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EPA/ROD/R06-03/568 2003 EPA Superfund Record of Decision: FORT CHAFFEE EPA ID: AR1213720187 OU 07 FORT CHAFFEE, AR 04/29/2003
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RECORD OF DECISION (RODS)Record of Decision:
FORT CHAFFEE EPA ID: AR1213720187 OU 07 FORT CHAFFEE, AR 04/29/2003
RECORD OF DECISION FOR TWO NO FURTHER ACTION GROUP VI ENVIRONMENTAL SITES
FORT CHAFFEE, ARKANSAS
1.0 DECLARATION
This Record of Decision (ROD) document addresses two environmental sites at Fort Chaffee, Arkansas, FTCH-045, Wood Dump Area (Site 45) and FTCH-013, Solid Waste Incinerator Slag Piles (Site 13). The United States Army has been identified as the lead agency for Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) response actions for the Fort Chaffee sites. The United States Army Fort Chaffee Base Transition Team (BTT) is the on-site organization responsible for the response actions.
The two No Further Action Group VI Environmental Sites, referred to herein as the Group VI Sites, have been identified to have some potential to require a response under CERCLA. In the Proposed Plan of Action for Group VI Environmental Sites (BTT, 2003), issued for public review on February 17, 2003, information from various environmental site investigations was summarized and the two Group VI Sites were proposed for no further action. No CERCLA action is necessary at Site 45 and no further CERCLA action is required at Site 13 to be protective of human health and the environment for the reasonably anticipated future industrial land use.
Areas that are to be transferred from the United States Army for reuse are referred to as the Excess Area. The area to be retained by the United States Army is referred to as the Enclave Area. Most of the Enclave Area is licensed to the Arkansas Army National Guard. The two Group VI Sites addressed in this ROD are located in the Excess Area. The two sites will be transferred to the Fort Chaffee Redevelopment Authority. The use of FTC11-013 will be restricted to industrial, which is the reasonably anticipated' future use. The FOST and deed will specify that the use of FTCH-013 be consistent with its reasonably anticipated industrial use. Although FTCH-045 is a no action site, certain use restrictions exist in most of the Wood Dump area by virtue of it co-location with two other environmental sites, FTCH-001 and FTCH-013. Dig and other notices associated with protection and maintenance of the remedy have been imposed on a portion of FTCH-045 that is overlain by the Additional Unpermitted Trench Area (AUTA) of Sanitary Landfill 41 (FTCH-001) cap. These notices have been set forth in the decision document for FTCH-001, Record of Decision for No Further Action at Two Group V Environmental Sites, Fort Chaffee, Arkansas, September 2001 and are available for review in the Administrative Record for Fort Chaffee. Additionally, the industrial land use restriction associated with SITE 13 has been imposed on that portion of FTCH-045 that is co-located with the Incinerator Slag Piles.
Record of Decision Page 1 of 11 Revision 0 Two No Further Action Group VI Environmental Sites April 2003 United States Army Fort Chaffee Base Transition Team Fort Chaffee, Arkansas
Fort Chaffee Base Transition Team Environmental Compliance Office
Building 2033 Barling, Arkansas 72923
or
Fort Smith, Arkansas 72903
The Army encourages the public and other interested parties to review relevant information to gain a better understanding of these environmental sites. All sampling results used for site evaluations of the current environmental condition at Fort Chaffee are part of the information in the Administrative Record for Fort Chaffee. The Administrative Record for Fort Chaffee environmental compliance efforts can be viewed at either of the following two locations:
1.1 FTCH-045: Wood Dump Area
This site is located at Fort Chaffee, Arkansas as shown on Figures 1 and 2.
1.1.1 Statement of Basis and Purpose
This decision document presents the no action decision for the site listed above. In accordance with CERCLA as amended by the Superfund Amendment and Reauthorization Act (SARA), United States Army Regulation 200-1, and to the extent practicable, the National Contingency Plan, no CERCLA action is necessary for this site. This decision is based on the Administrative Record file for this site.
1.1.2 Description of the Selected Remedy
No CERCLA removal action or remedial action is necessary for this site. Selection of no action is based on knowledge of site history and site operation. For the activities associated with the use of the site as a wood dump, no clear or significant adverse environmental impact was identified and no clear or significant risk to human health or ecological receptors could be identified. Evaluation of current site conditions supports the decision of no action.
1.1.3 Statutory Determinations
None of the CERCLA 121 statutory determinations are necessary since no remedy is being selected. No removal action or remedial action is required to further ensure protection of human health and the environment. Because no remedial action is needed (and therefore not selected) a five-year statutory review will not be conducted.
Record of Decision Page 2 of 11 Revision 0 Two No Further Action Group VI Environmental Sites April 2003 United States Army Fort Chaffee Base Transition Team Fort Chaffee, Arkansas
1.2 FTCH-013: Solid Waste Incinerator Slag Piles
This site is located at Fort Chaffee, Arkansas and is shown on Figures 1 and 2.
1.2.1 Statement of Basis and Purpose
This decision document presents the no further action decision for the site listed above. In accordance with CERCLA, no further CERCLA action is necessary for this site as amended by the Superfund Amendment and Reauthorization Act (SARA), United States Army Regulation 200-1, and to the extent practicable, the National Contingency Plan. This decision is based on the Administrative Record file for this site.
1.2.2 Description of the Selected Remedy
No further CERCLA remedial action is necessary for this site. The decision of no removal action or remedial action is based on knowledge of site history and site operation. Evaluation of current site conditions, including the surface soil sampling, subsurface soil sampling, and groundwater sampling supports the decision of no further action at this site. The no further action is also based on the most reasonably anticipated future industrial use of this site. However, deed restrictions for Site 13 assure that the future land use will remain industrial.
1.2.3 Statutory Determinations
No further remedial action is required to ensure protection of human health and the environment. None of the CERCLA 121 statutory determinations are necessary in this section since no remedy is being selected. The site is in compliance with acceptable risk levels for industrial reuse, therefore no removal action or remedial action is required to ensure protection of human health and the environment. Although this decision will not result in hazardous substance, pollutants or contaminants remaining on-site at levels that are not consistent with the intended industrial reuse of the property, its reasonably anticipated future use, a deed restriction will be implemented to assure land use remains industrial and five year statutory reviews will be conducted.
Record of Decision Page 3 of 11 Revision 0 Two No Further Action Group VI Environmental Sites April 2003 United States Army Fort Chaffee Base Transition Team Fort Chaffee, Arkansas
2.0 DECISION SUMMARY
This decision document addresses two environmental sites (Group VI) at Fort Chaffee, Arkansas for which the United States Army has been identified as the lead agency for CERCLA response actions. The BTT is the Army’s on-site organization responsible for these actions. The two Group VI sites have been included in lists of sites at Fort Chaffee that have some potential to require a response under CERCLA. The two sites require no further action to be protective of human health and the environment for the reasonably anticipated future land use. The sampling results and reference documents used to characterize the two sites discussed in Section 2.0 are found in the Administrative Record for Fort Chaffee located at the Fort Smith Public Library and the BTT-Environmental Compliance Office at Fort Chaffee.
In this document, Fort Chaffee is considered to consist of the geographic extent of the Fort Chaffee Military Reservation at the time of closure. Fort Chaffee was closed in October 1997 as part of the Base Realignment and Closure (BRAC) process. Fort Chaffee is approximately seven miles east-southeast of Fort Smith, Arkansas. The military reservation consisted of over 71,000 acres. Most of the land became part of the Fort Chaffee Maneuver Training Center operated by the Arkansas Army National Guard for reserve component training. The area retained by the United States Army (most is licensed to the Arkansas Army National Guard) is referred to as the Enclave Area. The remaining 7000 acres, the Excess Area, are being disposed by the United States Army for community reuse. The locations of the sites discussed in this decision document are shown on Figures 1 and 2. The proposed future use of the sites, the human health screening cleanup levels, and the previous uses by the military are presented in Table 1. The ecological risk status of the sites is summarized in Table 2.
2.1 FTCH-045: Wood Dump Area
2.1.1 Site Location and Description
FTCH-045, the Wood Dump Area, is an approximately 3.2 acre parcel located southeast of the intersection of Roberts Boulevard and Hari Cari road. It is to the west of the incinerator stacks and overlaps the western edge of FTCH-013 as shown in Figure 3. It also occupies the same parcel of land as the Additional Unpermitted Trench Area (AUTA) of Sanitary Landfill 41.
2.1.2 Site History and Enforcement Activities
The site was a collection point for wood debris. Periodically, the collected material was burned, and the burn residue buried randomly throughout the site. The use of the Wood Dump Area (FTCH-045) as a collection point and burn site for burnable materials ended in 1998. The site was subsequently graded and closed.
Record of Decision Page 4 of 11 Revision 0 Two No Further Action Group VI Environmental Sites April 2003 United States Army Fort Chaffee Base Transition Team Fort Chaffee, Arkansas
2.1.3 Site Characteristics
A site walkover conducted in August 1995 revealed that the surface of the area had been used for the disposal and burning of wooden pallets, trees and branches, and other wood debris. Residue from wood burning activities and broken glass bottles were also visible.
A geophysical survey was conducted in September 1998 to learn more about the trenches and to determine if other areas of buried material were present. The survey provided evidence that some burial activity had taken place and confirmed the presence of the two trenches.
The two waste trenches were found to contain incinerator residue, construction debris, and rubble, as well as nonputrescible household/municipal wastes similar to that buried in Sanitary Landfill 01. The two waste trenches and associated burial/disposal area, which cover approximately 1.8 acres, were incorporated into Sanitary Landfill 41 as the Additional Unpermitted Trench Area (AUTA) and addressed within the non-time-critical removal action at Landfill 01 in 2000. All of the remaining uncapped portion of FTCH-045 that lies in the middle of the horseshoe-shaped cap of the AUTA has been covered with 6- to 12-inches of clean topsoil from an off-site borrow source and graded to maintain drainage of the cap.
During a 1999 investigation of FTCH-013, incinerated material consistent with that at FTCH-013 was found to extend into the northern portion of the area designated as FTCH-045. The boundary between FTCH-013 and FTCH-045 was redrawn resulting in a smaller FTCH-045. The former portion of FTCH-045 has been addressed under the investigations for FTCH-013. A small portion of FTCH-013 remains co-located within the wood dump boundary.
2.1.4 Current and Potential Future Site and Resource Uses
FTCH-045 is co-located with FTCH-001 and overlaps FTCH-013. Its current and historical use is landfill/industrial. As shown on Figure 4, it is in an area that includes the North POW Landfill and Sanitary Landfill 41 referred to in the Fort Chaffee Public Trust’s Preferred Land Reuse Plan a former landfill area with no other reuse indicated. None of these landfills are active. Any reuse of the site as a landfill would require a permit application through Arkansas Department of Environmental Quality’s Solid Waste Division. The site is surrounded by industrial use areas, including the future I-49 Interstate Highway, Sanitary Landfill #1, and the U.S. Army Reserves compound. The most reasonably anticipated future use is landfill/industrial.
2.1.5 Summary of Site Risks
Activities associated with the use of the site as a wood dump have resulted in no adverse environmental impact and no risk to human health or the environment.
Record of Decision Page 5 of 11 Revision 0 Two No Further Action Group VI Environmental Sites April 2003 United States Army Fort Chaffee Base Transition Team Fort Chaffee, Arkansas
Although no restriction is necessary as a result of its use as a wood dump, notices associated with the protection and maintenance of the cap is in effect in the area of FTCH-001 that overlaps FTCH-045. These notices were addressed in the no further action decision document for Sanitary Landfill #1 (FTCH-001) and include dig, use and access restrictions and cap maintenance provisions.
Additionally, the very small portion of FTCH-045 to the northeast (not covered by the landfill cap) that overlaps FTCH-013 is subject to the industrial land use restriction that is addressed under FTCH-013.
2.2 FTCH-013: Solid Waste Incinerator Slag Piles
2.2.1 Site Location and Description
The Solid Waste Incinerator Slag Piles Site (FTCH-013) is located in the northwestern part of Fort Chaffee, approximately 1,500 feet east of the intersection of Roberts Boulevard and Hari Cari Road (Figure 3) and is approximately 11 acres in size. The site is characterized by the presence of incinerated material that is either exposed at the surface or buried beneath a soil layer of varying thickness.
2.2.2 Site History and Enforcement Activities
The site was used as a disposal area for incinerated material, including incinerator residue (slag) and other debris derived from the operation of two coal-fired solid waste incinerators located immediately east of the disposal area. The incinerators were operated from 1942 until approximately 1960. The incinerator buildings will be closed and secured within a fenced compound.
2.2.3 Site Characteristics
FTCH-013 lies near the top of a gently sloping hillside in an industrial area. A multi-phased remedial investigation was conducted from May 1999 to February 2000. Incinerator material was identified as dark gray to black, sand-to gravel-size and larger cinder particles and other incinerator debris. The incinerator residue was visually distinct which allowed straightforward visual delineation of the impacted area, both surface and subsurface. Incinerator material was observed on the surface soil throughout FTCH-013 boundaries. However, in most areas, it was only sparsely deposited on the surface. Two thick deposits of incinerator material were delineated in the subsurface (Figure 3).
Groundwater investigations did not indicate any clear or significant release of contaminants of concern. Although manganese is not a contaminant of concern, high levels have been detected in the shallow groundwater. The manganese in groundwater at FTCH-013 is believed to be the result of naturally occurring sources. This conclusion is based on the fact that no anthropogenic source has been identified, high levels of manganese are found in other wells at unrelated sites across Fort Chaffee and manganese oxide is a common precipitate on rocks through which the groundwater flows. Additionally, high levels of manganese occur in turbid groundwater samples. In some wells, the levels of manganese
Record of Decision Page 6 of 11 Revision 0 Two No Further Action Group VI Environmental Sites April 2003 United States Army Fort Chaffee Base Transition Team Fort Chaffee, Arkansas
detected were above an EPA guideline established for cosmetic effects (such as tooth or skin discoloration) or aesthetic effects (such as taste, odor, or color) of drinking water. Although there is not a maximum contaminant level (MCL) for manganese, biological research studies have indicated that manganese has the potential to cause adverse health effects in humans and animals at high doses.
2.2.4 Current and Potential Future Site and Resource Uses
The reasonably anticipated future land use for FTCH-013 is industrial which is consistent with its past military/industrial use and the preferred future use. As shown on Figure 4, the Fort Chaffee Public Trust’s Preferred Land Reuse Plan refers to the area as a former Landfill area with no other reuse indicated. The preferred future use of the areas surrounding FTCH-013 are industrial and include commercial, business park and non-residential campus, light business and industrial, and landfill areas. Present and past uses of the site and adjacent areas are also industrial as illustrated on Figure 5, including the I-49 Highway Corridor to the northwest, Roberts Boulevard and St. Mary’s Cemetery to the north and east, the U.S. Army Reserves’ fenced ECS-15 Compound to the south and Landfill 41 to the southwest.
2.2.5 Summary of Site Risks
A risk evaluation was conducted with the data collected from FTCH-013. Risks associated with all constituents detected in soil were evaluated for the industrial land use scenario. A hypothetical residential scenario was also evaluated for comparison purposes. With three exceptions, the maximum detections of the chemicals were used to evaluate risk. The three exceptions are arsenic, trichloroethene, and dioxin for which 95% UCLs were used. The groundwater pathway was not evaluated since groundwater results demonstrate that the COPCs in the residue do not clearly or significantly impact the ground water.
Continued industrial land use is the reasonably anticipated scenario for FTCH-013. The industrial worker scenario is used to evaluate exposure to site media that a typical worker may experience under conditions expected to occur when FTCH-013 remains in the industrial and/or commercial sector.
For the reasonably anticipated land use, industrial use, the cumulative cancer risk for all chemicals detected at Site 13 is 2E-05 and is within USEPA’s acceptable risk range of 1E-6 to 1E-4 (USEPA, 1990). The major contributor to the cumulative cancer risk is from arsenic, with lesser contributions from benzo(a)pyrene and dioxin. It should also be noted that the 95% upper confidence level (UCL) for arsenic in the incinerator residue (39.43 mg/kg) is in the same order of magnitude as the background maximum (22.5 mg/kg). The risk contribution for arsenic at its maximum background concentration would exceed 1x10-5 even if impacts from the residue were not considered. The other inorganic constituent that contributes to cancer risk, chromium, has a risk of only 4 x 10-7 The cumulative noncancer HI, under an industrial land use scenario, for all chemicals is 4E-01 and is below the USEPA’s acceptable HI value of 1 (USEPA, 1990). The major contributor to the cumulative noncancer hazard is thallium. which is assumed to be in the form of thallic oxide for incinerator residues.
Record of Decision Page 7 of 11 Revision 0 Two No Further Action Group VI Environmental Sites April 2003 United States Army Fort Chaffee Base Transition Team Fort Chaffee, Arkansas
Lesser contributors include antimony and cadmium.
This risk evaluation can be considered relatively conservative because of the following:
• It was based on the analytical results of the incinerator residue samples, not native soil. • The residue is exposed at the surface across only about 50% of the site. • Significant deposits of residue are limited to Zones A and B which together encompass
about 25% of the site. • Using the maximum detections of the chemicals for the evaluation exaggerates the risk.
For comparison purposes a hypothetical residential risk scenario was evaluated. The residential scenario assumes the resident occupies the site for 30 years. The cumulative cancer risk for the hypothetical residential scenario is 1E-04 and is at the upper boundary of USEPA’s acceptable risk range of 1E-06 to 1E-04. As with industrial usage, the major contributor to the cumulative cancer risk is from arsenic, with lesser contributions from the benzo(a)pyrene and dioxin. It should also be noted that the 95% UCL for arsenic in the incinerator residue (39.43 mg/kg) is in the same order of magnitude as the Fort Chaffee background maximum (22.5 mg/kg). The cumulative noncancer hazard (HI) of 6.E+00 exceeds USEPA’s acceptable HI value of 1. The major contributors to the HI are arsenic and thallium.
In summary, the site is considered to pose an acceptable risk to human health for the industrial land use scenario even if the workers are assumed to work only in residue zones that constitute only about half of the total site area. In comparison, residential use resulted in cumulative cancer and non-cancer risk that exceeded the USEPA targets. Use of the site for residential purposes as well as transportation of impacted materials offsite is not acceptable.
FTCH-013 was also evaluated for ecological risk. A qualitative ecological risk assessment was conducted for FTCH-013 based on three key factors: access to the site, amount of suitable habitat, and potential exposure to incinerator residue. Access to the site is somewhat physically limited by the surrounding industrial features including the U.S. Army Reserves fenced vehicle storage compound, ECS-15 on the south and southeast and Roberts Boulevard to the north and northeast. In the future with the construction of I-49 Interstate Highway, access will be even more restricted. Exposure to the incinerator residue is limited.
Only part of the 11-acre site actually provides suitable habitat for many ecological receptors. About 20% of the site is rock outcropping, quarry bottom or weathered bedrock surface that support little to no vegetation. FTCH-013 contains no permanent bodies of water to provide consistent sources of water. The site’s suitability for ecological receptors is limited and is expected to decline in the future as industrial development takes place in the surrounding areas. With the construction of the interstate highway, the wooded area that borders the site to the north will be cleared. FTCH-013 will be entirely surrounded by roadways and fences.
Record of Decision Page 8 of 11 Revision 0 Two No Further Action Group VI Environmental Sites April 2003 United States Army Fort Chaffee Base Transition Team Fort Chaffee, Arkansas
The potential exposure to incinerator residue at the surface is limited. Incinerator residue lies at the ground surface under a thin layer of soil in only about 50% of the site area. In approximately 30% of the site only sparse or scattered residue is present. The remainder of the area consists of thicker deposits buried undersoil ranging from 6 inches to 5.5 feet in thickness.
The negligible impact of FTCH-013 to ecological receptors is supported by the fact that no visible signs of stress to the flora and fauna have been noted by the BTT or during previous site inspections (ERM, 1996).
2.3 Community Participation
The proposed plan for the two sites in this ROD was summarized in a public notice published in local newspapers as noted below The notice also announced the availability of the Proposed Plan of Action for Group VI Environmental Sites, the location of supporting documents, and the public open house held on March 11, 2003. Both of these sites are addressed in this ROD for no further action. The proposed plan has also been presented to and discussed with the Fort Chaffee Restoration Advisory Board (RAB). The public forum included informational displays and afforded an opportunity for interested stakeholders to ask questions and/or comment to United States Army personnel. The public comment period ended on March 19, 2003. No written or verbal comments concerning the proposed plan have been received.
Newspaper Location Publication Dates
Arkansas Democrat Gazette - Northwest Arkansas Edition
Little Rock AR February 9, 2003 February 17, 2003 March 11, 2003
Southwest Times Record Fort Smith, AR February 9, 2003 February 17, 2003 March 11, 2003
2.4 Scope and Role of Response Action
This document is the sixth in a series of decision documents for Fort Chaffee that document the completion of required CERCLA response activities for the installation. The United States Army, in cooperation with other members of the BRAC Cleanup Team, has cooperatively developed a plan to periodically document attainment of requirements for the sites at Fort Chaffee. This decision document will record, in the administrative record that CERCLA response actions, required. by the United States Army relative to Fort Chaffee, have been completed for the included sites.
2.5 Explanation of Significant Changes
The decisions presented in this document differ significantly from those presented in the Proposed Plan of Action for Group VI Environmental Sites issued for public review February 17, 2003. The
Record of Decision Page 9 of 11 Revision 0 Two No Further Action Group VI Environmental Sites April 2003 United States Army Fort Chaffee Base Transition Team Fort Chaffee, Arkansas
decision for FTCH-013 has changed from No Action to No Further Action. This change has resulted in the implementation of Land Use Controls for the industrial use restriction at FTCH-013 and the monitoring of those controls with CERCLA Five Year Reviews as well as the costs associated with these actions.
3.0 RESPONSIVENESS SUMMARY
No verbal or written comments concerning the proposed decision were received from the public during the public comment period. Continued concern was expressed by EPA over the no action recommendation for FTCH-013 use presented in the Proposed Plan. This no action recommendation was based on the reasonably anticipated future industrial use of' the site which is consistent with the risk levels presented by the contaminants remaining at the site. This continued concern by EPA resulted in the change to the No Further Action decision presented in this Record of Decision. The change includes the implementation of land use controls and Five-Year CERCLA reviews at FTCH-013. Although EPA requested the same restrictions be placed on FTCH-045, the no action decision for FTCH-045 will remain in place. Comments by EPA and ADEQ on the Proposed Plan and Army responses are contained in the Administrative Record for Fort Chaffee and are available for review at the Fort Chaffee Base Transition Team Office and the Fort Smith Public Library.
4.0 REFERENCES
The documents supporting this Record of Decision are listed below:
United States Army Environmental Center, 1996. Final Fort Chaffee, Arkansas Environmental Baseline Survey at Army Base Realignment and Closure (BRAC) 95 Installations. Prepared by ERM Program Management Company, October. (An evaluation of overall environmental conditions at Fort Chaffee prepared as part of the BRAC process.)
BTT, 2003. Proposed Plan of No Action for Group VI Environmental Sites, Fort Chaffee, Arkansas, Revision 0, February 2003.
United States Army Fort Chaffee, Base Transition Team (BTT), 2002a. Proposed Plan of Action for Group IV Environmental Sites, Fort Chaffee, Arkansas.
BTT, 2002b. Remedial Investigation Report Solid Waste Incinerator Slag Piles, Site FTCH-013. Revision 3, March.
BTT, 2002c. Technical Memorandum Additional Surface Soil Sampling, (Site 13), Fort Chaffee, Arkansas (Excess), Revision 0, September.
BTT, 2001. Technical Memorandum – Identify and Document the Disposition of the Wood Dump Area, Site FTCH – 045. Revision 3, April.
United States Environmental Protection Agency (USEPA), 2000. USEPA Region 6 Human Health Medium-Specific Screening Levels (MSSLs). (Documentation of MSSLs developed by USEPA and used for comparison to concentrations detected.) September. Record of Decision Page 10 of 11 Revision 0 Two No Further Action Group VI Environmental Sites April 2003 United States Army Fort Chaffee Base Transition Team Fort Chaffee, Arkansas
Table 1 Land Use Summary
Site Description Proposed Use Human Health Screening/ Cleanup Level
Historical Use
FTCH-045 Wood Dump Area Industrial Activities associated with the use of the site as a wood dump have resulted in no adverse environmental impact and no risk to human health or the environment. A screening was not conducted for FTCH-045 however its use level should be consistent with the two overlapping sites, FTCH-013 and FTCH-001.
Industrial
Table 2 Ecological Risk Summary
Site Remedial Status
Ecological Status
Decision Comments
FTCH-045 No Action Negligible Risk No Action Placement of clean backfill up to1 foot over the majority of the site eliminates the surface exposure pathway. Portions of FTCH-045 not covered with clean backfill will be addressed under FTCH-013.
FTCH-013 No Action Negligible Risk No Action A qualitative ecological risk assessment addressing access to the site, amount of suitable habitat, and potential exposure to incinerator residue found no significant impact to ecological receptors.

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