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By 1997, the Navy was planning to conduct four separate projects involving polychlorinated biphenyl (PCB)-contaminated soil in Hawaii. PCB-contaminated soil from several installations throughout Oahu had already been excavated and temporarily stockpiled as part of these removal actions. Additional sites were identified in 2001 and 2003. In December 2002, the Navy awarded a fixed price contract to establish unit costs for treatment of stockpiled PCB-contaminated soil, and for excavation and treatment of additional PCB-contaminated soil that would be applicable to multiple installations and cleanup programs. In cooperation with U.S. Environmental Protection Agency Region 9 (EPA) and the State of Hawaii Department of Health (HDOH), the Navy used this contract to clean up PCB-contaminated soil from 82 individual transformer sites located at 14 Navy facilities on the Hawaiian islands as follows:
In March 2003, the Naval Facilities Engineering Command (NAVFAC) Hawaii developed a white paper requesting EPA approval to consolidate PCB-contaminated soils from these facilities for treatment at one location without triggering the Off-Site Rule under the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA). This request was approved by EPA. Additional excavation and stockpiling of PCB-contaminated soil in preparation for thermal desorption was initiated in November 2003.
A step-out grid sampling approach was employed under a Triad Approach dynamic work strategy (DWS) to define the lateral and vertical extent of the excavations for the design specification package. Fast turn-around analytical results for PCBs from off-site fixed-based laboratories were used to guide the DWS. This process decreased the number of sampling mobilizations to each site and allowed for near real-time analytical results, speeding up excavation efforts at the sites. ECC, the small business, fixed-price remedial action contractor (FRAC) used the design specification package to accurately estimate the cost for the removal actions and thermal treatment and to prepare an accelerated field schedule.
The treatment system was set up in November 2003 and definitive demonstration test runs were completed in January 2004. By May 2004, more than 32,000 cubic yards (cy) had been successfully treated at the Barbers Point facility. The treatment phase of the project was completed in August 2004 with 44,500 cy of PCB-contaminated soils treated at an approximate cost of $400/cy resulting in a cost savings of $24 million compared to $1,000/cy for off-island disposal.
| Site Name | Naval Air Station Barbers Point |
| Location | Oahu, HI |
| Site Type |
Transformer Site |
| Project Lead Organization | Naval Facilities Engineering Command (NAVFAC) Pacific Division, with support and oversight from EPA Region 9 and the Hawaii Department of Health (HDOH) |
| Project Lead Type |
U.S. Navy Lead |
| Regulatory Lead Program |
Base Realignment and Closure (BRAC), Superfund Remedial (U.S. Navy Installation Restoration [IR] Program) |
| Triad Project Status | Field Program Completed |
| Reuse Objective Identified |
Yes |
| Proposed Reuse: |
Re-use of treated soil as fill at Navy facilities |
As world tensions increased in the 1930s and early 1940s leading to World War II, the Navy rapidly increased its presence and number of facilities in Hawaii. During this period, the Naval installations were established throughout Oahu, including but not limited to: Pearl Harbor Naval Complex (PHNC), Ford Island PHNC, Naval Housing, Halawa Main Gate, Navy Public Works Center (PWC) Main Complex, PWC Shipyard, Iroquois Point, Former Naval Air Station (NAS) Barbers Point, Naval Magazine Pearl Harbor (NAVMAG PH) Lualualei Branch, Waipio Peninsula, NAVMAG PH WestLoch, Naval Computer and Telecommunications Area Master Station (NCTAMS) Wahiawa, Naval Radio Transmitting Facility (NRTF) Lualualei, and NAVMAG PH Waikele Branch. This profile concerns 82 sites from these installations for which the Navy goal was to move all sites to the "No Further Action" category.
The dynamic field program at the Navy sites identified areas where concentrations exceeded the clean-up goal of 1 part per million (ppm) total PCBs. Using a high-resolution grid sampling method and fast turnaround fixed-based laboratory analytical results, data density across the site was increased, mobilizations limited, and decision uncertainty managed. Based on the high-resolution grid sampling program, more than 44,500 cy of soil exceeded 1 ppm PCBs. These soils were excavated, treated, and placed back on-site as clean fill.
The Navy's goal for this project was to work cooperatively with the regulatory agencies in efficiently addressing PCB-contaminated soil at the Navy's bases in Hawaii. Removal actions involved delineation of contaminated soil exceeding a clean up goal of 1 ppm total PCBs. Contamination was delineated using direct push grid sampling and 3 day turn around time for fixed-based laboratory analysis of PCBs. Soils with concentrations exceeding the cleanup goal were excavated, after which additional step-out samples were collected to assess the need for more excavation.
In order to avoid prohibitive transportation and disposal costs for the excavated soil, the Navy shipped a thermal treatment facility from the mainland and temporarily operated the unit at the Former NAS Barbers Point for treatment of these soils. Following removal of the PCB contamination by thermal desorption at the treatment facility, samples of the treated soil were analyzed to verify that PCB concentrations had been reduced to below the cleanup goals. With concurrence from EPA and HDOH, the treated soils were made available for backfilling the excavated areas.
To reduce the number of samples collected at large excavation sites, the FRAC collected samples based on a hexagonal grid system developed by the U.S. Department of Energy (DOE). The use of this grid system saved the Navy significant time and analytical costs.
An efficient, Triad-based, high-resolution approach to the project was founded on a cooperative relationship between EPA, HDOH, and the Navy. Based on careful planning, the EPA approved NAVFAC's request for waiver of the Off-Site Rule. This maximized the efficiency of the treatment program by building economies of scale and providing the Navy with flexibility when selecting a treatment technology. This approval was the first of its kind for any U.S. Department of Defense (DOD) installation nationwide.
The Navy estimated an analytical savings of $165,000 using the DOE's efficient hexagonal grid sampling system.
Savings for thermal treatment at former NAS Barbers Point versus off site transport and disposal were estimated at $24 million.
More than 44,500 cy of contaminated soil from 82 sites was excavated, treated, and placed back on site as clean fill in less than 2 years.
A consolidated remediation verification report (RVR) for most sites associated with thermal treatment of PCB-contaminated soil and concrete is being developed. The report consolidates information from seven previously prepared RVRs, resulting in time and cost savings to the Navy.
The Barbers Point thermal treatment project combined treatment of soil from more than 80 sites at 14 different installations as part of the delineation, excavation, and treatment process. Conceptual site models (CSMs) were developed with varying degrees of complexity for most sites.
As part of the high-resolution approach implemented at the Site, uncertainty was managed by using a grid sampling system and systematic step out sampling for horizontal and vertical contaminant delineation. Three day turn around fixed-base laboratory analysis for PCBs was also used for near real-time results to manage decision uncertainty.
Project decision logic was relatively simple: if quick turnaround time analytical results indicated PCB concentrations above the 1 ppm action level, then excavation and step-out sampling continued. If results indicated total PCB concentrations below 1 ppm, then excavation was stopped horizontally or vertically depending on the location of the sample in relation to the existing contamination.
Project goals were achieved through systematic planning and stakeholder consensus. Early and continuous communication with HDOH and EPA was necessary to obtain approval on consolidation of soils for treatment and to ensure the on-site treatment unit met all regulatory requirements. The Navy maintained essential lines of communication with the community because the excavation and treatment projects affected four different Restoration Advisory Board (RAB) communities. The project was presented to the RABs during all stages of the project from identification of the proposed alternative to the fieldwork.
Site visits to the treatment unit by RAB members and other interest groups such as the Resident Officer in Charge of Construction, Navy technical and project management personnel, and Region environmental, compliance, and safety personnel, were helpful in communicating the Navy's commitment to cleanup.
Coordination of the funding of the project from various sites and various risk rankings, along with meeting or readjusting award dates due to technical and contractual issues was necessary. Continuous discussions and meetings were held with regulators to ensure compliance with regulatory requirements and regulatory approval prior to mobilization of the low temperature thermal desorption (LTTD) treatment unit.
Systematic planning also was used to address transportation manifesting issues prior to transport of the soils from the various sites to the "on-site" treatment unit located at Barbers Point.
A small business company received the competitively bid FRAC from NAVFAC Pacific. The FRAC was committed to using local small businesses in its subcontracting plan which included waste transportation and disposal, fuel sources, backfill and topsoil transportation, utility location, equipment transportation, and hydroseeding and landscaping services.
Investigations at the sites were developed based on previous analytical results; with simple CSMs developed for each location. Based on the historical analytical results, additional soil samples were collected using direct-push technology to define the lateral and vertical extent of contamination. These additional soil samples were collected using a high-resolution step-out methodology from locations where PCB concentrations exceeded the cleanup goal of 1 ppm. This methodology involved stepping out at 5- to 10-foot lateral intervals from the initial contaminated area and collecting additional samples. In addition, samples were collected at 2-foot vertical intervals to depths of 6 feet below ground surface (bgs) at each lateral step-out location.
The first lateral and vertical samples were analyzed at the fixed-base laboratory and results were provided within three days. If concentrations exceeded the clean up goal, the next lateral and vertical samples were analyzed by the laboratory. The DWS continued in this manner until the vertical and horizontal contamination above 1 ppm was delineated.
Dynamic strategies also were used to address unforeseen site-specific operation issues regarding various aspects of the treatment system and different site and weather conditions.
Additional step out sampling protocols were outlined in the decision logic to focus additional sampling in areas where PCB concentrations exceeded 1 ppm.
Analyses for PCBs were performed using off-site laboratory method SW-846 8082. Results for critical samples were provided in less than three days. Data was managed in near real time using fast turnaround laboratory data to drive sampling and excavation activities.
Careful monitoring of dust emissions was required to ensure minimization of inhalation issues. The placement of fixed monitoring stations assisted in proving compliance during some high wind instances.
TQRS not prepared
Data quality reviews included validation of fixed laboratory data using the National Functional Guidelines
Decision support tools were not used during this project. Data management consisted of receiving electronic deliverables in Excel format from the off site analytical laboratory. Sampling locations and analytical results were entered into an Oracle database following Navy protocol.
808-474-1171 ext.341
janice.fukumoto@navy.mil 415-972-3032 mitani.lewis@epa.gov 808-586-7537 mmiyasaka@eha.health.state.hi.us 808-486-3707 Trosenbush@ecc.net 406-442-5588 ext.226 laura.newman@ttemi.comTo update this profile, contact Cheryl T. Johnson at Johnson.Cheryl@epa.gov or (703) 603-9045.
