ment by draining ponds with pumps for five
remain in place. No analysis of remedial alterna-
summers beginning in 1999. Pumping would
tives was conducted for the OB/OD Pad source
area. A discussion of the OB/OD Pad is provided
allow the sediments to dry and the white
in Section 9 of this ROD.
phosphorus to sublime and oxidize. The
The remedial action objectives (RAOs) for the
treatment season would begin in May and end
ERF are designed to accomplish the following:
in September. A pond elevation survey would
Within 5 years of the ROD being signed,
be conducted to determine the optimal pump
reduce the dabbling duck mortality rate
placement. To enhance drainage, explosives
attributable to white phosphorus to 50% of
may be used to make small sumps for the
the 1996 mortality rate attributable to white
pumps and shallow drainage channels. These
phosphorus. Radio tracking and aerial sur-
shallow drainage channels would enhance hy-
veys suggest that about 1000 birds died
draulic connectivity between ponds to encour-
from white phosphorus at ERF in 1996.
age drainage.
Therefore, the allowable number of duck
Implement the following protective proce-
deaths from white phosphorus would be
dures to minimize disturbances to wetlands
approximately 500.
habitat:
Within 20 years of the ROD being signed,
Restriction of activities that disturb wild-
reduce the mortality attributable to white
life in Area B and Area D, which are prime
phosphorus to no more than 1% of the total
waterfowl habitat areas.
annual fall population of dabbling ERF
Selection of the narrowest and shortest
ducks. Currently, that population is about
walking corridors to minimize disturb-
5000. Therefore, the allowable number of
ances to vegetation and habitat.
duck deaths from white phosphorus would
Proper maintenance of equipment and
be approximately 50. This long-term goal
structures.
could be adjusted based on future popula-
Minimization of the use of equipment and
tion studies conducted during the monitor-
of staging-area footprints.
ing program.
Minimal localized use of explosives.
These objectives will be achieved by reducing
Preparation of work plans and solicitation
the area of white phosphorus-contaminated
of agency reviews.
media and reducing the exposure to white phos-
Monitoring for impacts to wetlands habitat.
phorus. Reducing the exposure will reduce the
availability of white phosphorus to ducks, which
Monitoring for waterfowl use of ERF
in turn will reduce duck deaths.
Sample pond bottoms for white phosphorus
Monitoring at ERF will be conducted to verify
at the beginning of the treatment season to
that RAOs are achieved. The following are goals
confirm or determine that the pond or area
of monitoring:
requires remediation. The sampling also
To verify that an exposure pathway does not
would establish a white phosphorus baseline
exist between waterfowl and white phos-
and determine additional areas that may
phorus-contaminated sediment.
require remediation. The baseline sampling
To determine the number of waterfowl
would be performed at the beginning of each
using ERF.
field pumping season (every year for the first
To determine the number of waterfowl
5 years, starting in 1999).
dying as a result of feeding in white phos-
Sample pond bottoms for white phosphorus
after treatment to determine effectiveness of
phorus-contaminated sediment.
To determine whether remedial action is
the treatment system. This verification sam-
effective or needs modification.
pling would be performed at the end of each
The major components of the preferred reme-
field pumping season (every year for the first
dy for OU-C are listed below. It is assumed that
5 years, starting in 1999).
implementation of the remedy will begin in 1999
Perform telemetry monitoring and aerial sur-
and end in 2018 (duration of 20 years). Treatment
veys every year for the first 5 years concur-
will occur between 1999 and 2003, and will be fol-
rently with pumping activities to determine
lowed by long-term monitoring from 2004 to
bird populations, usage, and mortality. These
2018.
activities would begin in 1999. Monitoring
Treat white phosphorus-contaminated sedi-
would be continued for 3 additional years to
19
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