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Site Report: St Law NEC Site 31 White Alice

Site Name: St Law NEC Site 31 White Alice
Address: Northeast Cape, Saint Lawrence Island, Savoonga, AK 99769
File Number: 475.38.009
Hazard ID: 576
Status: Active
Staff: Erica Blake, 9074512182 erica.blake@alaska.gov
Latitude: 63.305306
Longitude: -168.956333
Horizontal Datum:NAD83

We make every effort to ensure the data presented here is accurate based on the best available information currently on file with DEC. It is therefore subject to change as new information becomes available. We recommend contacting the assigned project staff prior to making decisions based on this information.

Problems/Comments

26 acre White Alice site operated from 1952-76 consisting of seven abandoned buildings, four radio antennas, four ASTs, and an abandoned tramway leading up Kanukhsam Mountain. PCBs and POLs found in soils. PCBs are on concrete transformer pads and adjacent soils. 1990 removal action removed 1000 drums and 29 transformers. POLs associated with former tanks and fuel lines. A Building Demolition/Debris Removal was completed in 2003. All the buildings, above ground structures and debris were removed including those at the White Alice site. IRP site. Air Force site deactivated 1976, transferred to Navy in 1982 for use as Arctic Submarine Lab. DSMOA site. A Building Demolition/Debris Removal was completed in 2003. All the buildings, above ground structures and debris were removed. The tram system is scheduled for removal in 2005.

Action Information

Action Date Action Description DEC Staff
8/29/1986 Preliminary Assessment Approved Site inspection by J. Gusmano and D. Johnson of EPA found 1,000 pounds of sludge, 1,000 gallons oily waste, 1,500 gallons solvents, 7 transformers, inorganic chemicals, acids, bases, and heavy metals. PCBs and oil detected in soil. Former Staff
1/1/1990 Preliminary Assessment Approved Naval Energy and Environmental Support Activity conducted Preliminary Assessment entitled "Draft Preliminary Assessment White Alice Site, Northeast Cape, Saint Lawrence Island, AK". All surface water expected to discharge to Bering Sea within 1.5 miles. Potential for PCB contamination and POLs identified due to transformers and storage tanks. Former Staff
7/4/1990 Interim Removal Action Approved (Old R:Base Action Code = SC - Site Control (Emergency Response)). URS Consultants removed 1,000 drums and 29 transformers. Drums were transported to Elmendorf via barge. Removal action required helicopter. Former Staff
7/4/1990 Update or Other Action (Old R:Base Action Code = SI - Site Investigation). URS Consultants conducted site investigation at 4 sites. Report entitled "Site Inspection, White Alice Site Northeast Cape, Saint Lawrence Island, Alaska, Final Report", dated 5/22/91. Former Staff
7/17/1990 Update or Other Action (Old R:Base Action Code = RAPR - Remedial Action Plan Review (CS)). URS Consultants, Inc. Draft Project Plans, Work Plan, Field Sampling Plan , QA Project Plan, and Site Health and Safety Plan for White Alice site. Former Staff
12/6/1990 Site Number Identifier Changed Old Reckey 1988320130901. Changed to reflect correct workplan. Former Staff
12/27/1990 Site Ranked Using the AHRM Initial ranking. Former Staff
8/1/1991 Update or Other Action (Old R:Base Action Code = MS - Monitoring/Sampling). URS Consultants conducted additional PCB, VOC, and pesticide sampling for the Navy due to data validation problems with the original data. Former Staff
5/21/1992 Site Ranked Using the AHRM Re-ranked, still too many unknowns. Former Staff
6/3/1992 Update or Other Action (Old R:Base Action Code = NFA - No Further Action Required (CERCLA)). ADEC did not close site, but it is not included on the NPL. EPA has listed this site for No Further Action. Former Staff
10/15/1992 Update or Other Action (Old R:Base Action Code = SI - Site Investigation). Reviewed Revised Site Inspection for the facility which indicates significant PCB contamination on the former transformer concrete pads. Low levels of PCB and VOCs also detected in stream sediment. ADEC recommends removal action and that extent of contamination be determined. Laura Noland
2/18/1993 Meeting or Teleconference Held ADEC facilitated meeting between Navy, Air Force, and Army Corps of Engineers to plan cooperative work at co-located sites such as NARL and POW Main Dewline and Wales, Tin City, and Saint Lawrence Island. Former Staff
3/23/1993 Interim Removal Action Approved ADEC requested Navy place warning signs in both English and local dialect to warn residents of contaminated soils. Laura Noland
9/8/1993 Interim Removal Action Approved (Old R:Base Action Code = SC - Site Control (Emergency Response)). Met with Navy representative who completed cap cover over dioxin contaminated soils at Wales, boarded buildings at Tin City and NE Cape, and erected signs at all three sites. Community meetings were held and fact sheets distributed. Laura Noland
1/25/1994 Site Added to Database PCBs, POLs, and pesticides. Former Staff
3/24/1997 Update or Other Action Site updated by Shannon and Wilson, based on the Navy Relative Risk Evaluation Worksheet dated 5/30/95. Individual sites assigned separate Reckey numbers: 198832X930902 (Site 0006), 198832X930903 (Site 0007), and 198832X930904 (Site 0008). S&W
12/1/1999 Update or Other Action No work has been performed at this site since 1993. The COE and Navy are currently negotiating over responsibility. The ADEC is attempting to aid in coordination between the two agencies to achieve a joint cleanup effort. Jeff Brownlee
9/13/2000 Site Ranked Using the AHRM Changed the Environmental/Recreation Area Value from 2 to 0. Score changed from 60 to 40. Former Staff
9/26/2000 Update or Other Action The COE has agreed to include this site in the FUDS program. It will be added to the Saint Lawrence Island Northeast Cape DERP/Army site. Jeff Brownlee
3/11/2002 Meeting or Teleconference Held Staff participated in a Restoration Advisory Board meeting for Northeast Cape and Gambell. Also participating in the meeting was the TAPP grant manager, Alaska Community Action on Toxins, ATSDR, the COE and their contractor. Dr. Bob Johnson with ATSDR presented information on the Reindeer Health Consultation. PAHs were found in low concentrations in reindeer tissue, but at levels well below benchmarks that would be considered a health risk at conservative subsistence use values. It was discussed that the reindeer range over the entire island and contaminant correlation with a particular site would be difficult. The Phase III investigation performed in Gambell was discussed. Jeff Brownlee
4/29/2002 Update or Other Action Staff reviewed and commented on a draft Engineering Evaluation/Cost Analysis for work at the White Alice Site at Northeast Cape. The work involves mostly Building Demolition/Debris Removal, but includes some Con/HTW. Concrete pads supporting transformers have will be remediated, and there will be a removal of an AST, a few dozen drums and three septic systems and associated piping. The work will include characterization/closure sampling for areas with know or potential contamination. Jeff Brownlee
1/29/2003 Update or Other Action Staff coordinated with Health and Social Services Epidemiology Section on responding to a report written by Alaska Community on Toxins (ACAT). The ACAT report, Contaminants in Wildlife and People of St. Lawrence Island, Alaska: A Report to the Communities of Savoonga and Gambell, was released in October 2002. The report claimed that St. Lawrence Islander people had a PCB concentration in blood higher than the norm. The report also claimed a causal effect between PCBs found in community members’ blood and military activity on the island, specifically Northeast Cape. After review of the data Epidemiology concluded that the PCB blood concentration in the people of Saint Lawrence is comparable to other Alaska communities dependant on a subsistence lifestyle. The review also concluded that the PCB blood concentrations detected are likely a result of global contamination through the food chain, although both Epidemiology and the DEC support continued cleanup of the military sites on the island. Jeff Brownlee
2/14/2003 Meeting or Teleconference Held Staff participated in comment resolution meeting for work at Northeast Cape planned for this summer and the 2004 field season. The work involves Building Demolition/Debris Removal and some Containerized Hazardous Waste removal. The primary issue that developed during the review was changing the Corps of Engineers anticipated cleanup level in concrete and soil from 25 mg/kg to one. A risk assessment has been performed for PCBs at Northeast Cape, but the risk calculations were not carried through to specific cleanup levels. Much of the building material contains mixed asbestos waste that would not be cost effective to separate into different waste streams, so the majority of debris (approximately 12,000 cubic yards) will be considered asbestos waste and containerized for off-island disposal. Jeff Brownlee
4/10/2003 Meeting or Teleconference Held Staff participated in a Restoration Advisory Board meeting for the two Formerly Used Defense Sites on Saint Lawrence Island. Upcoming projects for the summer were discussed. A Native American Lands Environmental Mitigation Program (NALEMP) project is scheduled in Gambell this summer. Portions of two military dump sites will be excavated and the debris removed off island. The work is being done because new housing is planned for these areas. A large Building Demolition/Debris Removal is planned for Northeast Cape. The project is scheduled for two years and includes some Containerized Hazardous Waste removal. The Alaska Community Action on Toxins (ACAT) report on PCB in blood serum of the Saint Lawrence Island people was discussed. There was some disagreement on interpreting the State Epidemiology review of the report, which indicated there were statistical and procedural problems with the report. Unfortunately there was no representative from Epidemiology to help clarify the issues. Dr. David Carpenter (State University of New York) was hired by ACAT to conduct the study and produce the report. Dr. Carpenter and ACAT participated in the RAB meeting. Jeff Brownlee
12/4/2003 Update or Other Action CS staff reviewed the previous environmental investigative work at Northeast Cape on Saint Lawrence Island for completeness. There has been stakeholder concern (chiefly Alaska Community Action on Toxins - ACAT) that several sites at the Cape have not been adequately characterized. Several data gaps were identified, but none that would not allow development of the feasibility study. The previous three investigation phases have been done with State approved workplans and reports according to industry standards Jeff Brownlee
12/23/2003 Update or Other Action CS staff reviewed and comment on a draft final risk assessment (human heath and ecological) for contamination at Northeast Cape on Saint Lawrence Island. The assessment was also reviewed by our risk assessor and a term contractor. Several sites are over risk departure numbers for both human health and ecological risk. The majority of sites over target hazard index and cancer risk levels are based on cumulative numbers. We are asking for summary tables separating the current exposure scenarios from potential future receptors settings. A large part of the risk drivers at the sites is from contaminated groundwater, which has to be evaluated by regulation, but is unlikely to be a future exposure pathway. The assessment does not carry through to risk based cleanup number which we need to have for the feasibility study and development of potential cleanup levels. Staff is working with the COE to incorporate our comments into a final document for department approval. Jeff Brownlee
1/22/2004 Meeting or Teleconference Held CS staff participated in a Restoration Advisory Board meeting for the FUDS on Saint Lawrence Island. Also participating were approximately 20 RAB members, Alaska Community Action on Toxins (ACAT), the RAB Technical Assistance Program (TAP) coordinator, the attorney for the two Saint Lawrence Island Native Corporations and a reporter for KALM radio in Nome. A summary report was presented of the building demolition/debris removal work done last summer at Northeast Cape. All of the buildings at the White Alice Site and the main Headquarters area have been removed. The COE is intending to award optional contracts for 2005 to remove some remaining items including the tram system to the former radar facility on a nearby mountain. CS staff summarized the characterization effort to date by site and discussed data gaps. The COE has decided to do one more investigation to address these data gaps. The investigation is planned for this summer and will include several groundwater monitoring wells. The Feasibility Study that was done for Gambell was discussed. Three sites remain that require a remedial action. Two sites need some additional hydrogeology information to support the proposed Method Two ingestion cleanup level. The Gambell NALEMP (Native American Lands Environmental Mitigation Program) report was also discussed. Approximately 50-tons of metallic debris from two former landfills were removed. The debris was mixed empty drums, Marston matting, engine parts, cable, piping and miscellaneous scrap. About 3-tons of incidental contaminated soil was containerized in super sacks and disposed off island with the metal debris. Confirmation sampling showed excavation limit results below Method Two cleanup levels. Jeff Brownlee
1/29/2004 Meeting or Teleconference Held CS staff participated in a comment resolution meeting for a risk assessment at Northeast Cape on Saint Lawrence Island. Also participating were members of the Restoration Advisory Board, Alaska Community Action on Toxins, The Technical Assistance Program coordinator for the RAB, The Army Center for Health Promotion and Preventive Medicine (CHPPM), the Native Corporations attorney, and the COE and their contractor. The risk assessment is in the draft final stage. The COE has incorporated all the draft comment changes and has included groundwater as an exposure pathway. The COE agreed to include summary tables that will allow readers unfamiliar with risk assessments to easily compare the site risks with the different exposure scenarios (for example permanent resident vs. subsistence user) (Brownlee, Smith) CS staff reviewed a preliminary workplan for investigation work at the Northeast Cape FUDS on Saint Lawrence Island. The investigation work will take place this summer and be the final investigation before the feasibility study (FS). Several monitoring wells will be installed as well as sampling of soil, sediment, groundwater and surface water. The work should provide information to fill data gaps and delineate contamination to better prepare volume estimates in the FS (Brownlee). Jeff Brownlee
9/10/2004 Site Characterization Report Approved Contaminated Sites staff reviewed a draft Removal Action Report for work done at the Northeast Cape FUDS on Saint Lawrence Island. An approximately $10 million building demolition/debris removal was performed by the Corps of Engineers at the site in 2003. A limited Containerized Hazardous and Toxic Waste (CON/HTW) removal was also conducted mostly at the White Alice site which is about a half mile uphill from the main Northeast Cape facility. All of the buildings and the majority of loose debris such as pole lines and antennae were removed and disposed of off island. A contract was approved to finish remaining optional work at the site in 2005. This work includes removal of the former tram system for the mountain top radar station and removal of 100-tons of Polychlorinated Biphenyl impacted soils Jeff Brownlee
11/19/2004 Site Ranked Using the AHRM Jeff Brownlee
1/24/2006 Meeting or Teleconference Held Contaminated Sites staff attended a Restoration Advisory Board meeting in Savoonga for the Formerly Used Defense Site projects on Saint Lawrence Island. The meeting was well attended by RAB members, community members, COE, Technical Assistance Program (TAP) coordinator, Alaska Community Action on Toxins, attorney for the corporation, and DEC. Agenda items included discussion on the biogenic vs petroleum fraction in sediment samples taken during the Phase IV RI. The DEC and COE explained how cleanup levels are determined in sediment and the results of the 2001 Risk Assessment. If the AK 102 levels found in sediment were considered to be 100% petroleum the risk would remain about the same and the response would remain the same. The DEC also explained the how remedial actions are determined through weighing the balancing criteria including toxicity reduction, long term solution, cost, community acceptance, etc Jeff Brownlee
5/4/2006 Update or Other Action Contaminated Sites staff reviewed and commented on a 2005 Interim Removal Action Report for the Northeast Cape Formerly Used Defense Site on Saint Lawrence Island. The work completed the Building Demolition/Debris Removal and Containerized Hazardous Waste project from 2003. Work completed included removal and off-island disposal of about 1,500-tons of debris, burning 370-tons of wood, disposing of approximately 290-tons of PCB contaminated soil and 160-tons of PCB impacted concrete Jeff Brownlee
9/15/2006 Update or Other Action Contaminated Sites staff reviewed and commented on a draft Feasibility Study for the Northeast Cape Formerly Used Defense Site on Saint Lawrence Island. No further action is proposed for 17 out of 30 sites at the facility. The study presents several remedial alternatives for the remaining sites including containment such as capping, insitu such as chemical oxidation and ex-situ treatments such as incineration or excavation and off site disposal. Limited actions such as natural attenuation, long-tem monitoring and institutional controls are also evaluated. The study does not attempt to choose specific alternatives, but evaluates the balancing criteria including cost for each individual site. Remedial alternatives will be chosen during development of the Proposed Plan. It is probable that many of the sites will have chosen remedies that are a combination of the presented alternatives for example excavation and off-site disposal combined with institutional controls and long-term monitoring Jeff Brownlee
6/22/2007 Exposure Tracking Model Ranking Jeff Brownlee
7/10/2007 Proposed Plan Final approved. Jeff Brownlee
7/24/2007 Meeting or Teleconference Held Contaminated Sites staff participated in a Restoration Advisory Board (RAB) meeting, public meeting and tribal meeting to introduce the proposed plan for the Northeast Cape FUDS. The meetings were held in Gambell and Savoonga and were well attended with high interest from the community. Alaska Community Action on Toxins (ACAT), the Technical Assistance Program (TAP) coordinator, corporation attorney, and Corps of Engineers were represented at the meeting. The proposed plan outlines the preferred remedies for the 34 sites at the facility Jeff Brownlee
1/8/2008 Meeting or Teleconference Held Contaminated Sites staff participated in a Restoration Advisory Board meeting for the Formerly Used Defense Sites on Saint Lawrence Island, Alaska. The meeting was held in Savoonga and attended by members of the RAB and community, Corps of Engineers, the COE contractor, Alaska Community Action on Toxins, the attorney for the native corporation, and the Technical Assistance Program advisor for the RAB. Agenda items included a discussion of the geophysics results of the investigation at the Site 7 Landfill, Responsiveness Summary for the Northeast Cape Proposed Plan and the changes to the plan that are resulting from those comments Jeff Brownlee
10/22/2008 Meeting or Teleconference Held Contaminated Site staff participated in a consultative meeting with the leadership from Saint Lawrence Island and Alaska Community Action on Toxics (ACAT) concerning the Formerly Used Defense Sites (FUDS) on the Island. The commissioner and SPAR director also participated. The island leadership and ACAT wanted to meet with the department to communicate concern about the environmental cleanups at Gambell and Northeast Cape. There is ongoing concern and perception that the FUDS are causing increased cancer incidence on the island. The community also is concerned about the two landfills that will remain at Northeast Cape and the contaminant impacts to an area creek/drainage area and soil and groundwater. The Corps of Engineers has $23-million programmed to address remaining contamination over the next few years Jeff Brownlee
11/7/2008 Update or Other Action Contaminated Sites staff reviewed a draft Decision Document for the Northeast Cape Formerly Used Defense Site (FUDS) on Saint Lawrence Island. There are several sites at the former surveillance station and White Alice Site to be remediated. The Headquarters Area has extensive diesel range organics impacting soil and groundwater. An insitu chemical oxidation pilot test will be done at a portion of this area to assess effectiveness for treating the larger contaminant mass. The drainage and wetlands below the Headquarters Area is planned for dredging or excavation of the more highly impacted sediments. There are several sites that will be excavated for petroleum and Polychlorinated Biphenyl (PCB) soil contamination. There will be institutional controls on several areas including two landfills, areas with residual petroleum impacts and shallow groundwater use controls Jeff Brownlee
3/31/2009 Meeting or Teleconference Held Contaminated Sites staff participated in a Restoration Advisory Board (RAB) meeting for the Northeast Cape Formerly Used Defense Site (FUDS). The meeting was held in Savoonga on Saint Lawrence Island and attended by the Corps of Engineers, the Technical Assistance Program representative, Alaska Community Action on Toxins, the Island Corporations attorney, RAB members, and interested community members. Discussion items included the Northeast Cape Decision Document which is in draft final review, remedial activities planned for this summer including Site 7 landfill investigation and capping and the Headquarters area chemical oxidation pilot study. We also discussed the ongoing Gambell NALEMP project and a new NALEMP project being started for the Fish Camp at Northeast Cape to remove possible lead based paint and asbestos in cabins built in the area from abandoned facility materials Jeff Brownlee
8/10/2010 Site Visit Contaminated sites staff conducted site visits and field work inspections at the sites where work was being conducted during the four-month long 2010 mobilization. Various remediation efforts were being conducted at sites 1, 3, 6, 8, 9, 13, 16, 21, 31, 28, and the Main Operations Complex (MOC) per the 2010 workplan. Work involved excavation and offsite disposal of nearly 4,000 tons of soil contaminated with POL's and PCB's. A UVOST investigation was also conducted at the MOC site. Other work conducted also involved the removal of dozens of frost-jacked wooden poles site wide, the collection and landfilling of debris distributed sitewide, as well as reseeding the site 7 landfill cap where remedial work was initially conducted in 2009. Travel to Northeast Cape was via airplane out of Anchorage and Nome, Alaska. Curtis Dunkin
2/3/2011 Exposure Tracking Model Ranking Initial ranking with ETM completed for source area id: 78224 name: Transformers - PCBs Bianca Reece
2/3/2011 Exposure Tracking Model Ranking Initial ranking with ETM completed for source area id: 78225 name: AST, fuel piping Bianca Reece
8/10/2011 Site Visit Staff conducted site visits to observe the status of ongoing remediation work being conducted by the Army Corps. of Engineers under the 2010 HTRW Removal Action Work Plan. 2010 remediation efforts included the removal of 1,500 tons of PCB-contaminated soil at sites 13, 21, and 31; the removal of 2,700 tons of petroleum-contaminated soil at Sites 3, 6, and 32, the removal of 17 tons of arsenic-contaminated soil at Site 21; construction of a landfill cap at Site 9; and the removal of 38.5 tons of metal and wood debris from Sites 9, 29, and site wide. Other work conducted included a UVOST investigation to delineate the petroleum-contaminated soil at the main operations complex, ground water monitoring at the main operations complex, and monitoring of natural attenuation of diesel contamination at Site 8 via surface water and sediment sampling. Curtis Dunkin
10/13/2015 Meeting or Teleconference Held CS staff participated in the semiannual Restoration Advisory Board (RAB) meeting which was conducted in Savoonga, AK on Saint Lawrence Island. Participants included representatives from the Army Corps of Engineers, ADEC, Savoonga residents and RAB members, the Alaska Community Action on Toxics, and the University of Alaska, Anchorage (UAA). The agenda included presentations by the Army Corps which summarized the 2014 and 2015 remedial efforts and results. The Army Corps conducted the last major removal and offsite disposal actions in 2014 and conducted groundwater monitoring at the Main Operations Complex in 2015; the 2015 draft report is pending. Dr. Frank von Hippel of UAA presented a summary of the results from a multi-year fish tissue sampling and analysis study to evaluate PCBs in Nine-spine Stickleback and AK Blackfish in the Suqi River; the drainage of which flows through the Northeast Cape FUDS. Curtis Dunkin
1/9/2017 CERCLA Removal Action Report ADEC received the Final 2014 Northeast Cape Removal Action Report (which is dated May 2016), and submitted final approval of the report to the Army Corps of Engineers. Site characterization and removal action requirements that are outlined in the 2009 Decision Document were conducted in consecutive years since 2009 and were completed in 2014. Future and ongoing work planned within the current five-year review period (2014-2018) includes monitoring as well as follow-on sampling and analyses of surface waters, sediments, groundwater, and soils; including the development and implementation of land use controls, and notices of environmental contamination with the landowner. Curtis Dunkin
6/1/2018 Document, Report, or Work plan Review - other ADEC reviewed the draft 2018 Remedial Action Review Work Plan and submitted comments to the Army Corps of Engineers. Curtis Dunkin
8/6/2018 Site Visit ADEC project manager traveled to Northeast Cape, Saint Lawrence Island, overnighted two nights onsite, and conducted three days of site inspections and field work observations with representatives of the Army Corps of Engineers and their technical contracted support who were implementing the 2018 Long-term Monitoring and Addendum Site Investigation Work Plan. Curtis Dunkin
11/15/2018 Meeting or Teleconference Held ADEC project manager participated in a technical project planning meeting with representatives from the Army Corps of Engineers and their contracted technical support staff to discuss the preliminary laboratory analysis results and field activities, as well as the prospective reporting of the 2018 long-term monitoring and addendum investigation efforts. Curtis Dunkin
2/15/2019 CERCLA ROD Periodic Review CERCLA Five-year Review Questionnaire Submitted: ADEC completed its responses to the questionnaire (5 pages) for the prospective draft Second CERCLA Five-year Review for the Northeast Cape FUDS sites and submitted its responses to the Army Corps of Engineers. Scheduled distribution date of the draft review report is May 2019. Curtis Dunkin
3/20/2020 CERCLA ROD Periodic Review ADEC reviewed the draft 2019 Second Multi-site Sitewide Periodic Review Report and submitted comments to the Army Corps of Engineers. Curtis Dunkin
6/30/2020 CERCLA ROD Periodic Review ADEC received and reviewed the responses to comments from the U.S. Army Corps of Engineers for the draft 2019 Second CERCLA Multi-Site Periodic Review. Curtis Dunkin
7/27/2020 CERCLA ROD Periodic Review ADEC received and reviewed additional responses to comments and participated in a resolution meeting for the draft 2019 Second CERCLA Periodic Review Report with representatives from the Army Corps of Engineers and their contracted technical support. Curtis Dunkin
8/2/2022 Site Visit ADEC staff traveled to Northeast Cape and conducted three days of field inspections and site visits in conjunction with the Army Corps of Engineers' implementation of the 2022 Work Plan effort that includes site 28 sediment removal and various follow-up actions at multiple sites from the Second Five-year and Periodic Reviews. The field team's mobilization to the site began in mid July and field work is anticipated to continue through the month of August. Additional site characterization is being conducted at site 8 and removal actions are occurring at the sites 15 and 28. Curtis Dunkin

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