5 71 0 File: 541.460.000nC.H.

J_ THE MEMPHIS DEPOTTENNESSEE

ADMINISTRATIVE RECORD

COVER SHEET

AR File Number _r] T

C.H.

571 1

BRAC Cleanup Team

Meeting Minutes

September 16, 1999

" 571 2

SEPTEMBER 8CT MEETINGMINUTES

Attendees

Name Organization Phone

Stanley Tyler RAB Member (901) 942-0329

Shawn Phillips Depot (901 ) 544-0611

Jordan English TDEC-DSF (901) 368-7953

Turpm Ballard EPA Region IV (404) 562-8553

Brian Deeken TDEC-DSF (901) 368-7955

JLrn Mornson TDEC-DSF (901) 368-7957

Denise K. Cooper Depot (901 ) 544-0610

Jack Kallal Depot (901) 544-0614

Scott Bradley CEHNC (256) 895-1637

Steve Duma CEHNC (256) 895-1144

Kurt Braun CESAM (334) 690-3415

Neil Anderson CESAM (901 ) 686-6195

Greg Underberg CH2M Hill (423) 483-9032

Terry Flynn Frontline (888) 848-9898

Review of Previous Meeting Minutes

The BCT discussed, approved and signed the August meeting mmutes.

Review of Open Action Items

The BCT and project team reviewed the action item list. Mr. Steve Dunn reported that the Memphis Depot

chemical warfare materiel removal action could not be moved ahead of the Ogden Depot project. Mr

Turpm Ballard responded to the question regarding the need for a feasibihty study for a record of decmton

that consisted of only institutional controls A feasibility study should be developed in order to compare the

costs of institutional controls to the costs of clean-up alternatives that allow unrestricted use. The

feasibility study will provide the public something to review by way of comparison Mr Shawn Phillipsfulfilled the action to provide the Depot Redevelopment Corporation (DRC) with documentation regardmg

sites that require no further action by providing the DRC a copy of the Federal Facilities Agreement. TheBCT changed suspense dates to pending for some project schedule items The attached action item list

provides updates to the August action items and provides action items resulting from the September BCTmeeting

Mr. Stanley Tyler requested clarificationofmformationprovlded m the action item revlew. Specifically,

Mr. Tyler asked what level of contamination would reqmre the government to return to the Memphis

Depot and conduct more cleanup actions. The BCT responded that the government would respond to

anythmg that was identified and detenmne the appropriate course of events Mr. Tyler asked ff there would

571

SEPTEMBERBCT MEETINGMINUTES

3

be some form of community notification if something was identified by a tenant. The BCT responded that

the government would be reqmred to follow the community involvement process identified in the National

Contingency Plan for removal actions, once the contamination was confirmed to be a result of the

government's past use of the facility and not from the tenant If the contamination was caused by the

tenant, then the tenant would be required to follow the same process

Review of Project Status

Offsite Monitoring Wells West of Dunn Field

Mr Kurt Braun reported that the Corps and the contractor, OHM, had negotiated the contract modification

for the installation of four additional offslte recovery wells The modification was at the district office for

s_gnature, but that it may not be signed untd the first part of October due to end of fiscal year workload

The contractor had dmcussed the project with the drilling sub-contractor and they may be able to mobilize

by the end of September based on the completed negotmtxon of the contract mo&ficatlon. Mr Braun willprovide Mr Phillips a schedule as soon as the contractors confirmed the dates

Interim Remedial Action for Groundwater Phase 11,4 - Additional Onslte Recovery Wells

Mr Braun indicated OHM had provided hun with an updated esttmate to install the four ad&tional

recovery wells Mr. Braun anticipated the wells would be installed by October 31, 1999, but wouldprovide Mr Phillips a schedule as soon as OHM confirmed the dates

Mr Philhps requested Mr. Braun and Mr. Dunn coordinate work schedules for the installation of the

&scharge piping system and the chemical warfare materiel removal action. Mr. Ptulhps requested thepiping system be m place and running by May 3, 2000

Operations and Maintenance for Wells

Mr. Braun said the contracting office had issued the request for proposal to Sverdrup Environmental, Inc.

and that they had conducted a site ws_t last week to lock at the groundwater pump and d_scharge system.

OHM and CH2M Hdl are updatmg the Operations and Mamtenance plan to mclude the monitoring

prevxously conducted by the United States Gcologlc Survey (USGS). Mr Braun anticipates recewmg the

updated plan by September 20, 1999, and awarding the contract on October 29, 1999 There will be no

break in O&M services as the current contract expires on November 4, 1999

Mr Philhps told Mr Ballard that the updated O&M plan requires two transducers to be placed m the

fluvml aquifer, one upgra&ent/onsite and one downgradient/offsite from the pumping system, to momtor

how the fluwal aquifer and the pumping system respond to precipitation The transducers monitored by

USGS were in the lower sands aquifer, but Mr. Phillips qnesttooed whether they were needed at all. The

BCT agreed the lower sands transducers were necessary to momtor how the lower sands responded to Allen

Well Field pumping Mr Braun questioned whether five transducers were enough Mr Phdhps instructedMr Braun to purchase six transducers - three for the lower sands wells, two for the fluvial aquifer and one

spare

Mr Ballard questioned if the momtonng wells to be installed west of Dunn Field would monitor the effects

of the four additional recovery wells Mr. Underberg responded affirmatwely that the additional

momtoring wells would be located to provide data on the effects of the additional recovery wells

Mr. Phillips also requested Mr Braun, Mr Underberg and Mr Dunn coordinate work schedules to allow

O&M of the onsite momtormg and recovery wells once the CWM removal action begins. Mr. Dmm

m&cated the contractors usually worked four 10-hour days, so O&M could occur on the days the

contractors were not working.

571 4 ....... ......SEPTEMBER BCT MEETINGMINUTES

Engineering Evaluation�Cost Analysis for the Old Paint Shop and Maintenance Area

Mr Braun received the final design from CH2M Hdl for this removal action Mr Neal Anderson was

reviewing the final demgn The request for proposal was scheduled to be awarded to Sverdrup by the end

of September, and the contract was scheduled to be awarded by the nuddle of November. Sverdrup would

then begm preparing the project safety and health plan and the work plan. Mr Braun anticipated the work

plan would be available for distribution to the BCT by January 15, 1999. Mr Braun will continue to

discuss vath Mr Ptullips how best to distnbut¢ the work plan. Mr Phillips anticipated a 30-day review of

the work plan by the BCT

Dunn Field Chemical Warfare Materiel Removal Action

Mr. Phillips began the chscusmon by aslang about the timeframe for work to begin at the Ogden Depot as

he wanted to discuss a trip to Ogden with the RAB tonight. The Defense Logistics Agency approved Mr.

Phdhps' request to fund the trip for two RAB members, and he wanted to begin the selection process Mr

Duma said the Site Safety Submissmn for Ogden was in the Department of Army review process, but that

he anticipated the contractors would mobilize on the jobsite m November 1999 Mr. Tyler volunteered to

mention the Ogden tnp and the need to choose two members during his BCT meeting remarks at the RAB

meeting.

Mr Dunn reported that annotated responses to comments on the draft Site Safety Submission (SSS) weresubmitted to the Depot, EPA and TDEC via emml on September 15, 1999. He requested that everyone

review their own comments and the annotated responses and contact him with any questions or comments

Mr Dunn reported that an advance copy of the draft final SSS with all appropriate Depot, EPA and TDEC

comments incorporated was scheduled to be subnutted to CEHNC for internal review on September 24,

1999. He anticipated the document would be forwarded to the BCT on October 4, 1999, with detailed

comment responses. The final SSS was scheduled to be distributed to CEHNC and the BCT in November1999. Once CEHNC has reviewed the fmal, it wall be forwarded to the Department of Army and the

Department of Health and Human Services in De_ember 1999.

Mr Ballard asked if evacuation procedures for the community had been incorporated into the Site Safety

Subrmssion as discussed at last month's BCT meeting Mr Phillips indicated he had discussed the matter

with Mr. Dunn and had provaded him with a point of contact and phone number for the Local EmergencyPlanning Committee. Mr. Phillips continued that he wanted to see m the SSS or the Protective Action Plan

(PAP) a summary of LEPC's evacuation procedures, at a mmimum, or LEPC's entire evacuatton

procedures, at a maximum. Mr Dunn &scussed the on-site notification chain and the maximum credible

event The BCT and Mr. Tyler stressed to Mr Dram that the community did not care about on-sitenotification chums or the maximum credable event The community wanted to know how they would be

notified in case of an emergency The BCT stressed to Mr Dunn that he needed to establish with the chainof notfficatlon with the LEPC and mclude this chain and the evacuation procedures in the SSS or PAP.

Mr Plulhps requested language such as, 'Upon any breakthrough of agent at the tent's exterior boundary,

the site safety and health officer will contact the LEPC LEPC will then determine how to proceed.' Mr

Terry Flynn suggested that the contractors conduct a dry run of the notification procedures once mobilized.

Mr. Phillips would provide comments on the action memorandum as soon as possible. Mr. Dunn will

provide the Depot contractor responses to the CWM removal EE/CA public comments on September 28,1999.

Dunn Field Remedial Investigation

Mr Underberg reported that CH2M I-hll processing the Dunn Field Remedml Investigatmn report and it

was on schedule to be distributed to the BCT on October 18, 1999 EPA, TDEC and CH2M l-hll

participated in a conference call on August 30, 1999, to discuss EPA and TDEC comments on the Dunn

Field risk assessment approach technical memorandum Mr. Underberg said the groundwater analytical

results from the well installed on the Belz property was free of volatde organic compounds (VOCs)

' 571 5SEPTEMBER BCT MEETINGMINUTES

Mr Phillips asked if there was a well between Dunn Field and the Allen Well Field, and Mr. Underberg

responded that it was the well installed on the Belz property that was free of VOCs. Mr. Underberg

continued that he had discussed the area's geology and hydrogeology with the University of Memphis

Groundwater Institute The general consensus was that depressed areas m the clay layer are located on

either end of Dunn Field Mr. Underberg mentioned that he needed the latest geophysical logs from USGS,

and Mr Ballard said he would contact USGS about provl&ng CH2M Hill with the information

Mr Underberg reported that he had identified with TDEC and the Depot four locations on the southeast

quadrant of Dunn Field to collect surface and subsurface soil samples One location was m the northem

porhon of the former bauxite pile area. One location was on the eastern edge of the fluorspar pile area

One was in the center ofa fiuorspar pile, and the sod bormg would be drilled through the concrete. One

was to the west of the westernmost pde In all, four soil borings to 30 feet below ground surface will be

drilled and five samples taken from each boring Three surface soil samples will be collected from a bare

spot where the newly planted grass has not grown. Aerial photos from 1964 showed a bare spot m the

same location, and that the spot was visible then. Mr Underberg said the spot could either be a swamp, as

the area holds water after a ram, or a concrete pad that has been covered with dirt since then Mr Tyler

asked what analysis would be run. Mr Underberg responded that the samples would be analyzed for the

full suite of analytes, since we have no information as to what may have been stored or spilled there. Mr.

Underberg wall provide each BCT member a sampling schedule via email

Mr. Ballard asked Mr. Underberg what he was looking at to clear the pistol range backstop Mr

Underberg responded that CH2M Hill had collected soil samples and analyzed them for metals. CH2M

Hill also dug pits into the backstop, looked through the removed dirt and found bullets. He continued that

the analytical results were not indicating risk levels that would require cleanup, but that the site was stillbeing evaluated m the Remedml Investigation Mr Underberg suggested s_eving the soft to remove the

bullets and reduce the cost of disposing of the dirt as a hazardous material, ff analytical results indicated

such. Mr. Anderson interjected that the cost of slewng the material would be manpower heavy and may not

be as cost effective as sunply removing one to two feet of sod and disposing of it

Mr Ballard suggested collecting confirmation samples before replacing any removed soft Mr Ballard also

suggested a way to calculate the risk 1) Weigh the excavated soft 2) Sieve out the bullets and weigh them.

3) Calculate the concentration as ffthe lead were chspersed in the soft, and estunate the risk from thatconcentratxon.

Mr Phillips brought the focus back to the need for a removal action or for the site to proceed through the

record of decision process. He reminded the BCT that since the lead was not migrating from the area and

that the property had not yet been transferred to become a park, the need for a removal acnon versus a

record of decision would be detenmned by the city's need for the area He suggested continuing with the

current process Mr. Braun offered the altematave that if the workload for Sverdrup slowed down, this soil

removal could be fit m. Mr. Ballard mentioned the documentation preparation and review as well as the

public participation required for a non-tune cnncal removal action and the BCT's upcommg review

schedule that may not allow a quick turn-around for a document review and approval. He continued that itcould be accomphshed as an intertm remedial action by pulhng the information from the ongoing Dunn

Field Remedml Investigation report and wrappmg it into a proposed plan. The proposed plan would also

require the BCT and public review and comment requirements, but it required less documentation

preparation than a removal action.

Main Installation Remedial Investigation

Mr. Underberg reported that the draft: final Main Installation Remedml Investigation was on schedule to bedistributed to the BCT on September 24, 1999 Mr Phillips provided Mr. Underberg the cover letter Mr.

Philhps also provided Mr. Underberg the address for Mr. David Ladd of USGS and requested two copies

be sent directly to Mr Ladd as part of the EPA subanttal.

. 571 6SEPTEMBER BCT MEETINGMINUTES

Mr. Underberg &scussed a recommendation to install another monitoring well offthe southwest comer that

resulted from development of the draft Main Installation Feasibility Study Mr Underberg indicated the

well should be installed between Elvls Presley Boulevard and the existing offsite monitoring well located

near the comer of Ball Road and Perry Road. Analytical data from this existing offsite well mdieated the

groundwater m that area was coming onto the Depot and it also indicated levels of PCE htgher than haswas found on the Depot Mr. Underberg said CH2M Hall had not determined if this was from an offsite

source and needed analytical data from the additional well to provide a better picture of what was

happening There are several potential sources, dry cleaners, m the area If the analytical data from the

additional well indicates the source is the Depot, then the data will be used to determine the extent of the

PCE plume.

Mr Philhps requested Mr Underberg to schedule installation of the additional well offthe southwest

comer of the Main Installation and provldmg the information via email directly to the Depot, EPA and

TDEC.

Mr Underberg proposed using a new amino assay field testmg kit to analyze the groundwater from theadditional well to quickly determine lfPCE was present. If this new field kit detected PCE, then Mr

Underberg wanted to close that well and move toward Elvls Presley Boulevard. Mr Plulhps respondedthat DLA would not want to chase the source once CH2M Hill determmed the Depot was not the source

Mr. Ballard interjected that the Department of Defense (DoD) has the authority to require someoneidentified as a source of contamination unpaeting DoD property to comply with the National Contingency

Plan and to clean up.

Mr. English added that the State was already planmng to conduct a prehminary assessment at that area.

He did not see identifying a potential responsible party and reqmring clean up as DoD's responslbfllty. He

said he appreciated DoD looking Into this area of contammation and for providing TDEC with the data.

Mr Underberg mentioned the PCE levels identified in the monitonng well north of Dunn Field on McLean

Street. Mr English indicated the State was also looking at that area for a possible preliminary assessment.

Mr. Ptullips mfonned Mr Underberg that if the first well installed offthe southwest comer of the MainInstallation indicated PCE, then he could install one additional well Mr. Ballard reminded Mr Phdhpsthat even if the source of the PCE contamination at the southwest comer was someone offslte, the

groundwater contanunatlon still affected the Community Environmental Response and Facditation Act(CERFA) environmental condition of category for those parcels. The BCT agreed to table this discussmn

untd they received further information regarding the source of PCE groundwater contaminatmn at thesouthwest comer of the Mare Installation.

BRAC Cleanup Plan

Ms. Cooper discussed the update of the BRAC Cleanup Plan (BCP) Work continued on Chapter 6 of the

BCP, so the Depot proposed distributing the draft BCP by September 30, 1999. The Depot will provade

revision pages that indicate text additmns and deletmns to allow greater ease m determining what was

updated. The Depot wdl request comments and concurrence on only the BCP Abstract and the installationrestoration schedules in order to forward the BCT to DLA on November 1, 1999

Ms. Cooper informed the BCT that Mr Dunn was workmg with the CWM field mvestigation contractorsand Mr Wilson Waiters, a Corps of Engineers CWM specialist, to prepare documentation regarding sites

identified as potentaally containing CWM m the 1997 Enwronmental Baselme Survey that were notincluded in the CWM removal action EE/CA Mr Philhps mdieated he had also discussed with Mr Duma

the issue of erastmg site numbers versus the site identifiers used m the CWM removal EE/CA, and MrDunn assured him the site numbers would be referenced m all future documentation.

571

SEPTEMBER BCT MEETINGMINUTES

7

Strategic Planning Session

Mr Flynn dmtributed a memo coneernlng the October 26 - 27 Memphis Depot Strategic Planning Sessionto be conducted at PickWick State Park that mcluded reformation regarding the accommodations and room

reservanons The BCT agreed to cooduct the Oetober BCT meetlag the afternoon of Monday, October 25,

1999, from 1 00 p.m until 5:00 p m. Mr Flyan will make arrangements for a conference room with the

hotel. The BCT suggested the following as Strategic Planmng Session agenda items' IRP schedule for the

BCP and the BCP Abstract. Mr. Flynn requested the project team provide Ms Alma Moore any other

agenda 1terns by October 15, 1999

Community Focus Group

Mr. Flynn provided the BCT a copy of the Focus Groups and Survey Report He indicated this report

provided the Depot and Fronthne with a real gauge of what affect the commumty relanons program have

had He continued by saying the Depot and Frontline must take this information, contmue to mold the

program based on the report's mformation and recommeodatlons, and continue to monitor future progress

using the same methods

Mr. Flyrm indicated the commumty's biggest issue, according to the focus groups and survey, was grounds

keeping. According to the report, the commumty feels that ffthe Depot cannot keep the grass mowed, thenhow can it do a quahty job of enxqronmental restoratmn, especially CWM removal The report also

mdtcated the community does not see any d_fferenee between the federal government at the Depot and the

city government. Therefore, the Depot Redevelopment Corporatmn's (DRC) actions impact the

commumty's attitude toward and trust in the Memphis Depot Caretaker Division.

Mr Enghsh recommended that the Depot resist that the DRC better involve the commumty or put more

effort into bnnging more reuse information to the commumty table He also recommended that the Depot

send the message to the commumty that public partlclpatmn regarding reuse occurred in the planmng

stages. Mr. Phllhps interjected the Depot cannot address the community's concerns regarding reuse. The

DRC is the appropriate organization to respond to these community concerns The Depot has neither the

knowledge nor the authority to respond to reuse issues involwng the DRC.

Mr Flynn continued that until the public puts pressure on the DRC, the DRC will let the Depot handle the

community's eoneems about reuse. The Depot needs to forward community information/coneerns to the

DRC for a response. The Depot should then respond to the commumty that the issue had been brought to

the DRC's attention If the Depot recewes no response, then the Depot should suggest that the community

contact the DRC or the DRC board of directors.

Mr English suggested reiterating the RAB charter mission statement as well as the missmns of the Depotand the DRC at the beginning of every RAB meeting. Mr. Jim Momson suggested the Depot prepares and

has available at every RAB meetmg a hst of frequently asked questions indicating the point of contact and

orgamzatmn to which the questaon pertains. Ms. Cooper also suggested including a reference to BCT or

RAB mectmg mmutes at which the issue was dmcussed

Mr. Flynn presented Mr. Ptulhps a plaque commemorating the 1999 Award of Excellence for External

Communicatloas Programs presented by the Canadmn Pubhc Relations Society for the commumty

relations program at the Memphis Depot Mr. Flynn also announced that the Memphis Depot's community

relations program had been awarded the International Association of Business Communicators 1999 Silver

Leaf Award for Community Relations

: 8571

SEPTEMBER 8CT MEETINGMINUTES

SI_AWN PHILLIPS

Memphis Depot CaretakerBRAC Environmental Coordinator

TURPIN BALLARD

Environmental Proteehon AgencyFederal Facihties Branch

JOint and Conservation

Division of Superfund

BRAC Cleanup Team member

DATE

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ADMINISTRATIVE RECORD

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