A GUIDE TO
THE REMEDIAL
INVESTIGATION/ FEASIBILITY STUDY (RI/FS)
KNOW WHAT IT IS:
The Remedial Investigation/ Feasibility Study (RI/FS) is an in-depth environmental study to:
1) Determine site characteristics and define the extent and magnitude of contamination at a site
2) Evaluate potential impacts on human health & the environment
3) Establish cleanup criteria
4) Identify and screen cleanup technologies
5) Assemble a range of cleanup alternatives, including a no action alternative and an alternative that removes all of the contamination
6) Evaluate cleanup alternatives against regulatory criteria
7) Identify one or more preferred cleanup alternative(s), deemed to be the most practicable cleanup alternative
The RI/FS is prepared by the liable party’s consultant under a legal agreement with the Department of Ecology (Ecology). The document is reviewed and edited by Ecology before it is issued for public review. The details given in the RI/FS are meant to provide the rationale for the preferred alternative(s).
The RI/FS is a step in the cleanup process of a contaminated site. It occurs after Ecology identifies the site and after legal responsibility for cleanup has been determined. Following public comment, the RI/FS is finalized. After Ecology selects a cleanup alternative for the site, it directs the preparation of a Cleanup Action Plan (CAP).
REVIEW THE DOCUMENT’S LAYOUT AND KEY
CHAPTERS.
INVESTIGATE THE FOLLOWING:
- Basis of decision-making
- Recurrent themes and assumptions
- Particular areas in which you have interest or expertise
QUESTION ASSUMPTIONS:
- Are the goals to preserve habitat and to dredge for contamination removal incompatible?
- Is the risk of leaving buried sediments negligible?
- Is the Bioaccumulation Screening Level protective?
- Will the removal of ASB sludges make the cleanup protective and effective over the long-
term? (as opposed to removal of sediment from the Waterway)
- Are public concerns better addressed by implementing a locally managed waterway instead of removing contamination in the waterway?
ASK YOUR OWN QUESTIONS:
- What happens to contaminated sediments in erosional areas?
- What will happen as a result of global warming?
- How can sediments be exposed?
- What do results from the log pond tests tell me?
RESEARCH THE ISSUES
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RI/FS Volume 1
Volume 1
contains the Remedial Investigation component of the RI/FS, which describes the nature
and extent of contamination and the environmental
setting at the site.
1) Introduction
This section includes a very general site description and information on document organization.
2) Project Background
This section includes information on the history of the Whatcom Waterway site, as well as the objective of this RI/FS
3) Environmental Setting
This section gives information on the physical condition, natural resources, and land and navigation uses of the Whatcom Waterway site.
4) Site Screening Levels
Ecology outlines the standards for cleanup, and the rationale for them here. Some of the standards are taken from state regulations.
Note any discrepancies between the regulation and practice:
·
A specific standard was devised for
· The depth to which the target cleanup standard applies is not regulated; it is determined by Ecology’s judgment
5) Nature and Extent of Contamination
The graphs, tables, and text outline the levels of contamination present. They paint a story about how contamination in surface layers has changed over time
Note what is not addressed:
· Retesting of samples in erosional areas
· Changes in the concentration of contaminants in the subsurface over time
· Phenol concentrations over time
6) Contaminant Fate and Transport
Information is presented on source control (prevention of recontamination), natural recovery (natural capping or burial of contamination), and factors that affect sediment stability (like wind and wave action).
Note what is not addressed:
· Potential for mercury to diffuse or move with groundwater
· Influence of changing conditions
· Method of achieving source control
7) Results of Engineering Testing
Initial tests conducted to evaluate options for sediment disposal are reviewed here.
8) Conceptual Site Model
This section includes conclusions from the Remedial Investigation. In general, the conclusions state that source control has been achieved and that the transport of historical contamination is negligible and/or will be further addressed in remedial designs. The North Sound Baykeeper believes many of the conclusions to be overly optimistic and premature.
The appendices to Volume 1 of the RI/FS show data and data summaries used to prepare the Remedial Investigation.
Appendix A Pre-Remedial Design Evaluation Report (2003)
Appendix B Sediment Data Summaries from 2000 RI/FS
Appendix C 2003 ASB Sampling Data
Appendix D Results of 2004 Testing of ASB Sludges and Berm Sands
Appendix E Data and Regression Analyses from BSL Development
The North Sound Baykeeper is concerned about the data presented here
· The regression formulated relies on the assumption that crabs caught near the Whatcom Waterway were resident.
· The consumption rate shown in the analyses does not match the consumption rate given in the RI/FS text
Appendix
F
Appendix G Enrichment Ratio Summaries for Subsurface Sediments
Appendix H Previous PSDDA Suitability Evaluations
Appendix I Year 5 Log Pond Monitoring Report
Note the log pond data at year 5 shows that there has been erosion of the interim cap.
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RI/FS Volume 2
Volume 2
contains the evaluation of cleanup technologies and alternatives that can be
used to conduct cleanup of the site.
1) Feasibility Study Introduction
This section includes a very
general site description and information on document organization.
2) Summary of
This section presents a summary from the RI. The findings state that source control has been achieved and that the transport of historical contamination is negligible and/or will be further addressed in remedial designs. The North Sound Baykeeper believes many of the conclusions to be overly optimistic and premature.
3) Cleanup Requirements
This section details the cleanup levels and the applicable laws for remediation and disposal options.
4) Sediment Site Units
This section outlines characteristics of the 8 Whatcom Waterway segments or “units.” Characteristics outlined for each segment include physical factors, land use and navigation, natural resources and contaminant distribution.
Note the land use and navigation section relies on potential land use and navigation
changes currently being visioned through the New Whatcom Redevelopment effort.
Subsurface contamination is described as “relatively low” throughout this section.
Subsurface concentrations of mercury are above the minimum cleanup level in these areas,
and in some areas above the bioaccumulation screening level.
5) Screening of Remedial Technologies
This section presents a fairly comprehensive overview of potential remedial technologies, and explains why Ecology believes that some of the technologies would not be appropriate at the Whatcom Waterway site.
6) Description of Remedial Alternatives
This section describes 8 alternatives in the following ways: actions by site unit, sediment disposal, costs & schedule, changes to existing habitat, and land use & navigation.
Note that the remedy in the alternatives does not change for some of the site units.
Natural recovery is predominantly favored for the areas adjacent to the shipping terminal and the ASB.
The only remedy for the log pond is enhanced capping.
7 Detailed Evaluation of Alternatives
This section gives the rationale for
choosing the preferred alternatives based on compliance, restoration time
frame, a ranking of benefits and a disproportionate cost-analysis
The rankings that have been given are subject to interpretation. For example,
* Overall protectiveness- high rank is based on removal of ASB sludges
* Permanence- high rank is based on full dredge
* Long term effectiveness- high rank is based on removal of ASB sludges
* Consideration of public concerns- high rank is based on creation of a
locally managed waterway and aquatic use of ASB, and therefore,
by leaving contamination in place in all areas except the ASB
8) Summary of EIS Evaluation
This section gives a summary of how well each of the different alternatives meets the EIS ranking criteria for the following: 1) Geology, Water, Environmental Health; 2) Fish & Wildlife; 3) Land Use, Navigation & Shoreline Public Access; 4 Air & Noise; and 5) Historic & Cultural Preservation
Note that a high ranking is scored for the above listed categories 1-3 for the following:
* leaving contamination in place
* creation of a locally managed waterway
* preservation of existing habitat
* creation of aquatic habitat in the ASB
9 Summary and Conclusions
This section concludes by identifying the preferred alternatives (# 5, #6). These both rely on leaving contamination in place, capping in some discrete areas, dredging the ASB, and upland disposal.
Appendix A Unit Cost and Volume
Assumptions
Appendix B Remedial Cost Estimates
Appendix C Habitat Bench Design Issues
for Areas Offshore of ASB
Appendix D Proposed Enhancements to
Shoreline Conditions within the Log Pond