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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
Transcript
Page 1: EPA Superfund Record of Decision

EPA/ROD/R06-03/5682003

EPA Superfund

Record of Decision:

FORT CHAFFEEEPA ID: AR1213720187OU 07FORT CHAFFEE, AR04/29/2003

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RECORD OF DECISION FOR TWO NO FURTHER ACTIONGROUP 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 SlagPiles (Site 13). The United States Army has been identified as the lead agency for ComprehensiveEnvironmental Response, Compensation, and Liability Act (CERCLA) response actions for the FortChaffee sites. The United States Army Fort Chaffee Base Transition Team (BTT) is the on-siteorganization 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 ProposedPlan of Action for Group VI Environmental Sites (BTT, 2003), issued for public review onFebruary 17, 2003, information from various environmental site investigations was summarized and thetwo Group VI Sites were proposed for no further action. No CERCLA action is necessary at Site 45and no further CERCLA action is required at Site 13 to be protective of human health and theenvironment 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 ExcessArea. The area to be retained by the United States Army is referred to as the Enclave Area. Most ofthe Enclave Area is licensed to the Arkansas Army National Guard. The two Group VI Sitesaddressed in this ROD are located in the Excess Area. The two sites will be transferred to the FortChaffee Redevelopment Authority. The use of FTC11-013 will be restricted to industrial, which is thereasonably anticipated' future use. The FOST and deed will specify that the use of FTCH-013 beconsistent with its reasonably anticipated industrial use. Although FTCH-045 is a no action site, certainuse restrictions exist in most of the Wood Dump area by virtue of it co-location with two otherenvironmental sites, FTCH-001 and FTCH-013. Dig and other notices associated with protection andmaintenance of the remedy have been imposed on a portion of FTCH-045 that is overlain by theAdditional Unpermitted Trench Area (AUTA) of Sanitary Landfill 41 (FTCH-001) cap. These noticeshave been set forth in the decision document for FTCH-001, Record of Decision for No FurtherAction at Two Group V Environmental Sites, Fort Chaffee, Arkansas, September 2001 and areavailable for review in the Administrative Record for Fort Chaffee. Additionally, the industrial land userestriction associated with SITE 13 has been imposed on that portion of FTCH-045 that is co-locatedwith the Incinerator Slag Piles.

Record of Decision Page 1 of 11 Revision 0Two No Further Action Group VI Environmental Sites April 2003United States Army Fort Chaffee Base Transition TeamFort Chaffee, Arkansas

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Fort Chaffee Base Transition TeamEnvironmental Compliance Office

Building 2033Barling, Arkansas 72923

or

Fort Smith Public Library 3201 Rogers Avenue

Fort Smith, Arkansas 72903

The Army encourages the public and other interested parties to review relevant information to gain abetter understanding of these environmental sites. All sampling results used for site evaluations of thecurrent environmental condition at Fort Chaffee are part of the information in the Administrative Recordfor Fort Chaffee. The Administrative Record for Fort Chaffee environmental compliance efforts can beviewed 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 withCERCLA as amended by the Superfund Amendment and Reauthorization Act (SARA), United StatesArmy Regulation 200-1, and to the extent practicable, the National Contingency Plan, no CERCLAaction 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 isbased on knowledge of site history and site operation. For the activities associated with the use of thesite as a wood dump, no clear or significant adverse environmental impact was identified and no clearor significant risk to human health or ecological receptors could be identified. Evaluation of current siteconditions 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 theenvironment. Because no remedial action is needed (and therefore not selected) a five-year statutoryreview will not be conducted.

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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 accordancewith CERCLA, no further CERCLA action is necessary for this site as amended by the SuperfundAmendment and Reauthorization Act (SARA), United States Army Regulation 200-1, and to the extentpracticable, the National Contingency Plan. This decision is based on the Administrative Record file forthis 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 orremedial action is based on knowledge of site history and site operation. Evaluation of current siteconditions, including the surface soil sampling, subsurface soil sampling, and groundwater samplingsupports the decision of no further action at this site. The no further action is also based on the mostreasonably anticipated future industrial use of this site. However, deed restrictions for Site 13 assurethat 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. Noneof the CERCLA 121 statutory determinations are necessary in this section since no remedy is beingselected. The site is in compliance with acceptable risk levels for industrial reuse, therefore no removalaction 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 remainingon-site at levels that are not consistent with the intended industrial reuse of the property, its reasonablyanticipated future use, a deed restriction will be implemented to assure land use remains industrial andfive year statutory reviews will be conducted.

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2.0 DECISION SUMMARY

This decision document addresses two environmental sites (Group VI) at Fort Chaffee, Arkansas forwhich 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 havebeen included in lists of sites at Fort Chaffee that have some potential to require a response underCERCLA. The two sites require no further action to be protective of human health and the environmentfor the reasonably anticipated future land use. The sampling results and reference documents used tocharacterize the two sites discussed in Section 2.0 are found in the Administrative Record for FortChaffee located at the Fort Smith Public Library and the BTT-Environmental Compliance Office atFort Chaffee.

In this document, Fort Chaffee is considered to consist of the geographic extent of the Fort ChaffeeMilitary Reservation at the time of closure. Fort Chaffee was closed in October 1997 as part of theBase Realignment and Closure (BRAC) process. Fort Chaffee is approximately seven mileseast-southeast of Fort Smith, Arkansas. The military reservation consisted of over 71,000 acres. Mostof the land became part of the Fort Chaffee Maneuver Training Center operated by the Arkansas ArmyNational Guard for reserve component training. The area retained by the United States Army (most islicensed to the Arkansas Army National Guard) is referred to as the Enclave Area. The remaining 7000acres, the Excess Area, are being disposed by the United States Army for community reuse. Thelocations of the sites discussed in this decision document are shown on Figures 1 and 2. The proposedfuture use of the sites, the human health screening cleanup levels, and the previous uses by the militaryare 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 theintersection of Roberts Boulevard and Hari Cari road. It is to the west of the incinerator stacks andoverlaps the western edge of FTCH-013 as shown in Figure 3. It also occupies the same parcel ofland 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 theburn residue buried randomly throughout the site. The use of the Wood Dump Area (FTCH-045) as acollection point and burn site for burnable materials ended in 1998. The site was subsequently gradedand closed.

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2.1.3 Site Characteristics

A site walkover conducted in August 1995 revealed that the surface of the area had been used for thedisposal and burning of wooden pallets, trees and branches, and other wood debris. Residue fromwood burning activities and broken glass bottles were also visible.

A geophysical survey was conducted in September 1998 to learn more about the trenches and todetermine if other areas of buried material were present. The survey provided evidence that some burialactivity 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, aswell as nonputrescible household/municipal wastes similar to that buried in Sanitary Landfill 01. The twowaste trenches and associated burial/disposal area, which cover approximately 1.8 acres, wereincorporated into Sanitary Landfill 41 as the Additional Unpermitted Trench Area (AUTA) andaddressed within the non-time-critical removal action at Landfill 01 in 2000. All of the remaininguncapped portion of FTCH-045 that lies in the middle of the horseshoe-shaped cap of the AUTA hasbeen covered with 6- to 12-inches of clean topsoil from an off-site borrow source and graded tomaintain drainage of the cap.

During a 1999 investigation of FTCH-013, incinerated material consistent with that at FTCH-013 wasfound to extend into the northern portion of the area designated as FTCH-045. The boundary betweenFTCH-013 and FTCH-045 was redrawn resulting in a smaller FTCH-045. The former portion ofFTCH-045 has been addressed under the investigations for FTCH-013. A small portion of FTCH-013remains 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 islandfill/industrial. As shown on Figure 4, it is in an area that includes the North POW Landfill andSanitary Landfill 41 referred to in the Fort Chaffee Public Trust’s Preferred Land Reuse Plan a formerlandfill area with no other reuse indicated. None of these landfills are active. Any reuse of the site as alandfill would require a permit application through Arkansas Department of Environmental Quality’sSolid Waste Division. The site is surrounded by industrial use areas, including the future I-49 InterstateHighway, Sanitary Landfill #1, and the U.S. Army Reserves compound. The most reasonablyanticipated 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 environmentalimpact and no risk to human health or the environment.

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Although no restriction is necessary as a result of its use as a wood dump, notices associated with theprotection 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) thatoverlaps 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 FortChaffee, 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 ofincinerated material that is either exposed at the surface or buried beneath a soil layer of varyingthickness.

2.2.2 Site History and Enforcement Activities

The site was used as a disposal area for incinerated material, including incinerator residue (slag) andother debris derived from the operation of two coal-fired solid waste incinerators located immediatelyeast of the disposal area. The incinerators were operated from 1942 until approximately 1960. Theincinerator 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 remedialinvestigation was conducted from May 1999 to February 2000. Incinerator material was identified asdark gray to black, sand-to gravel-size and larger cinder particles and other incinerator debris. Theincinerator residue was visually distinct which allowed straightforward visual delineation of the impactedarea, both surface and subsurface. Incinerator material was observed on the surface soil throughoutFTCH-013 boundaries. However, in most areas, it was only sparsely deposited on the surface. Twothick 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 shallowgroundwater. The manganese in groundwater at FTCH-013 is believed to be the result of naturallyoccurring sources. This conclusion is based on the fact that no anthropogenic source has beenidentified, high levels of manganese are found in other wells at unrelated sites across Fort Chaffee andmanganese 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

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detected were above an EPA guideline established for cosmetic effects (such as tooth or skindiscoloration) or aesthetic effects (such as taste, odor, or color) of drinking water. Although there is nota maximum contaminant level (MCL) for manganese, biological research studies have indicated thatmanganese 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 pastmilitary/industrial use and the preferred future use. As shown on Figure 4, the Fort Chaffee PublicTrust’s Preferred Land Reuse Plan refers to the area as a former Landfill area with no other reuseindicated. The preferred future use of the areas surrounding FTCH-013 are industrial and includecommercial, 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 tothe north and east, the U.S. Army Reserves’ fenced ECS-15 Compound to the south and Landfill 41 tothe southwest.

2.2.5 Summary of Site Risks

A risk evaluation was conducted with the data collected from FTCH-013. Risks associated with allconstituents detected in soil were evaluated for the industrial land use scenario. A hypotheticalresidential scenario was also evaluated for comparison purposes. With three exceptions, the maximumdetections 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 notevaluated since groundwater results demonstrate that the COPCs in the residue do not clearly orsignificantly impact the ground water.

Continued industrial land use is the reasonably anticipated scenario for FTCH-013. The industrialworker scenario is used to evaluate exposure to site media that a typical worker may experience underconditions 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 chemicalsdetected 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 contributionsfrom 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 backgroundmaximum (22.5 mg/kg). The risk contribution for arsenic at its maximum background concentrationwould exceed 1x10-5 even if impacts from the residue were not considered. The other inorganicconstituent that contributes to cancer risk, chromium, has a risk of only 4 x 10-7 The cumulativenoncancer 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 cumulativenoncancer hazard is thallium. which is assumed to be in the form of thallic oxide for incinerator residues.

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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 residentialscenario assumes the resident occupies the site for 30 years. The cumulative cancer risk for thehypothetical residential scenario is 1E-04 and is at the upper boundary of USEPA’s acceptable riskrange of 1E-06 to 1E-04. As with industrial usage, the major contributor to the cumulative cancer riskis from arsenic, with lesser contributions from the benzo(a)pyrene and dioxin. It should also be notedthat the 95% UCL for arsenic in the incinerator residue (39.43 mg/kg) is in the same order ofmagnitude 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 arearsenic and thallium.

In summary, the site is considered to pose an acceptable risk to human health for the industrial land usescenario even if the workers are assumed to work only in residue zones that constitute only about halfof the total site area. In comparison, residential use resulted in cumulative cancer and non-cancer riskthat exceeded the USEPA targets. Use of the site for residential purposes as well as transportation ofimpacted materials offsite is not acceptable.

FTCH-013 was also evaluated for ecological risk. A qualitative ecological risk assessment wasconducted for FTCH-013 based on three key factors: access to the site, amount of suitable habitat, andpotential exposure to incinerator residue. Access to the site is somewhat physically limited by thesurrounding 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 futurewith the construction of I-49 Interstate Highway, access will be even more restricted. Exposure to theincinerator residue is limited.

Only part of the 11-acre site actually provides suitable habitat for many ecological receptors. About20% of the site is rock outcropping, quarry bottom or weathered bedrock surface that support little tono vegetation. FTCH-013 contains no permanent bodies of water to provide consistent sources ofwater. The site’s suitability for ecological receptors is limited and is expected to decline in the future asindustrial 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 entirelysurrounded by roadways and fences.

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The potential exposure to incinerator residue at the surface is limited. Incinerator residue lies at theground surface under a thin layer of soil in only about 50% of the site area. In approximately 30% ofthe site only sparse or scattered residue is present. The remainder of the area consists of thickerdeposits 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 signsof 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 localnewspapers as noted below The notice also announced the availability of the Proposed Plan ofAction for Group VI Environmental Sites, the location of supporting documents, and the publicopen house held on March 11, 2003. Both of these sites are addressed in this ROD for no furtheraction. The proposed plan has also been presented to and discussed with the Fort Chaffee RestorationAdvisory Board (RAB). The public forum included informational displays and afforded an opportunityfor interested stakeholders to ask questions and/or comment to United States Army personnel. Thepublic comment period ended on March 19, 2003. No written or verbal comments concerning theproposed plan have been received.

Newspaper Location Publication Dates

Arkansas Democrat Gazette -Northwest Arkansas Edition

Little Rock AR February 9, 2003February 17, 2003March 11, 2003

Southwest Times Record Fort Smith, AR February 9, 2003February 17, 2003March 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 thecompletion of required CERCLA response activities for the installation. The United States Army, incooperation with other members of the BRAC Cleanup Team, has cooperatively developed a plan toperiodically document attainment of requirements for the sites at Fort Chaffee. This decision documentwill 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 Planof Action for Group VI Environmental Sites issued for public review February 17, 2003. The

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decision for FTCH-013 has changed from No Action to No Further Action. This change has resultedin the implementation of Land Use Controls for the industrial use restriction at FTCH-013 and themonitoring of those controls with CERCLA Five Year Reviews as well as the costs associated withthese actions.

3.0 RESPONSIVENESS SUMMARY

No verbal or written comments concerning the proposed decision were received from the public duringthe public comment period. Continued concern was expressed by EPA over the no actionrecommendation for FTCH-013 use presented in the Proposed Plan. This no action recommendationwas based on the reasonably anticipated future industrial use of' the site which is consistent with the risklevels presented by the contaminants remaining at the site. This continued concern by EPA resulted inthe change to the No Further Action decision presented in this Record of Decision. The changeincludes 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 forFTCH-045 will remain in place. Comments by EPA and ADEQ on the Proposed Plan and Armyresponses are contained in the Administrative Record for Fort Chaffee and are available for review atthe 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 EnvironmentalBaseline Survey at Army Base Realignment and Closure (BRAC) 95 Installations. Prepared byERM Program Management Company, October. (An evaluation of overall environmental conditions atFort 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 forGroup 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 WoodDump Area, Site FTCH – 045. Revision 3, April.

United States Environmental Protection Agency (USEPA), 2000. USEPA Region 6 HumanHealth Medium-Specific Screening Levels (MSSLs). (Documentation of MSSLs developed byUSEPA and used for comparison to concentrations detected.) September.Record of Decision Page 10 of 11 Revision 0Two No Further Action Group VI Environmental Sites April 2003United States Army Fort Chaffee Base Transition TeamFort Chaffee, Arkansas

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Table 1Land 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 thesite as a wood dump have resulted in noadverse environmental impact and no riskto human health or the environment. Ascreening was not conducted forFTCH-045 however its use level shouldbe consistent with the two overlappingsites, FTCH-013 and FTCH-001.

Industrial

FTCH-013 Solid Waste Incinerator Slag Piles Industrial Industrial Industrial

Table 2Ecological Risk Summary

Site RemedialStatus

EcologicalStatus

Decision Comments

FTCH-045 No Action Negligible Risk No Action Placement of clean backfill up to1 foot over the majority of thesite eliminates the surface exposure pathway. Portions ofFTCH-045 not covered with clean backfill will be addressedunder FTCH-013.

FTCH-013 No Action Negligible Risk No Action A qualitative ecological risk assessment addressing access to thesite, amount of suitable habitat, and potential exposure toincinerator residue found no significant impact to ecologicalreceptors.

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