First Environment is currently conducting semi-annual groundwater sampling, analyses, and reporting pursuant to a RCRA Hazardous Waste Facility Permit at the Open Burn / Open Detonation (OB/OD) Units of Anniston Army Depot in Anniston, Alabama. The OB/OD Units consist of approximately 120 acres designated as operational waste disposal units under RCRA and the units are used to burn off-specification rocket motors and detonate out of date or damaged munitions.
The contract period commenced in March 2012 and continues through 2017 under a base year period, plus four optional yearly renewal periods at the discretion of the facility. The scope of work includes the sampling of eight monitoring wells (four at the OB and four at the OD Unit) twice each year (spring and fall) for permit-specified constituents including volatile organic compounds, semi-volatile organic compounds, total and dissolved metals, explosives, and general chemistry parameters using sampling protocols required by the Alabama Department of Environmental Management (ADEM).
Samples are submitted to a DOD-approved sub-contracted laboratory for analysis and, upon receipt of the analytical data, First Environment conducts a detailed data validation. The validated results are then used to prepare a statistical analysis report of the results for submittal to ADEM within 38 days of the sample event.
Following the second monitoring event in December, a comprehensive annual groundwater monitoring report is prepared for submittal to ADEM within 50 days of the last event. The annual report includes discussions of sampling methods, water levels, groundwater flow directions, summaries of analytical results, and conclusions and recommendations for continued permit compliance, as well as supporting figures, tables, and appendices. The report complies with ADEM RCRA Permit and Clean Water Act Requirements.
This project posed several unique challenges at startup. Various previous contractors had conducted sampling and analyses dating back to 2005; however, ANAD could not provide a database of existing results or electronic files for statistical analyses for any of the pre-First Environment results. First Environment personnel combed through copies of lab data in old reports and assembled an electronic database for the site analytical results. First Environment then compiled the results from the last 12 sampling events and entered them into a statistical analysis program to allow completion of the May 2012 statistical evaluation within the contract-specified time frame.
First Environment’s approach to the groundwater monitoring program included a preliminary site visit to meet the key Anniston Army Depot staff and coordinate the site activities with the Unit managers. Field work is conducted by a veteran team of two environmental geologists experienced in working at DOD sites.
Both the OB/OD Units are active facilities within a restricted access area of the Depot (requiring special security clearances and badges), with daily munitions destruction events, and sample events required detailed planning and coordination (including radio contact procedures) to avoid delays or hazardous situations. Sampling events were conducted over two-day periods determined by the Unit destruction schedules, and have been frequently interrupted by munitions disposal activities that required First Environment personnel to leave the site for up to an hour at a time. Even with the interruptions, the sampling activities were completed on-schedule.