 2012 letter in response to draft final 9A5 Camp Adair cantonment VMA 5 Y SI rpt None. NDAI recorded for all analytes except lead, nickel, and zinc in 12 Apri 9A6 Camp Adair cantonment VMA 6 N l2012 letter. NDAI recorded for nickel and zinc in 22 May 2014 letter. Investigate lead in RI PA recommended not including 9A7 in HTRW project because of non-military industrial operation. ODEQ recommended further 9A7 Camp Adair cantonment VMA 7 N investigation in 12/13/2007 letter. Recommend for NDAI. 9A8 Camp Adair cantonment VMA 8 N NDAI recorded for all analytes except nickel in 12 April 2012 letter. Investigate nickel in RI.
Camp Adair AOPC Status and Recommendations 35 Draft April 2015
AOPC Description NDAI Current Status Recommended Action NDAI recorded for all analytes except barium and copper in 12 April 2012 letter. NDAI recorded for barium and copper in ODEQ May 22, 9A9 Camp Adair cantonment VMA 9 Y 2014 letter in response to Background Desktop Exercise. None. NDAI recorded for all analytes except nickel in 12 April 2012 letter. NDAI recorded for nickel in ODEQ May 22, 2014 letter in response to 9A10 Camp Adair cantonment VMA 10 Y Background Desktop Exercise None. NDAI recorded in ODEQ April 12, 2012 letter in response to draft final 9A11 Camp Adair cantonment VMA 11 Y SI rpt None. AOPC 9A12 lies within the footprint PA recommended NDAI due to subsequent non-military beneficial of 9A11. Recommend for NDAI. 9A12 Camp Adair cantonment VMA 12 N use (not FUDS eligible). ODEQ did not address in any letter. Camp Adair cantonment VMA 13 - 9A13 was misidentified and is actually part of AOPC 7B. NDAI recorded misidentified by PA. Actually belongs to for all anlytes at 7B in 12 April 2012 letter in response to draft final SI 9A13 AOPC 7B. Y rpt None. NDFA discussed in SI technical planning and SI Workplan. Not 9B1 Adair Army Hospital N discussed for closure in SI Rpt Recommend for NDAI. PA recommended NDAI due to subsequent non-military beneficial use. 13 Dec 2007 ODEQ letter denied NDAI request and Recommend for the FUDS PRP 9C Adair AFS/Village Auto Maintenance Bldg N recommended further investigation. process. NDAI recorded in ODEQ Dec 13, 2007 Letter in response to May 2007 10 Adair AFS Sewage Treatment Plant Y draft PA None. NDAI recorded in ODEQ Dec 13, 2007 Letter in response to May 2007 11 Boiler Houses Y draft PA None. NDAI recorded in ODEQ Dec 13, 2007 Letter in response to May 2007 11A Post Quartermaster Y draft PA None. NDAI recorded in ODEQ Dec 13, 2007 Letter in response to May 2007 11B Ordnance Repair Shop Y draft PA None. NDAI recorded in ODEQ Dec 13, 2007 Letter in response to May 2007 11C Hospital Y draft PA None. 12 Electrical Substations PA recommended NDAI. 12/13/2007 ODEQ letter recommended Recommend for further investigation 12A Camp Adair cantonment N further investigation. in RI. PA recommended NDAI. 12/13/2007 ODEQ letter recommended Recommend for the FUDS PRP 12B Camp Adair water supply N further investigation. process. NDAI recorded in ODEQ Dec 13, 2007 Letter in response to May 2007 13 Landfill Y draft PA None. PA recommended NDAI. 12/13/2007 ODEQ letter recommended 14 Laundry Facility and Steam Plant N further investigation. Recommend for NDAI. 15 Non-military Industrial Process Areas Not DoD responsibility. None.
Camp Adair AOPC Status and Recommendations 36
Table 2. Historical Soil Data
See included spreadsheet
Camp Adair Background Desktop Exercise 37 Draft April 2015
Figures Fig 1. Camp Adair AOPC Locations
Fig 2. Adair Village AOPC Locations (AOPCs 5, 8B1, 8B2)
Fig. 3. AOPC 5B/5D Soil Sample Locations
Fig. 4. AOPC 8B1 Soil Sample Locations
Fig. 5. AOPC 8B2 Soil Sample Locations
Camp Adair AOPC Status and Recommendations 38 NORTH BACKGROUND AREA
9A-3
8A-2 8A-3 8A-7 3 9A-8 9A-7 2
9A-11 7A 9A-1 1 11A 8A-1 6 12A 14 9A-9 7B 13 11B 9A-6
8A-6 9A-10 8A-5
9A-5
8A-4 9A-4
CENTRAL BACKGROUND AREA SOUTH (2) BACKGROUND AREA 5D 5A 5B 8B-2 9C
5C 11C 9B-1 8B-1 7C 4 7D SOUTH (1) BACKGROUND AREA
800 0 800 1,600 LEGEND Feet AREA OF POTENTIAL CONCERN (AOPC) BOUNDARY
BACKGROUND REFERENCE AREA BOUNDARY FIGURE 1 CAMP ADAIR AOPC r LOCATION MAP 5A
5D
5B
8B-2 5C
8B-1
7D 9C
50 0 50 100 LEGEND Feet AREA OF POTENTIAL CONCERN (AOPC) BOUNDARY FIGURE 2 ADAIR VILLAGE r AOPC LOCATIONS 5D
AOPC5-SL-02A AOPC5-SL-01!> !>!> AOPC5-SL-02 !.
5B AOPC5-SL-03!> AOPC5-SL-04!> TANK NO. 9 41 !> 40!>19 09!> 21 20 !> !> 37 22 !> 36 35 !> TANK 38 !> 08!> NO. 8 !> !> 34A 42 !> TANK !> TANK !>!> 34B NO. 7 !> 23 !> NO. 6 !> 30!> !> 34C TANK NO. 5 29 !> 32 33 24!> !> 43 !> TANK 31 NO. 4 48 27 28 39 !> 25!> 26!> !> !> !> 44 !> 45!>
LEGEND 25 0 25 50
!> SOIL SAMPLE LOCATIONS (1994) STORM SEWER/OWS PIPING Feet !> SOIL SAMPLE LOCATIONS (2012) FORMER UNDERGROUND STORAGE TANK FIGURE 3 !. OIL/WATER SEPARATOR AREA OF POTENTIAL CONCERN (AOPC) BOUNDARY r AOPC 5 B/D SOIL SAMPLE LOCATIONS 8B-1
69!> 70!> 63 TANK!> 61!> NO. 2 62!>65!> 68 TANK TANK 55 !> NO. 1 64 NO. 3 !> !> 67!> !>66 58!> 56!> !> AOPC8B1-SL-01!> 57!> 59
25 0 25 50 LEGEND Feet !> SOIL SAMPLE LOCATIONS (1994) STORM SEWER/OWS PIPING !> SOIL SAMPLE LOCATIONS (2012) FORMER UNDERGROUND STORAGE TANK FIGURE 4 AREA OF POTENTIAL AOPC 8 B1 SOIL SAMPLE LOCATIONS CONCERN (AOPC) BOUNDARY r 8B-2
DISPENSER ISLAND
AOPC8B2-SL-01!> 49 51!> 50!> !> !>52 TANK NO. 10 !> 53
25 0 25 50 LEGEND Feet !> SOIL SAMPLE LOCATIONS (1994) STORM SEWER/OWS PIPING
!> SOIL SAMPLE LOCATIONS (2012) FORMER UNDERGROUND STORAGE TANK FIGURE 5 AREA OF POTENTIAL AOPC 8 B2 SOIL SAMPLE LOCATIONS CONCERN (AOPC) BOUNDARY r