RECORD OF DECISION (RODS) - semspub.epa.gov

EPA/ROD/R05-99/1431999

EPA Superfund

Record of Decision:

US ARMY SOLDIER SUPPORT CTREPA ID: IN4210090003OU 00FORT BENJAMIN HARRISON, IN08/26/1999

U.S. Army Transition Activity Former Fort Benjamin Harrison

FINAL RECORD OF DECISION FOR ENVIRONMENTAL INVESTIGATION SITES SM20, SM21, SM26

Former Fort Benjamin Harrison Lawrence, Indiana

August 1999

U.S. Army Transition ActivityFormer Fort Benjamin Harrison

August 1999

RECORD OF DECISION FOR

ENVIRONMENTAL INVESTIGATION SITES SM20, SM21, SM26

FORMER FORT BENJAMIN HARRISON LAWRENCE, INDIANA

THIS PAGE WAS INTENTIONALLY LEFT BLANK

Record of Decision Former Fort Benjamin Harrisoni

DECLARATION FOR THE RECORD OF DECISION

STATEMENT OF BASIS AND PURPOSEWith this Record of Decision (ROD), the U.S. Army designates the remedial action for Environmental

Investigation Sites SM20, SM21, and SM26 at the former Fort Benjamin Harrison in the City ofLawrence, Marion County, Indiana. The determination to take remedial action is chosen in accordance withthe Comprehensive Environmental Response, Compensation, and Liability Act of 1980, as amended, andconsistent with the National Oil and Hazardous Substances Pollution Contingency Plan.

At EI Site SM26, the contaminated soils will be managed in a designated area known as an area ofcontamination, or AOC. An AOC consists of an area of contiguous contamination of varying amounts andtypes at a Comprehensive Environmental Response, Compensation and Liability Act (CERCLA) orResource Conservation and Recovery Act (RCRA) Corrective Action site. It is not a statutory orregulatory construct, but is rather a policy fashioned from interpretation of 55 Fed. Reg. 8758, thepreamble to the National Contingency Plan, where U.S. Environmental Protection Agency (EPA) assertsthat an AOC at a CERCLA site is analogous to a single RCRA land disposal unit. At the point and timethat material is removed from the AOC, it must be managed as a hazardous waste if it meets thatclassification.

SITE NAME AND LOCATION Three Remedial Action Sites Former Fort Benjamin Harrison, City of Lawrence, Indiana

• EI Site SM20 - Pesticide Mixing and Storage Areas, Building 605. • EI Site SM21 - Golf Course Pesticide Mixing Areas, Building 674, Shafter Road, east of

the state park entrance. • EI Site SM26 - Former Sewage Treatment Plant (west of Building 674), west of 5866

Lawton Loop West Drive.

ASSESSMENT OF THE SITEActual or threatened release of hazardous substances from these sites, if not addressed by implementing

the response action selected in this ROD, may present a potential threat to the environment.

DESCRIPTION OF THE SELECTED REMEDYThe selected remedies address the principal sources of risk at the three sites by removing all soil with

contaminants that exceed the target risk levels. Excavated soils will be disposed off-site, so that the siteswill not require any long-term management.

The major components of the selected remedy for each of the three sites include:

• Excavation of approximately 335 cubic yards of contaminated soil at SM20, 120 cubic yards atSM21, and 700 cubic yards at SM26;

• Characterization of the excavated soil and disposal at an appropriately-licensed special-wastedisposal facility; and

• Site restoration with addition of clean fill material, topsoil, and/or re-seeding.

Record of Decision Former Fort Benjamin Harrisonii

DECLARATION STATEMENT

The selected remedies are protective of human health and the environment, comply with federal andstate requirements that are legally applicable or relevant and appropriate to the hazardous substances whichare the subject of this action, and are cost-effective. These remedies utilize permanent solutions. Becausethese remedies will not result in hazardous substances remaining on-site above target risk levels, thefive-year review will not apply to these actions.

Record of Decision Former Fort Benjamin Harrisoniii

TABLE OF CONTENTS

DECLARATION FOR THE RECORD OF DECISION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . i

TABLE OF CONTENTS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . iii

ACRONYMS AND ABBREVIATIONS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . v

1. SITE NAMES AND LOCATIONS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1

2. SITE HISTORY AND BRAC ENVIRONMENTAL PROGRAMS . . . . . . . . . . . . . . . . . . . . . . 1

3. HIGHLIGHTS OF COMMUNITY PARTICIPATION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4

4. SCOPE AND ROLE OF RESPONSE ACTION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5

5. SITE DESCRIPTION AND CHARACTERISTICS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5

6. SUMMARY OF SITE RISKS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7

7. DESCRIPTION OF THE REMEDIAL ACTION ALTERNATIVES . . . . . . . . . . . . . . . . . . . . 10

8. SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES . . . . . . . . . . . . . . . . . 20

9. SELECTED REMEDY . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 23

10. STATUTORY DETERMINATIONS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 24

11. EXPLANATION OF SIGNIFICANT CHANGES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 25

12. REFERENCES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 29

LIST OF TABLES

Table 1. Analytical Results for DDT in Surface Soil at EI Site SM20 . . . . . . . . . . . . . . . . . . . . . . . 13Table 2. Analytical Results for 2,3,7,8-TCDF in Surface Soil at EI Site SM21 . . . . . . . . . . . . . . . . 15Table 3. Analytical Results for Lead in Surface Soil at EI Site SM26 . . . . . . . . . . . . . . . . . . . . . . . 17Table 4. Analytical Results for Zinc in Surface Soil at EI Site SM26 . . . . . . . . . . . . . . . . . . . . . . . . 19Table 5. U.S. EPA Evaluation Criteria . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 21Table 6. Lead and Zinc Concentrations at Third Sludge Drying Bed at EI Site SM26 . . . . . . . . . . . 26Table 7. Human Health Risk Assessment Summary for Residential Future Land Use at

EI Site SM20, Fort Benjamin Harrison, Marion County, Indiana . . . . . . . . . . . . . . . . . . . 28

Record of Decision Former Fort Benjamin Harrisoniv

LIST OF FIGURES

Figure 1. Location Map . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2Figure 2. Location Map for EI Sites SM20, SM21, and SM26 . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3Figure 3. Proposed Excavation Profile at El Site SM20 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12Figure 4. Proposed Excavation Profile at EI Site SM21 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16Figure 5. Proposed Excavation Profile EI Site SM26 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18

LIST OF APPENDICES

Appendix A Responsiveness SummaryAppendix B Derivation of Ecological PRGsAppendix C Letter from U.S. Fish and Wildlife: Consultation Regarding Indiana Bat Roost

TreesAppendix D Analytical Data for Soil Samples Collected from Third Sludge-drying Bed at EI

Site SM26

Record of Decision Former Fort Benjamin Harrisonv

ACRONYMS AND ABBREVIATIONS

ARAR Applicable or Relevant and Appropriate Requirement

BCT BRAC Cleanup Team

BEC BRAC Environmental Coordinator

BRAC Base Realignment and Closure

COC Contaminant of Concern

CTE Central Tendency Exposure

DDT 4,4'- dichlorodiphenyltrichloroethane

DRMO Defense Reutilization Marketing Office

EI Environmental Investigation

EPA U.S. Environmental Protection Agency

ERA Ecological Risk Assessment

FBH Former Fort Benjamin Harrison

FFS Focused Feasibility Study

HI Hazard Index

HLA Harding Lawson Associates

IDEM Indiana Department of Environmental Management

NFA No Further Action

PA Preliminary Assessment

PRG Preliminary Remediation Goal

RA Remedial Action

RAB Restoration Advisory Board

RME Reasonable Maximum Exposure

ROD Record of Decision

SAIC Science Applications International Corporation

STP Sewage Treatment Plant

TCDF tetrachlorodibenzofuran

TCLP Toxicity Characteristic Leaching Procedure

USASSC U.S. Army Soldier Support Center

Record of Decision Former Fort Benjamin Harrisonvi


Record of Decision Former Fort Benjamin Harrison1

1. SITE NAMES AND LOCATIONS

The former Fort Benjamin Harrison (FBH) was a U.S. Army installation located in the City ofLawrence, Marion County, Indiana. The former installation, consisting of 2,501 acres, was approximatelytwelve miles northeast of downtown Indianapolis (Figure 1). Residential areas and farmland bound FBH,with the exception of light industrial areas to the southeast. The subject of this Record of Decision (ROD)is the decision to pursue remedial action (RA) at three Environmental Investigation (EI) sites (RA sites) atFBH that have undergone environmental investigation and review.

The three RA sites are listed below:

• EI Site SM20 - Pesticide Mixing and Storage Areas, Building 605.

• EI Site SM21 - Golf Course Pesticide Mixing Areas, Building 674, Shafter Rd., east of the parkentrance.

• EI Site SM26 - Former Sewage Treatment Plant (west of Building 674), west of 5866 LawtonLoop West Drive.

The locations of the three RA sites are depicted in Figure 2.

2. SITE HISTORY AND BRAC ENVIRONMENTAL PROGRAMS

FBH was created by an act of Congress on March 30, 1903. The installation was established as aninfantry regiment post. Over the years it served as a training camp, induction and reception center, and washome to several Army schools, disciplinary barracks, a hospital, and a prisoner-of-war camp. In 1950FBHbecame the Army Finance Center. In 1980 FBH was reorganized as the U.S. Army Soldier SupportCenter (USASSC) responsible for personnel support, including finance, religion, legal aid, music, publicaffairs, morale, welfare, and recreation. USASSC housed five major tenants, including the Defense Financeand Accounting Service – Indianapolis Center, the Enlisted Records and Evaluation Center, Hawley ArmyCommunity Hospital, Readiness Group Harrison, and the 123rd Army Reserve Command.

In 1991 FBH was placed on the Department of Defense Base Closure List. As a result of the BaseRealignment and Closure (BRAC) program for FBH, environmental studies were conducted to addressreleases or suspected releases of hazardous substances.

An Enhanced Preliminary Assessment (PA) (Weston 1992), conducted in 1991, identified areas ofconcern requiring environmental evaluation and determined any immediate necessary actions.

In 1994 the FBH BRAC Cleanup Team (BCT) was formed. Consisting of the FBH BRACEnvironmental Coordinator, a representative of the U.S. Environmental Protection Agency (EPA) Region5, and a representative of the Indiana Department of




Environmental Management (IDEM), the BCT provides a means for the Army, EPA, and IDEM tocooperate in the planning and oversight of the BRAC environmental program at FBH. The BCT approvedand/or concurred with the Phase II EI workplan, including the technical sampling plan.

The EI at FBH was conducted in two phases. Phase I, completed in 1994, investigated theenvironmental media – soil, surface water, and groundwater – at sites identified in the enhanced PA. Thefindings of the Phase I Environmental Investigation Report (HLA 1995) helped to focus the activitiesof the Phase II EI that were conducted in the fall and winter of 1996/1997. Completion of these studieswas required to determine if the areas of concern were a threat to human health or the environment, as wellas to determine the suitability of the property for transfer.

The Phase I EI concluded that seven EI sites required no further action (NFA). Thisdecision is documented in a previous proposed plan (SAIC 1996). The Phase II EI concluded thatseventeen additional EI sites do not exhibit unacceptable risk to human health or the environment andrequire no further action. This decision is documented in a ROD dated March 1999 (SAIC 1999a).

The Phase II EI also concluded that three sites required further evaluation, including potential remedialaction, in order to eliminate their unacceptable risk to the environment, and to render them suitable fortransfer. These RA sites were further evaluated in the Focused Feasibility Study for EnvironmentalInvestigation Sites SM20, SM21, and SM26 (FFS) (SAIC 1999a) for the purpose of evaluating cleanupalternatives. The conclusions of the FFS are documented in the Proposed Plan for EI Sites SM20, SM21,and SM26 (SAIC 1999b). These three sites are the subject of this ROD.

3. HIGHLIGHTS OF COMMUNITY PARTICIPATION

In November 1994 the Restoration Advisory Board (RAB) was created. The RAB consists of theBRAC Environmental Coordinator (BEC) for FBH, a representative of EPA, a representative of IDEM,appointees from other governmental agencies, and community stakeholders. RAB meetings (co-chairedby the BEC and a community member) provide opportunities for progress to be presented and issues tobe discussed among all interested parties.

In addition, the Army holds public meetings at FBH to receive public comments on recently-publisheddocuments. These meetings follow public comment periods that last no less than 30 days. Notices of publiccomment periods are published as display advertisements in the Sunday edition of the Indianapolis Starand the documents are made available to the public at local libraries. The Administrative Record is availableto the public at the Fort Harrison Reuse Authority, 5830 North Post Road, Lawrence, Indiana 46216.

The FFS and the proposed plan for the three RA sites were published concurrently on March 22,1999. The availability of these documents was publicized and the 30-day comment period ended on April22, 1999. A public meeting was held at FBH on April


22, 1999. The public meeting provided an opportunity for interested parties to provide comments on theFFS and proposed plan; however, no public comments were offered.

Responses to comments on the FFS and proposed plan from IDEM and EPA are presented in theResponsiveness Summary at Appendix A to this document.

4. SCOPE AND ROLE OF RESPONSE ACTION

FBH is a former Army installation. Environmental studies (PA and Phase I and II EIs) have beenconducted to identify past releases or suspected releases of hazardous substances at FBH that may threatenhuman health or the environment, and to assure suitability of the property for transfer and planned reuse.Property disposal and reuse activities were initiated following base closure in September 1995 and havecontinued to the present. Remediation of the three RA sites will permit transfer and reuse of theseproperties. This ROD approves the recommendation for remedial action at the three RA sites.

5. SITE DESCRIPTION AND CHARACTERISTICS

This section describes each EI site and summarizes findings of the EI concerning contamination at thesites. The Phase I EI consisted of a records review, site visits, and sampling for the sites discussed in thisplan. The records review characterized historical use and evaluated the potential for the presence ofcontaminants. The Phase II EI consisted of additional field-sampling, based on the results of the Phase Iinvestigation, to further define the nature and extent of contamination at these sites. The Phase II EI alsoincluded a baseline risk assessment that evaluated risk to human health and the environment – discussedin Section 6. The environmental sampling programs conducted at each of the RA sites are briefly discussedbelow. Analytical data and risk assessment results for these sites are detailed in the Final Phase II EIReport (SAIC 1998) and in the Responsiveness Summary of the ROD for the seventeen NFA sites.

EI Site SM20 – Pesticide Mixing and Storage Areas, Building 605

Pesticides, herbicides, insecticides, and rodenticides were stored and mixed in and around Building605. This building is located just southeast of Building 604, which housed the former entomology office anda small plumbing shop. Pesticides were mixed in an outside fenced area on the northwest side of Building605. The mixing area is covered and has a bermed concrete floor with a catch basin for floor spills. Spillswere pumped and/or bailed out of the catch basin and transferred to storage drums that were sent to theDefense Reutilization. Marketing Office (DRMO) for storage and disposal. Empty pesticide containers andmixing vessels were triple-rinsed and disposed as sanitary waste. The rinse water was used either as apesticide dilutant or disposed through DRMO.

Building 605 is located above a steep embankment and near a concrete-lined drainage ditch that isabout 100 feet northeast of the building. This drainage ditch leads to


Hawthorne Pond, which is approximately a quarter-mile downstream. The potential for surface runoff fromthe site to affect Hawthorne Pond was noted in the PA.

The Phase I EI included sampling of surface and subsurface soil, surface water, and sediment fromwithin the cracks of the concrete lining of the ditch. Samples were analyzed for pesticides and herbicides.Pesticides and herbicides were detected in low concentrations in soil, surface water, and sediment. PhaseII EI sampling included surface and subsurface soils, groundwater, and sediment from the cracks in theconcrete-lined ditch. Surface and subsurface soils were analyzed for pesticides/PCBs, herbicides,dioxins/furans, cation exchange capacity, and total organic carbon. Groundwater and sediments wereanalyzed for pesticides/PCBs, herbicides, and total organic carbon.

The assessments performed in the final Phase II EI report and the FFS concluded that the surface soilat EI Site SM20 is contaminated with pesticides, primarily 4,4'dichlorodiphenyltrichloroethane (DDT).

EI Site SM21 - Golf Course Pesticide Mixing Areas, Building 674

Building 674 was a small concrete-block structure located along Shafter Road on the south side of theFBH golf course. The single-story building was used as an office for FBH golf course maintenancepersonnel, and for storing maintenance equipment. Maintenance personnel formerly used a small woodenshed adjacent to Building 674 as a pesticide mixing and storage facility. Pesticides were stored in the shedand mixed on a concrete pad located between the shed and Building 674. The shed did not have a concretefloor and had no spill containment. Pesticides also were reportedly mixed in the gravel lot on the north sideof Building 674. In 1998, Building 674 was demolished and removed from the site. A fence was installedalong the golf cartpath that passes near the location where the building stood. The topography at the siteslopes to the south toward Shafter Road. Along the north side of Shafter Road is an open turf-coveredditch that drains surface-water runoff during periods of heavy rain and diverts it westward along the road.

The Phase I EI sampled surface soil and ditch sediment. All samples were analyzed for pesticides andherbicides. Low concentrations of these analytes were detected in several samples. Phase II EI samplingincluded the collection of surface and subsurface soils, groundwater, and ditch sediment. Soils wereanalyzed for pesticides, herbicides, dioxins/furans, cation exchange capacity, and total organic carbon.Groundwater and sediment were analyzed for pesticides, herbicides, and total organic carbon.

Pesticides were detected in the surface soil at EI Site SM21. Chlordane was the pesticide, detectedmost frequently at the site. In addition to pesticides, a furan (2,3,7,8-tetrachlorodibenzofuran (TCDF)) wasdetected periodically at concentrations sufficient to warrant further evaluation.

EI Site SM26 - Former Sewage Treatment Plant (West of Building 674)

EI Site SM26 is the location of a former sewage treatment plant (STP) that was identified on aerialphotographs of FBH from 1913 and 1938. The former STP is located


in the wooded area south of Shafter Road, and west of Building 674, just upstream of the junction ofSchoen Creek with an unnamed tributary. The site lies on a hillside and the adjacent lowland. Remnantsof the STP still visible at the site include concrete walls that formed the cells of the contact beds and filterbeds, as well as earthen berms that surround the former sludge-drying beds. These former beds are situatedin the lowland adjacent to the unnamed tributary of Schoen Creek. In addition to these structures, the aerialphotographs show a septic tank located east of the former contact beds, but this structure is not visible atthe site and is probably buried. Past operational records for this treatment facility have not been found. Untilclosure of FBH, the area was used for the disposal of lawn debris (e.g., leaves, grass clippings), and halfof the contact bed cells are filled with this debris.

The Phase I EI included a records search and geophysical surveys to define the boundaries of theformer STP and identify any buried objects. No samples were collected. The Phase II EI sampled surfaceand subsurface soil, groundwater, surface water, and sediment. All soil, surface water, and sediment wereanalyzed for volatile organic compounds, semi-volatile organic compounds, pesticides, herbicides, totalmetals, total organic carbon, and cation exchange capacity. Groundwater samples were analyzed forvolatile and sernivolatile organic compounds, pesticides, herbicides, total and dissolved metals, and totalorganic carbon.

The evaluation of data in the Phase II EI concluded that the surface soils in the former sludge-dryingbeds were contaminated with metals. Pesticides were detected in the sediment of the nearby stream, buttheir source is likely the site-wide application of pesticides.

6. SUMMARY OF SITE RISKS

The sampling data collected from the three RA sites at FBH were used to perform risk assessmentsin the Final Phase II EI Report and the FFS (SAIC 1998a and 1999a). A baseline human health riskassessment was performed for all three RA sites modeled on methods and procedures outlined by the EPAin Risk Assessment Guidance for Superfund (EPA 1989a). The characteristics of potential humanreceptors were based on the site-use described in the Fort Harrison Reuse Plan (Clark, et al. 1997). Forexample, people exposed to the EI sites within the state park were evaluated under a set of assumptionsfor "recreational users."

Risk to human receptors was grouped into two types of health effects, carcinogenic andnoncarcinogenic. The target level for carcinogenic risk is 10-4 (i.e., one incident of cancer per 10,000individuals). The level of concern for noncarcinogenic risk is measured by the Hazard Index (HI). An HIgreater than 1 was considered to exceed the acceptable level of concern for noncarcinogenic effects.Human health contaminants of concern (COC) are those that contribute significantly to human health risk.

An ecological risk assessment (ERA) also was conducted. This risk assessment identified representativeecological receptors, such as earthworms, the American robin (Turdus migratorus), and the Indiana bat(Myotis sodalis), and evaluated the effect of


site-contaminants on those receptors. The ERA was accomplished in several phases. A screening ERA wasfollowed by the baseline ERA. The assumptions and methods of the screening and baseline ERA aredetailed in the final Phase II EI report. Levels of concern to ecological receptors are measured by aquantity called the Hazard Index (HI), which is similar to the HI used to assess noncarcinogenichuman-health risk. Ecological COCs are those contaminants that significantly elevate the level of concernto ecological receptors (i.e., exceed HI of 1) at a site.

The human health risk assessment and baseline ERA concluded that surface soil is the onlyenvironmental medium of concern at the RA sites. Levels of concern regarding risks to human andecological receptors from contaminants in surface water and sediment, and in groundwater for humans, donot exceed acceptable levels or otherwise fail to trigger the need for remediation. (e.g., residual risk at onesite is a product of site-wide application of pesticides).

A site-by-site summary of human-health and ecological-risk indicators from exposure to surface soilis provided below. For human health risk, each receptor modeled in the risk assessment is listed along withthe estimated cancer risk and HI. For ecological risk, a summary description of the results is provided.Additional details on the ecological risk assessment can be found in Section 6 and Appendix P of the FinalPhase II EI Report (SAIC 1998) and in the FFS (SAIC 1999a).

Note: Risk estimates are presented for both the reasonable maximum exposure (RME) and thecentral tendency exposure (CTE) for each receptor evaluated. The ecological risk values presentedwere computed in Round 2 of the baseline ERA. These results reflect the most realistic exposureassumptions.

EI Site SM20 - Pesticide Mixing and Storage Areas, Building 605

The current land use evaluated in the EI was maintenance. The future land use was evaluated ascommercial/industrial, since this property had been designated for special use by the City of LawrenceWater Department. Since publication of the FFS and proposed plan, however, the future disposition ofthis site has become uncertain. The Army is consequently providing for unrestricted future land use and hascompleted the baseline human health risk assessment under a residential future land use for EI Site SM20.(See Section II for additional information.) The risk indicators are as follows:

• Current Land Use: Maintenance WorkerRME: Carcinogenic Risk = 3 x 10-5 (3 in 100,000) HI = 0.02CTE: Carcinogenic Risk = 1 x 10-6 (1 in 1,000,000) HI = 0.005

• Future Land Use: Commercial/Industrial WorkerRME: Carcinogenic Risk = 3 x 10-5 (3 in 100,000) HI = 0.02CTE: Carcinogenic Risk = 1 x 10-6 (1 in 1,000,000) HI = 0.005


• Future Land Use: Residential AdultRME: Carcinogenic Risk = 9 x 10-5 (9 in 100,000) HI = 0.03CTE: not computed

• Future Land Use: Residential ChildRME: Carcinogenic Risk = 8 x 10-5 (8 in 100,000) HI = 0.1CTE: not computed

The risk to current or future receptors does not exceed the acceptable carcinogenic risk level of 10-4

and the noncarcinogenic HI of 1.

The ERA demonstrated that the American robin is the most sensitive of the receptors to the surface soilcontamination at EI Site SM20. The 19 for the robin was 41. Almost 90% of this measure is due to DDTlevels. Dieldrin and 2,3,7,8-TCDF also contribute; but DDT is the most widespread COC at the site.


At EI Site SM21, the current land use evaluated in the EI was recreational and maintenance, and thefuture land use was recreational. Risks were estimated for maintenance workers and for adult and childincidental recreational visitors. The risk indicators were as follows:

• Current Land Use: Maintenance WorkerRME: Carcinogenic Risk = 3 x 10-6 (3 in 1,000,000) HI = 0.03CTE: Carcinogenic Risk= 9 x 10-8 (9 in 100,000,000) HI = 0.004

• Current Land Use: Adult Recreational VisitorRME: Carcinogenic Risk = 2 x 10-5 (2 in 100,000) HI = 0.2CTE: Carcinogenic Risk = 7 x 10-7 (7 in 10,000,000) HI = 0.02

• Current Land Use: Child Recreational VisitorRME: Carcinogenic Risk = 2 x 10-5 (2 in 100,000) HI = 0.5CTE: Carcinogenic Risk = 1 x 10-6 (1 in 1,000,000) HI = 0.08

• Future Land Use: Adult Recreational VisitorRME: Carcinogenic Risk = 4 x 10-5 (4 in 100,000) HI = 0.4CTE: Carcinogenic Risk = 1 x 10-6 (1 in 1,000,000) HI = 0.04

• Future Land Use: Child Recreational VisitorRME: Carcinogenic Risk = 3 x 10-5 (3 in 100,000) HI = 1.0CTE: Carcinogenic Risk = 2 x 10-6 (2 in 1,000,000) HI = 0.2

For maintenance workers and recreational visitors, the health risk is below the carcinogenic risk of 10-4

and does not exceed the noncarcinogenic HI of 1.


As was the case at El Site SM20, the most sensitive of the ecological receptors at EI Site SM21 is theAmerican robin. Exposure to the furan 2,3,7,8-TCDF dominated the measurement HI of 5.


At EI Site SM26, the current and future land use is recreational. Risks were estimated for future adult andchild incidental recreational visitors. Risk to current receptors was determined to be identical to that offuture receptors. The risk indicators were as follows:

• Current and Future Land Use: Adult Recreational VisitorRME: Carcinogenic Risk = 2 x 10-6 (2 in 1,000,000) HI = 0.002CTE: Carcinogenic Risk = 5 x 10-8 (5 in 100,000,000) HI = 0.0002

• Current and Future Land Use: Child Recreational VisitorRME: Carcinogenic Risk = 7 x 10-7 (7 in 10,000,000) HI = 0.003CTE: Carcinogenic Risk= 3 x 10-8 (3 in 100,000,000) HI = 0.0003

For recreational visitors, the health risk is below the carcinogenic risk level of 10-4 and thenoncarcinogenic HI of 1.

The American robin and the short-tailed shrew both were estimated to have risk from exposure to leadand zinc in the surface soil of the former sludge-drying beds. The HI for the robin was 535, and the shrew,26. Surface soil at EI Site SM26 beyond the boundaries of the sludge-drying beds indicated nounacceptable level of concern for ecological receptors.

7. DESCRIPTION OF THE REMEDIAL ACTION ALTERNATIVES

As summarized above, the baseline ERA indicated an elevated level of concern for risk to ecologicalreceptors in excess of the acceptable risk threshold. The purpose of the FFS was to develop and evaluateremedial action alternatives in order to determine the appropriate response to the contamination at thesethree sites. Remedial action objectives were developed in the FFS in order to guide the development andevaluation of remedial action alternatives. Four remedial action objectives were identified:

• Remove or prevent exposure to surface soil containing concentrations of COCs that pose anunacceptable risk to ecological receptors;

• Prevent transport of contaminated surface soil to other environmental media; • Limit disturbance of ecological resources to the greatest extent possible; and • Restore the sites to conditions consistent with their planned re-use.

Due to the simplicity of the contaminants and the media, the alternatives development and evaluationin the FFS focused on a few, well-proven remedial-action technologies. The site conditions did not warranta broadly-scoped feasibility study.


Two alternatives were developed in detail for EI Sites SM20 and SM21 and three for EI Site SM26.For all three sites, Alternative 1 is the no-action alternative. EPA guidance requires the consideration of ano-action alternative to serve as a basis against which to compare other remedial alternatives. Theno-action alternative assumes that the Army would discontinue any institutional controls currently inexistence. Warning signs would not be posted, and the property could be transferred for use consistent withthe Fort Harrison Reuse Plan (Clark et al., 1997). A description of the other alternatives developed foreach site is presented below.


Alternative 1: No Action

Alternative 2: Excavation and Offsite Disposal of Contaminated Soil

This alternative consists of excavating and disposing the contaminated soil at an offsite special-wastedisposal facility. This alternative requires site preparation (including installation of fences, signs, anderosion-control mechanisms, and the mobilization of field teams), excavation, verification sampling,transportation of soils to a disposal facility, and site restoration.

The excavation contour was determined by the method shown in Appendix B of the FFS. Theproposed excavation contour is depicted in Figure 3. The resultant average residual concentration of DDTat EI Site SM20 would be approximately 0.029 ppm. This residual concentration corresponds to a residualHI to the American robin of approximately 2.4, based on the assumptions and methodology of the round2 baseline ERA. The excavation contour was developed with the intent of balancing ecological benefitderived from contaminant-removal with ecological harm caused by tree-removal and site-disturbance. Themost highly-contaminated soil is included within the boundary of excavation. Further reduction in the HIwould require removal of very large, mature trees at the northeast boundary of the site and the excavationof large volumes of soil contaminated with only small concentrations of DDT. The ecological disruptionthese actions would cause is not warranted by the small incremental reduction in risk from removingadditional soil.

The actual DDT preliminary remediation goal (PRG) for this remedial action was derived followingpublication of the FFS and proposed plan and is presented in Appendix B of this ROD. The DDT PRGfor this remedial action is 0.164 ppm. The approach taken to derive the PRG confirms that the limits ofexcavation presented in the FFS and proposed plan have been conservatively delineated. Table 1 presentsthe analytical results for DDT in the surface soil in order of highest to lowest concentration.



Table 1. Analytical Results for DDT in Surface Soil at EI Site SM20

Sample ID Concentration Units Qualifier

SM020SS010 6.8 ppm J

SS-DE-02 4.3 ppm D

SM020SS005 0.99 ppm J

SS-DE-10 0.98 ppm J

SM-020SS004 0.85 ppm J

SM020SS003 0.79 ppm J

SM020SS009 0.71 ppm J

SS-DE-07 0.55 ppm J

SS-DE-07 0.54 ppm D


SM020SS005 0.48 ppm J

SS-DE-04 0.45 ppm J


SS-DE-09 0.27 ppm D

SM020SS008 0.24 ppm J

SS-DE-06 0.18 ppm D

PRG = 0.164 ppm

SS-DE-12 0.15 ppm D

SS-DE-01 0.13 ppm R

SM020SS002 0.12 ppm J

SM020SS007 0.11 ppm J

SS-DE-03 0.099 ppm D

SM020SS006 0.0907 ppm J

SS-DE-08 0.085 ppm D

SS-DE-14 0.084 ppm J

SM020SS011 0.0739 ppm

SS-DE-03 0.053 ppm

SS-DE-13 0.047 ppm

SS-DE-11 0.34 ppm

SS-DE-05 0.014 ppm J


J - estimated concentrationD - dilutedR - rejected

Under this alternative, contaminated soil would be excavated initially to a depth of six inches. Basedon these limits, approximately 335 cubic yards of soil will be excavated.

Verification sampling would be conducted inside the excavation to confirm DDT concentrationshave been reduced to or below the PRG of 0.164 ppm. Details of the verification sampling have beensubmitted to IDEM and EPA under separate cover.

Prior to shipping excavated soil for disposal, the necessary special-waste certification would beobtained from IDEM. Alternatively, the necessary verification may be obtained directly from a qualifiedlandfill. Waste soil excavated from EI Site SM20 would be managed and disposed as a Category Bspecial waste, as defined by IDEM regulations.

Site restoration includes the addition of clean fill material and topsoil to restore the grade to matchthe natural topography, and re-seeding.

• Total Cost: $54,000• Completion Time: 1 week (in the field)



Alternative 2: Excavation and Offsite Disposal of Contaminated Soil

Excavation and disposal of the contaminated soil at EI Site SM21 would proceed in the same wayas described for EI Site SM20. This alternative includes the same elements of site preparation,excavation, verification sampling, disposal, and site restoration.

The excavation contour at EI Site SM21 was determined by the same method used at EI SiteSM20, shown in Appendix B of the FFS. A concentration of 10-6 ppm of 2,3,7,8-TCDF wasdetermined to correspond to a residual HQ of 1 to the American robin under the assumptions andmethodology of the round 2 baseline ERA. All locations where 2,3,7,8-TCDF were detected above10-6 ppm were included within the excavation contour.

The actual 2,3,7,8-TCDF PRG for this remedial action was derived following publication of theFFS and proposed plan and is presented in Appendix B of this ROD. The 2,3,7,8-TCDF PRG for thisremedial action is 2.5x10-5 ppm. The approach taken to derive the PRG confirms that the limits ofexcavation have been conservatively delineated. Table 2 presents the analytical results for2,3,7,8-TCDF in the surface soil in order of highest to lowest concentration.


Table 2. Analytical Results for 2,3,7,8-TCDF in Surface Soil at EI Site SM21


SS-GC-07 4.11x10-5 ppm

PRG =2.5x10-5 ppm

SS-GC-02 1.5x10-6 ppm

SS-GC-09 1.42 x10-6 ppm

SS-GC-03 1.21 x10-6 ppm

SS-GC-06 0.82 x10-6 ppm U

SS-GC-06 0.73 x10-6 ppm U

SS-GC-05 0.59 x10-6 ppm U

SS-GC-04 0.39 x10-6 ppm U

SS-GC-01 0.31 x10-6 ppm U

SS-GC-08 0.31 x10-6 ppm U

J – estimated concentrationU – non-detectD – dilutedR – rejectedNote: 2,3,7,8-TCDF was not analyzed for during Round 1EI sampling

The estimated excavation profile for EI Site SM21 is depicted in Figure 4. Based on an excavationdepth of six inches, the total volume of soil to be removed under this alternative is 120 cubic yards. Duringthe fall of 1998, the state removed from the site Building 674 and the concrete slab beneath it. Some minorregrading also was performed. To account for the limit of the regrading activities, lateral-extent estimatesbased on EI sampling results were increased by one-third.

Excavated soil would be disposed at an appropriately-licensed special-waste disposal facility. Theexcavation contour is based on the distribution of 2,3,7,8-TCDF in the soil. Note that chlordane, whichhas a promulgated RCRA-characteristic toxicity standard, also was detected at this site and may be presentin the excavated soil. Waste characterization conducted to satisfy IDEM certification requirements or theverification requirements of a special waste landfill would include analysis of the soil to ensure that it doesnot exceed the standard for characteristic toxicity.

Verification sampling would be conducted inside the excavation to confirm that the residualconcentrations of 2,3,7,8-TCDF are at or below the PRGs of 2.5x10-5 ppm. Details of the verificationsampling have been submitted to IDEM and EPA under separate cover and will be included in remedialaction planning documents.



• Total Cost: $29,000• Completion Time:<1 week (in the field)



Alternative 2: Simple – Technology Excavation and Offsite Disposal of Contaminated soils

Under this alternative, six inches of soil within the bermed sludge-drying beds would be excavated andremoved from the site. Concentrations of lead and zinc exceeding PRGs were limited to the surface soilof the former sludge beds. (PRGs for lead, copper, zinc, arsenic, and antimony were approved by the FBHBCT prior to the remediation of the FBH small-arms firing ranges.) Tables 3 and 4 present the analyticaldata for surface soil at EI Site SM26 for lead and zinc, respectively. As shown in Figure 5, only the soilfrom the sludge beds would be excavated – approximately 700 cubic yards of soil.

Table 3. Analytical Results for Lead in Surface Soil at EI Site SM26


SS-S1-02 1080 ppm J

SS-S1-03 851 ppm J

SS-S1-04 837 ppm J

SS-S1-01 442 ppm J

PRG = 440 ppm

SS-S1-05 233 ppm J

SS-S1-05 191 ppm J

SS-S1-06 58.6 ppm J

SS-S1-09 32.2 ppm

SS-S1-08 9.3 ppm

SS-S1-07 8.5 ppm

J – estimated concentrationD – dilutedR – rejected



Table 4. Analytical Results for Zinc in Surface Soil at EI Site SM26


SS-S1-02 2070 ppm J

SS-S1-04 1390 ppm J

SS-S1-03 1260 ppm J

SS-S1-01 764 ppm J

PRG = 234 ppm

SS-S1-05 161 ppm J

SS-S1-05 155 ppm J

SS-S1-06 135 ppm J

SS-S1-07 52.3 ppm

SS-S1-08 45.2 ppm

SS-S1-09 30.8 ppm

J–estimated concentrationD–dilutedR–rejected

EI Site SM26 is forested, including the former sludge-drying basins and the berms that enclose them.During development of alternatives, ecological benefit from the removal of contaminated soil was balancedwith the ecological harm caused by removal of trees and disturbance of the local ecosystem. Alternative2 attempts to minimize the impact on the environment by using hand-held shovels and other manualequipment within the sludge-drying beds.

The top six inches of soil would be removed and transported by hand to the edge of the bed, wheresmall-powered equipment would be used to transport the soil up the bluff. The location of the proposedaccess road to be used for moving soil up the bluff is also shown in Figure 5. The soil would be loaded intotrucks that would transport the soil to an appropriate off-site disposal facility.

Verification sampling would be conducted inside the excavation to confirm that COCs have beenreduced below the PRGs. Details of the verification sampling have been submitted to IDEM and EPAunder separate cover and will be included in remedial action planning documents.

• Total Cost: $198,000• Completion Time: 4 weeks (in the field)

Alternative 3: Excavation and Offsite Disposal of Contaminated Soils

Alternative 3 requires the excavation and disposal of the same amount of soil as Alternative 2. Therequirements for site preparation, excavation, verification, disposal,


and site restoration are also the same as in Alternative 2. This alternative differs in that an hydraulicexcavator or backhoe would be used instead of manual labor within the sludge-drying beds to remove thecontaminated soils.

In order to facilitate use of powered equipment in the sludge-drying beds, all trees less than 6 inchesin diameter would be removed, if necessary. Trees greater than 6 inches would be left in place, if possible.

Verification sampling would be conducted inside the excavation to confirm that COCs have beenreduced below to or below PRGs. Details of the verification sampling 19 have been submitted to IDEMand EPA under separate cover and will be included in remedial action planning documents.

• Total Cost: $146,000• Completion Time: 3 weeks (in the field)

8. SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES

The alternatives described above were evaluated against the nine criteria identified by EPA inGuidance for Conducting Remedial Investigations and Feasibility Studies under CERCLA, InterimFinal (EPA 1989b). The nine criteria are described in the Table 5.

The following analysis evaluates the remedial alternatives under the threshold criteria category (i.e.,overall protection of human health and the environment, and compliance with regulations). If the thresholdcriteria are met, the alternatives are further evaluated using the seven additional evaluation criteria. Thepurpose of this analysis is to identify the relative advantages and disadvantages of each alternative.

Threshold criteria:

• Overall protection of human health and the environment.

The no-action alternative (Alternative 1) does not satisfy the first threshold criterion of overallprotection of the environment. As described previously, all three RA sites currently pose unacceptable riskto ecological receptors. At all three sites, Alternative 1 would not reduce the risk and, consequently,unacceptable risk would remain. Alternatives 2 at EI Sites SM20 and SM21, and Alternatives 2 and 3 atEI Site SM26 reduce the current and future risks by removing and disposing contaminated soils. Alternative2 at EI Site SM20 reduces the risk to the American robin to an HI between 2 and 3. This value approachesthe threshold of 1. Further reduction of the HI does not justify the additional disturbance to the localecosystem.

• Compliance with all state and federal regulations.

Because no action would be taken under Alternative 1, no regulations would be invoked. Any actionstaken under Alternative 2 at EI Sites SM20 and SM21, and


Table 5. U.S. EPA Evaluation Criteria

U.S. EPA's Evaluation Criteria

U.S. EPA uses the following nine criteria to evaluate proposed cleanup alternatives:1. Overall protection of human health and the environment

U.S. EPA assesses the degree to which the alternatives eliminate, reduce, or control threats to publichealth and the environment through treatment, containment methods, and/or institutional controls such asfences and deed restrictions.

2. Compliance with all state and federal environmental regulationsU.S. EPA assesses whether the remedial alternatives being evaluated comply with all applicable orrelevant and appropriate requirements (ARARs) pertinent to the site conditions, or whether a waiver willbe necessary. A waiver would be allowed only if the chosen remedial alternative is considered to be animprovement over remedial alternatives that comply with ARARs.

3. Long – term effectiveness and permanenceThe alternatives are evaluated based on their ability to maintain reliable protection of human health andthe environment after the remedy is completed.

4. Reduction of contaminant toxicity, mobility, or volume through treatmentU.S. EPA evaluates each alternative based on how its treatment methods reduce the harmful nature ofcontaminants, the ability of contaminants to move, and the amount of contamination present.

5. Short – term effectivenessThe length of time needed to implement each alternative is considered, and U.S. EPA considers thepotential risk to workers and nearby residents while a particular remedial activity is being conducted.

6. Technical and administrative difficultyU.S. EPA considers the technical (e.g., how difficult is the alternative to construct and operate?) andadministrative (e.g., how will other government agencies and U.S. EPA coordinate monitoring programs?)feasibility of a remedy, including the availability of goods, services, and personnel needed to implementand manage the alternatives.

7. CostU.S. EPA considers capital and operations and maintenance costs as well as present net worth, which isthe cost in today's dollars of activities that will take place over the next several years.

8. State acceptanceU.S. EPA requests the state's comments on the Feasibility Study and Proposed Plan and must take intoconsideration whether the state agrees with or opposes the Proposed Plan for addressing contaminationproblems at the site.

9. Community acceptanceU.S. EPA assesses community acceptance of the Proposed Plan by providing the public with anopportunity for input in the selection of a remedy for the site. A public comment period is held, and U.S.EPA considers and responds to comments received from the community prior to the selection of a finalremedy.

In the evaluation process, U.S. EPA divides these nine criteria into three groups:A) Threshold criteria. Each alternative must meet threshold requirements in order to be eligible for selection.

These requirements include overall protection of human health and the environment, and compliance withARARs.

B) Primary balancing criteria. Of the nine criteria, U.S. EPA uses primary balancing criteria to compare thedegree to which the alternatives meet the individual criteria. The five prime balancing criteria are long – termeffectiveness and permanence; reduction of toxicity, mobility, or volume; short – term effectiveness;implementability; and cost.

C) Modifying criteria. Community and state acceptance are called modifying criteria because they couldpossibly result in changes to the Proposed Plan. U.S. EPA shall consider community acceptance whileselecting a cleanup plan after comments from the community have been received during the public commentperiod.


Alternatives 2 or 3 at EI Site SM26 would be performed in compliance with the regulations.

Note: Because the no-action alternative does not satisfy thethreshold criterion of protection of the environment, evaluation ofAlternative 1 under the primary balancing criteria has not beenperformed.

Primary Balancing Criteria:

• Long – term effectiveness and permanence

Alternative 2 at EI Sites SM20 and SM21 permanently reduces the residual risk to belowits current level and requires no institutional controls to maintain.

Alternatives 2 and 3 at EI Site SM26 are effective in the long term because residualcontamination will be at or below PRGs.

• Reduction of toxicity, mobility, or volume through treatment

For EI Sites SM20 and SM21, no treatment of soil is proposed, so no reduction of toxicity,mobility, or volume is achieved with-Alternative 2. However, the contaminants in the soil arenot mobile in the environment and affect only small volumes of soil that require excavation.

As described in Section 11, since the publication of the proposed plan, additional soilcharacterization data has been obtained that shows that the lead in the soil of the sludge-dryingbeds does not leach at levels that would trigger hazardous-waste management requirements.For this reason, the soil may be disposed directly, without treatment, as a special waste.

• Short – term effectiveness

Any negative short-term impacts during implementation of Alternative 2 at EI Sites SM20and SM21 would be minor. Worker-safety concerns are minor because of the relativesimplicity of the excavation tasks. At EI Site SM21, located on Shafter Road, traffic into andout of the state park would be temporarily affected. Trees and shrubs within the excavationzone could be removed if necessary.

At EI Site SM26, localized short-term impacts would occur because the site is located ina heavily-wooded area. Access would be gained through privately-owned property on LawtonLoop West Drive. The abandoned access road would be the point of entry for all equipment andsupplies required for Alternatives 2 and 3. Fences and signs would be posted to preventunauthorized entry to the construction site during implementation. Access to the sludge bedsfrom the clearing will require the removal of undergrowth and very few trees, and minorgrading. Alternative 3 would cause additional disturbance to the environment because smalltrees in the sludge beds would be removed to


accommodate the use of small-to medium-sized earthmoving equipment. Worker-safety and-exposure concerns at EI Site SM26 would be greater with Alternative 2 than with Alternative3 because the soil would be excavated by hand.

• Implementability

There are no technical or administrative obstacles to implementing Alternative 2 at EI SitesSM20 and SM21. The equipment is readily available, and the Army at FBH is familiar with thedisposal of special waste in Indiana.

For Alternatives 2 and 3 at Site SM26, the primary technical challenge would be thetransport of soil to the top of the hill. Care must be taken when driving construction equipmentup and down the hill. Additionally, excavation of soil from the sludge-drying beds may be mademore difficult by the presence of tree roots near the surface.

• Cost

Alternative 2 for EI Site SM20 would cost $54,000. For EI Site SM21, the cost ofAlternative 2 is $29,000.

Alternatives 2 and 3 for EI Site SM26 would cost $198,000 and $146,000, respectively.

Modifying Criteria:

• State acceptance

The Army received and considered comments from the IDEM and from EPA Region 5.Final resolution of the comments from IDEM and EPA is documented in the ResponsivenessSummary in Appendix A to this ROD.

• Public acceptance

No comments from the public were received on the proposed plan for the three sites.

9. SELECTED REMEDY

After reviewing each remedial alternative developed for EI Sites SM20, SM21, and SM26,and comparing the alternatives against EPA evaluation criteria, the Army has selected thefollowing remedies for remediation of contaminants at these three sites.


The selected remedy for EI Site SM20 is Alternative 2, Excavation and Offsite Disposal.The remedy satisfies the remedial-action objectives. It can be implemented easily withminimal impact to the surrounding environment, and is highly effective in the


long term because the majority of risk-causing contaminants would be permanently removedfrom the site.


The selected remedy for this site is Alternative 2, Excavation and Offsite Disposal. Theremedy satisfies the remedial-action objectives and can be implemented easily. Impacts to thesurrounding environment would be minimal, and the remedy is highly effective in the long termbecause contaminants would be removed from the site.


The selected remedy for EI Site SM26 is Alternative 3, Excavation and Offsite Disposal.This remedy can be implemented more quickly and with less risk to workers than thesimple-technology option developed in Alternative 2. Contaminants would be permanentlyremoved from the site, thus achieving the remedial-action objectives and long-termeffectiveness.

10. STATUTORY DETERMINATIONS

The selected remedial alternatives at the three sites are protective of human health and theenvironment. They utilize permanent solutions that eliminate the existing threats to ecologicalreceptors by removing contaminated soils to achieve levels at or below the PRGs. Thehuman-health risks at the three RA sites are below the carcinogenic risk target level of 10-4 andthe noncarcinogenic risk target level of an HI of 1.

The selected remedial alternatives at the three RA sites will be implemented in accordancewith all ARARs, as presented in Appendix C of the FFS. The U.S. Fish and Wildlife Service hasbeen consulted regarding the need for clearing trees in the habitat of the Indiana bat. Alltree-removal activities at EI Site SM26 have been conducted in accordance with theirrequirements, as documented in Appendix C of this ROD. Waste will be managed inaccordance with federal regulations, as well as the State of Indiana's special waste regulations,as applicable. Other ARARs, such as those governing fugitive dust emissions and erosioncontrol, will be addressed as necessary in forthcoming remedial action planning.

The selected remedies provide cost-effective solutions by using proven technology toremove contaminated soils and eliminating the cost of long-term monitoring. Removal ofcontaminated soils also decreases the potential for future remedial costs.

The remedies also utilize permanent solutions and technologies to the maximum extentpracticable. They provide for quickly- and easily-implemented actions that limit short-termexposure to workers and include permanent removal of contaminated soils for long-termeffectiveness.


Treatment as part of the remedial actions is not warranted for the three RA sites. Volumesare low and analytical data shows that the contaminated soils will not fail TCLP, permittingtheir disposal as Category B special waste.

11. EXPLANATION OF SIGNIFICANT CHANGES

This section describes changes in the proposed remedial actions for EI Sites SM20, SM21,and SM26 since publication of the proposed plan. Other information generated sincepublication of the proposed plan is also included below.

Elimination of Need for Optional Treatment at EI Site SM26

The purpose of the optional stabilizing agent under Alternatives 2 and 3 for EI Site SM26in the FFS was to render the waste soil non-hazardous for disposal. Application of thestabilizing agent would have bound the lead contamination to the soil matrix so that it wouldnot be readily leached from the soil by EPA’s toxicity characteristic leaching procedure(TCLP). Since publication of the Proposed Plan for EI Sites SM20, SM21, and SM26 (SAIC1999b), two soil samples have been collected from the sludge-drying beds and analyzed. Theanalysis indicated that the lead does not leach from the soil when the TCLP is performed, evenwithout the stabilizing treatment. (See response to comment 3.14 in Appendix A for moredetail.)

Based on these results, the Army will handle soil taken from the sludge basins as specialwaste. The preliminary TCLP data cited above indicates that the soil can be managed as aCategory B special waste. Prior to excavation, additional samples will be collected andanalyzed in accordance with the requirements of IDEM (through the waste certificationprocess) or a licensed special waste landfill (through the verification program process).

Additional Area of Concern at EI Site SM26

In May 1999 a field team from SAIC discovered a third sludge-drying bed at EI Site SM26.This third sludge bed is located east of the other two, as shown in Figure 5. It is bounded onthree sides by earthen berms. The fourth side is a hillside that bounds the bed.

On June 8, 1999, SAIC sampled the third sludge-drying bed. The same sample collectiontechniques and quality assurance/quality control methodology used during the Phase II EI fieldinvestigation were used during collection and management of these samples. Discrete sampleswere collected from two locations. Three samples were collected at each location: (1) asurface soil sample collected at a depth of 0 to 0.5 ft; (2) a subsurface soil sample collectedat a depth of 1 to 2 ft; and (3) a subsurface soil sample from the bottom of the boring at a depthof approximately 4 feet. All samples were analyzed for target compound list volatile organiccompounds, semi-volatile organic compounds, and pesticides, as well as target analyte listmetals, cation exchange capacity, and total organic carbon.


The analytical results indicate that the third bed has the same characteristics as the other two. Lead andzinc were detected above PRGs, while other metals, VOCs, SVOCs, herbicides, and pesticideconcentrations are comparable to those in the two larger sludge drying beds. The lead and zinc analyticaldata for the two sampling locations in the third bed are shown in Table 6.

Table 6. Lead and Zinc Concentrations at Third Sludge-Drying Bed at EI Site SM26

Depth(feet) Sample Location Lead

(ppm)Zinc(ppm)

0.0 - 0.5 SS-S1-10 1690 2070

0.0 - 0.5 (field dup.) SS-S1-10 1680 2020

0.0 - 0.5 SS-S1-11 3900 2350

1.0 - 2.0 SB-S1-10 238 555

1.0 - 2.0 SB-S1-11 763 1260

3.0 - 3.6 SB-S1-10 98.4 215

3.8 - 4.3 SB-S1-11 276 328

In addition to the discrete samples reported above, one composite sample was generatedfrom surface soil collected from six locations within the bed. The lead-toxicity of the surfacesoil was assessed through TCLP. Consistent with the findings in the first two sludge-dryingbeds, lead did not leach at sufficient concentrations to require that the soil be managed as ahazardous waste.

The proposed excavation depth for the third sludge-drying bed is two feet. Verificationsampling will be performed when the target depth, is reached. If concentrations of lead or zincexceed the PRG, another cut of soil will be removed and so on, until the PRGS area attained.The cost estimates for Alternatives 2 and 3 in Sections 7 and 8 above have been modified toreflect the additional volume of soil to be removed.

The results of the analytical data from the sampling of the third sludge bed are included inAppendix D of this ROD. The data has been validated, and the validation codes are included inAppendix D. Analytes for which no results are reported were undetected in all samples.Additional evaluation of the data is underway. The Army anticipates that the results of theevaluation will not change the selected remedial action. The soil from the third sludge bed willbe excavated, characterized, and disposed off-site in accordance with all applicable regulations.

Results of Human Health Risk Assessment for Residential Future Land Use at EI SiteSM20

Since publication of the FFS and proposed plan, the projected future land use at EI SiteSM20 has changed. The Army has provided for unrestricted use at this site by


demonstrating that the cancer risk posed under residential future land use does not exceed thetarget risk level of 10-4 and the noncarcinogenic risk does not exceed an M of 1. The resultsof the human health risk assessment for residential future land use at EI Site SM20 are shownin Table 7. The procedures used to evaluate the future residential land use scenario replicatethose used in the Phase II EI at this and other EI sites.


Table 7. Human Health Risk Assessment Summary for Residential Future Land Use at EI Site SM20, Fort Benjamin Harrison, Marion County, Indiana

Medium ExposureRoute

Noncancer HI Cancer Risk

Residental Rec. Visitor Ind. Const. Residential Rec. Visitor Ind. Const.

Child Adult Child Adult Worker Worker Child Adult Child Adult Worker Worker

Surface Soil Ingestion 9E-02 B 9E-03 B NA NA 7E-03 B NA 3E-05 B 1E-05 B NA NA 9E-06 B NA

(0 to <0.5 feet BGS) Dermal Contact 4E-02 B 2E-03 B NA NA 2E-02 B NA 1E-05 B 3E-05 B NA NA 2E-05 B NA

Inhalation (Dust) 0E+00 B 0E+00 B NA NA 0E+00 B NA 2E-09 B 2E-09 B NA NA 1E-09 B NA

Subsurface Soil Ingestion 0E+00 B 0E+00 B NA NA NA NA 6E-05 B 3E-05 B NA NA NA NA

(0.5 to 10 feet BGS) Dermal Contact 0E+00 B 0E+00 B NA NA NA NA 2E-05 B 6E-05 B NA NA NA NA

Inhalation (Dust) 0E+00 B 0E+00 B NA NA NA NA 5E-09 B 5E-09 B NA NA NA NA

Groundwater Ingestion NA NA NA NA NA NA NA NA NA NA NA NA

Dermal Contact NA NA NA NA NA NA NA NA NA NA NA NA

Inhalation (VOCs) NA NA NA NA NA NA NA NA NA NA NA NA

Sediment Dermal Contact NA NA NA NA NA NA NA NA NA NA NA NA

Surface Water Dermal Contact NA NA NA NA NA NA NA NA NA NA NA NA

Surface Soil, Groundwater, Sediment, and Surface Water

Combined Hazard Index: 1E-01 B 3E-02 B NA NA 2E-02 B NACombined Cancer Risk: 4E-05 B 5E-05 B NA NA 3E-05 B NA

Surface Soil, Groundwater, Sediment, and Surface Water

Combined Hazard Index: 0E+00 B 0E+00 B NA NA NA NACombined Cancer Risk: 8E-05 B 9E-05 B NA NA NA NA

NA - scenario or pathway not evaluated, or all chemicals detected in surface water samples were eliminated as COPCs0E+00 - pathway evaluated but no risks could be calculated due to lack of EPA-approved toxicity valuesB - HI ≤ 1 or ELCR ≤ 10-4

E - HI > 1 or ELCR > 10-4


12. REFERENCES

Clark, Quinn, Moses & Clark (Clark, et al.) 1997. Fort Benjamin Harrison Preliminary Plan,Planned Unit Development. January 30, 1997.

Harding Lawson Associate (HLA) 1995. Revised Final Phase I Environmental InvestigationReport, Fort Benjamin Harrison, Marion County, Indiana. September 1995.

Science Applications International Corporation (SAIC) 1996. Proposed Plan for No FurtherAction Sites at Fort Benjamin Harrison, Marion County, Indiana. November 1996.

SAIC 1997. Preliminary Rernediation Goals for EI Sites SM22, SM23, and SM24, Fort Benjamin Harrison, Marion County, Indiana. January 1997.

SAIC 1998. Final Phase II Environmental Investigation Report, Fort Benjamin Harrison,Marion County, Indiana. August, 1998.

SAIC 1999a. Focused Feasibility Study for Environmental Investigation Sites SM20, SM21,and SM26, Former Fort Benjamin Harrison, Lawrence, Indiana. March 1999.

SAIC 1999b. Proposed Plan for Environmental Investigation Sites SM20, SM21, and SM26,Former Fort Benjamin Harrison, Lawrence, Indiana. March 1999.

SAIC 1999c. Record of Decision for Seventeen No Further Action Sites in the Final Phase 11Environmental Investigation. March 1999.

U.S. Environmental Protection. Agency (EPA) 1989a. Risk Assessment Guidance forSuperfund, Volume I – Human Health Evaluation Manual (Part A). Interim Final.EPA/540/1-89/002. December 1989.

EPA 1989b. Guidance on Preparing Superfund Decision Documents: The Proposed Plan, TheRecord of Decision, Explanation of Significant Differences, The Record of DecisionAmendment. Interim Final. EPA/540/G-89/007. July 1989.

EPA 1997. Ecological Risk Assessment Guidance for Superfund: Process for Designing andConducting Ecological Risk Assessments. Interim Final.

Weston, Roy F., Inc. (Weston) 1992. Enhanced Preliminary Assessment. February 1992


APPENDIX A

RESPONSIVENESS SUMMARY FOR THE FOCUSED FEASIBILITY STUDY AND THE PROPOSED PLAN FOR

ENVIRONMENTAL INVESTIGATION SITES SM20, SM21, AND SM26


Responsiveness Summary Former Fort Benjamin HarrisonA-1

APPENDIX A

RESPONSIVENESS SUMMARY FOR THE

FOCUSED FEASIBILITY STUDY AND PROPOSED PLAN FOR EI SITES SM20, SM21, AND SM26

1. INTRODUCTION

This responsiveness summary has been prepared by the Army to document final resolution of commentsreceived on the Focused Feasibility Study for EI Sites SM20, SM21, and SM26 (FFS) and the Proposed Planfor EI Sites SM20, SM21, and SM26 (proposed plan). The following comments were received on theabove-referenced documents:

• Comments from IDEM on Focused Feasibility Study, dated May 17, 1999.�• Comments from IDEM on the Proposed Plan, dated May 17, 1999.�• Comments from U.S. EPA on the Focused Feasibility Study, dated May 19, 1999.• Comments from U.S. EPA on the Proposed Plan, dated May 13, 1999.

Due to schedule and program constraints, the Army will not be issuing revised versions of the FFS or theproposed plan. Consequently, comments related to the documents’ organization are noted but notaccommodated. Response is made to comments related to approach, methodology, and conclusions.

2. GENERAL COMMENTS ON FFS FROM IDEM (2-1 THROUGH 2-10)

2.1: The ARARs identified by the oversight regulatory agencies, IDEM and the U.S. EPA, were notconsidered when the FFS and PP were developed. Therefore it cannot be determined if the remedialaction alternatives comply with all the ARARs identified by the regulatory agencies. Attachment Icontains the ARARs identified by IDEM. The remedial action alternatives must comply with all theIDEM and US. EPA identified ARARS in order to be considered a viable remedial action alternative.

Response: The Army has fully considered all ARARs identified by the regulating agencies during reviewof the FFS and proposed plan. Note that IDEM Attachment 1 coincides with Appendix C of the FFS, withthe exception of 326 IAC, the volatile organic compound (VOC) rule. VOCs are not COCs at the sites underdiscussion, thus the rule is not applicable.

2.2: Clarification for the exclusion of specific sample locations from the excavation areas for EI sitesSM20 and SM21 is required.

Response: See response to comments 3.8 and 3.11.

2.3: The groundwater is not being addressed for sites SM20, SM21, and SM26 Data for chemicalgroups of particular concern have been rejected during the quality assurance/quality control processof the environmental investigation. Therefore, the actual nature and extent of contamination is notknown and more measures must be taken to protect human health and the environment from theexposure to potentially contaminated groundwater.


Response: Herbicide data in the groundwater samples at EI Sites SM20 and SM21 were rejected due tolow recoveries of surrogates (less than 10 percent) and low recoveries in the matrix spike/matrix spikeduplicates. However, the surface and subsurface soil herbicide data indicate that the threat of herbicidecontamination of the groundwater at these sites is not credible. At EI Site SM20, 2,4-D was detected in 5 outof 29 surface soil analyses. The only other herbicide detected in surface soil was dicamba, which wasdetected only once. No herbicides were detected in the subsurface soil at EI Site SM20. At EI Site SM21,2,4-D was detected in 3 of 23 surface soil samples and was the only herbicide detected in the surface soil.No herbicides were detected in the subsurface soil. Based on these results, there is no potential for herbicidecontamination in the groundwater at these sites.

2.4: The FFS does not discuss preliminary remediation goals (PRG) for chemicals of concern at EISites SM20, SM21, and SM26 The PRGs should be briefly discussed in the document. In addition, thedocument should state that preliminary estimates of excavation were developed using the PRGs andthat the final excavation limits will be determined using verification sampling results to document that(1) approved cleanup standards have been met or (2) the hazard indices (HI) for the remediation areasare less than onefor all receptors.

Response: Final PRGs had not been developed at the time the FFS was published. PRGs for the principalcontaminants of concern have since been developed for DDT at EI Site SM20 and for 2,3,7,8-TCDF at EISite SM21, and are included in this Record of Decision. The PRGs were developed using the samemethodology employed in development of Preliminary Remediation Goals for EI Sites SM22, SM23, andSM24 (SAIC 1997), which was approved by the Fort Benjamin Harrison BRAC Cleanup Team (BCT).

The preliminary limits of excavation were not determined using PRGs, but for EI Site SM20 and SM21 weredrawn by determining what concentrations of COCs would produce an acceptable HI for the American robinunder the assumptions of the Round 2 Baseline ERA. These assumptions are not the same as those usedin the derivation of a PRG. The concentration used to draw the preliminary limits of excavation is a moreconservative measure than the PRG derived using the methodology approved by the BCT.

The Army proposes to excavate the soil in accordance with the limits presented in the FFS, even though thelimits drawn based on the PRG would be less extensive. The Army has elected this approach to ensure thatall COCs at concentrations greater than the PRG are removed. A verification sampling program will confirmthat residual concentrations are at or below the PRG, ensuring that no ecological receptors are exposed tounacceptable risk.

PRGs were developed for the principal COCs at EI Sites SM20 and SM21. At EI Site SM20, the principalCOC is DDT, and the PRG is 164 ppm. At EI Site SM21, the principal COC is 2,3,7,8-TCDF, and theecological PRG is 2.5xl0-5. ppm. Lead and zinc are the COCs at the former sludge-drying beds of EI SiteSM26. Ecological PRGs were developed for these two metals in Preliminary Remediation Goals for EISites SM22, SM23, and SM24 (SAIC 1997). The BCT-approved PRGs for lead and zinc are 440 ppm and234 ppm, respectively.

2.5: The FFSfails to address what impact the run-off or drainagefrom these particular sites have onany environmental sensitive discharge points such as ponds and creeks, e.g., Hawthorne Pond andSchoen Creek etc. In addition, if the discharge has any negative impact additional remedial action maybe necessary at these areas either as part of the remedial action for the subject sites or as a separateaction.


Response: The Army has investigated all areas of environmental concern at FBH under the oversight ofthe BCT. All watersheds potentially affected by these areas of concern have been investigated. The findingsof the investigations were published in the Phase I and Phase II EI reports. The FFS addresses only thoseareas exhibiting unacceptable risk, as discussed in the document. Hawthorne Pond was not identified by theBCT as an area of concern, and so has not been investigated. However, note that the pond was drained anddredged to the underlying hardpan clay in the summer of 1996 by the state park management.

Surface water bodies at FBH were maintained by the Army in compliance with state recreational waterstandards until closure of the installation in 1995. These water bodies have been under the control of the statesince that time and maintained as part of the state park. Since pesticide storage and mixing activities at EISite SM20 ceased in 1991, it would not be expected that any residual effects from that site would remain inHawthorne Pond. Schoen Creek was investigated as the drainageway from EI Site SM26. (See also responseto comment 3.5.) The drainageway from EI Site SM20 is concrete-lined, albeit cracked in some places. TheArmy has investigated soil found in the cracks of the drainageway concrete, and the results have beenincluded in the risk assessment of the site. The Army believes the areas have been evaluatedcomprehensively.

2.6: Sediments have to be addressed separately from contaminated soils. Sediments have different,more stringent clean-up levels than soils. If sediments pose an unacceptable risk to human health orthe environment, they must be addressed through a remedial action.

Response: No response required.

2.7: Clarification is needed on how the excavation depth and the extent of the excavation wasdetermined without having PRGs established.

Response: The estimated depth of contamination in the FFS is six inches. In general, concentrations ofCOCs drop off considerably below six inches. The Army determined that, for the purpose of making apreliminary volume estimate, a six-inch depth was appropriate. The appropriateness of this estimate will beconfirmed in the field during the verification sampling. If the COC concentration remains above the PRG afterthe top six inches have been excavated, another cut of soil will be removed and verification samplingrepeated.

How the lateral extent of contamination was determined is described in Appendix B of the FFS and in theresponse to comment 2.4, above.

2-8: If dust-suppression controls, such as wetting the soils with water, are used as part of the remedialaction, the runoffmust be controlled to avoidfirther spread of contamination.

Response: The small volume of water needed for dust control will not generate a run-off problem.

2.9: The FFS does not discuss the needfor implementing deed restrictions or other institutionalcontrols to limit site use to the anticipated land and groundwater uses and exposure scenariosevaluated in the baseline risk assessment. Institutional controls are required to ensure that the EI Sitesare not usedfor purposes other than those evaluated in the baseline risk assessment. ne Army shouldrevise the FFS to discuss institutional controls that will be implemented for the former FBH site.

Response: At EI Site SM20, which is to be transferred to the FHRA, the Army will provide for unrestrictedreuse, since the planned reuse has changed since completion of the El. The baseline


human health risk assessment was performed for residential future land-use since publication of the proposedplan. The risk assessment shows that risk to residential receptors does not exceed the risk threshold. This isdiscussed further in Section 11 of this ROD.

EI Sites SM21 and SM26 are located in Fort Harrison State Park, currently under lease by the Army to thestate. The future use of these sites by the state park will be recreational, and the sites will be renderedsuitable for recreational use following cleanup. Once the state park parcel is found to be suitable for transfer,the Army will assign it to the Department of the Interior (DOI) for transfer to the state for public use. Thetransfer of the property to the state by DOI is made contingent on its use only for public recreation. Shouldthe property no longer be used for this purpose, it would revert to the DOI, and the Department of the Army.As such, the Army finds no need to impose institutional controls on the use of these sites.

2.10: The FFS states that excavation may cause ecological harm as a result of tree removal and sitedisturbance; however, the plan does not elaborate on the types of ecological harm that could becaused ky excavation activities. The plan should specifically evaluate potential habitat disturbances.For example, the Indiana bat tends to roost below the bark of dead trees. The Army should evaluatewhether contaminated areas contain large, dead trees or other trees with loose bark that may serveas potential bat roosting sites. If so, the Army should consider potential removal options that wouldminimize disturbances to ecological habitats in the remediation areas.

Response: The type of ecological harm possible during remediation is that which would normally occurwhen large, mature trees are removed. Short-term disturbances of the local ecosystem are inevitable due tothe loss of trees and the use of heavy equipment. However, these impacts would be minimal due to the smallsize of the three sites. The Army is planning to avoid tree removals that would cause the destabilization ofslopes and subsequent soil erosion.

The Army has been working with the U.S. Fish and Wildlife Service (USFWS) to ensure that any remedialaction-related disturbance of potential roost trees of the Indiana bat is done in full consultation. Appendix Dcontains a letter from the USFWS approving removal of potential bat trees at EI Site SM26 and concludingthat all issues related to the Indiana bat have been resolved to their satisfaction. On April 14, 1999, the Armyremoved potential roost trees from EI Site SM26.

3. SPECIFIC COMMENTS ON FFS FROM IDEM (3-1 THROUGH 3-22)

3.1: Page 2-1, paragraph 3: Specify if Hawthorne Pond has been negatively impacted by the run-offfrom site SM20. If this is the case, specify what measures will be taken at Hawthorne Pond to alleviateany negative impact.

Response: See response to comment 2.5.

3-2: Page 2-5, paragraph 2: The ecological risk assessment for SM20 does not address the subsurfacesoil detections alpha-chlordane, DDE, dieldrin, gamma-chlordane, and Aroclor-1260 in boringSM020SB003 at a depth of three feet. This requires explanation. If the subsurface poses a risk tohuman health or the environment, it must be addressed.

Response: The screening ecological risk assessment performed in the Final Phase II EI did not identify soilbelow the surface as an environmental medium of concern for the ecological receptors evaluated. Thecontinuation of the risk assessment from the screening phase in the Final Phase II EI through both rounds ofthe baseline ecological risk assessment in the FFS was performed only


for those media that indicated risk in the screening phase. No further evaluation of subsurface soils wasnecessary. The human health risk assessment indicates no unacceptable risk to human health.

3.3: Page 2-13, paragraph 2: At EI Site SM21, excavation of 120 cubic yards has been planned toremove the ecological threat of pesticides, specifically due to gamma-chlordane, in surface soil. It isnot clearly stated what level of contamination is allowed to remain in the soil. The text mentions threesoil sample locations which had the highest concentrations of gamma-chlordane, including soil sampleSS-GC-06. This sampling location is not included in the proposed area of soil removal illustrated onFigure 4-2. An explanation is necessary for excluding this location.

Response: Alpha- and gamma-chlordane were the most frequently detected pesticides, but detectionfrequency alone does not determine extent of excavation. The risk assessment results (see Table 2-4) showthat only 2,3,7,8-TCDF poses a risk above the threshold value of 1. The extent of contamination was basedon 2,3,7,8-TCDF, not gamma-chlordane. 2,3,7,8-TCDF was undetected in soil sample SS-GC-06.

3.4: Page 2-17, paragraph 4 & 5: See general comment # 6. [2.6]

Response: The Army agrees that sediment determined to be contaminated and exhibiting unacceptablelevels of risk should be remediated. However, that sediment must be capable of supporting the sensitiveorganisms that more stringent cleanup goals are intended to protect. The soil beneath the turf of the swaleat EI Site SM21 is not sediment, and its evaluation as such during the El was overly conservative. The Armywill not manage these turf-covered surface soils as if they are capable of supporting sensitivesediment-dwelling organisms.

3.5: Page 2-29, paragraph 3: See general comment # 6. [2.6]

Response: As stated on page 2-29 of the FFS, the resulting HI for sediment at EI Site SM26 was 8.Although this exceeds the target of 1, it falls within the range of 1 to 10, which is “indicative of a smallpotential for adverse affects.” (See page 2-8 of the FFS.) Within this range, the Army may consider whetherimplementation of a remedial action is justified, particularly in sediment, where it is difficult to quantify small,incremental risk accurately. No single COC drives the overall risk. Only DDD has an HQ that exceeds 1.Metals and SVOCs contribute the remainder of the risk. Comparison of the RME concentrations of a fewCOCs in sediment at SM26 with the concentrations at other EI sites suggest that concentrations at EI SiteSM26 do not exceed what would be expected site-wide. Arsenic, DDD, DDT, and benzo(a)pyrene RMEconcentrations in sediment were compared among EI Sites SM26, SM25h, SM27 and 30. As shown in thetable below, the concentrations at SM26 are well within the range of those at the other sites. Because the HIfor sediment-dwelling invertebrates falls between 1 and 10, and there is no indication that the COCconcentrations exceed what are found at other sites at FBH, the Army has concluded that sediment at EI SiteSM26 is not a medium of concern.

EI Site SM26 EI Site SM25h EI Site SM27 EI Site 30

Arsenic 6.2 ppm 7.8 ppm 5.8 ppm 9.7 ppm

DDD 23.5 ppb 39 ppb 110 ppb Not analyzed

DDT 8.8 ppb 11 ppb 12 ppb Not analyzed

Benzo(a)pyrene 180 ppb 69 ppb Not analyzed 520 ppb


3-6: Page 4-2, paragraph 2: In the “Excavation” section it is stated that 6 inches of contaminated soilwould be removed at EI Site SM20. The plan should instead state that contaminated soil will beexcavated until cleanup levels are attained or until the exposure pathway is eliminated (for example,until the depth of an earthworm's habitat is exceeded). In addition, the plan states that excavation maycause ecological harm as a result of tree removal and site disturbance; however, the plan does notelaborate on the types of ecological harm that could be caused by excavation activities. Every effortshould be made to hand-excavate contaminated areas near trees because robins would be expectedto feed near the trees where they nest. The plan should be revised to (1) discuss PRGs that will be usedto determine the extent of excavation and (2) describe specific ecologically sensitive areas that willbe protected as appropriate.

Response: The purpose of verification sampling is to confirm that PRGs have been attained. If they havenot, another cut of soil will be removed. The verification sampling plan has been submitted to II)EM and EPAunder separate cover.

See response to comment 3.4 for a discussion of how the extent of excavation was determined and howPRGs will be used during verification sampling.

None of the sites are located in an “ecologically sensitive area” of the state park. Disposition of potentialIndiana bat roost trees has been coordinated with the USFWS (see Appendix D). As discussed in the FFSand proposed plan, in defining the extent of contamination the Army has attempted to balance the benefitsgained by removing DDT with the ecological harm done by clearing the trees. While clearing the trees wouldnot have a significant impact on the habitat of birds that nest in the area, it could significantly destabilize thehillside. Based on this reasoning, the Army concluded that the slight benefit gained by excavating additionalsoil was not justified by the ecological cost.

Note that robins are relatively far-ranging and would not necessarily be expected to feed near their nestingtrees.

3.7: Page 4-2, last paragraph: PRGs must be established otherwise it cannot be verified if the cleanupgoals are met.

Response: PRGs have been established and are included as Appendix B to this ROD. See also responseto comment 2.4.

3.8: Figure 4-1, page 4-3: At EI Site SM20, the plans call for excavation of 335 cubic yards of soil.However, there is an apparent error in the area proposed for excavation. Figure B-1 illustrates theproposed excavation profile, but does not include the location of SM02OSSOOI. On page 2-3, inparagraph five, this sample location is discussed as having concentrations of eight pesticides. It needsto be included in the excavation area.

Also, areas around the following locations need to be considered for "hot spot" excavation:SD-DE-01, SM020SS011, SS-DE-06, SS-DE-08, and SS-DE-09. These locations have been found tocontain one or more of the identified ecoCOCs.

Alpha-chlordane, DDE, dieldrin, gamma-chlordane, and PCB-1260 were detected at boringSM020SBOO3 in the sample collected from 3 feet below ground surface at EI Site SM20. TheEcological Risk Assessment (ERA) does not address the presence of these compounds in thesubsurface. An explanation is needed on why this was not addressed


Response: Location SM020SS01 is included in the area of excavation. The line in Figure B-1 wasmistakenly drawn to the east of the sample point. A corrected figure is included in this ROD.

The Army disagrees with the need for so-called “hot-spot” remediation. The reasoning for drawing theproposed excavation boundary is detailed in Appendix B. COCs that lie outside the boundary of the proposedexcavation contribute to the residual HI, which is estimated to be 2.4 based on the assumptions of the Round2 Baseline ERA. The cited exceedances outside the bounds of the proposed excavation area do not constitutea “hot spot.”

With reference to the last paragraph of comment, see response to comment 3.2.

3.9: Page 4-5, paragraph 2: Please specify how the excavation depth was determined without havingPRGs established.


3.10: Page 4-5, paragraph 4: The surface regrading may have spread the contaminants. Describehow the extent of contamination was determined after surface regrading.

Response: Based on experience in earthmoving, it was estimated that surface regrading redistributedsurface soil by approximately five to ten feet. To account for this redistribution, the original bounds ofexcavation (based on sampling data prior to surface regarding) were extended by approximately fifteen feet.

3.11: Figure 4-2, page 4-6: The proposed excavation profile for EI Site SM21 calls for the removalof 120 cubic yards of soil. The proposed excavation profile should include the following locations:SS-GC-06, SM021SS001, SM02ISS002, SB-GC-02, SB-GC-01, SM02ISS011, SM02ISSO12 andSS-GC-07. These locations have one or more of the following compounds: TCDF, alpha-chlordane,and gamma-chlordane. Action levels for these ecoCOCs should be defined so that the effectivenessof the proposals for excavation and removal can be fully evaluated.

Tables 4.9-2 and 4.9-3 of the Phase II Report show the following locations which have a fair amountof alpha-chlordane and/or gamma-chlordane: SD-GC-01, 02, 03, & 04 and SM021SE001 &SM021SE002. These locations are not shown on Figure 4-2 of the proposed excavation profile.Because these locations have elevated levels of the ecoCOCs, there should be a discussion on whathas been done or what should be done to address the contamination at the noted locations. Thesamples seem to have been taken from the ditch.

Response: The limits of excavation at EI Site SM21 were drawn based on 2,3,7,8-TCDF, the only ecoCOCto exceed the target risk level. Based on the same methodology presented in Appendix B, a concentration of10-6 ppm was derived and used to draw the limits of excavation. As described in the response to comment3.10, this profile was extended to account for likely spreading of soil when the site was regraded. Theproposed remediation at EI Site SM21 targets 2,3,7,8-TCDF only. The risk assessment demonstrated that therisk from 2,3,7,8-TCDF drives the overall risk to ecological receptors. The contributions of alpha- andgamma-chlordane are minimal.

3.12: Page 4-7, paragraph 1: If dust-suppression controls such as wetting the soils with water areused, the run-off must be controlled to avoid further spread of contamination.



3.13: Page 4-7, paragraph 3: Specify which levels of TCDF are considered elevated and beingexcavated.

Response: Page 4-5 of the FFS states that concentrations of 2,3,7,8-TCDF above 10-6 ppm. were includedwithin the excavation boundary. The PRG for 2,3,7,8-TCDF, as presented in Appendix B of this ROD, is2.5xl0-5 ppm. See also response to comment 2.4.

3.14: Page 4-8 ff. EI Site SM26: In this section, which covers the remedial action alternatives forSM26 including the stabilization treatment. The Army refers to the firing ranges to point out similaritiesbetween these sites and SM26 However, the contaminated materials in the sludge drying bed may havesignificantly different characteristics that might reduce the effectiveness of the treatment process. Ifsludge remains in the bed or will be part of the matrix being treated, it is likely that the sludge wouldcontain more organic material and less inert material than the soil at the firing range and would bemore difficult to treat. The FFS should state whether sludge remains in the sludge drying bed andshould discuss the effectiveness of the stabilization technology in treating sludge.

Response: In order to determine the benefit of soil treatment at EI Site SM26, the Army collected twosurface soil samples from the former sludge-drying beds. (Total lead concentrations were 730 ml/kg and 700mg/kg.) These samples were subjected to the toxicity characteristic leaching procedure (TCLP) and theleachates contained concentrations of 0.013 and 0.052 mg/L, respectively. These concentrations are wellbelow the regulatory limit of 5 ug/ml, indicating that treatment of the soil is unnecessary to reduce disposalcosts. This change in the plan was discussed at the public meeting on April 22, 1999, and is described inSection 11 of this ROD.

3.15: Page 4-9, paragraph 3: See general comment # 8. [2.8]


3.16: Page 4-9, paragraph 4: Specify which substance will be used to reduce the leachability of lead.If this substance is used, run-off control to Schoen Creek may be necessary to avoid any negativeimpact on the creek.


3.17: Page 4-11, paragraph 3: Clarify how attainment of the cleanup goals will be verified. IDEMstaff are not aware that PRGs have been established or that the overseeing state and federal agenciesapproved PRGs for these sites.

Response: The verification sampling plan has been submitted to IDEM under separate cover. Theverification sampling plan for the remedial actions at the three subject sites is consistent with the methodologyused for the BCT-approved verification sampling plan for the firing range removal actions.

Documentation supporting the derivation of ecological PRGs for DDT and 2,3,7,8-TCDF (EI Sites SM20 andSM21, respectively) also has been submitted to IDEM under separate cover. The methodology used to derivethese PRGs is the same as that used for derivation of the PRGs for the firing range removal action. Whilethe Army submits this documentation to its partners on the BCT to solicit IDEM and EPA approval, suchapproval is not required to proceed.

Responsiveness Survey Former Fort Benjamin HarrisA-9

3.18: Page 4-13, paragraph 3: See general comment # 8 [2.8].


3.19: Page 5-4. table 5-1: Under "Compliance with ARARs, " please note that neither IDEM northe U.S. EPA had input on the ARARs list provided in Appendix C. Therefore, it must be assured thatall the remedial action alternatives comply with the ARARs identified by IDEM and the U.S. EPA inorder to be considered a viable remedial action alternative.

Response: See response to comment 2. 1.

3.20: Page 5-6. table 5-2: Under "Compliance with ARARs," please note that neither IDEM nor theU.S. EPA had input on the ARARs list provided in Appendix C Therefore, it must he assured that allthe remedial action alternatives comply with the ARARs identified by IDEM and the U.S. EPA in orderto be considered a viable remedial action alternative.


3.21: Page 5-8. table 5-3: Under "Compliance with ARARs," please note that neither IDEM nor theU.S. EPA had input on the ARARs list provided in Appendix C Therefore, it must be assured that allthe remedial action alternatives comply with the ARARs identified by IDEM and the U.S. EPA in orderto be considered a viable remedial action alternative.


3.22: Appendix C: Neither IDEM nor the U.S. EPA had input on the ARARs list provided inAppendix C. Therefore, it must be assured that all the remedial action alternatives comply with theARARs identified by IDEM and the U.S. EPA in order to be considered a viable remedial actionalternative. State ARARs are provided in Attachment 1.


4. GENERAL COMMENTS ON PROPOSED PLAN FROM IDEM (4-1 THROUGH 4-5)

4.1: Under 40 CFR 300.515(e)(1), both EPA and the State of Indiana must be involved in preliminarydiscussions of the alternative addressed in the FS report for a site prior to preparation of the proposed planand record of decision (ROD). At the conclusion of the remedial investigation (RI) and FS, the lead agency,in conjunction with the support agency develops the proposed plan. In addition, 40 CFR 300.515(e)(1) and 40CFR 300.430(f)(2)(iii) state that the proposed plan must include a statement that the lead and supportagencies have reached agreement or, when this is not the case, a statement explaining the concerns of thesupport agency regarding the lead agency's proposed plan. The Army did not confer with IDEM beforepreparing the proposed plan and has therefore not complied with 40 CFR 300.515(e)(1). In addition, the Armydid not submit the focused FS for the sites to IDEM for review prior to issuing the PP.

Response: The commentor's citation of the law is inaccurate. Since FBH is not a Superfund site (i.e., onthe National Priorities List) and has no Superfund Memorandum of Agreement with the state, therequirements of 40 CFR 300.515(h) apply, not 40 CFR 300,515(e). In compliance with these requirements,the Army has afforded the state and EPA reasonable opportunity to review and


comment on the FFS and proposed plan. The comments of the state and EPA have been considered fully andare addressed in this responsiveness summary.

4-2: The proposed plan does not discuss the need for implementing deed restrictions or otherinstitutional controls to limit site use to the anticipated land and groundwater uses and exposurescenarios evaluated in the baseline risk assessment. Institutional controls are required to ensure thatthe EI sites are not used for purposes other than those evaluated in the baseline risk assessment. TheArmy should revise the proposed plan to discuss institutional controls that will be implemented for theformer ormer FBH site.


4.3: The proposed plan does not state the date, time, or place of the public meeting. This is the secondproposed plan generated recently for the former FBH site that does not contain this importantinformation; its omission from the previous proposed plan may be a reason for the low attendance ofcommunity members at the last public meeting for 17 no further action sites. The Army appears todepend on newspaper advertisements as the primary method to announce the public meetings;however, newspaper advertisements should be a secondary means of advertising the meetings. Thelack of information concerning the public meetings in the proposed plans and the late timing of thenewspaper advertisements announcing the public meetings suggests a need for improved planning onthe part of the Army. The public comment period should be extended an additional 30 days to allowmore community involvement in the next public meeting.

Response: Throughout the execution of its BRAC environmental mission at FBH, the Army has maintainedan open relationship with all interested stakeholders. In 1994, after extensive outreach efforts to the localcommunity and neighborhoods, the BCT determined that general public interest in the Army's closure missionat FBH is extremely limited. Interested citizen-stakeholders were appointed to the FBH Restoration AdvisoryBoard (RAB) in 1994. Over the years, the community members present at RAB and other public meetingshave demonstrated satisfaction with the Army's environmental program. There has been no indication recentlythat this situation has changed, and the Army plans no modification of its approach. The Army believes thepublic comment period for the FFS and proposed plan was more than adequate, and declines to extend it.

4.4: The proposed plan does not discuss preliminary remediation goals (PRG) for chemicals ofconcern at EI Sites SM20, SM21, and SM26. The PRGs should be briefly discussed in the plan. Inaddition, the plan should state that preliminary estimates of excavation limits were developed using thePRGs and that the final excavation limits will be determined using verification sampling results todocument that (1) approved cleanup standards have been met or (2) the hazard indices (HI) for theremediation areas are less than one for all receptors.


4.5: The proposed plan states that excavation may cause ecological harm as a result of tree removaland site disturbance, however, the plan does not elaborate on the types of ecological harm that couldbe caused by excavation activities. The plan should specifically evaluate potential habitatdisturbances. For example, the Indiana bat tends to roost below the bark of dead trees. The Armyshould evaluate whether contaminated areas contain large, dead trees or other trees with loose barkthat may serve as potential bat roosting sites. If so, the Army should consider any potential removaloptions that would minimize disturbances to ecological habitats in the remediation areas.



5. SPECIFIC COMMENTS ON PROPOSED PLAN FROM IDEM (5-1 THROUGH 5-3)

5.1: Site Background, Page 3, Paragraph 3: The proposed plan states that the decision to conductno further action at 17 EI sites is documented in a ROD dated March 1999. However, the ROD for the17 no further action sites has not been signed. The plan should state that the Army has proposed nofurther action for 17 sites and that the associated ROD will be signed after the BRAC Cleanup Team(BCT) has reached concurrence concerning the actions required at the 17 sites.

Response: The Army published its final resolution of comments on the Final Phase II EI report and theproposed plan for seventeen NFA sites in the responsiveness summary of the ROD for the seventeen NFAsites. While IDEM’s concurrence with this decision is desirable, such concurrence is not required for theArmy to proceed. Contrary to the commentor's assertion, the Army signed the ROD for the seventeen NFAsites on March 14, 1999. The statement cited is accurate.

5.2: Remedial Action Alternatives, EI Site SM20, Page 5, Paragraph 3: The proposed plan statesthat 6 inches of contaminated soil would be removed at EI Site SM20. The plan should instead statethat contaminated soil will be excavated until cleanup levels are attained or until the exposure pathwayis eliminated (for example, until the depth of an earthworm's habitat is exceeded). In addition, the planstates that excavation may cause ecological harm as a result of tree removal and site disturbance;however, the plan does not elaborate on the types of ecological harm that could be caused byexcavation activities. Every effort should be made to hand-excavate contaminated areas near treesbecause robins would be expected to feed near the trees where they nest. The plan should be revisedto (1) discuss PRGs that will be used to determine the extent of excavation and (2) describe specificecologically sensitive areas that will be protected as appropriate.


5.3: Remedial Action Alternatives, EI Site SM26, Page 6, Paragraph 4: The proposed plan statesthat the Army has gained considerable stabilization treatment experience at the former FBH firingrange. However, the contaminated materials in the sludge drying bed may have significantly differentcharacteristics that might reduce the effectiveness of the treatment process. If sludge remains in thebed or will be part of the matrix being treated, it is likely that the sludge would contain more organicmaterial and less inert material than the soil at the firing range and would be more difficult to treat.The ROD should state whether sludge remains in the sludge drying bed and should discuss theeffectiveness of the stabilization technology in treating sludge.


6. GENERAL COMMENTS ON FFS FROM EPA (6-1 THROUGH 6-9)

6.1: The Focused Feasibility Study (FFS) provides neither a detailed visual or written summary of thecontaminants of concern and their associated concentrations as they vary at each site. The existinganalytical data is only summarized by the number of detections, the location of the maximumconcentration detected, as well as the reported maximum concentration. In most instances, theproposed remedies will not address all contaminants of concern directly, and the effectiveness of theproposed remedies cannot be sufficiently evaluated given the current level of


detail provided regarding the contaminants of concern. EPA's Guidance for Conducting RemedialInvestigations and Feasibility Studies Under CERCLA, Interim Final, October 1998 (EPA) states that,"Analyses that are important to the subsequent risk assessment and subsequent development ofremedial alternatives include the horizontal and vertical extent of condition in soil, ground water,surface water, sediment, air, biota, and facilities.... Data should be arranged in tabular or graphicalform for clarity." Revise the FFS to include detailed information regarding the contaminantconcentrations found in environmental media, as directed in current EPA guidance.

Response: The requested tabular presentation of COC data in the medium of concern (i.e., soil) has beenincluded in this ROD.

6.2: Throughout the FFS, the human health risks are only characterized as being below 10-4. ThePreamble to the NCP (March 8, 1990, 55 FR) elaborates on Section 300.43(e)(2) as follows: "EPAbelieves it is necessary to explain how it intends the Point of departure to be used. Where theaggregate risk of contaminants based on existing ARARs exceeds l0 -4 or where remediation goals arenot determined by ARARs, EPA uses 10-6 as a point of departure for establishing preliminaryremediation goals. This means that a cumulative risk level of 10-4 is used as a starting point (or "initialprotectiveness" goal) for determining the most appropriate risk level that alternatives should bedesigned to attain. The use of 10-6 expresses EPA's preference for remedial actions that result in risksat the more protective end of the risk range, but this does not reflect a presumption that the finalremedial action should attain such a risk level." Therefore, the FFS needs to be revised such that thepoint of departure for human health is 10-6 and remedies that would be protective to that risk thresholdneed to be presented.

Response: The Army stated previously– in the responsiveness summary of the March 1999 ROD forseventeen NFA Site--that the use of 10-4 as the target cancer risk level is common. It is cited in EPA RegionIV guidance and has been adopted by other EPA regions. If 10- 4 is used as the target for an exposurepathway, then the chemical contributors identified as COCs have individual cancer risks within the target riskrange. If 10-6 is used for an exposure pathway, then the chemical contributors identified as COCs haveindividual cancer risks below 10-6. Cleanup for chemicals with cancer risks less than 10-6 is not warrantedgenerally.

EPA, while disagreeing with the Army, should understand that the Army has the authority to establish its ownrisk thresholds for remediation. The Army will not revise the subject document.

6.3: The FFS does not address management of water during the excavation process. Neither ARARsnor costs associated with this activity have been addressed. Assuming that the excavations have thepotential to occur during rain events, any water (also including potential groundwater infiltration) thatenters an open excavation must be managed, as it could hinder excavation operations, impactsoil/waste disposal/treatment alternatives, as well as topsoil placement. Information on how any waterencountered or generated during the remedial activities will be managed needs to be included in theFFS.

Response: Silt fences and/or hay bales will be used to control soil-transport caused by rain. These controlswere used during the removal actions at the firing ranges and were determined to be adequate for that muchlarger, much longer field effort. The likelihood of encountering groundwater is remote, given the shallow depthof contamination; however, if groundwater is encountered, a field change-order will be issued andconventional de-watering techniques will be used. Any wastewater generated will be managed in accordancewith applicable regulations.


6.4: The Remedial Action Objectives (RAOs) presented in the FFS are based upon the protection ofecological receptors. However, the human health risk assessment, conducted as part of the Phase IIEnvironmental Investigation (EI) Report, estimated a carcinogenic risk of 3 x 10-5 for a current andfuture maintenance worker at EI SM20 and 4 x 10-5 for a future adult recreational visitor at EI SM21(Table 0.1-3, Final Phase II EI Report - Appendix 0). These estimated carcinogenic risks fall withinthe upper end of the risk range of 1 x 10-4 through 1 x 10-6 which is cited in the National ContingencyPlan (NCP) as an acceptable risk range.

Revise the FFS to address the following issues associated with potential human health risks at sites EISM20 and EI SM21.

• Since soils will be excavated from sites EI SM20 and EI SM21 to protect ecologicalreceptors, the reduction in the estimated human carcinogenic risk due the excavationactivities should also be addressed. This will verify a higher level of protection for humanreceptors that may use the property after it is transferred.

• A review of Figure 4-1 in the FFS and the analytical results of sampling at locationsSM020SS001 and SM020SS006 in site EI SM20 indicate that the concentrations ofalpha-chlordane, gamma-chlordane, dieldrin, and PCB-1260 exceed the PreliminaryRemedial Goals (PRGs) that were used for screening purposes in the human health riskassessment. In addition, a review of Figure 4-2 and the analytical results of sampling atlocations SM021SS001 and SM021SS002 in site EI SM21 indicate that the concentrationsof alpha-chlordane, gamma-chlordane and heptachlor epoxide exceed the PRGs. Each ofthese sample locations is outside the excavation limits proposed by the Army for sites EISM20 and EI SM21. Although the PRGs used in the human health screening analysis werebased on residential levels, the overall carcinogenic risks at both sites are in the upper endof the EPA risk range cited in the NCP. Therefore, the Army should evaluate whetheradditional excavation of soils near the sample locations identified above would result in areduction of human health risks, which would better ensure the health of human receptorsafter the property is transferred.

Response: (To first bullet:) It is true that human health risk will be reduced by the remedial action.However, the Army does not see the value of quantifying the estimated risk reduction since the baselinehuman health risk assessment concluded that there is no unacceptable risk to human health.

(In response to the second bullet:) The “PRGs” to which the commentor refers are not site-specific cleanupgoals but rather screening levels used to remove some contaminants from the risk assessment process.Concentrations that exceed these screening levels do not necessarily pose unacceptable risk. The baselinerisk assessment demonstrates that human health risks posed by COCs at EI Sites SM20 and SM21 are belowthe target risk goal of 10-4 . (See response to comment 6.2 for explanation of this target risk level.) As statedin response to the first bullet, the Army does not see the value of quantifying the estimated risk reduction sincethe baseline human health risk assessment concluded that there is no unacceptable risk to human health.

6.5: The FFS incorporates conclusions and decisions based on the ecological risk assessment (ERA) whichwas presented in the Final EI. Many significant issues associated with the ERA are outstanding and theseissues have not been resolved or adequately addressed. The limits of excavation proposed in the FFS for eachsite may be affected by the issues identified in the comments on the ERA. The comments on the FFS aredesigned to identify the significant issues associated with the ERA. It is recommended that discussion tofacilitate resolution of the issues and expedite the remedial process take place.


The most significant issue is associated (with) the toxicity assessment/exposure assessment portions ofthe ERAs, since toxicity reference values (TRVs) were not available or identified for many of theecological contaminants of concern (COCs). Therefore, there are many COCs that are not represented(i.e., included in) by the hazard quotient (HQ) and hazard index (HI) values. The HQ and HI valuesthat result from the comparison of COC exposure estimates with TR Vs represent the primary decisionpoints for both the ERAs and the FFS. However, HQ values were not established for many of theCOCs, therefore, the resulting H1 values (i.e., the sum of HQ values) are not truly representative ofthe potential ecological exposures associated with each site, since the majority of the ecological COCsare not considered or included in any other evaluation. Therefore, ecological exposures to many ofthe COCs has not been adequately considered in the conclusions or decisions for remedial action. Itshould be noted that EPA is not necessarily suggesting that TRVs are necessary to complete the ERA,however, the lack of TRVs must be addressed and those COCs without TR Vs must be consideredqualitatively.

Response: In the ROD for seventeen NFA sites, March 1999 (page A-29), the Army addressed this issuein its final resolution of comments on the Final Phase II EI report. The Army acknowledges that risk fromconstituents without TRVs should be discussed qualitatively; however, inclusion of a qualitative discussionwould not change the conclusions of the baseline ERA.

6.6: Conclusions reached as a result of Round 2 of the baseline ERA form the foundation upon whichremedial decisions are based. One of the primary elements of Round 2 is that the arithmetic mean ofthe range of concentrations for each COC is utilized as the exposure point concentration, instead ofthe upper 95 percent confidence limit (95 UCL) of the range of concentrations for each COC. Thisapproach generally serves to significantly lower the resulting HQ and HI values. Typically, themaximum concentration of each COC is used as a conservative exposure point estimate during thescreening level ERA (according to EPA guidance), and the 95 UCL is used as the exposure pointconcentration during the baseline ERA, as an estimated reasonable maximum exposure concentration.Revise the FFS accordingly or provide adequate justification for not utilizing the 95% UCL during thebaseline ERA(s).

Response: In performing the ecological risk assessments, the Army followed verbal guidance from Ms.Brenda Jones, EPA Region 5 ecologist, that use of the arithmetic mean would be appropriate in the BaselineRound 2. (See previous comment response on Page A-6 of the responsiveness summary in the March 1999ROD for seventeen NFA sites).

6.7: One of the fundamental premises of the ERAs in this FFS is that HQ and HI values that arebetween 1 and 10 represent insignificant risks. This contention is in conflict with EPA guidance whichstates that HQ and HI values over 1 indicate a potential for adverse ecological risk, and that valuesless than one do not necessarily indicate the absence of ecological risk. Integral to the EPA approachis the consideration of all site-specific, receptor-specific and contaminant-specific factors, not just HQand HI values.

Response: The Army states nowhere in the FFS that HI values between 1 and 10 represent "insignificantrisks." In earlier documents the Army proposed an ecological risk threshold of 10 in the surface soil; however,this position was reevaluated in the March 1999 ROD for seventeen NFA sites (see Section 8), in which athreshold of 1 was used. The executive summary of the FFS states that, "HI values that exceed 1 indicatethat unacceptable risk from contaminants may exist." This point is further discussed on page 2-8, which statesthat values between 1 and 10 "...may indicate that further action is necessary; however, other factors suchas habitat destruction during


remediation efforts need to be considered because the risk from site contaminants may be very small. If theseother factors warrant it, HI values between 1 and 10 are acceptable."

6.8: Neither the ERA nor the FFS provide an adequate evaluation of ecological receptors associatedwith surface water and sediment at and downstream of the sites. This is a significant issue since theHI values (for both Round 1 and Round 2 calculations) are significantly above 1, and often aresignificantly above 10. It appears that the rationale for evaluating aquatic receptors is based on onlythe immediate area adjacent to the source and does not take consider (sic) potential downstreamreceptors, (i.e. receptors associated with Hawthorne Pond and Schoen Creek). In some cases, theexclusion of the viable downstream habitats represents an unacceptable data gap. For example, thereis discussion regarding sediment samples collected near Site SM26 which specifically identifies SiteSM20 as a possible source of pesticides in the headwaters of Schoen Creek. However, aquatic riskto sediment at SM20 were dismissed since the samples were collected from drainage ditches and notconsidered viable aquatic habitat. The inadequate evaluation of this migration pathway may impactthe identification and evaluation of the technology types and process options and the development ofremedial action alternatives.

In addition, Appendix B of the FFS provides specific information that suggests thatsediment-associated benthic organisms should he considered, since elevated levels of DDT areconcentrated in two of the drainage ways leading to the concrete-lined ditch, and that the forestedarea adjacent to Site SM20 is considered essential habitat for the Indiana bat. The Indiana bat is afederally-listed endangered species that is primarily insectivorous and probably consumes a varietyof insects that have an aquatic life stage, such as caddis flies and mosquitoes. Inclusion of aquaticreceptors and aquatic receptors as food items would likely result in higher HI values, and may requirethat soil and sediment within the drainage ways be evaluated further as continuing sources ofcontamination.

Response: See response to comment 2.5, in addition to the following:

As detailed in response to comment 3.5, the concentrations of pesticides detected in the sediment at EI SiteSM26 are typical of the surface water drainage features at FBH. While EI Site SM20 is a potential upstreamsource, the sediment data from EI Sites SM25h and SM27 indicate that potential sources of residual pesticidesin the sediment are more widespread and most likely reflect the use of pesticides throughout FBH.

The Army evaluated potential risk to the Indiana bat in the screening ERA in the Phase II EI, followingextensive consultation with the EPA Region 5 ecologist. The food-web associated with the Indiana bat wasconsidered fully in the risk assessment, having been identified previously and considered during developmentof the PRGs for the removal action at the firing ranges. The HI for the Indiana bat was estimated to be 0.08in the screening ERA, due to contaminants in surface soil. The aggregate site used to estimate this riskincluded EI Sites 5, 6, 16, SM18, SM20, and 30. The HQ for DDT at this aggregate site was 6xl0-4.

6.9: The General Comments presented above significantly impact the development and analysis of theremedial action sections of the report. While the specific comments presented below are focused (sic)on the information currently presented in the FFS, the potential exists that additional concerns wouldsurface once the focus of the general comments has been addressed. For example, if further evaluationof the ERA results in increasing the media excavation area, then several sections of the FFS (e.g.,excavation details, discussion of alternatives, cost estimates, etc) would then need to be revised.Therefore, it is recommended that the issues identified by the General Comments be evaluated/discussed prior to revision of the FFS or implementation of the proposed remedial actions.


Response: No response necessary.

7. SPECIFIC COMMENTS ON FFS FROM EPA (7-1 THROUGH 7-40)

7.1: Page 2-1. Section 2.1.1. Site SM20. Site History: The site history text indicates that thedrainage ditch adjacent to SM20 leads to Hawthorne Pond (approximately one-quarter miledownstream), and that runoff from the site may affect Hawthorne Pond The drainage ditches andHawthorne Pond represent contaminant migration pathways from the sources at SM20 and should befurther sampled and the resulting data used to fully evaluate risk to ecological receptors associatedwith these pathways.


7-2: Page 2-5. Section 2.1.2.1. Site SM20. Surface Soil Results: The specific congeners of furansshould be identified (i.e., 2,3,7,8-TCDF instead of just TCDF), since the toxicity's of the variouscongeners vary significantly.

Response: References to TCDF have been changed to 2,3,7,8-TCDF in this ROD and responsivenesssummary.

7.3: Page 2-8. Section 2.1.3.2. Ecological Risk Assessment Results: The text states that HQ valueswere calculated for each COC, however, this is not the case. The majority of COCs listed in the tablesin Appendix A have not been assigned TRVs, and hence have no HQ values. The FFS should be revisedto state that HQ values were not calculated for all COCs, and the revised text should include adiscussion of the effect on the ERA and FFS resulting from the lack of TRVs and HQ values. Also seeGeneral Comment 5 [6.5].

It is agreed that other factors need to be evaluated along with the HQ and HI values; however, theonly other factor given primary consideration within the FFS is the example of habitat destructionduring remediation activities. The FFS should be revised to identify and discuss other appropriatesite-specific, receptor-specific, and chemical-specific factors, and to acknowledge that the HQ andHI values represent only one aspect of the potential for adverse effects to ecological receptors.

Response: (To first paragraph:) See response to comment 6.5.

(To second paragraph:) The FFS will not be reissued, but the requested information is incorporated inresponses to comments in this responsiveness summary. See also response to comment 2.10.

7.4: Page 2-9. Section 2 1.3.2. Ecological Risk Assessment Results: Although the concrete lineddrainage ditch may not constitute an aquatic ecosystem, it does represent a contaminant migrationpathway, and may be pertinent to downstream ecological receptors. The FFS should be revised toaddress this issue.


7.5: Page 2-10. Section 2.1.4. Application of Baseline Ecological Risk Assessment Assumptions:The standard method for establishing reasonable exposure point concentrations is


to use the 95 UCL, in order to account for standard deviation factors associated with the data. Alsosee General Comment No. 6 [6.6].


7.6: Page 2-10. Table 2-1. Site SM21. Receptors Evaluated at EI Site SM20: Table 2-1 identifiessediment dwelling biota as one of the groups of receptors evaluated within SM20 for the Baseline ERA;however, sediment dwelling biota were not evaluated. The FFS should be revised to address thesereceptors. Also see General Comment No. 8 [6.8].

Response: Appendix A of the FFS, contains an evaluation of sediment-dwelling biota under the assumptionsof the baseline ERA. However, these sediment results were not used in the remedial action decision-makingprocess. Sediment was not evaluated in the FFS for the reasons stated on pages 2-9 and 2-17.

7.7: Page 2-11. Table 2-2. Results of the Baseline ERA for the American Robin at EI Site SM20:The HQ values and HI value in the Round 1 column differ significantly from the values presented forthe same information as presented in the Appendix A, Table A-l. For example, the HQ for DDT in TableA-1 is 482, while it is reported as 187 in Table 2-2; and the HI is 501 in Table A-1, while it is reportedas 204 in Table 2-2. In addition, is type of discrepancy also exists in the Executive Summary (Par 2,page ES-1 and Par 3, page ES-2), during the discussion of ED values. The FFS should be revised toresolve these discrepancies.

Response: Screening ERA tables were inserted mistakenly in place of the Round 1 baseline ERA tablesin Appendix A. The tables depicting the Round 2 baseline ERA results are correct and are correctlyreferenced in Section 2 of the FFS. Since the Round 2 baseline ERA results are the basis for decision-makingand those results are presented correctly in Appendix A, no changes will be made to the FFS.

7.8: Page 2-16 Section 2.2.2.3. Site SM21 Sediment Results: The text states that the sediments havelikely been affected by runoff from the former mixing areas; however, these sediments and theassociated sediment-dwelling biota were not further evaluated. Even though the drainage channel isnot a "surface water feature", it nonetheless represents a contaminant migration pathway todownstream aquatic habitats. The FFS should be revised to address this media and associatedreceptors.

Response: See responses to comments 2.5 and 6.8.

7.9: Page 2-1 Table 2-2. Receptors Evaluated at EI Site SM21: Table 2-3 identifies sedimentdwelling biota as one of the groups of receptors evaluated at SM21 within the Baseline ERA; however,sediment dwelling biota were not evaluated. The FFS should be revised to address these receptors.Also see General Comment No. 8 [6.8].

Response: See responses to comments 6.8 and 7.6.

7.10: Page 2-19. Table 2-4. Results of the Baseline ERA for the American Robin at EI Site SM21:The HQ values and HI value in the Round 1 column differ significantly from the values presented inAppendix A, Table A-5 (apparently mislabeled as Round 2). The FFS should be revised to resolve thisdiscrepancy.



7.11: Page 2-25, Section 2.3.2.3. Surface Water and Sediment Results: The text states that the fourupstream samples were located in areas representative of background conditions. However,information presented in Site Hydrogeology, Section 4.18.4, of the EI and shown on Figure 4.18-6,indicate that the samples were collected at locations that may not have been representative of"upstream" conditions. The locations are adjacent to the former Sewage Treatment Plant (STP) andbased on topography, would receive overland flow/runoff from the site and be in thehydrogeologically downgradient direction of the discharges from the site. In addition, Section 4.18.4of the EI indicates that groundwater discharge is to the unnamed tributary and Schoen Creek.Therefore, it is not clear whether the evaluation can be used to assess the potential impact from theSTP.

It was noted that mercury and lead were detected at elevated concentrations in groundwater andsubsurface soils at this site. However, a review of the EI contaminant data for surface water indicatethat lead and mercury were not analyzed. Please clarify that the appropriate analyses have beenconducted.

Response: Surface-soil sampling results indicate that concern is unwarranted regarding the movement ofcontaminants by overland flow and runoff to the upgradient surface water and sediment sampling locations.Constituent concentrations in "up-stream" surface soil are too low to represent a significant threat frommovement overland. The only credible sources of groundwater contamination are the former sludge-dryingbeds. Upgradient surface water and sediment sampling locations are unaffected by the sludge beds, asindicated by the groundwater contours depicted in 4.18-6 in the Phase II EI.

Surface water samples were analyzed for lead and mercury during the Phase II EI and these elements wereundetected in all four samples analyzed.

7.12: Page 2-28 Section 2.3.3.2. Ecological Risk Assessment Results: The text indicates that ascreening ERA was conducted as well as two rounds of assumptions in the baseline ERA. Theinformation presented is not easily understood and should be clarified. At the present time, the ERAfor this site should not be considered complete. Also see the General Comments presented above.

Response: The first paragraph of Section 2.1.4 on page 2-9 of the FFS states that only the screeningERA was performed in the Final Phase II EI for Site SM20. It goes on to describe that the baseline ERAwas performed for the site in the subject FFS. The text indicates where in the FFS the baseline ERAcomputations are located. The same methodology was used as that in the Final Phase II EI, except thebaseline ERA is included in the FFS rather than the EI See also response to comment 6.5.

7.13: Page 2-29. Section 2.3.3.2. Ecological Risk Assessment Results: The use of the arithmeticmean is questioned. Please see General Comment No. 6 [6.6].


7.14: Page 2-30 Section 2.3.3 2 Ecological Risk Assessment Results: A summary of the Screeningand Baseline results, similar to Tables 2-2 and 2-4, should be tabulated and presented.

Response: Tables 2-2 and 2-4 were included because the baseline ERA results that they present firstappear in the FFS. The tables were necessary to summarize the results of the raw data tables presented inAppendix A of the FFS. The baseline ERA numbers for EI Site SM26 were produced in the Final Phase IIEI and summarized on page 2-29.


7.15: Page 3-1. Section 3.1. Remedial Action Objectives: The text indicates that NEPArequirements have been considered within the remedial actions proposed in the FFS. It is indicated thatFort Harrison State Park constitutes essential habitat for the federally-listed endangered species, theIndiana bat. Thus, disturbance of the habitat that would be caused by the remedial action must beconsidered. The ERA did not include any evaluation or mention of the Indiana bat or its associatedhabitat. It is not clear how the balance between remedial action and disturbance of the habitat is tobe made when the potential for adverse effects to the bat have not been estimated by the riskassessment. EPA was not made aware of the potential presence of the endangered species or specieshabitat and therefore it was not included as an assessment endpoint. The ERA is considered aniterative process and should be modified and adjusted for inclusion of new information as it becomesavailable. This is considered a significant data gap and should be addressed by conducting an ERAwhich would produce results to be used in remedial decision making regarding the protection of thebat. It should be noted that all decisions and actions associated with the federal endangered speciesmust include coordination with the Fish and Wildlife Service.

Response: Contrary to the commentor’s assertion, EPA—for the past five years, minimally—has beencognizant of the presence of the Indiana bat, Indiana bat-essential habitat, and other species of concern atFBH, and has participated with the Army on the BCT in consultation with the USFWS. During the planningand execution of the ecological risk assessment, the EPA Region 5 ecologist consulted with the Army inselection of indicator species for assessment, as well as in identification of the food web and feeding rangeof the Indiana bat. The Indiana bat was fully considered in the screening risk assessment in the Final PhaseII EI. The Army consults fully with USFWS regarding any activities that have the potential to affect the bat(see Appendix C).

7.16: Section 3 1. Page 3-1: The RAOs presented are not media specific. Current EPA Guidancestates that, “Remedial action objectives aimed at protecting human health and the environment shouldspecify: the contaminant(s) of concern; exposure route(s) and receptor(s);and an acceptablecontaminant level or range of levels for each exposure route (i.e., a preliminary remediation goal).”The RAOs presented neither include acceptable contaminant levels nor media specific exposure routes,both of which are necessary for RAO development. Revise the FFS accordingly.

Response: The information requested can be found in the PRG discussion at Appendix B of this ROD.

7.17: Section 3.3. Containment. Page 3-3: The FFS states that, “there is no evidence that migrationof these contaminants has occurred.” This statement does not appear to be supported by theinformation presented in Section 2 of the FFS. At EI Site SM20, vertical migration of organics seamsto be supported by the fact that organics were detected throughout EI Site SM20 at three feet belowground surface, (bgs) and DDT, dieldrin, and TCDF were detected at a depth of 20 feet bgs in at leastone boring. Organic constituents were also detected in sediments, indicating that they are migratingvia erosion and sediment transport mechanisms. At EI Site SM21, alpha and gamma chlordane weredetected at depths of two to three feet, and as deep as 10 to 11 feet at some locations as well as insediments. At EI Site SM26, metals and semivolatiles such as PAHs were detected at intervals of 9 to10feet and 19 to 20 feet, as well as in sediments. These analytical results do not appear to support thepremise that migration of COCs is not occurring. This no migration argument was used to rule out theuse of containment technologies. As this logic appears to be flawed given the current level of detailpresented regarding contaminant distribution, the discussion presented on why containmenttechnologies are not warranted at these three sites needs to be revised. The FFS needs to eitheradequately discuss the


migration potential of the contaminants of concern or include containment technologies as analternative at the FFS EI Sites.

Response: The detection of contaminants in the subsurface does not necessarily indicate migration. Muchof the land at these sites has been heavily disturbed and reworked during the history of FBH’s active use.Cut-and-fill operations can easily result in soil from the surface being relocated several feet below grade.Additionally, the concentrations of COCs at the surface must be evaluated relative to those below grade toascertain how likely or significant is contaminant migration. For example, lead in the sludge-drying beds atEI Site SM26 was detected at 442, 1080, 851, and 837 ppm. Samples taken at the same locations betweenone and two feet bgs contained lead at 14.5, 6.3, 16.8, and 8.9 ppm, well within the range expected for normalbackground lead concentrations. The Army has judged these reasons adequate to eliminate containmenttechnologies from consideration.

7.18: Page 4-1 through 4-14. Development of Remedial Action Affirmatives: Each of these sitesincludes excavation boundary. However, it is not clear whether the proposed limits of the excavationwill sufficiently address potential continuing sources of contamination which may be discharging toadjacent surface water ecosystems. This issue should be addressed as indicated in the GeneralComments.


7.19: Section 4.1.2. Excavation page 4-2: The Excavation and Off-site Disposal alternative doesnot specify the project remediation goals (PRGs) for each constituent that was (were) used to estimatethe limits of soil excavation presented in Figure 4-1. The approach to soil excavations that EPAnormally employs is to specify a project remediation goal that is ultimately included in the ROD thatspecifies a maximum contaminant level for each constituent of concern. This approach allows for easein implementing the alternative Additionally, the establishment of PRGs is discussed in the Preambleto the NCP (March 8, 1990, 55 FR). Section 300.43(e) states that, "The first step in the FS processinvolves developing remedial action objectives for protecting human health and the environment whichshould specify contaminants and media of concern, potential exposure pathways, and preliminaryremediation goals." Revise the FFS to include PRGs for each media of concern, for each exposurepathway, as discussed above.


7.20: Section 4.1.2. Excavation. Page 4-2: The second paragraph discusses that, "The excavationwould begin in the open areas near Buildings 604 and 605 and continue towards the trees." Twoconcerns exist regarding this statement. First, the trees are not presented in any of the figures in theFFS. Secondly, the excavation should proceed from the most upgradient portions of the proposedremediation area to the most down gradient areas. This approach will ensure that during any rainevents, the open face of the excavation will not become cross-contaminated by run-off from yet to beexcavated areas. Revise the FFS to address both of these concerns.

Response: The portion of the proposed excavation area nearest to the buildings is the most-upgradient area.The basis for this proposed approach is the same concern expressed in the comment. The tree-line has beenadded to the figure in this ROD.

7.21: Figure 4-1 Page 4-3: The Excavation and Off-site Disposal alternative does not address somespecific areas discussed in Section 2.0. For example, sampling location SM020SS00l was one of twolocations where pesticides were concentrated according to the FFS on page 2-3, but


this location is on theftinge of the limits of excavation. Additionally, sediment sampling locationSD-DE-03 reportedly had the highest concentrations of alpha-chlordane, gamma-chlordane, dieldrin,and DDD, yet this area is also not within the proposed limits ofexcavation. Either revise theinformation presented in Section 2 to provide more detail regarding the results of the investigationsor revise the proposed remedy such that the areas that are described as containing the highestdetected constituents are addressed by the proposed excavation remedy or it is readily apparent whyit was unnecessary to include these areas as part of the excavation.

Response: See response to comment 2.8 for discussion of the sampling location SM020SS001. SampleSD-DE-03 is a sediment sample. Sediment is not a medium of concern at E1 Site SM20 for the reason statedon page 2-9 of the FFS.

7.22: Section 4.2.2. Excavation, page 4-5: The Excavation and Off-site Disposal alternative doesnot specify the PRGs for each constituent that was (were) used to estimate the limits of soil excavationpresented in Figure 4-2. The approach to soil excavations that EPA normally employs is to specify aproject remediation goal that is ultimately included in the ROD which specifies a maximum contaminantlevel for each constituent of concern. Ihis approach allows for ease in implementing the alternative.Additionally, the establishment of PRGs is discussed in the Preamble to the NCP (March 8, 1990, 55FR). Section 300.43(e) states that, "The first step in FS process involves developing remedial actionobjectives for protecting human health and the environment which should specify contaminants andmedia of concern, potential exposure pathways, and preliminary remediation goals." Revise the FFSto include PRGs for each media of concern, for each exposure pathway, as discussed above.

Additionally, Section 2 of the FFS states on page 2-13 that gamma-chlordane was the most commonpesticide detected, yet it is not even listed as a constituent of concern for this alternative. Either revisethe information presented in Section 2 to provide more detail regarding the results of the investigationsor revise the proposed remedy such that the constituents described as being most prevalent areaddressed by the proposed excavation remedy or it is easily apparent as to why is was unnecessaryto include gamma-chlordane as a constituent of concern for the excavation. Additionally, thegamma-chlordane and the proposed constituent of concern, TCDF, do not appear to be co-located,as discussed in Section 2, on pages 2-13 and 2-14, and the highest concentrations of TCDF andgamma-chlordane were not detected at the same location.

Response: (To first paragraph:) See response to comment 2.4.

(To second paragraph:) See also response to comment 3.3. Further evaluation of the distribution of the dataindicates that 2,3,7,8-TCDF and gamma-chlordane are not as tightly collocated as initially believed. However,with a HQ < 1, gamma-chlordane does not contribute significantly to the overall risk and its continuingpresence at the site will not pose an unacceptable risk to ecological receptors.

7.23: Section 4.2.2. Excavation, page 4-5: The second paragraph discusses that, "Even thoughchlordane did not contribute significantly to the ecological risk (HQ<1) at the site, the excavationboundary also incorporated areas with the greatest concentrations of chlordane. As the HQ of lessthan one was based on the mean concentrations instead of the ninety-five percent confidence intervalconcentrations, the proposed alternative will not be sufficiently protective. Revise this alternative suchthat the proposed limits of excavation are based on a ninety-five percent confidence interval, not themean. Also see General Comment 6.

Response: See response to comments 6.6 and 7.22.


7.24: Figure 4-2, page 4-6: The Excavation and Off-site Disposal alternative does not address somespecific areas discussed in Section 2. 0. For example, sampling locations SS-GC-02, SS-GC05,SS-GC-06, and SM02ISS001 were the locations with some of the highest concentrations of pesticidesdetected according to page 2-13, but these locations are not included within the limits of excavation.Either revise the information presented in Section 2 to provide more detail regarding the results of theinvestigations or revise the proposed remedy such that the areas that are described as containing thehighest detected constituents are addressed by the proposed excavation remedy or it is easily apparentas to why is was unnecessary to include these areas as part of the excavation.


7.25: Section 4.3, Page 4-8: The remedial alternatives presented for EI Site SM26 appear toaddress only zinc and lead reportedly due to the fact that none of the other COCs pose unacceptablerisk to human health or the environment in any of the other units sampled as part of EI Site SM26. Thisstatement does not appear to be supported by the information presented in Table 2-6, on page 2-30.Five additional Eco COCs are identified in Table 2-6 including alpha-chlordane, gamma-chlordane,TCDF, dieldrin, and DDT Either revise the information presented in Section 2 to provide more detailregarding the results of the investigations or revise the proposed remedial actions such that allconstituents of concern are addressed by the proposed alternatives or it is easily apparent as to whyis was unnecessary to address these constituents Of concern as part of the remedial activities.Additionally, revise this alternative such that the proposed remedies address all constituents that posea risk to human health and the environment based on a ninety-five percent confidence interval, notthe mean. Also see General Comment 6.

Response: Table 2-6 clearly indicates that lead and zinc are the only two ecological COCs at EI Site SM26.See also response to comment 6.6.

7.26: Section 4 3.2, Site Preparation, page 4-9: In order to prevent spilling excavated materialsalong the "load-out pathway," it is recommended that some type of protective barrier be used as partof a contingency plan to manage any potential spills. Revise the site preparation section to allow forthe placement of some type of protective barrier that would minimize any potential tracking ofhazardous constituents during the "load-out "process. Given the long haul distances discussed in thetwo excavation alternatives for this Site, this comments (sic) is applicable to both Alternatives 2 and3. Revise the FFS to discuss and cost placement and management of protective barriers along the"load-out pathway"

Response: The need for such a protective barrier will be evaluated in the work plan. Note that thecontaminated material to be removed from EI Site SM26 is not a hazardous waste. (See response to comment3.14.) Therefore, it is unlikely that such a protective barrier will be necessary.

7.27: Figure 4-3. Page 4-10: The Excavation and Off-site Disposal alternatives discuss a "bermed"area that is not clearly indicated on Figure 4-3. Revise the text and Figure 4-3 such that the berm isclearly shown on Figure 4-3, and the berm is described (i e., composition, height). Additionally, as theberm is purported to act as a barrier, provide a discussion on how any water that builds up inside ofthe berm will be managed, and/or disposed of.

Additionally, the Excavation and Off-site Disposal alternatives do not address some specific areas discussedin Section 2.0. For example, sampling locations SS-S1-05 and SB-S1-07 were the locations with elevatedlevels of metals detected according to pages 2-22 and 2-24, but these locations are not included within theproposed limits of excavation. Either revise the information


presented in Section 2 to provide more detail regarding the results of the investigations or revise theproposed remedy such that the areas that are described as containing elevated levels of constituentsare addressed by the proposed excavation remedy or it is easily apparent as to why is was unnecessaryto include these areas as part of the excavation.

Response: (To first paragraph:) The earthen berms are depicted in Figure 4-3. The sludge-drying beds aredesigned so that water will infiltrate the floor of the beds, not accumulate in them.

(To second paragraph:) Lead and zinc drive the ecological risk at this site. Neither lead nor zinc was detectedabove the PRGs in any surface soil sample outside the proposed limits of excavation.

7.28: Table 5-1. page 5-4: Under the evaluation of Overall Protection of Human Health and theEnvironment, Alternative 2 is listed as being protective even with an HQ of 2.4. Revise this discussionto further justify this statement. Also see General Comment 7 [6.7].

Response: See response to comment 6.7. The Army believes that a residual HI of approximately 2 isprotective of the environment.

7.29: Table 5-1. page 5-4: The discussion for Alternative 2 under Long-term Effectiveness andPermanence states that some residual contamination would remain on-site after implementation. Adiscussion on whether leaving residual contamination is protective in the long-term, is effective, andprovides permanence is not addressed, neither is the potential for further cross-contamination viaerosion and sedimentation in the long-term addressed Revise Table 5-1 such that the concernsdiscussed are addressed.

Response: See response to comment 7.28. The FFS will not be revised.

7.30: Table 5-2 page 5-6: Under the evaluation of Overall Protection of Human Health and theEnvironment, Alternative1I provides a discussion of the HI ranging between 1 and 10. Revise thisdiscussion such that it complies with the premise discussed in General Comment 7 [6.7].


7.31: Appendix B. Section B. 1 page B-1: The rationale for the definition of the excavationcontour for the Excavation and Off-site Disposal Alternative is only presented for EI Site SM20. Thisdetail needs to be provided for each of the Sites. Revise the FFS such that Appendix B is expanded toaddress all three site covered by the FFS or that the rationale for only provided (sic) this level of detailfor EI Site SM20 is presented

Response: The excavation boundary for EI Site SM21 was determined in the same manner as EI SiteSM20. Only one of the two sites was discussed because the methodology was identical and inclusion of bothwould have been unnecessarily repetitious. The limits of excavation at EI Site SM26 are clearly based on thediscrete boundary of the sludge-drying basins as demarcated by the earthen berms.

7.32: Appendix B. Section B.1. page B-1: Specific Comment Nos. 19 and 22 discuss the use ofPRGs for each constituent used to estimate the limits of soil excavation. The establishment of PRGs isdiscussed in the Preamble to the NCP (March 8, 1990, 55 FR). Section 300.43(e) states that, 'The firststep in the FS process involves developing remedial action objectives for protecting human health andthe environment which should specify contaminants and media of concern, potential exposurepathways, and preliminary remediation goals." Revise the FFS to include


PRGs for each media of concern, for each exposure pathway, as discussed in Specific Comment Nos.19 and 22.

Additionally, revise the discussion presented in Section B.3, page B-3, regarding the application ofthe arithmetic mean to determine the excavation boundary such that PRGs for each media of concern,for each exposure pathway are provided.

Response: PRGs for the medium of concern are included in Appendix B of this ROD. See also responseto comment 7.16.

7.33: Appendix B. Section B.3, page B-4: The first full paragraph on this page discusses the factthat the concrete lined channel is not considered to be part of the exposure unit for EI Site SM20. Thisapproach does not seem to be appropriate given the potential for further releases from this area viaerosion and sedimentation. It would seem more prudent to attempt to remove as much contaminationas possible from this area. Since the channel is concrete-lined, this would seem to be a relativelystraight-forward task. Revise this section to include an expanded discussion on each of the sevenevaluation criteria to be considered when addressing activities at the concrete-lined channel.

Response: Further releases from the area—once remediated as planned—are not likely given the extremelylimited area of cracks in the concrete-lined channel which could contain any detectable contamination.Removal of the concrete-lined channel is not indicated by the findings of the risk assessment. Additionally,removal of the concrete would destabilize the channel and threaten the local habitat with increased erosionand soil runoff. See also response to comment 2.5.

7.34: Appendix B. Section B.3. Page B-5: The discussion provided in the information in Table B-2does not address the fact that the recommended excavation limits would not result in a more permanentsolution. This discussion needs to be conducted in the context of all seven evaluation criteria used toevaluate the remedial alternatives. Revise this discussion such that each of the seven evaluationcriteria are compared for each of the excavation limits proposed.

Response: The Army disagrees that incorporation of this evaluation is required in Appendix B. Thepermanence of this solution is addressed appropriately in Table 5-1, under the criteria “Overall protection ofhuman health and the environment” and “Long-term effectiveness and permanence.”

7.35: Appendix C Section C.4. page C-5: TBC Guidance listed for lead and zinc need to beprovided for each contaminant and media of concern. Refer to Specific Comment Nos. 19, 22 and 32.

Response: No TBC guidance is available for the other COCs discussed in the FFS. See also Appendix Bof this ROD and response to comment 2.4.

7.36: Appendix C. Applicable Or Relevant And Appropriate Requirements (ARARs): Althoughmany potential ARARs have been identified and discussed in Appendix C, some additional ARARsidentified in the April 21, 1997 EE/CA for Sites SM22, SM23, and SM24 may also be appropriate forinclusion in this FFS for units SM20, SM21 and SM26 The potential ARARs identified below arerelated to the site's Army status, its potential to impact surface water, and potential stormwatermanagement needs (e.g., treatment and discharge) which may need to be addressed in conjunction withstorm water management activities addresses under 327 IAC 15-5 (Stormwater Run-off Associated WithConstruction Activities).


Army Regulation 200-2: Environmental Effects of Army Actions 32 U.S.C. 4371 er seq. National Environmental Policy Act (NEPA) 33 CRF Part 320 3; State Certification under Section 401 of the CWA 327 IAC 2-1-6: Indiana Water Quality Standards/Criteria IAC 5-2-11: Effluent Limitations

Revise the FFS to include an evaluation of these potential ARARs for Sites SM20, SM21, and SM26.In addition, following evaluation of these additional ARARs, ensure that the remainder of the document(i.e., excavation limits, risk evaluations, etc) are appropriately modified, where applicable

Response: The Army has evaluated further the ARARs for this action in light of comments from IDEMand EPA. See also response to comment 2. 1.

7.37: Appendix D Section 1 Page D1 -1: The cost estimates provided do not include costs foradditional studies or delays, nor are costs provided that are associated with special permitting,wetland, archeological or endangered species habitat considerations. These costs are associated withadministrative feasibility issues. If this level of detail has not been included in the cost estimate, it isunclear as to whether all of the administrative feasibility considerations have been addressed. Revisethis section of the FFS to explain in greater detail why costing for these administrative issues have notbeen included, and revise the FFS to a discuss the administrative feasibility considerations that wereaccounted for by the FFS.

Response: The items cited in the comment are included under “Indirect Capital Costs.” All requiredpermitting and endangered species habitat considerations are being pursued with the appropriate governingagencies.

7.38: Appendix D: The cost estimates provided only allow for one round of verification sampling.Provide the rationale for why only one round of sampling was assumed for confirming the limits ofexcavation for each EI Site.

Response: Previous sampling suggests the contamination is limited to the top six inches. Additionalverification sampling will be performed—and funded—as required.

7.39: Appendix D. Section 2. page D3-3: The line item under Site Restoration for RegradingTemporary Access Road is listed as being a lump sum, costed at rate of one day. It therefore, seemsto be implied that the smallest increment for this activity would be one day. The cost informationpresented under this line item and the cost detail presented in Table D-6 uses an increment of half aday. A unit of half a day does not seem applicable to this line item. Revise this section to include adiscussion on how Means intended this value to be used, and if still relevant, that the lump sum valuehas been adjusted to reflect only a partial day. This comment also applies to the line item informationpresented on page D3-5 and cost information in Table D- 7.

Response: Regrading of the temporary access road at SM20 and SM21 would take approximately one day.The single-day estimate was split evenly between the two sites.

7.40: Appendix D. Tables D-6 and D-7. pages D3-8 and D3-9: These two cost estimates do notinclude any costs for erosion control for dust control. Provide a discussion on why these activities arenot applicable to these two alternatives.

Response: Erosion control is not required because the sludge basins are surrounded by large berms. Therich organic nature of the soil in the beds will naturally limit dust generation.


However, dust control may be added during development of the work plans, or in the field if it is determinedto be necessary.

8. COMMENT ON PROPOSED PLAN ORGANIZATION AND CONTENT FROM EPA(8-1).

8.1: Section 40 CFR 300.410 outlines the basic requirements of a removal site evaluation. U.S. EPAguidance on conducting non-time critical removal actions states that an Action Memorandum is usedto provide a concise, written record of the decision to select an appropriate removal action. Typicallythe Action Memorandum is prepared following a preliminary assessment and EE/CA.

The Proposed Plan format was compared to the format for an Action Memorandum, since the purposeof the Proposed Plan appears to closely resemble the purpose of an Action Memorandum. Based onthis comparison, the basic content of the Proposed Plan has the following shortcomings:

-Limited information is provided regarding site characteristics.-Limited information is provided regarding potential contaminants for the historical activitiesconducted at the site.-Limited information is provided illustrating graphic representations of sampling locations and testpits.

The quantitative data collected is not presented and is not compared to any standard or backgroundlevel.

Response: It is unclear why EPA has evaluated the proposed plan against the organization and content ofan action memorandum. The actions presented in the proposed plan are not removal actions, but ratherremedial actions. As such, the Army followed Guidance on Preparing Superfund Decision Documents(EPA 1989), the appropriate guidance from EPA for developing proposed plans (see Chapter 2).

The purpose of a proposed plan is to distill the content of previous studies and present the essentialinformation in a format that is easily read and understood by the public. All of the “shortcomings” identifiedcan be found in the Final Phase II EI report (SAIC 1998) and the FFS. A proposed plan is not intended topresent such comprehensive background information.

The Army has presented its quantitative evaluation of sampling data in the Final Phase II EI report and theFFS. The baseline human health and ecological risk assessments make the requested comparisons againstscreening and background concentrations and conclude with the identification of contaminants of concern.The proposed plan summarizes the conclusions of these risk assessments; however, it is neither necessarynor desirable to repeat such detailed quantitative analyses in the proposed plan.

9. COMMENTS ON PROPOSED PLAN FROM EPA (9-1 THROUGH 9-4).

The proposed plan for Environmental Investigation (EI) Sites SM20, SM21, and SM26 (ProposedPlan) is principally based upon the Focussed (sic) Feasibility Study (FFS) for the same EI Sites. U.S.EPA recently issued several deficiency comments regarding the FFS that will first need to be addressedby the Army. Since the Proposed Plan is based upon the detailed information in the FFS, all applicablemodifications to the FFS must be taken into account in a revised Proposed


Plan or in the decision document for EI Sites SM20, SM21, SM26 The following General and SpecificComments provide examples of areas of the Proposed Plan that also need to be addressed. But again,it is critical that the revised Proposed Plan or decision document incorporate all applicable FFSmodifications, based upon U.S. EPA comments on the FFS.

9.1: Introduction: The introduction section contains a statement indicating that the Army, inconsultation with the U.S. EPA and the Indiana Department of Environmental Management (IDEM),will make the final decision regarding the need for remediation at these sites only after the publiccomment period has ended... However, the section titled "Modifying Criteria" found on the bottom leftcorner of page 12 includes evaluation of State and public acceptance issue and comments. It is notedthat this section applies to the Nine criteria identified by U.S. EPA in the 1998 guidance, however itshould be assured that the U.S. EPA's concerns, if applicable, should also be evaluated. Revise theProposed Plan or address this issue in the decision document.

Response: EPA’s comments have been evaluated and are addressed in this responsiveness summary.

9.2: Site background: The third complete paragraph on page 3 references the decision regardingthe status of the 17 additional EI sites as requiring no further action., The decision was documentedin the Record of Decision (ROD) dated March 1999. While these facts are true, the ROD has not yetbeen determined to be completely acceptable to the U.S. EPA and therefore the premise eluded (sic)to in this section may not be entirely accurate. Ensure that the Proposed Plan is revised, whereappropriate, to account for any changes to the ROD, or in it's (sic) effective date or address this issuein the decision document for EI Sites SM20, SM21, and SM26.


9-3: Site Characterization: While possibly a matter of semantics, the language used in thesubsection under this main section is misleading. The subsection provides information on the resultsof the EI's at EI Sites SM20, SM21, and SM26. Often, the text uses language such as "Pesticides andHerbicides were detected in several samples". These statements are not necessarily accurate. Whilethe associated data can be referenced via publicly available data, it would be more prudent to eitheruse the term "moderate" or a comparable term, or to simply state that concentrations, which were ashigh as several thousand microgram per kilogram (ug/kg), should be identified as "low".

Response: In characterizing the concentrations as “low,” the Army was not making judgments aboutwhether those levels were “safe” or “unsafe.” Characterizing these concentrations as “low” or “moderate”would not change the course of action. The only characterization that is relevant in determining the courseof action are the characterizations of the baseline human health and ecological risk assessments. The riskassessment determines what concentrations are "too high."

9.4: Discussion of Human Health and Ecological Risk Assessment: As the review of the FFS hasidentified several significant concerns with regard to both the human health and ecological riskassessments, the information presented in this section should be modified accordingly once the FFShas been revised. At issue are the risk levels for both human health (e.g., carcinogenic "target risklevel" of 1x10-4) and ecological risks and their respective target risk levels. For example, the lastsentence in the second paragraph, second column on page 4 states that an HI greater than 1 wasconsidered to exceed the target risk level. This is not consistent with the statements made in the FFS.


Furthermore, subsections under this main section reference historical information that does not appearto be accurate. The human health risk assessment prepared by the Army as part of the Phase II EIestimated a carcinogenic risk of 3x10-5 for a current and future maintenance worker at SM20, and4x10-5 for a future adult recreational visitor at SM21. This information differs from the informationpresented in the Proposed Plan, and is a significant issue since the Proposed Plan does not accuratelydescribe risks to future human users of the sites. Revise the Proposed Plan accordingly, or addressthese issues in the decision document.

Response: Page 2-8 of the FFS presents the Army’s position regarding the risk threshold for ecologicalreceptors. In summary, an HI of 1 is the target; values below 1 are acceptable. HIs between 1 and 10 areindicative of a small potential for adverse affects. If the HI falls between 1 and 10, other considerations mustbe made to determine whether a remedial action is the best course of action. The Army revised its riskthreshold criteria after the Final Phase II EI; but, since publication of the ROD for seventeen NFA sites, allevaluations of ecological risk have been consistent with the rules summarized above.

The human health risk assessment results presented in the FFS were based on RME concentrations. Thosecited in the proposed plan were based on the CTE concentrations. The Army acknowledges the confusionthis may have caused and has presented results for both in this ROD. Since neither value exceeds the riskthreshold, no revision of the FFS or proposed plan is warranted.

APPENDIX B

DERIVATION OF ECOLOGICALPRELIMINARY REMEDIATION GOALS (PRGs)


Deviation of Ecological PRGs Former Fort Benjamin HarrisonB-1

APPENDIX B

Derivation of Ecological Preliminary Remediation Goals for EI Sites SM20 and SM21, Former Fort Benjamin Harrison

Preliminary remediation goals (PRGs) for two chemicals of concern (COCs) in surface soil were derivedto protect ecological receptors at Environmental Investigation (EI) Sites SM20 and SM21. Based on thebaseline ecological risk assessment for these sites, which was presented in the Focused Feasibility StudyFor Environmental Investigation Sites SM20, SM21, and SM26 (SAIC 1999), the American robin wasdetermined to be the ecological receptor most at risk from exposure to COCs at sites SM20 and SM21.4,4'- dichlorodiphenyltrichloroethane (DDT) at SM20 and 2,3,7,8-TCDF at SM21 were the primarysources of risk. The Focused Feasibility Study (FFS) evaluated risk to the American robin and theshort-tailed shrew because exposure for these receptors is expected to be greater due to their small homeranges as compared to the other receptors evaluated in the Phase II EI. The FFS determined thatremediation would eliminate the risks from these COCs to the American robin and to other receptors. ThusPRGs were calculated for the American robin and for the COCs: DDT at site SM20 and 2,3,7,8tetrachlorodibenzofaran (TCDF) at site SM21. The level of protection provided the American robin isprovided to other receptors at the site.

The derivation of PRGs follows the protocol presented in Final Preliminary Remediation Goals for EISites SM22 SM23 and SM24, Fort Benjamin Harrison, Marion County, Indiana (SAIC 1997). A briefoverview of the protocol is presented below along with the recommended PRGs. Any modifications to theoriginal protocol also are discussed. Please note that hazard quotients (HQs) were referred to as ExposureQuotients in SAIC (1997).

The PRGs for soil exposure at Fort Benjamin Harrison were calculated by assuming that soil contaminantspass through a typical food web to the American robin. The three exposure scenarios presented in SAIC(1997), based on degree of protection, were used to calculate a range of PRGs. They are:

• Most conservative (Scenario 1) - Home ranges and residence time of predators and prey aremathematically compressed to ensure maximum contact. Bioavailability factors for uptake fromingested soil are equal to 1. All bioaccumulation factors are set at 1, making ingestion exposureequivalent to a diet consisting entirely of contaminated soil.

• Intermediate exposure (Scenario 2) – Exposures are intermediate between the mostconservative and the least conservative exposure scenarios. Home ranges and residence timeremain at maximum levels. The most highly contaminated food item is used as the entire diet (e.g.,earthworms). Bioavailability factors from ingested soil are equal to 1. Bioaccumulation factors areCOC-specific, if available. If not, the default of 1 is used again.

• Least conservative (Scenario 3) - Home ranges of receptors are allowed to overlap with EIsites as they do in nature. The receptors eat a realistic mix of contaminated diet with COC-


specific bioaccumulation factors, and some exposure parameters are based on measured values ratherthan on conservative estimates. Bioavailability factors for uptake from ingested soil are based onpublished data, if available.

Each exposure scenario also incorporates a range of toxicity reference values (TRVs; see discussion belowon TRVs for more details).

PRG EQUATION PARAMETERS

As shown in Table B-1, all exposure parameters are similar to those used for the American robin in thePRG document (SAIC 1997) with the exception of the Absorption Factors (AFs) in surface soil andBio-accumulation Factors (BAFs). The following sections discuss some of the exposure parameters in moredetail. Unless otherwise noted, exposure parameters are from USEPA (1993).

Area Use Factors – Area use factors (AUFs) are calculated as the lesser of 1 and the ratio ofcontaminated habitat to total home range. The areas of EI Sites SM20 and SM21are 1.69 acres and 0.56acres, respectively. Using a home range of 1.04 acres for the American robin, the area use factors of 1.0and 0.54, respectively, were calculated.

Temporal use factors – The temporal use factor (TUF) adjusts the average daily exposure to a long-termchronic basis by considering the fraction of foraging time that the receptor spends at the site. For Scenario3 in this evaluation, as in the original PRG document, the American robin was considered as a migratoryspecies assumed to be absent from the site for four months of the year (EPA 1993), so the TUF =8/12 =0.67. The specific TUFs used for each scenario are found in Table B-1.

Absorption factors – Soil-matrix interactions reduce the gastric absorption of contaminants relative totheir absorption from water or other vehicles typically used in toxicity studies. Chemical-specific absorptionfactors (AFs) for the fraction of a chemical absorbed from surface soil were used in the PRG document(SAIC 1997). In the absence of readily-available AFs for DDT and 2,3,7,8-TCDF, a conservative valueof 1 was used for each chemical (i.e., all of the chemical is absorbed). Although this is conservative, theoverall effect on the PRGs is minor because total soil ingestion is only 1.9% of total food ingestion. As aresult, the contaminant contribution from soil is minor in comparison with the contribution from food. Forexample, if an AF for soil of 0.5 is assumed for DDT, then the recommended PRG increases by less than2%.

Dietary exposures – Dietary-exposure parameters (body weight, daily food ingestion and dietarycomposition) for American robins were taken from USEPA (1993). Data for daily soil ingestion were takenfrom Sample and Suter (1994). Because data were not available about some groups of biota used for food,the following assumptions were made:

• In Scenarios 1 and 2, all of the American robin diet is made up of soil-dwelling invertebrates, whichare highly-exposed to soil contaminants. This assumption is made because soil-dwellinginvertebrates (earthworms) and plants have the highest direct exposure to soil


contaminants. Earthworms were chosen as the representative soil-dwelling invertebrate becausetheir high rate of soil ingestion will result in a conservative PRG.

• In Scenario 3, fruits and seeds are the preferred plant diet items for robin, and insects consumedby robins have the same BAF as earthworms.

Uptake parameters – The uptake parameters used to calculate exposure of ecological receptors arepresented in Table B-1. DDT bioaccumulation factors for plants, earthworms, and small mammals weretaken from HAZWRAP (1994), which is a compilation of various studies concerning uptake factors andbioaccurnulation factors. In the absence of chemical-specific bioaccumulation factors, default values of 1for 2,3,7,8-TCDF were used.

Toxicity reference values – For each exposure scenario, both unscaled and body-weight scaledno-observable-adverse-effect-levels (NOAELs) and lowest-observable-adverse effect levels (LOAELs)were used as toxicity reference values (TRVs) for American robins. The NOAEL is the highestconcentration of a contaminant that causes no observable adverse effect on a test species, while theLOAEL is the lowest concentration of a contaminant that does cause an observable adverse effect on atest species. Because toxicity is related to metabolic rate, which depends on body weight, TRVs can beadjusted to the body weight by applying a scaling factor. For the American robin, the corresponding testspecies’ NOAEL and LOAEL were multiplied by the body-weight ratio of the avian test species, raisedto the 0.25 power (Opresko et al. 1994). TRVs are presented in Table B-2 based on data from Sampleet al. (1996).

Table B-1. Exposure Parameter Values for American Robin

Exposure Parameter Scenario 1 Scenario 2 Scenario 3

Area Use Factor (Site 20/Site 21) 1/1 1/1 1/0.54

Temporal Use Factor 1 1 0.67a

Absorption Factor-Soil (DDT/2,3,7,8-TCDF)b

1/1 1/1 1/1

Soil Intake (g/d)c 1.9 1.9 1.9

Total Food Intake (g/d)d 97.6 97.6 97.6

Plants (g/d) 0 0 28.6e

Earthworms (g/d) 97.6 97.6 14.6e

Insects(g/d) 0 0 49.3e

Small Mammals (g/d) 0 0 5.1e

Bio-accumulation Factorsf

Soil to Plant (DDT/TCDF) 1/1 0.00077/1 0.00077/1

Soil to Animal (DDT/TCDF) 1/1 0.57/1 0.57/1

Small Animal to Small Animal (DDT/TCDF)

1/1 2.9/1 2.9/1

Body Weight (g)d 81 81 81

a Assumes migration from the site for four months of the year (EPA 1993) b Conservatively assumed c Sample and Suter (1994) d Based on average adult body weight and food consumption rates (EPA 1993) e Calculated from dietary composition of nestling/fledgling (EPA 1993) because detail of adult diet was lacking f DDT values from HAZWRAP (1994). In the absence of data for 2,3,7,8-TCDF, a value of one was assumed


Derivation of PRGs

The first equation presented below is the standard “forward” exposure equation to determine risk basedon soil concentration, and was taken from SAIC (1997). This “forward” equation provides the risk,represented by the hazard quotient (HQ), based on the soil concentration. The second equation is a“backward” calculation that determines what soil concentration would result in a HQ of 1. Equation 2 wasused to derive the PRGs presented in Table B-2.

Where: HQ = Hazard quotient (required to be 1.0 for the PRG) AUF = Area use factor (unitless)TUF = Temporal use factor (unitless)CS = Concentration of contaminant in soil (µg/kg)SI = Amount of soil ingested daily (g/d)AF = Fraction of contaminant absorbed from soil (unitless)Br = Bioaccumulation factor for contaminant from soil to fruits and seeds (unitless)FIp = Quantity of food ingested that is plants (g/d)BAFinv = Bioaccumulation factor for earthworms and other soil invertebrates (unitless) FIinv = Quantity of food ingested that is soil invertebrates (g/d) BAFsm = Bioaccumulation factor for small mammals (unitless) FIsm = Quantity of food ingested that is small mammals (g/d) BW = Body Weight (g) TRV = Toxicity reference value (mg/kg bw/d) CF1 = Conversion factor (kg/1000g) CF2 = Conversion factor (1000g/kg) CF3 = Conversion factor (1000µg/mg)

In a similar manner to the PRG document (SAIC 1997), the PRGs derived based on the scaled LOAELsin Scenario 3 are the PRGs recommended in this ROD. These PRGs are 164 ppb for DDT at SM20 and0.025 ppb for 2,3,7,8-TCDF at SM21.

It is unlikely that the computed exposures of ecological receptors under future conditions will be higher than under theassumed current conditions. This is because it is assumed conservatively that all receptors are currently exposed overeach site regardless of actual variations in habitat type. Unless future changes in habitat would make the site unsuitablefor the receptors, it is fikely that their exposure to soil contaminants throughout whatever habitat remains will be the sameas under current conditions, so the PRGs for current exposure will remain valid for future conditions (Table B-2).


Table B-2. TRVs and PRGs for the American Robin

Chemicals of Concern for the American Robin

TRV (mg/kg bw/day)

Scenario 1 PRG Soil

Concentration (ppb)

Scenario 2 PRG Soil

Concentration (ppb)

Scenario 3 PRG Soil

Concentration (ppb)

DDT

DDT-Unscaled – NOAEL 2.8 x 10-3 2.28 3.9 6.37

DDT-Scaled -- NOAEL 7.2 x 10-3 5.86 10.1 16.4

DDT- Unscaled – LOAEL 2.8 x 10-2 22.8 39.4 63.7

DDT- Scaled – LOAEL 7.2 x 10-2 58.6 101 164

2,3,7,8-TCDF

2,3,7,8-TCDF-Unscaled – NOAEL 1.0 x 10-6 0.0008 0.0008 0.002

2,3,7,8-TCD -Scaled – NOAEL 1.11 x 10-6 0.0009 0.0009 0.002

2,3,7,8-TCDF-Unscaled -- LOAEL 1.0 x 10-5 0.008 0.008 0.023

2,3,7,8-TCDF-Scaled – LOAEL 1.11 x 10-5 0.009 0.009 0.025


References

EPA. 1993. Wildlife Exposure Factors Handbook, Vol. 1. EPA/600/R-93/187a. Office of Research andDevelopment, Washington, D.C.

HAZWRAP (Hazardous Waste Remedial Action Programs). 1994. Loring Air Force Base, EcologicalRisk Assessment Methodology. Martin Marietta Energy Systems, Inc. Draft.

Opresko, D.M., B.E. Sample, and G.W. Suter II. 1994. Toxicological Benchmarks for Wildlife: 1994Revision. ER/ES/TM-86/R3. Oak Ridge National Laboratory, Oak Ridge, Tennessee.

SAIC. 1997. Preliminary Remediation Goals for EI Sites SM22, SM23, and SM24 Fort BenjaminA Harrison, Marion County, Indiana. USAEC Contract No. DACA31-94-D-0066 Task Order No.0003. January 1997.

SAIC. 1999. Focused Feasibility Study for Environmental Investigation Sites SM20, SM21, and SM26Former Fort Benjamin Harrison, Lawrence, Indiana. USAEC Contract No. DACA31-94-D0066 TaskOrder No. 0003. March 1999.

Sample, B.E., and G.W. Suter II. 1994. Estimating exposure of terrestrial wildlife to contaminants.ER/ES/TM-125. Environmental Sciences Division, Oak Ridge National Laboratory, Oak Ridge,Tennessee.

Sample, B.E., D.M. Opresko, and G.W. Suter II. 1996. Toxicological Benchmarks for Wildlife: 1996Revision. ER/ES/TM-86/R3. Oak Ridge National Laboratory, Oak Ridge, Tennessee.

APPENDIX C

LETTER FROM THE U.S. FISH AND WILDLIFE SERVICE: CONSULTATION REGARDING INDIANA BAT ROOST TREES


United States Department of the Interior

FISH AND WILDLIFE SERVICEBLOOMINGTON FIELD OFFICE (ES)

620 South Walker StreetBloomington, IN 47403-2121

(812) 334-4261 FAX (812) 334-4273 April 9, 1999

Mr. Paul Carter SAIC 655 Metro Place South, Suite 745 Dublin, Ohio 43017

Dear Mr. Carter:

This responds to your letter of March 29, 1999 requesting endangered species consultation with theU.S. Fish and Wildlife Service (FWS) regarding remediation of an abandoned sewage treatment plant(Site SM 26) at the former Fort Benjamin Harrison in Marion County, Indiana.

These comments have been prepared under the authority of the Fish and Wildlife Coordination Act (16U.S.C. 661 et. seq.) and are consistent with the intent of the National Environmental Policy Act of1969, the Endangered Species Act of 1973, and the U. S. Fish and Wildlife Service’s MitigationPolicy.

Endangered Species

The proposed project is within the range of the Federally endangered Indiana bat (Myotis sodalis) andbald eagle (Haliaeetus leucocephalus). Your letter contained a report from a recent survey of potentialroost trees for the Indiana bat at the project site. Since the Indiana bat is already known to exist at FortHarrison, it is necessary to determine whether the proposed remediation may adversely affect thisendangered species.

Your survey results concluded that there are 10 potential roost trees within the study area. Four ofthese trees are actually within the remediation area, and the remainder are on or near the surroundingberms. One of the peripheral trees is a large cottonwood with exfoliating bark beginning to occur on itsupper limbs, which experience has shown provides optimum potential to serve as a roost tree, if notnow then in the near future.

Since the project site is on the periphery of the Indiana bat essential habitat at Fort Harrison State Park,overall tree removal will be relatively minor, and there is an ample supply of potential roosttrees in the State Park, we conclude that the project will not adversely affect the Indiana bat if thefollowing measure is implemented:

Avoid removal of potential roost trees during the Indiana bat occupancy season (April 15- September15). This measure will avoid the small possibility that an occupied roost tree would be removed.

We also recommend the following conservation measures for Indiana bat habitat:

1. Minimize cutting of mature trees throughout the project area.

2. Preserve the large cottonwood if possible, to provide a potential roost tree after the site isrestored.

This precludes the need for further consultation on this project as required under Section 7 of theEndangered Species Act of 1973, as amended. If, however, new information on endangered species atthe site becomes available or if project plans are changed significantly, please contact our office forfurther consultation.

For further discussion, please contact Mike Litwin at (812) 334-4261.

cc: Steve Jose, Indiana Division of Fish and Wildlife, Indianapolis, IN Indiana Division of State Parks, Indianapolis, IN

APPENDIX D ANALYTICAL DATA FOR SOIL SAMPLES COLLECTED FROM THIRD

SLUDGE-DRYING BED AT EI SITE SM26


U - UndetectedJ - EstimatedB - Compound Detected in blankR- Rejected Appx. D 1 of 11

APPENDIX DAnalytical Data for Soil Samples Collected from

Third Sludge-drying Bed at El Site SM26

Sample Type Sample ID Depth Compound Unit ResultData

QualifierMETALS SS-S1-10 0-0.5 FT Al mg/kg 4420

0-0.5 FT Sb mg/kg ND R0-0.5 FT As mg/kg 7.50-0.5 FT Ba mg/kg 1570 J0-0.5 FT Be mg/kg ND U0-0.5 FT Cd mg/kg 8.6 J0-0.5 FT Ca mg/kg ND U0-0.5 FT Cr mg/kg 53.3 UJ0-0.5 FT Co mg/kg ND U0-0.5 FT Cu mg/kg 3310-0.5 FT Fe mg/kg 127000-0.5 FT Pb mg/kg 1690 J0-0.5 FT Mg mg/kg ND U0-0.5 FT Mn mg/kg 171 J0-0.5 FT Hg mg/kg 40.50-0.5 FT Ni mg/kg ND U0.0.5 FT K mg/kg ND U0-0.5 FT Se mg/kg ND U0-0.5 FT Ag mg/kg 49.5 J0-0.5 FT Na mg/kg ND U0-0.5 FT Tl mg/kg ND U0.0.5 FT V mg/kg 10.5 B0-0.5 FT Zn mg/kg 2070G-0.5 FT CN mg/kg 2.6

SB-S1-10 1-2 FT Al mg/kg 11401-2 FT Sb mg/kg ND R1-2 FT As mg/kg 1.6 B1-2 FT Ba mg/kg 249 J1-2 FT Be mg/kg ND U1-2 FT Cd mg/kg 1.4 J1-2 FT Ca mg/kg 180000 J1-2 FT Cr mg/kg 7.6 UJ1-2 FT Co mg/kg ND U1-2 FT Cu mg/kg ND U1-2 FT Fe mg/kg 37401-2 FT Pb mg/kg 238 J1-2 FT Mg mg/kg ND U1-2 FT Mn mg/kg 156 J1-2 FT Hg mg/kg 26.61-2 FT Ni mg/kg ND U1-2 FT K mg/kg ND U1-2 FT Se mg/kg ND U1-2 FT Ag mg/kg 8.1 J1-2 FT Na mg/kg ND U1-2 FT TI mg/kg ND U1-2 FT V mg/kg 2.7 B1-2 FT Zn mg/kg 555 J1-2 FT CN mg/kg ND U


APPENDIX D Analytical Data for Soil Samples Collected from



QualifierMETALS SB-S1-10 3.3.6 FT Al mg/kg 12600

3.3.6 FT Sb mg/kg ND R3.3.6 FT As mg/kg 15.33.3.6 FT Ba mg/kg 154 J3.3.6 FT Be mg/kg 0.71 B3.3.6 FT Cd mg/kg 0.74 J3.3.6 FT Ca mg/kg ND U3.3.6 FT Cr mg/kg 20.2 UJ3.3.6 FT Co mg/kg 8.8 B3.3.6 FT Cu mg/kg ND U3.3.6 FT Fe mg/kg 2550003.3.6 FT Pb mg/kg 98.4 J3.3.6 FT Mg mg/kg ND U3.3.6 FT Mn mg/kg 770 J3.3.6 FT Hg mg/kg 2.93.3.6 FT Ni mg/kg ND U3.3.6 FT K mg/kg 951 B3.3.6 FT Se mg/kg ND U3.3.6 FT Ag mg/kg ND UJ3.3.6 FT Na mg/kg ND U3.3.6 FT Tl mg/kg 23.3.6 FT V mg/kg 28.93.3.6 FT Zn mg/kg 2153.3.6 FT CN mg/kg ND U

SS-S1-10D 0-0.5 FT Al mg/kg 48000-0.5 FT Sb mg/kg 43.2 UJ0-0.5 FT As mg/kg 7.20-0.5 FT Ba mg/kg 1650 J0-0.5 FT Be mg/kg ND U0-0.5 FT Cd mg/kg 8.3 J0-0.5 FT Ca mg/kg ND U0-0.5 FT Cr mg/kg 43.3 UJ0-0.5 FT Co mg/kg 4.4 B0-0.5 FT Cu mg/kg 3320-0.5 FT Fe mg/kg 134000-0.5 FT Pb mg/kg 1680 J0-0.5 FT Mg mg/kg ND U0-0.5 FT Mn mg/kg 171 J0-0.5 FT Hg mg/kg 600-0.5 FT Ni mg/kg ND U0-0.5 FT K mg/kg ND U0-0.5 FT Se mg/kg 1.70-0.5 FT Ag mg/kg 49.7 J0-0.5 FT Na mg/kg ND U0-0.5 FT TI mg/kg ND U0-0.5 FT V mg/kg 12.4 B0-0.5 FT Zn mg/kg 20200-0.5 FT CN mg/kg 2.9





QualifierMETALS SS-S1-11 0-0.5 FT Al mg/kg 6350

0-0.5 FT Sb mg/kg 17.6 J0-0.5 FT As mg/kg 8.50-0.5 FT Ba mg/kg 2250 J0-0.5 FT Be mg/kg ND J0-0.5 FT Cd mg/kg 8.3 J0-0.5 FT Ca mg/kg ND U0-0.5 FT Cr mg/kg 42.1 UJ0-0.5 FT Co mg/kg 8.5 B0-0.5 FT Cu mg/kg 7150-0.5 FT Fe mg/kg 264000-0.5 FT Pb mg/kg 3900 J0-0.5 FT Mg mg/kg ND U0-0.5 FT Mn mg/kg 203 J0-0.5 FT Hg mg/kg 55.90-0.5 FT Ni mg/kg ND U0-0.5 FT K mg/kg ND U0-0.5 FT Se mg/kg ND U0-0.5 FT Ag mg/kg 39.1 J0-0.5 FT Na mg/kg ND U0-0.5 FT Tl mg/kg ND U0-0.5 FT V mg/kg 180-0.5 FT Zn mg/kg 23500-0.5 FT CN mg/kg 0.74

SB-S1-11 1-2 FT Al mg/kg 20801-2 FT Sb mg/kg ND R1-2 FT As mg/kg 3.71-2 FT Ba mg/kg 619 J1-2 FT Be mg/kg ND U1-2 FT Cd mg/kg 4.6 J1-2 FT Ca mg/kg ND U1-2 FT Cr mg/kg 27.4 UJ1-2 FT Co mg/kg ND U1-2 FT Cu mg/kg ND U1-2 FT Fe mg/kg 71501-2 FT Pb mg/kg 763 U1-2 FT Mg mg/kg ND U1-2 FT Mn mg/kg 171 J1-2 FT Hg mg/kg 381-2 FT Ni mg/kg ND U1-2 FT K mg/kg ND U1-2 FT Se mg/kg ND U1-2 FT Ag mg/kg 14.9 J1-2 FT Na mg/kg ND U1-2 FT TI mg/kg ND U1-2 FT V mg/kg 3.9 B1-2 FT Zn mg/kg 1260 J1-2 FT CN mg/kg ND U





QualifierMETALS SB-S1-11 3.8-4.3 FT Al mg/kg 9320

3.8-4.3 FT Sb mg/kg ND R3.8-4.3 FT As mg/kg 11.23.8-4.3 FT Ba mg/kg 221 J3.8-4.3 FT Be mg/kg 0.56 B3.8-4.3 FT Cd mg/kg ND UJ3.8-4.3 FT Ca mg/kg 17700 J3.8-4.3 FT Cr mg/kg 16.8 UJ3.8-4.3 FT Co mg/kg 7.2 B3.8-4.3 FT Cu mg/kg ND U3.8-4.3 FT Fe mg/kg 206003.8-4.3 FT Pb mg/kg 276 J3.8-4.3 FT Mg mg/kg ND U3.8-4.3 FT Mn mg/kg 554 J3.8-4.3 FT Hg mg/kg 4.23.8-4.3 FT Ni mg/kg ND U3.8-4.3 FT K mg/kg 896 B3.8-4.3 FT Se mg/kg ND U3.8-4.3 FT Ag mg/kg 3 J3.8-4.3 FT Na mg/kg ND U3.8-4.3 FT Tl mg/kg ND U3.8-4.3 FT V mg/kg 20.23.8-4.3 FT Zn mg/kg 3283.8-4.3 FT CN mg/kg ND U





QualifierPESTICIDE/PCBs SS-S1-10 0-0.5 FT beta-BHC ug/kg 16.5 J

SB-S1-10 1-2 FT beta-BHC ug/kg ND UJ

SB-S1-10 3-3.6 FT beta-BHC ug/kg ND UJ

SS-S1-10D 0-0.5 FT beta-BHC ug/kg ND UJ

SS-S1-11 0-0.5 FT beta-BHC ug/kg 14.4 J

SB-S1-11 1-2 FT beta-BHC ug/kg ND UJ

SB-S1-11 3.8-4.3 FT beta-BHC ug/kg ND UJ





QualifierHERBICIDES SS-S1-10 0-0.5 FT Dalapon ug/kg ND UJ

0-0.5 FT Dicamba ug/kg ND UJ0-0.5 FT Dichloroprop ug/kg ND UJ0-0.5 FT 2,4-D ug/kg ND UJ0-0.5 FT MCPA ug/kg ND UJ0-0.5 FT MCPP ug/kg 1500 J0-0.5 FT 2,4,5TP ug/kg ND UJ0-0.5 FT 2,4,5-T ug/kg ND UJ0-0.5 FT 2,4-DB ug/kg ND UJ0-0.5 FT Dinoseb ug/kg ND UJ

SB-S1-10 1-2 FT Dalapon ug/kg ND U1-2 FT Dicamba ug/kg ND U1-2 FT Dichloroprop ug/kg ND U1-2 FT 2,4-D ug/kg ND U1-2 FT MCPA ug/kg ND U1-2 FT MCPP ug/kg ND U1-2 FT 2,4,5TP ug/kg ND U1-2 FT 2,4,5-T ug/kg ND U1-2 FT 2,4-DB ug/kg ND U1-2 FT Dinoseb ug/kg ND U

SB-S1-10 3-3.6 FT Dalapon ug/kg ND U3-3.6 FT Dicamba ug/kg ND U3-3.6 FT Dichloroprop ug/kg ND U3-3.6 FT 2,4-D ug/kg ND U3-3.6 FT MCPA ug/kg ND U3-3.6 FT MCPP ug/kg ND U3-3.6 FT 2,4,5TP ug/kg ND U3-3.6 FT 2,4,5-T ug/kg ND U3-3.6 FT 2,4-DB ug/kg ND U3-3.6 FT Dinoseb ug/kg ND U

SB-S1-10D 0-0.5 FT Dalapon ug/kg ND UJ0-0.5 FT Dicamba ug/kg ND UJ0-0.5 FT Dichloroprop ug/kg ND UJ0-0.5 FT 2,4-D ug/kg ND UJ0-0.5 FT MCPA ug/kg ND UJ0-0.5 FT MCPP ug/kg 2200 J0-0.5 FT 2,4,5TP ug/kg ND UJ0-0.5 FT 2,4,5-T ug/kg ND UJ0-0.5 FT 2,4-DB ug/kg ND UJ0-0.5 FT Dinoseb ug/kg ND UJ





QualifierHERBICIDES SB-S1-11 0-0.5 FT Dalapon ug/kg ND UJ

0-0.5 FT Dicamba ug/kg ND UJ0-0.5 FT Dichloroprop ug/kg ND UJ0-0.5 FT 2,4-D ug/kg ND UJ0-0.5 FT MCPA ug/kg ND UJ0-0.5 FT MCPP ug/kg 1200 J0-0.5 FT 2,4,5TP ug/kg ND UJ0-0.5 FT 2,4,5-T ug/kg ND UJ0-0.5 FT 2,4-DB ug/kg ND UJ0-0.5 FT Dinoseb ug/kg ND UJ

SB-S1-11 1-2 FT Dalapon ug/kg ND UJ1-2 FT Dicamba ug/kg ND UJ1-2 FT Dichloroprop ug/kg ND UJ1-2 FT 2,4-D ug/kg ND UJ1-2 FT MCPA ug/kg ND UJ1-2 FT MCPP ug/kg ND UJ1-2 FT 2,4,5TP ug/kg ND UJ1-2 FT 2,4,5-T ug/kg ND UJ1-2 FT 2,4-DB ug/kg ND UJ1-2 FT Dinoseb ug/kg ND UJ

SB-S1-11 3.8-4.3 FT Dalapon ug/kg ND U3.8-4.3 FT Dicamba ug/kg ND U3.8-4.3 FT Dichloroprop ug/kg ND U3.8-4.3 FT 2,4-D ug/kg ND U3.8-4.3 FT MCPA ug/kg ND U3.8-4.3 FT MCPP ug/kg ND U3.8-4.3 FT 2,4,5TP ug/kg ND U3.8-4.3 FT 2,4,5-T ug/kg ND U3.8-4.3 FT 2,4-DB ug/kg ND U3.8-4.3 FT Dinoseb ug/kg ND U





QualifierSVOCS SS-S1-10 0-0.5 FT 4-Chloro-3-methylphenol ug/kg ND U

0-0.5 FT Acenaphthene ug/kg ND U0-0.5 FT 2,4-Dinitrophenol ug/kg ND U0-0.5 FT Phenanthrene ug/kg 250 J0-0.5 FT Anthracene ug/kg 110 J0-0.5 FT Carbazole ug/kg ND U0-0.5 FT Di-n-butylphthalate ug/kg ND U0-0.5 FT Fluoranthene ug/kg 6400-0.5 FT Pyrene ug/kg 5800-0.5 FT Benzo(a)anthracene ug/kg 370 J0-0.5 FT Chrysene ug/kg 330 J0-0.5 FT Benzo(b)fluoranthene ug/kg 6200-0.5 FT Benzo(k)fluoranthene ug/kg ND U0-0.5 FT Benzo(a)pyrene ug/kg 390 J0-0.5 FT Indeno(1,2,3-cd)pyrene ug/kg ND U0-0.5 FT Dibenzo(g,h)anthracene ug/kg ND U0-0.5 FT Benzo(g,h,i)perylene ug/kg 270 J

SB-S1-10 1-2 FT 4-Chloro-3-methylphenol ug/kg ND U1-2 FT Acenaphthene ug/kg ND U1-2 FT 2,4-Dinitrophenol ug/kg ND UJ1-2 FT Phenanthrene ug/kg 83 J1-2 FT Anthracene ug/kg ND U1-2 FT Carbazole ug/kg ND U1-2 FT Di-n-butylphthalate ug/kg ND U1-2 FT Fluoranthene ug/kg 210 J1-2 FT Pyrene ug/kg 170 J1-2 FT Benzo(a)anthracene ug/kg 110 J1-2 FT Chrysene ug/kg 110 J1-2 FT Benzo(b)fluoranthene ug/kg 220 J1-2 FT Benzo(k)fluoranthene ug/kg ND U1-2 FT Benzo(a)pyrene ug/kg 110 J1-2 FT Indeno(1,2,3-cd)pyrene ug/kg ND U1-2 FT Dibenzo(g,h)anthracene ug/kg ND U1-2 FT Benzo(g,h,i)perylene ug/kg 91 J

SB-S1-10 3-3.6 FT 4-Chloro-3-methylphenol ug/kg ND U3-3.6 FT Acenaphthene ug/kg ND U3-3.6 FT 2,4-Dinitrophenol ug/kg ND UJ3-3.6 FT Phenanthrene ug/kg ND U3-3.6 FT Anthracene ug/kg ND U3-3.6 FT Carbazole ug/kg ND U3-3.6 FT Di-n-butylphthalate ug/kg ND U3-3.6 FT Fluoranthene ug/kg ND U3-3.6 FT Pyrene ug/kg ND U3-3.6 FT Benzo(a)anthracene ug/kg ND U3-3.6 FT Chrysene ug/kg ND U3-3.6 FT Benzo(b)fluoranthene ug/kg ND U3-3.6 FT Benzo(k)fluoranthene ug/kg ND U





QualifierSVOCS SB-S1-10 3.3.6 FT Benzo(a)pyrene ug/kg ND U

3.3.6 FT Indeno(1,2,3-cd)pyrene ug/kg ND U3.3.6 FT Dibenzo(g,h)anthracene ug/kg ND U3.3.6 FT Benzo(g,h,i)perylene ug/kg ND U

SS-S1-S10D 0-0.5 FT 4-Chloro-3-methylphenol ug/kg ND U0-0.5 FT Acenaphthene ug/kg ND U0-0.5 FT 2,4-Dinitrophenol ug/kg ND U0-0.5 FT Phenanthrene ug/kg 220 J0-0.5 FT Anthracene ug/kg 130 J0-0.5 FT Carbazole ug/kg ND U0-0.5 FT Di-n-butylphthalate ug/kg 110 J0-0.5 FT Fluoranthene ug/kg 5900-0.5 FT Pyrene ug/kg 510 J0-0.5 FT Benzo(a)anthracene ug/kg 340 J0-0.5 FT Chrysene ug/kg 300 J0-0.5 FT Benzo(b)fluoranthene ug/kg 5700-0.5 FT Benzo(k)fluoranthene ug/kg ND U0-0.5 FT Benzo(a)pyrene ug/kg 350 J0-0.5 FT Indeno(1,2,3-cd)pyrene ug/kg ND U0-0.5 FT Dibenzo(g,h)anthracene ug/kg ND U0-0.5 FT Benzo(g,h,i)perylene ug/kg 280 J

SB-S1-11 0-0.5 FT 4-Chloro-3-methylphenol ug/kg ND U0-0.5 FT Acenaphthene ug/kg 7000-0.5 FT 2,4-Dinitrophenol ug/kg ND U0-0.5 FT Phenanthrene ug/kg 24000-0.5 FT Anthracene ug/kg 10000-0.5 FT Carbazole ug/kg 450 J0-0.5 FT Di-n-butylphthalate ug/kg 320 J0-0.5 FT Fluoranthene ug/kg 48000-0.5 FT Pyrene ug/kg 59000-0.5 FT Benzo(a)anthracene ug/kg 39000-0.5 FT Chrysene ug/kg 32000-0.5 FT Benzo(b)fluoranthene ug/kg 38000-0.5 FT Benzo(k)fluoranthene ug/kg 15000-0.5 FT Benzo(a)pyrene ug/kg 34000-0.5 FT Indeno(1,2,3-cd)pyrene ug/kg 19000-0.5 FT Dibenzo(g,h)anthracene ug/kg 190 J0-0.5 FT Benzo(g,h,i)perylene ug/kg 1900

SB-S1-11 1-2 FT 4-Chloro-3-methylphenol ug/kg ND U1-2 FT Acenaphthene ug/kg ND U1-2 FT 2,4-Dinitrophenol ug/kg ND UJ1-2 FT Phenanthrene ug/kg 250 J1-2 FT Anthracene ug/kg 93 J1-2 FT Carbazole ug/kg ND U1-2 FT Di-n-butylphthalate ug/kg ND U1-2 FT Fluoranthene ug/kg 510





QualifierSVOCS SB-S1-11 1-2 FT Pyrene ug/kg 420

1-2 FT Benzo(a)anthracene ug/kg 270 J1-2 FT Chrysene ug/kg 250 J1-2 FT Benzo(b)fluoranthene ug/kg 380 J1-2 FT Benzo(k)fluoranthene ug/kg ND U1-2 FT Benzo(a)pyrene ug/kg 270 J1-2 FT Indeno(1,2,3-cd)pyrene ug/kg ND U1-2 FT Dibenzo(g,h)anthracene ug/kg ND U1-2 FT Benzo(g,h,i)perylene ug/kg 220 J

SB-S1-11 3.8-4.3 FT 4-Chloro-3-methylphenol ug/kg 81 J3.8-4.3 FT Acenaphthene ug/kg ND U3.8-4.3 FT 2,4-Dinitrophenol ug/kg ND UJ3.8-4.3 FT Phenanthrene ug/kg 100 J3.8-4.3 FT Anthracene ug/kg ND U3.8-4.3 FT Carbazole ug/kg ND U3.8-4.3 FT Di-n-butylphthalate ug/kg ND U3.8-4.3 FT Fluoranthene ug/kg 270 J3.8-4.3 FT Pyrene ug/kg 270 J3.8-4.3 FT Benzo(a)anthracene ug/kg 140 J3.8-4.3 FT Chrysene ug/kg 120 J3.8-4.3 FT Benzo(b)fluoranthene ug/kg 260 J3.8-4.3 FT Benzo(k)fluoranthene ug/kg ND U3.8-4.3 FT Benzo(a)pyrene ug/kg 140 J3.8-4.3 FT Indeno(1,2,3-cd)pyrene ug/kg ND U3.8-4.3 FT Dibenzo(g,h)anthracene ug/kg ND U3.8-4.3 FT Benzo(g,h,i)perylene ug/kg 120 J





Qualifier Cation SS-S1-10 0-0.5 FT Cation Exgenge Capacity meq/100gm 37.6

SB-S1-10 1-2 FT Cation Exgenge Capacity meq/100gm 8.4

SB-S1-10 3-3.6 FT Cation Exgenge Capacity meq/100gm 19.1

SB-S1-10D 0-0.5 FT Cation Exgenge Capacity meq/100gm 44.4

SS-S1-11 1-2 FT Cation Exgenge Capacity meq/100gm 42.8

SB-S1-11 3.8-4.3 FT Cation Exgenge Capacity meq/100gm 12.7

SB-S1-11 Cation Exgenge Capacity meq/100gm 16.9


Date post:	09-Apr-2022
Category:	Documents
Upload:	others
View:	13 times
Download:	0 times