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Technical Review Document

Technical Review Document

Engineering Evaluation / Cost Analysis - Phase I

Former Fort Ord

Monterey County, California

June 2, 1997

This document summarizes the technical review conducted by Summit Envirosolutions,® Inc. (Summit) on behalf of Ecological Consultants for the Public Interest (ECPI). Summit conducted this review as part of the technical assistance team for the Fort Ord Toxics Project. The review addresses the technical content of the Engineering Evaluation/Cost Analysis - Phase I, Former Fort Ord, Monterey County, California.

The purpose of the Summit review is to evaluate the Engineering Evaluation/Cost Analysis (EE/CA) from a public interest point of view. For purposes of this evaluation, the public interest is interpreted to be the adequate protection of human health and the environment. Our review was general in nature and focused on the methods used to achieve the defined goals and objectives, as well as the organizational format and presentation of the technical material. Editorial comments and specific analyses of technical data were beyond the scope of this review.

The review is summarized by presenting both general and specific comments. The general comments precede the specific comments and are intended to address significant aspects of the document as a whole. Specific comments are tailored to sections within the EE/CA and are accompanied by specific document references.

General Comments

In general, the EE/CA appears to have accomplished the task of comprehensively documenting available information, conducting safety-specific risk evaluations, establishing criteria for evaluating alternatives for reducing risk associated with ordnance and explosives (OE), and making recommendations for specified areas at the former Fort Ord facility. However, clarification on a number of general and specific technical, procedural, and organizational issues is warranted in order to provide a basis for evaluating the adequacy and completeness of the EE/CA action and the recommended alternatives.

  1. The document provides several discussions regarding the goals and objectives of an EE/CA including:

Currently, these various statements present an inconsistent focus for the reader. The document would benefit from a concise Goal and Objective Statement presented in the Introduction that clearly states what the EE/CA strives to accomplish.


Based on our review of the document, it is our opinion that an adequate goal statement should read... "The goal of the EE/CA is to evaluate technically and administratively feasible alternatives for optimally reducing the risk associated with public exposures to, and interaction with OE at the Fort Ord facility. The objectives for accomplishing this goal are (1) to document available information pertaining to the nature and extent of OE at Fort Ord; (2) to identify areas where further investigation is warranted, (3) to identify risk for sites where adequate information has been developed, and (4) provide decision criteria for evaluating and recommending the most feasible alternatives. Using a defined goal as a comprehensive focus, each task can be evaluated relative to its effectiveness and/or relevance to accomplishing the goal and objectives. The goal and objective statement should be referenced in each section, or the section should include a statement of relevance to the overall goal discussed.

  1. The EE/CA was prepared based on background information and site characterization data which relied on a statistical means of sampling. As stated in the document, the statistical sampling does not diminish the potential risk to the public at the former Fort Ord, nor is it intended to demonstrate that the site is safe. This is a critical issue. While it is true that the report was prepared using the standard of care that is customary in the environmental profession, the statistical sampling and analysis protocols that support the basis for the report represent the most important component of the overall program. Without a valid, conservative, systematic, and statistically verifiable program of site investigation and data analysis, the EE/CA exercise, which is based in large part on the OECert risk evaluation model, becomes academic. The report would benefit from a discussion in the Introduction that establishes a level of confidence regarding the site characterization program conducted by other contractors. This discussion should include a reference to sampling and analysis methods, protocols, regulatory guidance, statistical analysis methods, and quality assurance and quality control measures.

  1. Figure 1.2-1 provides a schematic diagram of what is referred to as the OE removal process. It is our understanding that this figure is intended to convey the overall process and should therefore explain the relationship between Phase I and Phase II. Completion of a "Phase I" report implies that a significant stage in a series of events has been accomplished leading to the overall goal of the EE/CA. We agree that a significant amount of work has been accomplished, documented, and presented in the EE/CA - Phase I. It is unclear however, what the criteria were for distinguishing between Phase I and Phase II. It appears that a significant amount of baseline characterization work still remains to be accomplished for large portions of the facility (e.g., archives review, field sampling, data analysis, evaluation of alternatives). The document would benefit from an explanation of the decision criteria established for the Phased approach and what distinguishes Phase I from Phase II.

  1. It was stated several times throughout the document that the Ordnance Explosive Cost Effective Risk Tool (OECert) was developed by QuantiTech, Inc. under contract to the U.S. Army Engineering and Support Center, Huntsville (CEHNC). The document also noted that "the risk analysis model [was] identified for use by CEHNC", and "the use of the OECert tool for the purposes of the EE/CA has not been validated by Earth Tech." Because the model was developed specifically under contract to the CEHNC, it appears that there may be a conflict of interest by using this model as an exclusive interpretation of risk. Furthermore, since the title includes a reference to the model as a "cost effective" risk tool and a large portion of the data presented in Appendix D was directly related to cost, it appears that cost is integrated as a primary factor in the model. Based on this interpretation, it is unclear why risk is not evaluated independent of cost.



  1. The document provides a summary of detection technologies for site investigation and characterization with emphasis on future work at the site. Previous detection methods have exclusively employed the use of the magnetometer. It is unclear why only the magnetometer was used for previous investigations when the presentation of additional technologies for consideration implies potential application of a variety of methods. We strongly recommend that an up to date literature search of available technologies for detecting OE at Ford Ord be conducted. At a minimum, we recommend that the documents listed under references (page 5) be reviewed. In addition, we recommend an evaluation of the limitations of the previous investigation work which provided the basis of the EE/CA - Phase I. If alternative detection technologies prove to be more appropriate (as implied in the document), strong consideration should be given to identifying the Phase I sites where additional work should be done to reduce risk.

  1. The alternatives that were evaluated for reducing risk involve those that consider physical exposures and the hazards associated with direct OE interaction (i.e., safety issues). Although a cursory statement is made in Section 2.4.1.1 regarding the Department of Defense removal response authority, a statement which addresses the issue surrounding potential impacts to human health through alternate exposure scenarios should be made in the introduction to clarify what risks this EE/CA is addressing.

Specific Comments

Section 1.0 Introduction

Section 1.1, Page 1-3., Line 38. The document states that "New information and further discoveries will inherently affect the findings and recommendations of this EE/CA". Neither the document nor Figure 2.1-1 provides an explanation of the administrative mechanism for addressing new information in the context of the EE/CA. The discovery of chemical identification sets at site 13B earlier this year for example, represents a significant issue. The document should clarify what role Phase II or other phases will play in addressing new information, and how the new information will affect the conclusions drawn as part of Phase I.

Section 1.1, Page 1-4., Line 25. The document indicates that "The Phase II EE/CA will provide a presumptive remedy at areas of the former Fort Ord for which recommendations were not made in the Phase I EE/CA." Based on the lack of site characterization data for a number of sites scheduled for investigation in the Phase II work, it is premature to conclude that any remedial approach is "presumptivley appropriate" until more data are available. The document should clarify that a "presumptive remedy" if appropriate, will only be chosen for Phase II sites where thorough, accurate, and complete data sets have been developed which indicate that one or more response actions outlined in the Phase I EE/CA are appropriate for Phase II sites.

Section 2 Site Characterization

Section 2.3.5, Page 2-66, Line 29. The document presents an introduction to the sites for which recommendations are provided. The document states "Sufficient quantitative data exist on these sites to perform risk evaluations .... to provide recommendations based on those evaluations made." The document does not provide a qualifying statement which provides a level of confidence or assurance that "sufficient quantitative data" refer to data obtained during a rigid and systematic process of investigation, characterization, and interim remedial action. Although the EE/CA report makes reference to previous reports by contractors, the EE/CA would benefit from a more comprehensive general statement regarding the adequacy of the site characterization data being used as a basis for risk evaluations and remedial alternative evaluations.

Section 2.4.2, Page 2-135, Line 34. The document states that Earth Tech contracted with QuantiTech to evaluate the risk of public exposure to OE at selected areas of the former Fort Ord. The document does not adequately define "exposure" and should provide a comprehensive understanding of this term.

Section 2.4.2, Page 2-136, Line 23. The document states that "...Quantitech determined that the OE density estimate ranged from 12.01 per acre....to 0 per acre at sites 1, 2, 4a, 6, 9, 13a, 14SE, 17, 20, 22, ...". It is unclear how sites 1, 4a, 9, 13a, and 22 could be attributed a 0 density value when these are sites that require further sampling activity. Please either clarify the rationale here or modify the document accordingly. This comment applies to text contained in lines 32 through 36 as well.

Section 2.5, Page 2-138, Line 32. As a basis for analysis, the document refers to "pertinent regulatory guidance documents". Please reference these documents and list them in the references (Section 7.0).

Section 2.5, Page 2-139, Line 27. The document states that.".....the use of the OECert tool for the purpose of this EE/CA has not been validated by Earth Tech." It is unclear whether this comment refers to validation of the model itself, or validation of its appropriateness for use in this EE/AC. Please clarify this comment and provide justification for its use in either case.

Section 2.5, Page 2-138, Line 35. The document states that "Should site conditions or future land uses change substantially, the conclusions drawn and recommendations made for the EE/CA study areas could change substantially from present conditions." Neither the document nor Figure 2.1-1 provides an explanation of the criteria established for determining when substantial changes occur. Nor is there an explanation of the administrative mechanism for addressing new information in the context of the EE/CA. These issues should be addressed.

Section 3.0 Identification of Removal Action Objectives

Section 3.1, Page 3-1, Line 20. The document states that "Removal of all OE is not considered practicable, given technical limitations....". Generally, this statement reflects a number of concerns related to the quality of the data used to develop the EE/CA as discussed in General Comment No. 2 . At a minimum, the document should provide the public with a summary of the technical limitations (detection technology, removal technology, etc.) independent of costs, as a basis for evaluating the merits of the recommendations.

Section 3.3, Page 3-2, Line 39. The document states that the "..milestone schedule includes ...information pertinent to the successful completion of this project." The document would benefit from the presentation of a more comprehensive conceptual schedule which communicates the overall schedule for subsequent phases of investigation, characterization, risk evaluation, and remedial measures for the entire facility.

Section 4.0 Identification of Alternatives

Section 4.2, Page 4-12, Line 8. General Comment. The first paragraph provides an overview of Section 4.2. It is not clear what connection this section has to the goals and objectives outlined in the EE/CA. If the methods described in this section are consistent (or different) from methods previously employed to detect and remove OE by other contractors, it should be discussed.

If this section describes methods proposed for use as part of removal actions based on recommendations presented in this EE/CA, it should be discussed. Lastly, none of the recommendations presented in Section 6.0 refer to the methods outlined in Section 4.2. This inconsistency should be addressed.

In addition, the section is titled Remedial Technologies. Since the section addresses both detection and removal technologies, the Section should be titled OE Detection and Remedial Technologies.

Section 5.0 Evaluation of Removal Action Alternatives

Section 5.1, Page 5-3, Line 32. The section addressing the effectiveness criteria provides a four-part sub-division of the components used to derive the overall effectiveness parameter. In this four-part sub-division, protection of public safety is weighted the same as the three other components that factor into effectiveness. Since the Effectiveness Criteria is only one of three main evaluation criteria, protection of public safety is attributed an 8.25% weight in the overall evaluation. Given the importance of public safety, it seems appropriate to give a greater percentage weight to the protection of public safety qualitative evaluation of the three criteria. In addition, since Implementability and Cost are directly proportional to one another, and the effectiveness criteria is inversely proportional to both, the effectiveness criteria, that which appears most important, is rendered relatively neutral in the qualitative analysis. Clarification should be provided as to why protection of public safety is weighted so low in the overall evaluation and how the weighted values supports the goal of the EE/CA.

Section 5.3.1.2, Page 5-15, Line 12. The document references a 20-year time frame for effectiveness of institutional controls. It is not clear why a 20-year time frame was selected. The document should provide clarification for the long-term effectiveness time frame.

Section 5.3.2.2, Page 5-27, Line 4. The text, in addressing institutional controls for Low Density, Group II land uses states that "...the use of signs alone would not facilitate use of the land for its designated future land use (parks and recreation). For this reason, warning signs should be considered an interim measure, ultimately being replaced by an appropriate removal action... " Therefore, institutional controls alone cannot be a viable recommendation for this group. However, on page 5-35, lines 19-21, "The recommended alternative for low-density Group II sites is currently Alternative 2, Institutional Controls." This recommendation should be reconciled with the assessment presented on page 5-27. This type of discrepancy was also noted for low-density Group III, and moderate to high-density Group I recommendations.

References

Jet Propulsion Laboratory, California Institute of Technology. May 12, 1994. Sensor Technology Assessment for Ordnance and Explosive Waste Detection and Location. JPL D-11367 Revision.

PRC, Inc. December, 1994. Unexploded Ordnance Advanced Technology Demonstration Program at Jefferson Proving Ground (Phase I). AEC Form 45.

PRC Inc. March 1995. Evaluation of Individual Demonstrator Performance at the Unexploded Ordnance Program at Jefferson Proving Group (Phase I). AEC Form 45.

U.S. EPA, 1993. Approaches for the Remediation of Federal Facility Sites Contaminated with Explosive or Radioactive Wastes. EPA/625/R-93/013.

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